Document 1gD4jDongnD11xJBMpwwBdmMK
I /
Aeaur O Snail. Inc. CmI laborawias Hanovar Road
/ norttamParfc Nw J*rjy 07932 (201)377-8700
/ <// August 23, 1374
Mr. James Kail inborn
Acting Director of PlanningEvaluation and Research
OSA
'
MNWA Building
Room 110
1728 M Street. N.W.
Washington, D. C. 20036
a; Contract No. L/A 74-167 -
Dear Mr. Kallenborri:
,* X.
' -. '
,
1V
The following is the preliminary report being sj^nda^gy August 23, 1974 tor Insertion into the Vinyl CWori^H^ing^rpst^^Ms^red. the report
presents the findings ga&wrafl^bw^nii study tefcmodnrjJig^tne seven weeks begun
'v 1 19" The con^U)woij|i,lMW^Dpd and presented in this report are
preliminary, net tut.4^ ^il oe sVbjectedto further analyses in the remaining
period of the dOWr&ct.';v .
,,
PleliA da not hesitate to call should you have any questions about tbi
1 report.
;
Sincerely.
/
*
Joseph Nemec^ Jr., Ph.D. Vice President
mjs
FOSTER D. SNELL. Inc.
1;
A Subsidiary at BOOZ AUEN a HAMIITOM Inc.
`i
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00S336
DRAFT FINAL REPORT
ECONOMIC IMPACT STUDIES OF THE EFFECTS OF PROPOSED OSHA STANDARDS FOR VINYL CHLORIDE
Acting Director of PlanningQ^aluation and Research OCCUPATIONAL SAFETY AND Qjj^LTH ADMINISTRATION
U. S. DEPARTMEN
LABOR
MNWA Builfling Room llOt^
03
an>1
FOSTER D. SNELL, Inc. A Subsidiary of
Booz, Allen 6 Hamilton Inc. Hanover Road
Florham Park, New Jersey 07932
September 13, 1974
I
Snell
Foster D Snell. Inc General Laboratories Hanover Road Florham Park New Jersey 07932
(201)377-6700
September 13, 1974
Mr. James Kallenborn
Acting Director of Planning, Evaluation and Research
OSHA
MNWA Building
Room 1100
1726 M Street, N.
Washington, D.C.
336
Re: Contract No^^A 74-167 J Dear Mr. Kallenbori?*^
The following i^_tli^ Draft Final Report being submitted for insertion into the Vinyl Chloride Hearing Transcripts. The Draft Final Report supersedes the Preliminary Report and includes refinement of the Preliminary Report as yjtpft as incorporation of limited new information.
This Draft Final K?grt presents Snell's evaluation of the technical feasibility and resulting costs of compliance with various^tajpeet levels of Vinyl Chloride exposure. The work includes data on monitoring and personal protective Wfifipment, and worker medical surveillance.
S 0 O S jJ S
0j
A Subsidiary of
BOOZ * ALLEN & HAMILTON Inc
Mr. James Kallenborn OSHA September 13, 1974 Page Two
,,A
The report is organized into tWcjTgec lions:
Analysis of th'|?j^dings and conclusions
Supporting App^ibes
t
We would like to thank you for the operation provided by you and your associates in this study, Please do not hesitate to call should you have any questions about this report.
Sincerely.
j
Joseph Nemec. Jr., Ph.D. Vice President
<P
FOSTER D.'SNELL. Inc.
mjs
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CO u u
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TABLE OF CONTENTS
J.
11.
i
III.
IV.
J V.
VI.
INTRODUCTION
METHODOLOGY
INDUSTRY STRUCTURE
IIIA. VINYL CHLORIDE MONOMER
IIIB. POLYVINYL CHLORlBE^RODUCTION
IIIC. KEY POLYVINYL CHLORIDE MARKETS
W-
(J)TECHNOLOGY OVERVIEW
IVA. VINYL CHLORIDE IVB. POLYVINYL CHLORIDE
A
FINDINGS AND ECONOMIC AN
VA. VB. VC. VD. VE.
ECONOMIC IMPACT ASSESHgStJJNT PERSONAL PROTECTIVE EftffiPMENT AVAILABILITY AND COSTS MONITORING EQUIPMENT ^f^ILABILITY AND COSTS
MEDICAL SURVEILLANCE COSTS VINYL CHLORIDE EXPOSURE DATA
CONCLUSIONS AND RECOMMENDATIONS
1-1
II-l
III-l
m-2
III-5 III-9
rv-i
IV-2 IV-9
V-l
V-2
v-ll
V-15 V-20 V-22
VI-1
APPENDICES
A - DETAILED PROCESS DESCRIPTIONS AND PROCELHH ES B EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) \N1.) VINYL CHLORIDE
MONOMER (VCM) PLANTS
C - ECONOMIC DETAIL'S ^ D - PERSONAL PROTEcfj&S& EQUIPMENT AND HYGIENE
E - MONITORING EQUIFMSrf^ F - MEDICAL SURVEILLAN^^IF EMPLOYEES G - SAFETY AWARENESS PROGRAMS
H - NIOSH RECOMMENDED OCgUPATIONAL HEALTH STANDARD FOR THE MANUFACTURE OF SYNTHETIC POLYMER \gpM VINYL CHLORIDE
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INDEX OF EXHIBITS
1-1 THE SCOPE OF THE SNELL STUDY
II-l VINYL CHLORIDE/POLYVINYL CHLORIDE PRODUCERS VISITED AND INTERVIEWED BY PHONE BY SNELL STAFF FOR DATA COLLECTION
II-2 II-3 III-l
GOVERNMENT AGENCIES . MtfUSTRY ORGANIZATIONS , AND EQUIPMENT MANUFACTURERS VISITED bJLSNELL STAFF FOR DATA COLLECTION
r\
FIRMS CONTACTED DURING MANUFACTURERS
SNELL TELEPHONE SURVEY OF EQUIPMENT
\jfy PROFILE OF VINYL CHLORIDE PRODUCERS
III-2 VINYL CHLORIDE MARKET TREftB3
m-3 VINYL CHLORIDE PRODUCTION ^^^KERS - 1974
III-4 III-5
PROFILE OF POLYVINYL CHLORI
RODUCERS
ilM*
r
COMPANY CAPACITY AS PERCEN
TOTAL POLYVINYL CHLORIDE PRODUCTION
CAPACITY
HI-6 GEOGRAPHIC DISTRIBUTION OF POLYVINYL CHLORIDE PLANTS - 1974
ill-7 U.S. POLYVINYL CHLORIDE PLANT AGE - 1974
Following Page
1-1 II--7
II--7
II-7
IH-2 III-3 III-4 III-8 III-8
III--8 III-B
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*
IV-3 IV-4 IV-5
IV-6 rv-7 IV-8
JV-9 1V-10 IV-11 . rv-12 IV-13
IV-14
VINYL CHLORIDE PROCESS DESCRIPTION
ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974
EXAMPLE OF A STANDARD OPERATING PROCEDURE FOR MAINTENANCE AT DOW CHEMKkSrjcO. VINYL CHLORIDE WORKS
CAPSULE OVERl{fEl| OF POLYVINYL CHLORIDE PROCESSES
REPRESENTATIvO^LYVINYL CHLORIDE SUSPENSION RESIN MANUFACTURE TECHNOLOGICAL^jCe'RVIEWS OF SUSPENSION (S) EMULSION (E) AND
COPOLYMERIZAXIOMS AND E TYPES) o'
THE POLYMERIZATION CYCLE IN THE SUSPENSION AND EMULSION PROCESSES POTENTIAL EXPOS^^CHECKLIST BASED ON SUSPENSION POLYVINYL CHLORIDE
Following Page IV-8 IV-8 IV-8
IV-12 IV-12 IV-12
IV-12 IV-12
TYPICAL FLOW DIAC^fljl FOR THE BULK PROCESS
OVERVIEW OF COPOLYMERIZATION
TYPICAL TIME REQUIREMENTS FOR IMPLEMENTING VARIOUS ENGINEERING CONTROL METHODS FOR POLYVINYL CHLORIDE PLANTS POLYVINYL CHLORIDE ECONOMICS - 1974
IV-12 IV-12 IV-12
IV-12
V-9
ESTIMATED INDUSTRY COSTS OF ACHIEVING A 15-25 PPM VCM CEILING AND 10-15
TWA PPM TARGET LEVEL IN PVC PLANTS AS CALIMED BY INDUSTRY AND ASSESSED BY SNELL
Following Page
V-8
V-10
COST ANALYSES BASED ON DATA PROVIDED BY FIRESTONE FOR AN ATTEMPT TO REACH "NO DETECTABLE TARGET VCM LEVELS USING ENGINEERING CONTROLS PRIMARILY
V-8
V-ll V-12
U .S. INDUSTRY CLAIMEEfcptME TO REACH SELECTED VCM LEVELS IN PVC PLANTS THROUGH ENGINEERED CONTROLS
o
SUMMARY OF PVC INDUSTRY COST IMPACTS, COMPLIANCE TIME AND CAPACITY ENDANGERED BY VCM TA^|t LEVEL
V-9 V-9
V-13 i
V-14
ESTIMATED VINYL CHLORWTECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1974 Dollars) a
<
POLYVINYL CHLORIDE ECONOMICS IMPACTED BY ELECTED VCM LEVEL STANDARDS (1974 Dollars)
V-9 V-9
V-15
ESTIMATED CAPITAL AND INDUSTRY AT 1974 CAPACIT,
AL COSTS FOR VCM TARGET LEVELS FOR THE VCM 974 Dollars)
V-9
V-16
ESTIMATED CAPITAL AND ANNUAL COSTS FOR VCM TARGET LEVELS FOR THE PVC INDUSTRY AT 1974 CAPACITY (1974 Dollars)
V-9
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<
V -17 VI-1
SUMMARY OF THE DlSTRlBUTlfcjil^ibF REPORTED ENGINEERING CONTROL METHODS ESTIMATED FOR SELECTED VCM ^VELS IN POLYVINYL CHLORIDE PLANTS
PVC INDUSTRY CLAIMED ANNUALJ^bSTS TO ACHIEVE VCM TARGET LEVELS AND
SUSTAIN 1974 CAPACITY
^S
G
Following Page V-10
VI-3
J
00 01
CP
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00 Cl b 0|
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i
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1. INTRODUCTION
This chapter presents the background of the economic impact study of the proposed OSHA standards for vinyl chloride, the study scope and the organization of the report.
1. SNELL'S ASSIGNMENT WAS TO ASSESS THE ECONOMIC IMPACTS RESULTING FROM THE COST TO INDUSTRY FOR MEETING ALTERNATE STANDARDS FOR WORKER EXPOSURE TO VINYL CHLORIDE MONOMER (VCM) IN THE VCM AND POLYVINYL CHLORIDE (PVC) MANUFACTURING INDUSTRIES
On January 22, 1974 the Occupation^Lj&d,fety and Health Administration (OSHA) was informed by the National Institute for Occupational Safety aruf'iiealth (NIOSH) that the B.F. Goodrich Chemical Company reported the deaths of several of its employees from qPTZtre liver cancer (angiosarcoma) may have been occupationally related. As a result of this information, subsequent epidemiological studies and a fact-finding hearing, an Emergency Temporary Standard (ETS) was p^^blaged by OSHA on April 5, 1974 detailing preliminary regu
lations on worker exposure to VCM (50 ppm catling exposure limit).
As required by law, six months after the issuance of an ETS a permanent standard must be formulated and
approved. Therefore, on May 10, 1974 OSHA pi^Ro^hed a proposed permanent standard which included "no-
detectable limit".
J To aid OSHA in carrying out its standard s%mg mandate Snell was assigned to prepare this report dealing with assessing the economic impacts of alternate s'^SjJ^ards for worker exposure to VCM in the VCM and PVC manu
facturing Industries. The alternate standards inv^d^gpted are: to to . 50 ppm ceiling to 25 ppm ceiling
. 25 ppm 8-hour time weighted average (TWA) with a 40 ppm ceiling
. lower TWA(s) with a ceiling
. "no-detectable" proposed permanent standard
The study is limited to U.S. production of VCM and PVC. to
to to
Exhibit 1-1, on the following page, is a summary of the scope of the Snell study.
to
&
M 1-1
EXHIBIT 1-1 U. S. Department of Labor/Occupational Safety
and Health Administration THE SCOPE OF THE SNELL STUDY"
Primary Emphasis
Secondary Requirements
Deliverables
Assess the economic impact of VCM
Deliver preliminary report on
regulation on VCM and PVC manufacturing only
the 50 ppm, 25 ppm and 'no
Concentrate on PVC manufacture (approximately SO'I'j of level of effort)
Include a study of VCM manulaemre (approximately 20'luof level of effort)
detectable ' casts in 7 week: starting on July 1, 1074 on 23 August 1974
Investigate the following alternate standards
Present draft final report in
- 50 ppm ceiling
11 weeks (13 September 1914)
* '25 ppm ceilinc - 25 ppm TWA^Vith 40 ppm ceiling
an
- lower TWA(s) with ceiling - 'no detectable1 level
i
Emphasize key regulator)' considerations
an
JnchjtJ^secondary regulator)' considerations^
Key deliverables art
- estimates of the time table required in each of these
- engineering and work practices primarily
i - use of personal protective equipment
environmental and personal monitoring - assembling of exposure data
- residual monomer levels in PVC
medical surveillance costs ;eeping costs workers id areas
evaluations for effective, implementation
.. in the near-term, 6 months to one year
.. in the longer-term, 2 years
or more
- estimates of the costs of actiicving the various levels of VCM controls evaluated
- assessment of economic impact on the basis of technical feasibility, timing and costs
(1) Other regulatory considerations include, for example, emergency situations and signs and labels, but were not included in the scope of Snell's work. All the tegulatoty considerations assigned for study are listed in the Exhibit. The work scope did not include study of PVC substitutes or evaluation of economic impacts outside the VCM and PVC sectors,
(2) TWA Time weighted average
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.2 THE REPORT IS ORGANIZED INTO TWO PARTS
conclusions and recommendations are presented first supported by detailed appendices
First Part Of The Report Represents The Findings Of Economic ct Together With Recommendations
One includes the following outputs:
\
Chapter I - introduction. This chapter summarizes the problem, the scope of the stucjfy a^id the organization of the study.
Chapter II - Met!ttc(&blogy. This chapter presents the Snell study methodology. Chpater III - Indutsf^y Structure. This chapter presents data on: Chpater III - Industry Structure. This chapter presents data on:
location of plants;
processes of VCM and PVffr and includes:
This chapter describes the
process description and flow diagrams for each major process; representative operating procedures.
Chapter V - Findings and Economic Analysis. This chapter details the major findings and economic analysis emphasizing technical feasibility, timing, and costs based on aggregating individual company data to the industry levels as a
function of various VCM levels.
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1-2
Chapter VI - Conclusions and Recommendations
(2) The Second Part Of The Report Presents Detailed Study Documentation (Appendices)
This part of the report is comprised of eight appendices and supports the material in Part One.
Appendix A Detailed Process Description and Procedures
Appendix B *
Exposure Data For Polyvinyl Chloride (PVC) and Vinyl ^IhJ^ride (VCM) Plants
Appendix C Economi^Details
Appendix D Person^l^ffotective Equipment and Hygiene
Appendix E Monitori^ quipment
i
A ppendix F
Medical S-tfAfvjp,,illance of Employees
O
Appendix G Safety Awareness Programs
Appendix H N10SI1 Ilec^wgriended Occupational Health Standard for the Manufacture of Synthetic Polymer from Vinyl Chloride.
This chapter presented the scope of the study and organization of this report. The following chapter details the methodology used by Snell to carry out the study.
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1-3
II. METHODOLOGY i
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II. METHODOLOGY
The Final Report supersedes the Preliminary Report. The timing of the project was such that on August 23. 1974, seven weeks from the start of the study, the Preliminary Report was submitted to USDOL/ OSHA for inclusion into the Hearing Record for comments. The Preliminary Report featured:
fact-finding, such as field visits and telephone interviews including recontacting of parties for data clarification; preliminary analysis,;^^egulatory scenarios.
The Final Report represents refinement cl&tRe Preliminary Report as well as inclusion of limited additional information. The draft of the Final Repoi^J^s timed for September 13, 1974 by the end of the eleventh week
of the study.
The methodology used by Snell in fulfil^ng the work requirement was to perform the study in several major tasks described below. All exhibits ifr^presented at the conclusion of the text of this chapter.
* 1. PLANT AND INDUSTRY VISITS WER PRINCIPAL MEANS OF INFORMATION GATHERING
During the course of the ffi^ffitigation, Snell team members mad(/29/ndustry
00
>1
l/l
visits. The vinyl chloride^apd polyvinyl chloride industries corisrSt of 30 producers and(5^>lants. ^iese visits involved either day long technical
discussions in uieir engineering and production offices or detailed plant tours.
~SY% rV $ fO
Exhibit II-l presents the plants, location and purposes of these trips. These trips were comprised of:
0 CO
01 Kj
II-l
I
24 want visits
16 polyvinyl chloride plants representing the polyvinyl chloride plants
8 vinyl chloride plants representing vinyl chloride plants
if the
8 visits to corporate engineering offices O
'3 -
INDUSTRY RELATED ORGANIZATIONS, GOVERNMENTAL AGENCIES, EQUIPMENT MANUFACTURERS AND SPECIALISTS WERE VISITED TO SUPPLEMENT INFORMATION OBTAINED FROM PLANT VISITS
. In order to gain a broader view n$rfl|e technical feasibility and necessary costs, personal visits were made to rectjgttized experts in the areas covered by the study.
M
. Exhibit II-1 details the organizations^, governmental agencies, and equipment manufacturers visited and the tyj^^f information obtained. These visits included:
4 visits to government agencies 3 visits to industry organizations 4 visits to equipment manufacturers or technical specialists
3. A TELEPHONE SURVEY WAS CONDUCTED OF
1UFACTURERS OF MONITORING EQUIPMENT,
RESPIRATORY DEVICES, PERSONAL PROTECT^fjEQUlPMENT AND PROCESS EQUIPMENT
The purpose of this task was to obtJ^-dletailed information covering costs,
availability, and technology. Information was obtained both directly through the telephone survey and the brochures and catalogues sent to Snell as a result of the conversations.
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II-2
Exhibit II-3 details the manufacturers interviewed during the telephone survey. Calls were made to:
13 monitoring equipment manufacturers 7 manufacturers of respiratory equipment 6 producers of protective clothing 7 processing equipment manufacturers
4. THE SNELL INFORMATION CENTER STAFF CONDUCTED A LITERATURE SURVEY TO IDENTIFY AND OBTAIN BACKGROUND INFORMATION ON AREAS RELEVANT TO THIS STUDY
To obtain an'overview of Tfljajiufacturing processes, pollution problems, marketing, end-use products, and p^i,^it)le protective devices, etc.. a survey of the following journals was performed: )
. Hydrocarbon Processing - 15 years . Modern Plastics - ^j^ars
Chemical Marketing Reporter - 3 years . Chemical and Engine^fiig News - 3 years
Chemical Engineering""*! 5 years . European Chemical News - 3 years
Standard chemical referencgjfucts such as the Encyclopedia of Polymer Science and Technology and the Kirk-Ot'ES^r Encyclopedia of Chemical Technology were also researched to obtain more g^^al information.
Chemical Marketing Abstracts and Chemical Economics Handbook were used for basic industrial facts.
II-3 1
p800 SJ0
5. THE STUDY METHODOLOGY EMPHASIZED THE PARAMETERS DEFINED IN EXHIBIT 1-1, IN THE INTRODUCTION CHAPTER
The methodology described in the above points was employed to determine and define the scope of the following parameters:
Profiling of industry structure and processes
Definition of the number of workers potentially exposed to VCM considering
job'description unit operation potential exposure
; levels
Determination of costs and riteal^s of controlling exposure levels through engineering controls and imjirbved work practices with particular attention to:
"buttoning-up" of pla^rt^
ventilation J operation
maintenance
4 O^
process improvements, such as reducing free monomer levels in the jtaiylner
Investigation of further method personal protective equipment eering and work practices
d costs of protection through the use of and controlling exposure through engin-
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II-4
i
Development of a technical and economic information base for personal and area monitoring and leak determination equipment
Isolation of information regarding:
medical surveillance costs record keeping costs covered workers regulated areas
Detailed methodology is resented as footnotes to exhibits, textual reference or material in the appen
f\
. v..
6 AS DIRECTED BY OSHA THE STUDY
LT PRIMARILY WITH PVC PRODUCTION
Approximately 80% of the level of effort in subsequent chapters reflects this.
devoted to PVC production. Discussion emphasis
J
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11-5
7. WORK AFTER THE PRELIMINARY REPORT FOCUSED ON THE FURTHER ANALYSIS OF VCM LEVELS, AND THE RESULTANT COSTS, GENERAL DATA REFINEMENT AND FURTHER EVALUATION OF TECHNOLOGY
The principal work elements in the finalization of the Preliminary Report included:
Study of comments fyom^OSHA, public review and Snell's internal review of the Prelimfp$jpy Report resulting in clarifications and refinement of the data/;-*
Aggregation of individuate plant exposure data from each company
as well-as from OSHA'tdLdevelop industry profiles of average
VCM levels
(Jft
Development of order-of^tiignitude estimates of the potential
economic impacts of meeting the PVC industry exposure limits of a 10-15 ppm VCM ceiling with a 5-10 ppm TWA
Preparation of a case sti|^3c4in the PVC industry as an illustration of cost analysis approach J wInternal review of the cost analysis resulting in data refinement
Incorporation of limited new information on technology such as stripping
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II--6
8. WHERE THERE WAS A QUESTION AS TO THE POSSIBLE PROPRIETARY NATURE OF INFORMATION. DATA SOURCES WERE CODED
The elements of each coded plant designation are as follows:
Random number only for VCM plants
Random leading number for PVC plant
m
- PVC Plant Capacity^ on
- S = Small, less than^ 100 million
<s - M= Medium, 100 to
200 million lbs^^ -
PVC Plant Age New = to 10 yrs. Int. = 11 to 20
yrs.
Old = Over 20 yrs.
- L = Large, over 2olf3Hilion lbs.
PVC Plant Siting C = Cold climate W = Warm climate
For example, the code for one of the PVC plants is as follows:
52
-S
- Old
-C
Exhibits featuring the code refer back to this page for meaning of the elements of the code
*****
This chapter detailed study tpethodology. The chapter that follows presents the preliminary findings and conclusions.
SS00 5JS
II--7
i
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Firm or Organization Visited
V^Air Products, Inc.
/V O p(Qr-
~V alley Forge, Pennsylvania
*^Allied Chemicals, Inc.
Corporate H.O. Morristown, New Jersey
/l/1?
' 14S, t
American CherateAl Co. Long Beach, CauW^a
Conoco
*]
. Corporate H.Qs-'Saddlebrook, New Jersey . Oklahoma City,^klahoma
Diamond Shamrodlt//^
. Corporate H.Q. Cleveland, Ohio . Delaware City, D^Vare
. Deer Park, Texas '^
SI
Dow Chemicals, USA . . Plaqucminc, Loui&Sfifl . Oyster Creek DivisiflfiT'Freeport, Texas . Texas Division, Fr^eS&rt. Texas Fthyl Corporation
1'aion Rouge, Louisiana^'jJ*X_
Firestone Tire & Rubber Co
Akron, Oltio
General Tire & Rubber Co. Ashtabula, Ohio
Purpose of Visit
EXHIBIT II-XI) USDOL/OSHA VINYL CHLORIDE/POLYVINYL CHLORIDE PRODUCERS VISITED AND INTERVIEWS BY PHONE BY SNELL STAFF FOR DATA COLLECTION
Technical and engineering data collection on PVC
Technical and engineering data collection on VCM
Plant visit on VCM and PVC
Technical and engineering data collection plant visit on PVC
Technical and engineering data collection on PVC
Plant visit Plant visit
Plant visit on VCM plant visit on VCM Plant visit on VCM Plant visit on VC
interview
plant visit on PVC
Firm or Organization Visited
B. F, Goodrich Co. . Corporate H.Q. Cleveland, Ohio . Calvert City, Kentucky . . Long Beach, California . Louisville, Kentucky , Pedricktown, New Jersey
Goodyear Tire & Rubber Co. Niagara Falls, New York
Great American\gnemical Co. Fitchburg, Massachusetts
Hooker CheniicafcCorp. Florence, New Jejjji^'
Monsanto
f/f\
spnngfield, Massachusetts
SNational Starch & mical Co,
Corporate H.Q. PfStn^eld, New Jersey
' Olin-Thompson Plastic^ Assonet, Massachusetts
Pantasote
Passaic. New Jersey
Robiniech, Inc.
QD
Painesville, Ohio
Shell Oil Co. . Corporate H, Q. Houston, Texas
. Deer Park, Texas
Stauffer Chemicals Delaware City, Del,
Tenneco Burlington, New Jersey
Purpose of Visit
EXHIBIT 11-1(2) USDOL/OSHA
Technical and engineering data collection Plant visit on VCM Plant visit on PVC Plant visit on PVC . Plant visit on PVC Plant visit on PVC
Plant visit on PVC
Plant visit on PVC
Phone interview on PVC
Technical and engineering data collection on PVC
Plant visit on PVC
Plant visit on PVC
Plant visit on PVC
Technical and engineering data collection on VCM Plant visit on VCM Plant visit on PVC
Plant visit on PVC
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O
Firm or Organ!
Visited
^Union Carhirir. So, Charleston, W^J^Virginia
- Uni royal Chemical Co. Akron, Ohio
Source: Snell
ay
'A
I
t;
EXHIBIT 11-1(3) USDOL/OSHA Purpose of Visit Technical and engineering data collection on PVC Plant visit on PVC
Q --'
I. Government Agencies
U, S, Department of Labor Washington. D. C.
National Institute for Occupational Safety and Health Cincinnati, Ohio Environmental Protection Agency Washington, D. C. and Research Triangle Park, N.C. U. S. Dcpau&Tj)nt of Commerce Washington, ,^ C.
II. Industry Orga-ttfgitions Manufacturinjr^^emists Association
New York, l^ey^lork Organizational Resources Council, Inc, Washington, Society of the`Plashes Industry New York, New Yfl
III. Equipment ManujacUirers. Medical Laboratories. Industrial Consultants. Etc, The Pfaudler Co. ^Biv, Sybron Corp.
Rochester. New YmkJ Diagnostic Sciences. Inc. - Ivan K, Smith Morris Plains, New Jersey Tec-Air, Inc, - David Metal East Northport, New York Human Motivation Resources - Joel D. Schaffer Morris Plains, New Jersey
Source; Snell
EXHIBIT II-2 USDOL/OSHA GOVERNMENT AGENCIES, INDUSTRY ORGANIZATION'S. AND EQUIPMENT MANUFACTURERS VISITED BY SNELL STAFF FOR DATA COLLECTION
General data collection and attend hearings
Discussion on medical, monitoring, and protective equipment
General data collection Industry marketing data collection
*
Discussions on technical feasibility and marketing data General discussion Discussions on technical feasibility
Discussions on polymerizers and other technical questions (sole U, S. suppliers of glass lined equipment) Medical surveillance data collection Protective equipment data collection Safety program data collection
BF5 QQS3&3
0
I. Monitoring Equipment Manufacturers
AID West Chester, Pennsylvania
Bacharach Instrument Co. Pittsburgh, Pennsylvania
Bechmann Instrument Fullerton, Q^tidrnia
Bendix Corpmaimn Environmenta'fsclence Division Baltimore, Mwytand Byron Instrument^ Inc.
Raleigh,
Carle Instruments Fullerton, Califojjirt
Century Systemj&S^. Arkansas City, Kansas II. Respiratory Eqni^S^^ Nianufacturets
m
Bausch Si Lomb
,,
Rochester, New Y\yy J-
Mine Safety Appliances Pittsburgh, Pennsylvania
Minnesota Mining & Manufacturing, Inc^^f*
Minneapolis, Minnesota
Scott Aviatian South Haven, Michigan
EXHIBIT 11-3(1) USDOL/OSHA FIRMS CONTACTED DURING THE SNELL TELEPHONE SURVEY OF EQUIPMENT MANUFACTURERS
Hewlett-Packard Co. Avondale, Pennsylvania Microcliemical Specialties Co. Berkeley, California Perkin-Elmer Norwalk, Connecticut Anatolc J, Sipin Co, 386 Park Avenue, S. New York, New York Varian Association Palo Alto, California Wilks Scientific Norwalk, Connecticut
Survive-Air Santa Ana, California
Welsh Scientific, Inc. Providence, Rhode Island
Willson Products Pennsylvania
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Q
III, Protective Clothing Manufacturers
Arrow Disposables, Inc, Cincinnati, Ohio
E. I, Dupont de Nemours Wilmington, Delaware
Durafab . Cleburne, Texas
IV, Processing
ent Manufacturers
Dresser Industries (Compressorrwta Vacuum Pumps) Connersvilldl^/^jlana
Durion Com
Inc.
(Valves and Pumps)
New York, Neyiaork
Fluid Handling System
(Viking Pumpfa=r"J
Secaucus, Netto^roey
t==H
GAF
^
(Cleaning Systi^jg^}
New York, New York
Source: Snell
Edmont-Wilson Coshocton, Ohio
Mars, Inc, Ashville, North Carolina
Uniroyal, Inc. New York, New York
Nash Engineering Co. (Compressors and Vacuum Pumps) Norwalk, Connecticut
Process Pumps, Inc, (Pumps) Kenilworth, New Jersey
Stauffer Inc. (Cleaning Systems) Westport, Connecticut
EXHIBIT II-3 (2) usdol/os; IA
O
XJ // f\
on
III. INDUSTRY STRUCTURE
BFS Q0S3S5
"\
III. INDUSTRY STRUCTURE This chapter presents an overview of the structure of the U.S . vinyl chloride monomer (VCM) and poly vinyl chloride (PVC) industries. Key elements of production, prices and markets are delineated to provide a background and comparative criteria to judge the economic impact of proposed regulations on VCM and PVC manufacturing. The chapter is divided into three sectiop&V
. Section IIIA* - Vinyl Chloricfe=M'onomer Production
qn
. Section IIIB - Polyvinyl Chl^rhde Production Section IIIC - Key Polyvinyl chloride Markets
III-l
BFS 008366
O
IIIA. VINYL CHLORIDE MONOMER
This section defines the structure of the vinyl chloride monomer (VCM) manufacturing industry.
1. . NINE COMPANIES OPERATE 14 VCM PLANTS
Exhibit III-l, on the following page, presents a profile of the VCM producers in
terms of plant locations. capacities and manufacturing process. Process related factors are'discussed^ Chapter IV.
Shell, Dow and Goodric
S-
are the leading 1974-1975 producers, accounting for
approximately 58% o eplate capacity.
Approximately 5,22ion pounds VCM are estimated to be available annually for conversion into PVC in 1974-1975, assuming no major economic impact from OSHA regulation;^
Q^
With the exception of the Goodrich plant in Calvert City, Kentucky, the U .S. VCM plants are locat^^ warm climate areas -- Texas, Louisiana, Puerto Rico, and California. Mngeneral, the plants are open except for weather screening.
VCM plants are generaHylocated in or near petroleum rich areas to minimize the cost of feedstock (ethylene) transfer.
BFS 00S 36?
III--2
',5
O
\
Major Ptoclucer/Location
Allied, Geismar, La.
American Chemical, Watson, Calif.
Conoco, Lake Charles, La.
Dow, Freeport, Tex.
Dow, Oyster Creek, Tex.
Dow, Plaquemine,, La.
Ethyl, Baton Rouge, La.
Ethyl, Houston, Tex,
Goodrich, Calvert City, Ky, -- -h
Monochem, Geismar, La.
PPG, Guayanilla, P. R.
PPG, Lake Charles, La.
Shell. Deer Park, Tex.
7:
Shell, Norco, La.
Total
r^
Correcting for 90!o operating. level
Subtotal
Syo lost in polymerization 7I
Subtotal
Estimated 1974 exports
Estimated 1974 imports
Subtotal
Other uses of VCM
r_ *
Total available for PVCv^/Qirsion
Order of magnitude values
1974-1915 . Nameplate Capacity (Million I,b$,)
1,400 450
900 1,500
300 no G25 r 180 r*700 ("450 r 270 ("150 1,000 350 ("500 ("300 r 800 ("700 6,095
070 6,025
300 S, 725
300 Negligible
5,425
200 5,225
. EXHIBIT III-l
USDOL/OSIIA
PROFILE OF VINYL CHLORIDE PRODUCERS
Process
Oxychlorination Stauffer Oxychlorination Stauffer Oxychlorination Dow Oxychlorination Dow Oxychlorination Dow Direct Chlorination Direct Chlorination Direct Chlorination Goodrich Oxychlorination Acetylene Oxychlorination Oxychlorination Stauffer Oxychlorination Stauffer Oxychlorination
BFS 00S3&S
Sources,-
(1) 'Company and industry totals based on Modern Plastics. May, 1974 and plant site estimates based on Chemical Marketing Reporter, 17 September, 1973, and industry interviews.
(2) Industry interviews. -
(3) Snell assessment
i
O
2. U.S. VCM PRODUCTION HAS INCREASED APPROXIMATELY 370% TO 6,000 MILLION POUNDS IN 1974 SINCE 1964, WHILE THE MID-1974 PRICE IS 7 TO 10 CENTS PER POUND OR ALMOST DOUBLE THE 1972 PRICE . Exhibit III--2, on the following page, presents production, sales and price
data for the years 1962 through 1978-1980 (estimated) , Sales and unit cost 11 information ar^lso presented. . Since 1964 protection of VCM has increased from 1,615 million pounds to an estimated 6.. 02ffcihillion pounds in 1974, for an increase of 373%.
"jfc
. For the yearsrJ962 to 1972, production of VCM increased from 1,311 million pounds to 5, O&Fmillion pounds or 388%, while merchant sales increased from 516 million pounds to 3,343 million pounds or 647%. Merchant uses were 39% of production i*fT962 and 66% of production in 1972. This indicates a decreased forward integration in the industry with growth. The doubling (^Splice from 1972 to mid-1974 is attributed to the great escalation in feedstock cc^s^doe to the "energy crisis".
3. THE VCM MANUFACTURING INDUSTRY HAS APPROXIMATELY 940 PRODUCTION WORKERS . Based on a Snell survey of VCM producers, representing approximately 65% of 1974-1975 nameplate capacity (see Exhibit 1II-1), estimates were developed of the number of production and related personnel in the industry.
Ill--3
BFS 00S3S9
(
EXHIBIT III-2 USDOL/OSHA VINYL.CHLORIDE MARKET TRENDS
Year
1962 1963 1964 1965 m I960 1967 1968 1969 1970 1971 1972 1973 1974 1978-- 19S0 (Unimpacred by OSHA Standards)
Production^ (MM Lbs.)
1,311 1,435 1,615 2,000 2,500 .424 .969 3,736 4, 040 4,336 5,089 5,348 6,025(3)
tty*
W (p
XP
Sales(^) (MM Lbs.)
516 501 597 688 836 952 1,463 2,359 2,720 3,003 3,343 NA NA
NA .j
Unit Value ($/Lb.)
7.5 7.0 6.4 6.1 5.9 5.3 4.6 4.4 3.9 4.2 4.0 5(2) 7-10(?)
NA
Sources;
(1) "Synthetic Organic j^emicals", U. S, Tariff Commission, Annual Reports 1960-1.973.
(2) Posted price in tanks (works, freight equalized), Cnemical Marketing Reporter, December 31, l')73
and June 4, 1974.
a
(3) Estimate based on l97^icity 6,695 MM Lbs. in Exhibit III-i at DO^b utilization.
(4) 7,500 MM Lbs. capacitjrat^O^ utilization per Hydrocarbon Processing, May. 1974, p. 83,
NA=Not Available
i.
BFS Q083?
Exhibit III-3. on the following page, summarizes employment data for 1974
production, maintenance.%hd laboratory personnel have responsibilities with likelptpod of VCM exposure; these represent 720 workers or'^ of manufacturing employment
there are approximately 220 iri^nagement and support personnel
- `-A * .
. This section defined the' structure of the VCM in '
PVC manufacture.
v
y. The section that follows similarly profiles.
(P
BFS 0083?
in-4
Broad Job Classification
Production^ Maintenance^ Laboratory Management and Support' `
Total VCM Workers Scaled From Snell Survey
EXHIBIT III - 3 USDOL/OSHA
VINYL CHLORIDE PRODUCTION WORKERS - 1974
Approximate 1014 Number of Workers
410
'JO- 250 60 220
y0 -\4 940
Percent of Total
44% 27
6 23
100%
: ^oteS:
w I1) Includes line supervisors, such as foremen
(2) Includes plant managers, engineering staff, clerical, etc.
ft
Source;
Snell survey of industry covering approximately 65% of 1974-1075 nameplate capacity
ft
ft
ft ft ft ft N lu
iX
IIIB. POLYVINYL CHLORIDE PRODUCTION
This section defines the structure of the polyvinyl chloride (PVC) manufacturing industry. The exhibits supporting this discussion appear sequentially after the text of this section.
1. 21 COMPANIES OPERATE 36 MAJOR PLANTS
A profile of PVC producers in terms of plant locations, nameplate capacities, and probable pblymerizer (reactor) sizes is summarized in Exhibit III-4. Exhibits III--5 and I1I-6 p'fpvide interpretation of these data.
The total 1974 nameplate capacity of the industry is approximately 5.4 billion pounds per year^^with over 1.9 billion pounds of new capacity scheduled over the next two years'.
r .'V"' As shown in Exhibit III-5, no single company dominates PVC production.
Goodrich, Qre^largest single producer with five plants, produces approximately 20% of the nation's PVC . The next fit^gp^rgest producers, with a total of nine plants, each produce between 6% &nt&9% of total production. These producers are Firestone, Conoco, Unioirffiarbide, Borden and Diamond Shamrock.
Each of the n thirteen producers, with a total of twenty plants, shares from 1% to less than 5% of total production.
The remaining two companies, with a total of two plants, each shares less than 1% of total PVC production.
Ill-5
BF5 0083?
PVC is produced in sixteen states, as shown in Exhibit III-6. Production is close to raw material supply (VCM) or near resin market centers.
Over 5fl%_nf PVH resin cananitv is er^nnnntrated in five states Ohio, lew Jersey) Texas/TMassachusSTTsUnd (JaliTornia.
Within these five states are located eighteen producing plants.
/Only ten plants_are located in warm climates where open structures are possible; the remaining twenty-six plants are sited "InTstates having moderate to cold temperatures.
A majority of the operating plants are older than ten years, as estimated in Exhibit III-7.
/'-y Q
,'
About^8%^ tj^plants are older than ten years.
Only 8% of opgr^ing plants are less than five years old. with the
"newest plant '^Gtingoperation in It)" 1.
1
,m
Two new plants are scheduled to come on stream in late 1974, and
several others
planned for later construction, seen from Exhibit 1II-4.
Historically, PVC production has been a batch operation and manufacturing was conducted in relativete^nall reactors to maintain product flexibility, quality, and most important, thestFre^ctors were not available in large capacities.
t=X]
As shown in Exfeijpit III-4, reactor sizes are almost equally divided between those prams using reactors less than 2,500 gal. capacity, and those between 2,500 gal. and less than 7,500 gal.
Only nine plants use polymerizers equal to or larger than 7,500 gal.
BFS 80S37
III-B
According to recent technological developments, the trend is toward larger reactors in new plants. An industry-wide summary of PVC homopolymer production as a function of reactor size in 1972 vs. 1S75 is summarized in Exhibit III-8.
Approximately fi5% of the homopolymer produced in 1972 was made in reactors with 7,500 gallons or smaller capacity.
By 1975, it i^ than 60% of to
;cted that the smaller reactors will account for less `oduction .
Y Bulk polymerizh^lncapacity is expected to almost double.
The use of small reamers is expected to continue in the long run, but
X The four methods used for pplymerizing PVC include suspension, emulsion, bulk,
and solution polymerization, '
suspension polymerization being used at a majority
of plants as shown in Exhibit
Suspension resin productitfa^is reported in 33 plants, accounting for 78% of 1973 output.
Emulsion resin production is reported in 16 plants, accounting for 13% of 1973 output.
Four plants produce bulk resins, while 2 plants produce solution resins, accounting for 9% of 1973 output.
III-7
,, i
.2 THE PVC MANUFACTURING INDUSTRY HAS APPROXIMATELY 5,600 PLANT EMPLOYEES
Based on the survey of PVC producers by Snell, estimates were developed of the 1974 number of production and related personnel in the industry, as shown,.i^Exhibit III--10.
the approximately 3*d?6K) workers identified with suspension processes represonU5$% of industry employment, while emulsion process worlds represent 27%; bulk and solution process workers repr^^it 9%
55% of PVC plant employm^it is represented by production workers, while 24% by maintenance personnel;_thesej^5jarox^ imately 3,900 workers have the higlisLliklilipod_olVM. ex^esuren^
The Snell survey yielded an estiffifl^ of 5,575 plant employees. A confidential study by industry soumcs independent of Snell, presented in Exhibit B-l, identified 5,045 workers.
*****
This section defined the structure of the PVC manufacturing sector. The section that follows defines key PVC markets.
BFS 008376
Ill--8
I
EXHIBIT III - 4(1)
USDOL/OSHA PROFILE OF POLYVINYL CHLORIDE PRODUCERS
Producer Air Products
American Chemical Atlantic Tubing Borden
Certain-Teed Conoco
Diamond Shamrock Ethyl Firestone
General Tire & Rubber
Location
Calvert City. Ky, Pensacola," Ua.
t^EtSMEeach, Cal,
O
mioj^yf.^111. LeominatclfyMass. Springfield, Mass.
A
Lake ChaiL-<7--fcA '
Aberdeen, Oklahoma CityXdaJyiN
Deer Park, Tex. j Delaware City, DcILJJ
Baton Rouge. La.
Pottstown, Pa. Penyville, Md.
Ashtabula, Ohio
Approximate 1974 Nameplate Capacity
(million lbs.)
125 60
ICO
125 190
70
250 215
250 100 130 190 315
125
Planned Million Lbs.
Per Year
200-300
Additions Starting Date
planned
50 200-
2nd qtt. 1974 late 1974
300 late 1974
( ( unspecified (
200
-
4th qtt. 1974
late 1974
unspecified
under way
| unspecified - under way
I
Probable Polymcriz.T Size Range (call' ,
<2, 500 2,500 - <7,50; >7,500
X X
XX
X
X XX X
n. a.
XX
X X
X
XX X
XX
X X
X x
M
BFS 00SJ?
EXHIBIT III - 4(2)
USDOL/GSHA PROFILE OF POLYVINYL CHLORIDE PRODUCERS
Producer Georgia-Pacific 0. F. Goodrich
Goodyear Great American Chemical Hooker Chemical Keysor-Century National Starch Olin Pantasote
Location
Plaqueminc, La.
Aj0S*fy.ake( Ohio fifth?. 111. Lon^feach, Calif. LoiHs^iJle, Ky. Pedr^rk^jn, N. J.
Xiagai^jfpls, N. Y, Plaqueminc, ,La.
' Fitchburg, TOTss.
0 Burlington, Wfwi Hlcksville.
Saugus, Cal. ^ ^*s
Meredosia, 111.
Assonet. Mass.
Passaic, N. J. Point Pleasant, W. Va,
Approximate 1974 Nameplate Capacity
(million lbs.)
Planned Million Lbs.
Per Year
Additions Starting
Date
220 4t!i qtr, 1974
315 235 190 180 160
100 100 100 3rd qtr. 1974
70
180 15
35 (1)
10
- ( expansion 5 held in
( abeyance
150
60 95,
Probable Polymerize r Size Range (pallo, ,
<2,500 2,500 - <7,50.'
>7, 500
n, a.
xx xx xx xx xx
X
*X
X
X
X X
X XX
x XX
BF5 0083?
00
\
)
EXHIBIT III - 4(3)
USDOL/OSHA PROFILE OF POLYVINYL CHLORIDE PRODUCERS
Producer Robintech Stauffer Tenncco
Union Carbide Uni royal
Location
Approximate 1974 Nameplate Canacicy
(million lbs.)
Planned Million Lbs.
Per Year
Paincsville, Ohio
.A
r - Y'\
Delaware City,
250 160
220
10 55
Burlington, N, J. Flemington, N.J, Pasadena, Tex.
./ ft")
'~-'r ft: (_
150 85
300-
S, Charleston, W. Va. Texas City, Tex,
o
160 240
Painesville, Ohio .A
. Total Nameplate CapaciiyV^^S
_
Planned or 1,900+ Anticipated New Capacity
Additions Starling Date
4th qtr, 1974 3rd qtr. 1975 3rd qtr. 1976
4th qtr. 1974
Notes:
(1)
Operates a pilot plant at Plainfield, N, J, with an estimated capacity of 0,2 million pounds
(2) Jointly owned by Pantasoto and Central Tire & Rubber, and operated by Pantasote
Sources.- Chemical Marketing Reporter, May 20, 1974; industry interviews; Modern Plastics. May 1974,
Probable Polymeri" kT Size Ranee (gall : )
<2.500 .500 -<7,500 >7,500
X
XX
XX XX
N, A. .
X XX
XX
22 27 9
N. A. - not available
VO
I
BFS 00S3?
'/rtr\i
EXHIBIT III - 5
USDOL/OSUA `
COMPANY CAPACITY AS PERCENT Or TOTAL POLYVINYL CHLORIDE PRODUCTION CAPACITY
' Company
197-1 Company Nameplate Capacity (million lbs.)
Share of Total Capacity at mid 1974 (percent)
Accunu cd Perci
B. F. Goodrich Firestone
10S0 505
1L9-, ^^0.3 ^
10. . 29.1.
Conoco
465
37. F
LUii^Carbide Bor^fii
400 7.4 45.2 3S5 7.1 52.
pi a month Sham rock
350 6.4 5$. 1
Rohi'ntttg^ Tenne^jf)
250 4.6 63.." 235 4.3 67. C
Air ProMuett. Goodycti^_jH)
205 3. S 71.-1 200 3.7 75.1
Hooker
.
195 3.6 78.7
Ethyl
ISO 3.3 82.0
Stauffer --^
ICO 2.9 84.0
CD
American Chemical
160 2.9 87.8
>1 Pantasote
155 2.9 90, 7
Olin
150 2.8 93. 5
General Tire
125 2.3 95.8
Uniroyai
^ (A
120
2.2.
98.0
Great American
'
70 1.3 99.3
Kcysor-Cenrury
35 0.6 99. 9
National Starch
10 0.2 100.1
Total
5.435
100.1 -7/P1)
<5>
Note:
(1) Does not add to lOO^o because of rounding errors,
Oj
Source;
Exhibit III - 4 and Snell estimates
i
State /ohioTM
V Ncw
(l)
Number of Plants
yXOali fornfa ^
Illinois
Maryland l/Kentucky
^ j'f).
..Louisiana' r Delaware ^
. /A
^West Virginia
^
.Mississippi2'
^Oklahoma (2)
^.Pennsylvania ^
V New York U)
Florida,'(2)
TOTAL
ur>
26
Notes: (1) Sited in moderate to cold climate
(2) Sited in warm climate
20
10 30
Source:
Exhibit 111 -4 and Snell estimates
EXHIBIT III - 6
USDOL/OS1IA
GEOGRAPHIC DISTRIBUTION OF POLYVINYLCHLORIDE PLANTS - 197 i'
Production Capacity (million lbs.)
810 635 400 4S0 385 370 315 305 280 2G0 255 250 215 100 115 SO
5. <135
3.735
1, 700 5, <135
Share of Total Capacity (percent)
14. 0 cb 11.7
0.0 8.8 7.1 6.8 5.8 5.6 5.2 4.3 4.7 4.6 4.0 3.5 2.1 1. 5
100.1%(3)
68.7
31,4
100. I*#)
Accun .'.ted Pc: t
14. i 20. 2J.. 44. : 51. ' 58. 64. 1 60. : 74. I' 70. 84. ' 80. n 92.9C, 98.
100. ,-(3)
(
BFS 00SJS1
BFS 0QS3S2
(Un.pl* Kf * tliSL 10 y*S
Producer
Air Products American Chemical Borden
Conoco Diamond Shamrock Ethyl Firestone General Tire Goodrich Chemical
Location
Calvert City, Ky. Pensacola, Fla,
V=ach- Calif.
/S* . \
Lepmin)ter, Mass.
mh^fliu. ni.
Spril(?gn3d, Mass.
Abe rdCeil/ Miss.
Oklalionia^^ty, Okla.
Deer Park, Tex. Delaware Ciw^ADel,
MBaton Rouge,,
Pottstown, Pa,^" fiT\ Pcrryville, Md/^
Ashtabula, Ohio
Avon Lake, Oliio Henry, 111. Long Beach, Calif. Louisville, Ky. Pedriektown, N. J.
EXHIBIT III - 7(1) USDOL/OSIIA `
U. S. POLYVINYL CHLORIDE PLANT AGE- 197
Plant Are As Approximately Indicated By Startup patc^ (y cart,
0- 5
C - 10 11 - 15 1G - 20 21 - 25 over 2'
o
E)
(3
I
Producer Goodyear
Great American Hooker
Key sor-Century National Starch Olin Pantasote
Robiniech Stauffer Tenneco
Location
Niagara Falls, N, Y. Plaquemine, La. # Fitchburg, Mass,
'tlifcksvilic, N. Y. ijfilrlifigton, N. J.
Sa^gJs^Calif,
111. Assonej^Cl^ss.
Passaic, N. La Poinr PlcSsSte) W. Va. Painesvillcy^Sri^ Delaware Cit^e^el,
Flcmingron, N, J, Burlington, N. J.
EXHIBIT III - 7(2)
USDOL/OSIIA U.S. POLYVINYL CHLORIDE PLANT AGE - 197-1
Plant Age As Approximately Indicated fiy Startup Datc^ (years) 0-5 G - 10 11-15 1G - 0 21 - 25 over 2G
x
BF5 QBS3S3
i
EXHIBIT III 7(3)
USDOL/OSHA U. S. POLYVINYL CHLORIDE PLAN'!' AGE'- 1974
Producer
Location
Plant Ai''C As Approximately Indicated lly Startup Dare^ (years')
0-5 G - 10 11-3;
1C - 20
25 over 2u
Union Carbide
Uniroyal Total
Notes;
(1) (2)
S. Charleston, W, Va, Ljikv Texas City, Tex.
fv~.
[ Gainesville, Ohio
Up
r(f>
12
7// 2 U^7A)
Or when plant underwent drastic rebuildine Cj 0
Joint plant with GcncralTirc &. Rubber and operated by Pantasote
*(C Ye
U4?s
CD-
//
Source;
Snell industry interviews
<P
BFS O0S3S4
EXHIBIT III-8
USDOL/OSHA
pvc homgpqlyv.er production in varici'-; SIZE REACTORS - 1972 197S
IF LI
BF5 00S3S5
Note: Source;
Assumes no impact from OSHA requirements
Disch, C, E.. Plastics -- Raw Materials to End Markets and Coatings-- New Technology and Markets, American Chemical Society, Brooklyn, 1974, p.7.
BF5 00S3SS
Produce/^ Air Products
4
American Chemical Atlantic Tubing Botden
Conoco Diamond Shamrock Ethyl Corp. Firestone General Tire
Location^
Calwprt City, Ky. 1*c5s|pola, Fla,
Long^ach, Calif.
iP ftLeomfinjtet, Mass.
Illiopolis, 111. Springfli^d', Mass.
0 Aberdeen, Miss. Oklahoma^ Okla, Deer Park, e\
Delaware
Baton Rouge. La.
Pottstown, Pa. Pertyville, Md.
Ashtabula, Ohio
EXHIBIT III - 9(1)
USDOL/OSHA
POLYVINYL CHLORIDE PRODUCTION BY RESIN TYPE
Suspension Resin
x
X
X
X
X X X
X X
X X
X
x
_______ Product line
Emulsion
Bulk
Resin
Resin
X X
X X X X
Sole:; ( Resi t
BFS 00838?
Produce/1) Goodrich Chemical
Goodyear Great American Hooker Keysor-Century National Starch Olin Panrasore
Location^1) A'^^-akc, Ohio
Hcru^-in. ho%_^Ach. Calif. LouisyiHs, Ky. Pedrlgjjiown, N. J.
ffh NiagarSrFalh, N. Y. Plaquemincslu.
Fitchburg'/ Mass. Bur]ington,\^^
Hicksville,
Saugus, CM{<(Jp)
Mcredosia, ill
Assonct, Mass,
Passaic, N. J, Point Pleasant, W, Va
EXHIBIT III - 9(2)
USDOL/OSHA
POLYVINYL CHLORIDE PRODUCTION BY RESIN TYPE
Suspension Resin
X X X X X
X
Product Tine
Emulsion
Dull*
Resin
Resin
X
SoluL,:" * Resi.'
X
X X
X X
EXHIBIT III - 9(3)
USDOL/OSHA
POLYVINYL CHLORIDE PRODUCTION BY RESIN TYPE
BBS 00S3SS
Producer D)
- -,;^3(C3iion (1)
Robimech
^f^fi^csville, Ohio
Stauffer
arc City, Del.
Tenneco Union Carbide
Bhrffn&ton, N.J. Flemington, N.J.
S. C&arjpston, W, Va. Tej&sCity, Tex.
Uni royal
Pain4$y#_i&r, Ohio
Total 1973 U. S, Production, million lbs.
'"Si
(fi
Percent of Total Production
Suspension Resin
x
X
X
x
X
x =3a3 ^ 3,558
78J/o
_______ Product line
Emulsion
Bulk
Resin
Resin
X X
X
x 16 t^5 593 13$
x
-
274
6JA
Solir u Rl : ,
13'
:
Note: Sources;
(1) Jointly owned with General Tire, operated by Pantasote I
Industry interviews and Snell assessment of product lines Monthly Statistical Report. The Society of the Plastics Industry,' Inc., April 6, 1973 and March 20, 1974 for production data
n
Broad Job Classification
Production Maintenance Laboratory ' Management aniKt$Jiort^ Total PVC Industry tv^r^rs Scaled From Snell Survey (3)f jQ
Percent of Approximam ^LfeCapacicy Covered by Snell Survey0
EXHIBIT III - 10 USDOL/OSIIA
POLYVINYL CHLORIDE PRODUCTION WORKERS - 1974'
Suspension
1,020 790 260
6_10_
3, 580
Emulsion
700 470 100 140
1, 500
Workers By Process Type Bulk Solution
Total Percent of Tou i
135 25
C 25 f_
185 ( { 125 !_
3, 030 ~ 1,350
300 ^ 805
65% 24
7 14 _
185
310
5, 575
iooY*
---- -- '
79%
67%
1007a
100%
Notes; Sources:
(1) Includes line supervisors, such as foremen (2) Includes plant managers, engineering staff, clerical, etc. (3) Personnel associated with compounding and fabrication In integrated facilies ace not counted
Snell survey of industry
BFS QQS3S9
V}
IIIC. KEY POLYVINYL CHLORIDE MARKETS
This section presents data on polyvinyl chloride (PVC) output trends, prices, end-uses, and polymc characteristics regarding free monomer levels as shipped to fabricators. Supporting exhibits appear sequt tially at the end of the text.
1. PVC PRODUCTION HAS INCREASED OVER 300 PERCENT FROM 19G3 TO 1973, AND FROM 1972 TO MID-1974 PRICES IIAVE APPROXIMATELY DOUBLED
Exhibit III-ll y \ production, sales, and unit value trends since 1960. - The increa^D in output from 1963 to 1973 was/318%^)
fib
'
- The leveling of output from 1972 to 1973 is attributed to a significant extent to fetedsiock and capacity shortages,
A - In 1963, captrca^onsumption represented only 13% of production, while
in 1972 this w*&s 10%.
- Unit value has'eaSadily decreased until 1972.
Exhibit 111-12 presents 3Hi9nt price data for the major resin types as well as price and supply/demand forWasts for the 1978-1980 period.
Between 1972 and mid-1974 prices have approximately doubled due to the effects of the "energy crisis", for example, from $Q.10-$0.11 per lb. in 1972 to $0.21-$0.23 per lb. in mid-1974 for homopolymer resins.
By 1978-1980 price leveling is expected, assuming minimal impact from safety and environmental regulations.
III-9
BFS Q0&390
, - The average expected increase by 1978-1080 in PVC output compared to 1074 levels is of the order of 40%.
In 1978-1980 VCM supply and PVC capacity is expected to be reasonably balanced if construction expectations materialize, although PVC capacity may be tight,
. Exhibit III--13 summarizes the supply situation of PVC and VCM including imports and exports.
'
. - Exports of PVC crynained at approximately 160 million lbs. in 1972 and 1973, while VCM exportstdroppod 32% from 62D to 420 million lbs.
Imports of PVC inifc^ased over 15 times from 1972 to 1973, from 4 t
million lbs., while/j^CM imports remained essentially negligible.
Exports represent apj^roximatel VCM output.
f U. S . PVC output and 8% of
2. MAJOR MARKETS FOR PVC INCLUDE
TRUCTION, HOUSEHOLD PRODUCTS. CONSUMER COODS.AND
ELECTRICAL USES
(Ji
, PVC products find use in almost every major sector of the economy as shown in
Exhibit III-14.
Pipe and conduit applications in building and construction are the single most important end-use, accounting for 24% of 1973 consumption.
Flooring, wire and cable, and furniture account for another 25% of 1973 consumption.
BFS 0QS391
111-10
-^ t
The more rapidly growing markets for PVC are construction products, packaging, pipe, and fittings.
More mature segments include apparel, flooring, home furnishing, phonograph records, transportation equipment, and wire and cable coating.
Exhibit 111-15 provides end-use forecasts of the PVC market through 1978-1930. During this period j^^sumption is expected to range from 6,330 to
6,82t) million lbs.
Construction is cxpet$c$to be the dominant segment at approximately 56-6 market share, a sjtg^icant increase from approximately 43% in 1973.
3A 3. PVC FABRICATION PROCESSES INCLUDE "dA&ENDERING. COATING, EXTRUSION, MOLDING AND PASTE
PROCESSES
Exhibit III--16 summarizes PVC cbjus^mption by major fabrication process as well as resin kind.
The'table below show's the distribution of resin typo in 1973 production.
1973
Resin Kind & Use
Thousand Lbs.
Percent of Total
Total Polyvinyl CUoride & Copolymers Production (Dr)' Roan Content) Hornopolymer Resins Copolymer Resins Dispersion Psisins, Latexes, & Wending
4, SCI, 500 3,432, C77
539, 027 589,196.
Source: Exhibit HI-16
100 75 12 13
III-ll
BFS 008392
The table below shows the distribution of fabrication type in 1973 end-use.
Fabrication Typo
Calendering Coating Extrusion Molding Paste Process All Other
*
Total U.S. Sales and Use
Thousand Lbs.
913,1 GO 4S3.SS3 2,237,092 511,082 155, 577 22-1,331
4,585,70G '
1073
Percent of Total
19,0 10,5 50,1 11.1
3.-1 4.9
00. op
Source; Exhibit III-1G y
S 7^'
UP
Extrusion is the mo^^|i^nportant means of fabrication with 50% of the resin processed by this means. Approximately one-half the extrusion throughput is to manufacture rigid pipe and tubing ^except fittings) .
4. FREE MONOMER LEVELS IN PVC S ED TO FABRICATORS VARY SIGNIFICANTLY AS A
FUNCTION OF RESIN TYPE AND
END-USE
Exhibit III-17 relates avet^aJj&order of magnitude free monomer levels in the principal types of PVC to major fabrication category.
BFS 00S J9J
III-12
The table below summarizes the quantity of resin in three categories of free monomer content.
Possible Free Monomer Level (ppm)
Approximate 1973 U. S. Sales Erul-Use (Million Lbs.)
Percent of Total
CO ^
c*
less than 100 100 to 500 over 500
305 3, 215
510
70 12
Total
4, 590
100`%
Source;, Exhibit III-17
According'tj^ndustry sources with improvements in stripping technology
average mourner levels in pipe grade and general purpose resins of less than 100 pjim pan be achieved. Thus, the total resin consumption averaging less than lOjpnpjn average free monomer levels can be 3,050 million pounds on a 1973 anhaa'l basis or approximately 84% of the total yearly consumption.
'P
Stripping of copolymers and latex products to below 100 ppm free monomer levels is reportg^flo require significant technological development.
Exhibit A-7 in Appendix A broadly discusses stripping technology
CP
This report chapter presented the industry structure of VCM and PVC production and end-uses
The chapter that follows briefly describes the technology of the industry.
BF5 00S394
111-13
EXHIBIT III - 11
USDOL/OSIIA
POLYVINYL CHLORIDE AND COPOLYMER RESINS , RESIN EQUIVALENT BASIS
Year
production 1,000 lbs, drv basis
Sales 1,000 lbs. dr/ basis
Value 1,000 dollars
U ','ali d' Ti-
1960
_..-4935, 503
900,431
206, 550
1961
294
965,810
186,741
, ' \ 'L>
1962
,-jfal*1.510
1,150, 807
202,601
; , 76
1063 1964 19C 5
1,385,845 'frtbc.891
Uj07, 467
1,207,102 1,373,740 ' 1,715,321
216,114 240.056 297,1S9
. .`.I >. :75
. ' 73
1GGC
1.S1G.457
301.743
, , Lu
1967
2;T42, 433
1, 927,942
302,110
`M57
1963
2,63^394
2,329,511
326,56G
mo
1969 1970
; 3k^57063 3,Jl5^E0-l
2,748,068 2,847,001
. 375.393 333,503
. : 05
1971
3,`13A32S
2,995,434
402,723
- 7. :34
1972
4, SSifTOO
3, 8G5, 000
503,048
. ; 30
03
1973 preliminary
4'1%
xjy
Source:
"Synthetic Organic Chemicals ', U.S. Tariff Commission, Annual Reports I960-1973
$
$>
Co
'tt 0|
Resin
Homopolymer Resins, S/lb.
Copolymer Resins,' $/lb
o
Disperdon Resins, $/lb.
EXHIBIT III - 12
USDOL/OSHA
POLYVINYL CHLORIDE OUTPUT AND PRICE FOREMASTS
1970^
0.10 0.12 0.19
1972 (1) 0.10 - 0.11
0.13 0.19
July 197-1(3) 0.21 - 0.23 0.23 - 0.25 0.31 - 0.35
C)
1973-19 ; _
0.22 - 0. i
0.24 - 0. 0.32 - 0.
(Jp
Total PVC Production/1'! " billion Lbs. PVC Capacity^ Million LbJ.VYear
VCM Capacity^ Million Lbs^Tcar
~ 4.700 ~ 5,000 ~ 0,200
6,300 - f. .0
6,120-7,- :0
^7,50
BFS 80S39&
Note.- . Sources:
197E-19S0 valneVfiajtot include ar.y impact of OSIIA regulations, and price and output projections are jud: to be on tiie low
(1) Discli, G, E,, JjaRic;--Raw Materials to End Markets and Coatinp$--Naw Technology and Markets, American Ci'.ei^ '
ry Snell
(2) Chemical Marketing Reporter, July 22, 1974
(3) Hydrocarbon Processing, May 1974, p, 83
Commodity
PVC VCM
PVC VCM
PVC VCM
PVC VCM
EXHIBIT III - 13(1)
USDOL/OSIIA
SUPPLY SITUATION OF POLYVINYL CHLORILI AND VINYL CHLORIDE (Million pounds)
12 months. Jan. - Dec,
1913
1972
73/72 (percent)
_____ ________________ Recent Monthly Trends
Oct.
Nov.
Dec.
Jan.
Feb.
1973
' 1974
March
Apri
4930
4555
Production Trends
375 3CS 377
472 455
450
378 372 402 495 467 429(2)
Export Trends
1C IS 15 23 30 41
15 27 33 36 24 45
31 52
Import Trends
G oog.
4 -
6 1
Net Supply (1. 2)
46
0.3 -
3 ncg.
365 354 363
357 351
372
+8
444 425 410
459 443
.384
BFS Q0S39?
i
pVC VCM
Notes: Sou rce
EXHIBIT III 13(2)
USDOL/OSHA
SUPPLY SITUATION OF POLYVINYL CHLORIDE \XD VINYL CHLORIDE (Million pounds)
1973
3,7 7.9
Exports As Percent of Produotion
1972
Oct. - Jan. 1972 (cum.)
3.6 12.0
4.4 7.2
Jen, - Feb, 1974 (c O
3.6 6.2
-
1JT
(!) Long-term conrradt_sJ,B)fout G5i6 (2) Net supply equals production plus imports less exports
Chemicals and Rubber Program, Office of business Research and Analysis, U. S. Department of Commerce, April 16. 1974
BFS 0QS3 9S
(P
BFS 0083 99
Market
Apparel Da by Pants
3$
'
Building and cAj^rpetion
Extruded oa/St\molding5
Fleering lighting (j7
Panels and siding .
pipe and eonJuis^
Pipe fittings
A-
Rainwater systems, soffits, fascias
Swiruming pool litS-fP,
Wcarkersftipping
Windows, other pro's
Electrical Wire and cable
Home furnishings Appliances Furniture Carden hose Housewares Wall coverings and wood surfacing films
EXHIBIT III 14(1)
USDOL/OSIIA
POLYVINYL CHLORIDE MAJOR MARKED 1S70 - 1973 (million pounds)
1970
1971
1972
1973
23.0
110.0
47.0
ria 325.0
9.0 60.0 475.0
na 30.0 30.0 45.0
410.0
21. 0
247.0 35.0 80.0 97.0
'
19.a
112.2
50.6
6.6
23S.2 S.8
SO. 4 523.0
74. S 23. G 39.6 30.8 50.6
354.2
23.6 250.8
33.0 81.4
101.2
24.2 140.8
CO. 0
50,6 470.8
11.0
70.4 803. 0
85.8 v 30.8 44.0 39. C 55.0
429.0
35.2 297.0
44.0 103.4 127.6
2C.4 145.2
68.2
57.2 464.2
11.0
85. 8 1155.0
96.8 35.2 39.6 35.2 57.2
426.8
41.0 319.0
39.6
112.2
118,8
EXHIBIT B-l (5)
INDUSTRIAL HYGIEIE SURVEY CP VltfVL CHLORIDE
JOILCLASS I FI CATION.
Loading Operator
IN fOTER PLANT to. 1
OPERATION
<P
'rify Discornecticg
. Jk Iank Car4'
(J>
PEAK EXPOSURE ppm VQT _ _ _ _ _ _ Minims
20.4 25.9
35.9 30.9 161 48.1 26.2 22.9 8.0 5.9 26.8
5 10
16 6 8 7 8 5 9 17 13
l
BFS 008400
BFS 00S401
JOB CLASSIFICATION Sr, Asst Gem B
: *Frcsh ajr mask worn
i
Source: Snell summary of industry data
EXHIBIT B-1
PEAK EXPOSURE
pm VO'1
Mini/ics
90.2 10 59.0 G 70.4 10.5 11.7 2.5 13.9 4
7.5 3
7.6 4 5.7 2 9.7 5 0.5 5
3.8 2
EXHIBIT B-1Q4 (1) 1 USDOL/OSHA
MONITORING RESULTS FOR 50
LEVELS III i'fliOiO PLANT NO. 2
m mirror?
LOCATION
Sample Pc&p|p- 4/25/74 - G/4/74
.Ho of sa-Heslt 499 each location
tjn
VCH Concentration, ppm
Control Room Laboratory Loading Rack Product Tanks Furnace Area -1 ( ) NO. OF SAMPLES
o m-
Average
0.3 0 .4 0.4 0.5 0.3
____ -JlAxirm 7.4 9.1
n+(i>
7.2 11+CL)
EXHIBIT B-i,,4(2)
levels in rara plant no. 2
AREA MONITORING
Sample Period - A/25/7A - 6/A/7A
. No, OF SAMPLES - A99 EACH LOCATION
LOCATION
1
'D
FurnaciNrEa - 2
sJJ ^
Finishii^J^a -1
VQ-1 Concentration, ppm
Average 0.5 0.3
....... Maximm URl) XL+Q)
Finishing Ar/v- 2
0.7 7.5
Finishing Ar^0 3 Finishing Are^^I
m
( ) no. of samples
0.5 t
0.6
n+0) U'hC5)
BFS 008483
EXHIBIT B-104 (3)
LEVELS IN ram PLANT NO. 2
TUfl
1975
Operations Specialist
1.5 (2)
Sr. Op, Teckijcian
Op, Technkh
Day Operations' rfF\
Lad Personnel ~
1.2 (2) 1.2 (2)
9.5 6)
Shift Supcrvisobs^'' Office Personnel
0.4 (2)
Eoilepjv\ker
Electrician
3.5
J22L 1.3 (8) 0.7 (4)
2.2 (8)
0.6 (9' 4.6 (8)
1.0 (6)
0.6 (4) 2.4 (5) 4.3 6)
BFS 00S4B4
Ail
lVELS IN IDfO-'iER PLANT NO. 2
\ Instrument
31'IAumyimXiiQRii^
1973 1.9
______ m 1.0 6) .
Laborer
A.5 2.6 6)
MlLl^RgKT
1.9 tt)
PipEF,ffnr
LdADI fsCJ^RATOU
CP
Marine Operator
A,5 4,7 (6) U 10.2 (5)
1.3 (6)
Tank Car Cleaner Ov'FRALL AV
3.7 (2) 2.2117).. . _______ 2J_m
CP
Source: Snell summary of industry data
BFS 00S405
EXHIBIT B-105 (1) USDOL/OSHA MONITORING RESULTS FOR 38
\ ' LEVELS IN HONCKER PLANT NO. 3
JQB_CLASSIFI CATIOM Loading rpjsj
DERATION
Disconni Tank Lar
MiXPPSUPE
PPM VCM
MINUTES
13.3 10
!.
Lab Item (Jfy Repair Techt^'*
"Fresh air mask
Sample Analysis
Opening LgUIPTlENT
24.6
1.1 1.0
10
10 10
BFS 00S486
I
I EXHIBIT B-105 (2)
LEVELS IN FOiTJ-ER PLANT NO. 3
job CLflssifrtyTiffi
m Di stn. Techv^
OPERATION
Equipment SURVEILLANCE
*
PEAK EXPOSURE
PPM VCM
MINUTES
,6 10
2.3 10
.3 10
C/D
Reactor Tech,' - 1
EQUIPMENT Surveillance
.6
.3 .3
10 10 10
BFS
EXHIBIT B 5 (3)
lVELS IN HOfEMER PLANT NO. 3
JOB-CLASSIFICATION
Reactor Techn - 1
Reactor Teckm - 2
Reactor Techn - 3
Distn. Techn
Control Ctr Techn
, i ^ ^,it
...
C ) NO. OF SA'IPLES
--------- IML ppm Vinyl Chloric"
$ 122 ___ WL
g.
iPr 1.0 <Jp
1st Otr ^0.1 0)
2nd Otr 6.4
/?'
0.1 (2)
0.5 (2)
0.4 0.1
i0^
__<J>
0.8 (2) 0.4
3.4 (4)
--,--
*M.D. = NONE DETECTED
l
l
EXHIBIT B-1U5 (4)
LEVELS IN EMM PLATT NO. 3
^-CLASSIFICATION* *
m.
Tfi'-i Vimyl Chloric-
197^
1st Otr
2nd Otr
i Lab Techn
*
Loading Techn
Repair Techn
Supervision
m
2.1
0.1
l
6.1 (2) 12.3 6) 2-0.1
--.--
7 A G)
6.3 0.N (7) 0.3
Services Techn
---------- 1__ML
0.9
Overall Average
1.7
1.2 07)
1.2 (21)
( ) NO. OF SAMPLES
*N.D. = NONE DETECTED
Source: Snell summary of industry data
Jl
BFS 0BS4B9
EXHIBIT B-106 (1) USDOL/OSHA* MONITORING RESULTS FOR 2
Area Unit- Operation
Polymerization
Current VC, 2.8 - IS
Quality Control Lab Warehouse Silo
1. 6 0.9 2. 3
How
(Historical
*IIow Measured
BFS 00S 410
I
EXHIBIT B-106 (2)
PVC Area
Emulsion Autoclave Charge Operator
Suspension Autoclave Charge Operator
Autoclave Cleaner
VINYL CHLORIDE EXPOSURE DATA SUMMARY
PERSONNEL MONITORING RESULTS
Dates 1974
No. Samples
Average Exposure
(ppm)
Range ppm
3/14-3/15
2
2.8 1. 5-4.0
3/14-5/3 y, 15 3/15-5/2 V";, 7
3.7 5.2'
0. 1-7.8 0.3-13
Autoclave Cleaner 1
3/14-5/3
First Floorman
4/16-5/3
Ribbon Blender Operator 4/16-5/3
FCM Mill Operator
4/16-5/3
Q. C. Lab Technician
4/16-5/3
Hopper Car Load Operator 4/16-5/3
Bagging Machine Operator 4/29
r
> A
75 '
oA
14 15
14 > 4. 1 14 3.7 14 1.6
1.1 2. 3 1 0.9
1
5. 5-162
1. 6-44 0. 6-13' 0.2-12 0. 1-5. 6 0. 3-4.4
-
Remarks
Within temporary standard
Within temporary standard No entry. Within temporary
standard Vessel entry with mask. 6
samples above standard but exposure less because of protection. Within temporary standard Within temporary standard Within temporary standard Within temporary standard Within temporary standard Within temporary standard
B FS 0 0 S 4 11
EXHIBIT B-106U)
NOTE:
Previous analyses performed are not now regarded as being
reliable. Based on observ itions following 50 ppm regulation, one
location (autoclaves) was above 50 ppm and two other locations (centrifuge Shed and water collectiM&sdrains in polymerization building) may range
above 50 ppm for brief pkff&cis. Fresh air masks are now used before entering an autoclave and '-fch^Lcentrifuge shed. Measurement means for
specific jobs was carbon tu^jejfpump system attached to operators. Area
and unit operation surveillanceJfJbalyses were by Miran I and II infrared
instruments and a portable Centu analyzer.
" ime ionization hydrocarbon
BFS 008411
Source: Snell summary of industry data
lob jClassiflcation Supervisors Reactor Technicians Distillation Technicians Control Room Technicians Loading Operators Maintenance Chemists Lab Technicians Office Personnel Tank Car Cleaners
EXHIBIT B-107
USDOL/OSHA
VINYL CHLORIDE TWA AS A FUNCTION OF JOB CLASSIFICATION FOR VINYL CHLORIDE PRODUCING PLANTS
Plant 34
Plant 50
Plant 38
Average
3
1 0.3
1
NA 2 2 2
NA NA 3 NA
1
Q 10
{ 13 '/,
3 NA
i ^5 o
^0.6 NA X?
%
NA
<P
0 6 0.4 NA 7 NA NA
3 9 2 NA 4 NA NA
Sources; Exhibits B-103, B-104, and B-105 and Snell assessment of industry provided data. NA = Not Available
BFS 00&413
I
EXHIBIT B-lGfl
USDOL/OSHA
SUMMARY OF Gt>HA VINYL CHLORIDE MONOMER MONITORING OAT: VINYL CHLORIDE MONOMER PUNTS
BFS Q08414
Notei (1) Data based on approximately 10 mln pippin type samples with 1 liter ambient air collection over charcoal tubei analyzed by the NIOSH method. Plant coder are those developed by OSHA.
pt (3) Index (I) developed from the formula; Number of points In r*ngc/h>Ul number of points reported * 1/15.
Source*: OSHA data rubmitied to Snell; Snell *Melament of data.
,
l
BF5 QQ8415
PENDIX C CONCplC DETAILS
/A
i
APPENDIX C ECONOMIC DETAILS
This appendix presents economic details supporting the findings and conclusions of Chapters IV and V.
Exhibit C-l presents typical delivery times for key equipment items.
Exhibit C-2 presents Snell's overview of the time requirements in implementing engineered controls for VCM exposure in PVC plants. Exhibit C-3 is a case study for/^PVC plant representative of the industry
Exhibit C-4 provides the statisticWanalysis of the economic data for the
50 ppm ceiling case for PVC.
O
Exhibit C-5 presents the distribution of reported plant additions of engineering controls estimated for selected VCM iej&ls in PVC plants.
G
BFS
BFS 0QS41
Item Pump*(1)
Valve*(1) Compressors*2) Reactor Vessels
N >
EXHiniT C.- 1(1)
USDOL/OSHA
TYPICAL EQUIPMENT DELIVERY,TIMES FOR MID-1974 ORDERS
centntugais
t-aruon Steel (C. S.)
Stainless Steel (S, S.)
Hastclloy
Canned
S. to 15 hp
'7^5 to 50 hp
Nasli Vacuum
:;;T;^00 ACFM 23" Vac. C.S. \_T^00 ACFM 28" Vac, S. S.
Viking (positive displacement) ^Alf^jzcs
A11 Types
'errands, S. djh^r^plastic lined)
Low hp reciprocating Medium sizes reciprocating Standard sizes centrifugal Large sizes centrifugal Medium sizes screw type
io t^nro^hp
10 to100 over IE
Glass lined Stainless
5.000 to 18, 060 gal. Same size!LJJ *
Months from Order to Shipment Delivery Time________
4 6 14 -16 12 14 - 18 8 18 5-6 4 -6 6-8
2-3 4-8 4 -8 10 - 12 4-5
16 -24 Somewhat less than glass lined
-X
Tanks Spare Parts
Notes: Sources;
Field erected
over 10,000 gal.
16 - 20
Pump shafts, impellers, casing
Valve parts
Agitators for reactors
Caskets
Filter cartridges
Heat exchanger tubes
C.S.
S.S.
For control instrument!
10 - 12
3-4 3-4 1-2 1-2 9-10 much longer than C.S.
2- 3
V
(P
(1) 1 to 5 items of standard construction can blTdCained straight off the shelf in many instances
(2) Based on delivery schedules reported to be subjeg^jo substantial upward revisions
Interviews with selected major suppliers and Snell estimates
(P
EXHIBIT C - 1(2)
BFS 00S 41
00
t
!*-*-
EXHIBIT 02(1)
,
USDOL/OSHA SNELL'S OVERVIEW OF TIME REQUIREMEN IN IMPLEMENTING ENGINEERED CONTROL;
OF VCM EXPOSURE IN FVC PLANTS
THE NATURE OF THE ENGINEERING SOLUTION IS A MAJOR FACTOR IN THE DETERMINATION OF THE IMPLEMENTATION TIME
* .A From Snell's evaluation of the various measi^S^ reported by the industry several broad categories ofengineering control measures to reduce area VCM cdfic&ntrations and to forestall excursion have emerged.
Ventilation, including spot ventil^ti^ of critical pieces of equipment
Modification of the loading/unloadi^g^quipment
f
Modifications to the reactors includim
matic cleaning
Improvement of the stripping equipment
A (ft
BFS 00S419
I
BFS 00S42
J
GS
Others, such as: piping modifications
EXHIBIT C-2 (2) USDOL/OSHA
pump and compressor replacement
provision for adequate, contained venting of criticial pieces of equipment, sections of piping, etc.
(1) Ventilation Of Enclosed Areas And Spot Ventilation Of Critical Equipment Has
Already'Been Substantially Implemented To Meet The Emergency Temporary
Standard
yj
While indicating that su^slahtial additions are still required to meet more
stringent standards, mospa&the respondents have installed some form of
improved ventilation. InHa&Northern climates substantial additions to heating equipment will be ^e^ired to maintain adequate temperatures in
the enclosed areas.
`* jb
The considerable ductwork aiyfadditional heating, necessary to implement
the 10 fold increase in ventilatioj Required in many plants, may require
up to 6 months of design work.'i
another 8 months for procurement and
3 months for installation. Thus
l^ficant venting improvements have a
time delay of about 18 months.
Comparatively minor work on spot'Ventilation can usually be accomplished in about 1/2 to 3 months. 'Necessity for spot welding and such may require a shutdown of at least part of the plant, which, for production reasons, may add a further delay to the implementation.
EXHIBIT C-2 (3) USDOL/OSHA
12) Changes To The Loading And Unloading Facilities Are Required. Some Of Them May Require Substantial Amounts Of Time
. The replacement of the present system of gauging the tank cars with more sophisticated equipment may be a major cost element to VCM producers who own and operate fleets of tank cars. A delay of 1 year to 2 years may be expected due to the large num ber of units involved.
rr-
. Immediately required changes to loading and unloading facilities peVtains to venting of the conncct-disconnect line between tank car (or barge) and product storage. This can be accomplished by venting through a vacuurinpump, and/or nitrogen flush and implementation is u matter-qMreeks.
' />==S
(3) Leaks Around The Reactor May
Difficult To Control
The problems of the leaks ardbr the reactors have been fully discussed in Appendix A, andCi particular Exhibit A-3.
time needed in replacing o^tjjrr^^conditioning the reactors is estimated at 18to 24 months
BFS 00S4
time needed in installing is estimated at 30 months wash system
washing system months for water
I
EXHIBIT C-2 (4) USDOL/OSHA
(4) Improvement Of Stripping Would Reduce The Amount Of Free Monomer Downstream Of The Reactor, But Implementation May Be Subject To Long Delays
PVC manufacturers recognize the advantages of improved Stripping and some steps have already been implemented in many plants.
The problem in the implementation of improved strippingsystems is that some manufacturers are awaiting the completion of engineering development work before installing any interim Improvement.
A* very important element in stripping improvement is the introduction
of sparging steam into the stripper. Some plants will have to add steam
generating capacity to achieve this, and thus implementation will be dependent on design, preretirement and installation of additional steam
generating equipment. In This case a delay of up to 3 years can be antic
ipated.
-J
(5) Implementation Of Other
Control Methods Is More Directly Related
To Delays In Equipment *jenve,ty -
aA Typical of such Engineering Control'methods would be, for instance:
Replacement of reciprocating b delay 18 months).
tary compressors (estimated ,
Replacement of seal pump by seaWj^p (canned) pumps (estimated delay 12 months).
B F5 0OS42
Repiping (substitute welded for flanged).
EXHIBIT C-2 (5) USDOL/OSHA
Replacement of flexible (or even open channel) transfer lines with permanently connected piping.
Replacement of open strainers with more sophisticated (possibly self-cleaning) equipment.
2. THE NOVEL TECHNOLOGIES WHICH MAY BE REQUIRED TO ACHIEVE EXTREMELY LOW
LEVELS ARE SEVERAL YEARS AWAY
~
9
Due to the extremely proprietary nature of any new development, it is not possible to indicate engineering details of new technologies involved. Continuous polymerization has a good potential, but commercialization has not been achieved to date.
The main areas of new technologies are:
^
Radical changes in production method. Generalization of the bulk (or mass)if>tocess subsequent to equipment improvements.
BFS 00S423
Improvement of stripping.
(1) Radical Changes In Production
Under Development
Continuous polymerization in totally /enclosed, remotely controlled trains would obviously contribute ^bringing the PVC plant to very
low background levels. Appropriate equipment type, with a view to the minimization of leakage, could be incorporated into the de sign at nominal incremental cost.
*
EXHIBIT C-2 (6) USDOL/OSHA The table below summarizes a potential timetable for the implementation of such technology.
Hypothetical Continuous Polymerization Implementation
Completion Date
Develop Demonstrate Design Procure and In
January 1976 January 1977 January 1978 January 1980
A variant may be uiilizWi^n of part of present equipment. This may lead to a somewhat earli^^nplementation.
Since such technology iVm matter of economics and engineering risk, the added burden cf severe ,}$nitations on VCM emission may actually help to spur its developmeffP'by making it more economically attractive. It is to be noted that one respondent indicated the existence of such a technology but described it 'sgr*bighly uneconomical".
B FS BBS 41
VV
<
EXHIBIT C-2 (7) . USDOL/OSHA
(2) The Bulk (Mass) Process May Potetrfially Be More Amenable To Low Area Levels Of VCM
)' Inherently the bulk process, whl6h has no spent water stream, nor dryer
gas to be disposed of. should b^jhore environmentally acceptable. At
present too few plants exist in the spited States to permit an evaluation of
the specific economic impact of engineering controls measures without
' disclosing proprietary data.
//f/ A
The values reported by the one responcl^nt using the Bulk Process both for the implementation time and for tft^Jiosts per pound of capacity are among the highest in the industry.
1
BFS 00S42
01
t
-> I
*
EXHIBIT C-3 USDOL/OSHA PVC PLANT CASE'STUDY
A CASE STUDY OF A REPRESENTATIVE PVC PLANT DETAILS THE ESTIMATED PROGRESSIVE PLANT ADDITIONS TO REACH A VCM TARGET LEVEL OF 25 PPM CEILING WITH 10 PPM TWA
Exhibit C-3A details the equipment which the case study plant is installing
to meet a 50 ppm VCM ceiling.
'Q
Supplier delays in shipment have delayed/installation of ventilation fans and the sequential monitoring system; however, installation of all equip ment to reach the 50 ppm VCM ceiling is^eStimated by the company to be approximately 90% complete.
Exhibit C-3B details the equipment requirements which the case study plant estimates for a 25 ppm VCM coiling target ^eveh. Engineering, purchase
and installation is estimated to require threey#ars.
Exhibit C-3C details the equipment requirer
which the case study plant
estimates for a 25 ppm VCM ceiling with a 10
TWA target level.
Development, engineering, purchase and insKg^ tion is estimated to require 03 up to four years. "0
Page C-3A(4) presents a sample calculation,for productivity loss. In the industry aggregates. productivity loss was-calculated based on the plant sample for each VCM target level.
a 0j -L
K) 0-,
EXHIBIT C-3A (!)
Item I. Engineering Controls
VCM Unloading
USDOL/OSHA
CASE STUDY. COMPANY ESTIMATED COSTS TO ACHIEVE A 50 PPM VCM CEILING IN A PVC PLANT AND SUSTAIN 1974 CAPACITY
Description
Capital Costs (C/lb.)
Annual Costs (C/lb.)
J. No additions at Sf^ppm VCM ceiling
t
Ventilation
Building Ventilation^
Raise Vent StacksXJpX
Ventilate Strainer f rt\
Supplement Polymewzer Exhaust
System
A
Reactor Cleaning Stripping
Proprietary Equipment No additions at 50 ppS^CM ceiling
Other Engineering
Replace Resin Air Conveyor Ducting
New Pump Seals
^
Housekeeping
Subtotal, Engineering Controls
Amortization of Capital (12% - 10 Years)
Total Annual Engineering Controls Costs
-j
0.0370 0.0014 0.0028
0.0014 *
.0.0016
0.0004 0.0004 0.0250
0.0700
0.0033 0.0003
-
0.0007
0.0007
i
-
0.0050
0.0124 [ >i 0.0i in174
BFS Q8S41
EXHIBIT C-3A (2)
Item
II. Personal Protective Equipment
Description
Showers and EJating Facilities
Breathing
(Reallocated to 25 ppm VCM ceiling)
rX Install^Br*eathing Air Lines Res pi letters and Filters All
Emp^g^es Cartridse^Respirators Airfed Respirators
Clothing
Daily CoV^x^lls for Employees Impervious Suiting
Other
Employee warning
Subtotal, Personal Protective Equipment
Amortization of Capital (12% - 5 years)
Total Annual Personal Protective Equipment Costs
Capital Costs (l/lb.)
0.0014 0.0216 0.0018 0.0014
--
0. 0262
Annual Costs (l/lb.)
-
0.0079 0.0659 0.0026 0.0528 0,0079 0.0082 o'. 1453 0.0073 0.1526
y
*
?
B F S &0 S 4 2 S
Item HI. Monitoring
Description
Personal Monitoring
Area and Leak Monitoring
I
Medical Testing
Recordkeeping
Subtotal, Monitoring Costs
Pumps, Cartridges and Contract Analysis
(3) Organic Vapor Analyzers ScquentiaLSystem
Testing (Program and Follow-Up
Personnel/^cords
Amortization of Capital (12% - 5 years) Total Annual Monitoring Costs
**,
Subtotal, Engineering, Protective and Moniteg^ig Costs
Productivity Loss
QD
Total Costs
Capital Costs (C/lb.)
EXHIBIT C-3A (3)
Annual Costs (C/lb.)
0.0014
0.0082 0.0412
0.0508
0.1470 0. 84 0.987
0.0177
0.0528 0.0007 * 0.0385 0.0029 0.112 6 0.0141 0.1267 0.2966 0.46 0.7566
(1) Productivity Loss
Production Loss * ft* Lbs. Lost = o.075 1974 Capacity
(Lbs* - unimpacted by
OSHA staridard)
Industry Costs Per Lb. of Plant Output
(Capital Costs From Exhibit IV Manufacturing Cost From Exhibj; i. e. Cost of Manufacture Less V Costs And Capital Charges)
-13.
Additional Estimated Costs for Ersgaapering Controls in Case Study Plant at 1974 Capacity
Subtotal, Estimated Plant Cost PeifTafy, Output (Capital Amortized @ 12% - 10 Years) Additional Personal And MonitorinJ^^sts
in Case Study Plant at 1974 CapacitjfX} (Capital Amortized at 12% - 5 Years
Subtotal
Total Additional Costs Per 1974 Production
Lb. To Sustain 1974 Production (Capital or Annual Cost x Production Loss)
.
Source; Company Interview and Snell estimates
Capital Costs (0/lb.)
Annual Capital Costs (0/lb. /yr.)
11.110
. 1.970
0.07
11.18
0.08
*
11.26 0.840
0.01 1.98 0.02
2.00
i
EXHIBIT C-3A(4
O&M Costs (0/lb. /yr.)
Annual * Capital And
O&M Costs (0/lb. /yr.)
3.900
5.870
'0.00 3.90 0.26
4.16
0.015.88 0,28
6. 16 0.460
/:
EXHIBIT C-3B (1)
USD OB/OSIIA
CASE STUDY COMPANY ESTIMATED COSTS TO ACHIEVE A 25 PPM VCM CEILING
IN A PVC PLANT AND SUSTAIN 1974 CAPACITY
Item I. Engineering Controls
VCM Unloading Ventilation
Reactor Cleaning
Stripping
Description
No additions-#}! 25 ppm VCM ceiling
Building ven^Lstvion Latex blend t&mk exhaust Exhaust hoods tanks and
charge Vent hoods for0recovery pumps Vent hoods forta^fVmerizers Ventilation for Sasjsension
blend tanks Proprietary equij^Qnt Modify reactor manhead gaskets
to permit multiple reactor opening for cleaning without leakage
No additions at 25 ppm VCM ceiling
Capital Costs (l/lb.)
Annual Costs (0/lb.) ,
0.2923 0.0007 0.0071
0. 0028 0,0082 0.0083
0.0550 . 0.0313
0.0264 0.0002 0.0003
0.0010 0.0010
0.0165
BBS 0QS431
BFS 008432
Item Other Engineering
Description
Proprietary equipment to reduce polymerizer entry
Maintenance equipment for pump and line cleaning to reduce employee exposure to VCM (Temporary workplace hoods, exhaust systems, etc.)
Strairi&?4)leed-off system to V CM recovery
Reactc(r"clcaning water collection system^
Replac^JffiistLng reactor relief syste^n^ith valves
Capital Costs (/lb.) 0.0033 0.0495
0.0220 0.0220 0.0769
Subtotal, Incremental Engineering Control Costs, 25 ppm VCM Ceiling O'. 5794
Engineering Costs To Meet 50 ppm VCJVf Ceiling
0.0700
Subtotal, Engineering Controls, 25 ppm VOA Ceiling Amortization of Capital (12% - 10 years) f L
0.6494
___ , *
Total Annual Engineering Controls Costs, 25 ppm VCM Ceiling
EXHIBIT C-3B (2) Annual Costs (g/lb.) 0.0016 0.0132
0.0007 0.0132
0.0741 0.0050 0.0791 0. 1149
\a 1
Item
Description
II. Personal Protective Equipment
Showers and Eating Facilities
Showers and eating facilities
Breathing
No additions for 25 ppm VCM ceiling
Clothing
No additions for 25 ppm VCM ceiling V- i
Other
Trainin^'and records
o
Subtotal, Incremental Personal Protecti$Equipment,
25 ppm VCM Ceiling
rj
Personal Protective Equipment Costs To Meet 50 ppm
VCM ceiling
Subtotal, Personal Protective Equipment Costs, 25 ppm
VCM Ceiling
pg
Amortization of Capital (Showers and EatlnQ 12% - 10 Years, Remaining Items @ 12% - 5 years)
Total Annual Personal Protective Equipment Costs, 25 ppm VCM Ceiling .
Capital Costs (<?/lb.)
EXHIBIT C-3B(3)
Annual Costs (C/lb.)
0.1544
0.0609
0.1544 0.0262 0.1806
0. 0066 0.0675 0,1453 0.2128 0.0343
PS00 sa a
I
EXHIBIT C-3B (1)
Item III. Monitoring
Description
Capital Costs (C/lb.)
Annual Costs (C/lb.)
Personnel
Gas Chromatograph
1
(Split 50 - 50 with area monitoring) '
0.0029
0.0033
Area and Leak Monitoring
Area and Leak Monitoring
Gas Chromatograph ' (Split with personnel monitoring)
Computerize sequential monitoring system for trend analysis
. 0.0029 | 0.0269
0.0033 0.0020
Medical Testing
No additions for 25 ppm VCM ceiling
-
-
Recordkeeping
IniSjpged under personal equipment* otner
Subtotal. Incremental Monitoring ^^|ts, 25 ppm VCM Ceiling
0,0327
-
0.0086
Monitoring Costs To Meet 50 ppmj^SM Ceiling OD .n
Subtotal, Monitoring Costs, 25 pprrLVfcM Ceiling
O* Amortization of Capital (12% - '5 years)
Total Annual Monitoring Costs, 25
VCM Ceiling
0.0508 0.0835
0. 1126 0.1212 0.0231 0.1443
o
Subtotal, Engineering, Protective a^^ionitoring Costs
0.91
0.41
CD
QJ Productivity Loss (@12. 5%) fc
1. 50
0. 81
U 4k Total Costs
2.41
1. 22$
Source: Company Interview and Snell estimates.
*u._
.I
EXHIBIT 0 3C (1)
; USDOL/OSIIA
CASH STUDY . COMPANY ESTIMATED COSTS TO ! ACHIEVE A 25 PPM VCM CEILING' 1 WITH 10 PPM TWA IN A PVC PLANT
AND SUSTAIN 1974 CAPACITY
Item
Description
I. Engineering Controls -
VCM Unloading
No additions for 25 ppm VCM ceiling with 10 ppm TVfjQ
Capital Costs (d/lb.)
Annual Costs (p/lb.)
`*
_
Ventilation
No additions for Sfyjpm VCM ceiling with 10 ppm TW^^
-
-
Reactor Cleaning
Clean vessel technp^glgy (Includes cleaning techniques and potential reformulation pf reactor charge)
0.2747
0.0275
Stripping
Improved processremove VCM from prodi$e^=jProprietary) *
5.6044
0.0879
Other
Improve reactor e/^jgency relief system (manifold additional values to VCM recovery)
0. 1099
0.0055
Repair VCM leaks
- 0.0165
Development work is incomplete as of June 1974, company estimates = 4 years to completion. i
BFS 00S435
BFS 00S436
Subtotal, Incremental Engineering GSnjffbls, 25 ppm VCM Ceiling
With 10 ppm TWA *
f)
Engineering Costs To Meet a.25 ppm
Ceiling
Subtotal, Engineering Costs,. 25 ppm 'WCfjfa Ceiling With
10 ppm TWA
.
"
Amortization of Capital (12% - 10 years) 'A
Total Annual Engineering Controls Costsfjyi ppm VCM Ceiling With 10 ppm TWA
on
Capital Costs (C/lb.)
5.9890
EXHIBIT C-3C (2)
Annual Costs (C/lb.)
0. 1374
0.6493 6.6383
0. 0791
0.2165
1.1750
1.3915
%
Item
II. Personal Protective Equipment
Showers and Eating Facilities
Breathing
Clothing
Other
Description
EXHIBIT 03C (3)
Capital Costs (C/lb.)
Apnual Costs (C/lb.)
l^radditions for a 25 ppm VCM ceiling 10 ppm TWA
Subtotal, Incremental Personal Protective Equipment, 25 ppm VCM Ceiling With 10 ppm TWA
Personal Protective Equipment CastedTo Meet a 25 ppm VCM Ceiling
Subtotal, Personal Protective Equi^ifijrant Costs, 25 ppm VCM Ceiling
With .10 ppm TWA
^
0.1806 0.1806
0.2128 0.2128
Amortization of Capital (Showers and Eating Facilities @ 12% - 10 years. Remaining Items @ 12% - 5 years)
Total Annual Personal Protective Equipment Costs, 25 ppm VCM Ceiling With 10 ppm TWA
0.0343 0.2471
Item III. Monitoring
Description
EXHIBITC-3C (4)
Capital Costs (d/lb.)
Annual Costs (d/lb.)
Personal
No additions for 25 ppm VCM ceiling and 10 ppm TWA
Area and Leak
Monitor VCM leaks (Additional Personnel)
Medical Testing
No additions for 25 ppm VCM ceiling and 10 ppm TWA
Recordkeeping
No additions for 25 ppm VCM ceiling ^jand 10 ppm TWA
Subtotal. Incremental Monitdffihg Costs, 25 ppm VCM Ceiling With
10 ppm TWA
*=/
m
Monitoring Costs To Meet a ?5^pm VCM Ceiling
0. 0835
Subtotal, Monitoring Costs, 2^gpm VCM With 10 ppm TWA
0. 0835
Amortization of Capital (12% - 5 years) Total Annual Monitoring Costipp> ppm VCM Ceiling with 10 ppm TWA
Subtotal, Engineering, ProtectjW^and Monitoring Costs
Productivity Loss (@17.5%) Total Costs
Source: Company Interview and Snell estimates.
i
6. 90 3. 15 10.051
II 1
0.0082
0. 0082 0. 1212 0. 1294 0. 0231 0. 1525 0. 56 1. 34 1.
BFS 008438
EXHIBIT C-4 (1) USDOL/OSHA STATISTICAL ANALYSIS OF THE ECONOMIC DA FOB THE 50 PPM CEILING* CASE FOR PVC
Snell performed a statistical analysis of the data submitted by the industry and audited by Snell, on the basis explained below.
A unit cost per pound .of plant capacity was developed by dividing the total annual costs of compliance by the nameplate capacity for each reporting plant.
Annual cost elements for VCM controls developed by Snell from audit of industry reports as detailed in the* case study of Exhibit C-3, the expfefH^ltory text of Chapter V, and as summarized below:
Annual engineering
including:
capital costs atQ^ocovery factor of 12%. over 10 years operation and maintenance cost of the additional equipment other costs as reported by the individual plants.
Annual cost of protectwq,equipment including:
capital cost of additional shower and eating facilities over 10 years at 12% capital req^Fery
capital cost of p^rgShal protective equipment such as respirators and ancillary equipmqptfamortized over 5 years at 12% costs of short livcflQtems (garments) on a yearly basis * * operations and maintenance costs of the equipment including the costs of breathing air.
BFS Q 98439
EXHIBIT C-4 (2) USDOL/OSHA
Annual cost of monitoring equipment including:
capital cost amortized over 5 years at 12% operation and maintenance costs of the equipment medical and record keeping costs.
The summartion of these cost elements gave, for each plant in the sample, a total annual cost incurred
or committed to meet the Emergency Temporary Standard. This total annual cost divided by the nameplate
capacity of the plant gives the unit cos,fc4>er pound of capacity for controlling VCM exposure on an annual
basis.
A/
\ Examination of the data led to the a priori exclusion of three samples from the population. Two are data pertaining to the two Firestone plan^and the third sample corresponds to a very small manufacturing
plant* which has to bear the burden of veijy high costs on a minimal production (about 1/20 of plant average).
With these exclusions, the characterises of the population are:
Mean unit Cost Standard Do^pUon
0.221<t/lb. 0.152
The excluded data were examined toWpidate statistically their exclusion. The differences from the mean were respectively: 2.29<F/lb., 2.076<?/lb., andfo,659c/lb., 15 Standard Deviation, 13.6 Standard Deviation, and
4.0 Standard Deviation. The highest samplWacluded was only 2.7 Standard Deviations away from the mean. The exclusion of these three samples was statistically justified, particularly given the comparative large size of the sample population examined. In such cases usually an "ascribable cause" for the exclusion is found. As indicated above, in one case the size of the plant was responsible.
BF5 008440
f
EXHIBIT C-4 (3) USDOL/OSHA
The two other excluded samples represent Firestone data for both plant locations. Snell reviewed the Firestone data with particular care and the audit results are shown in the table below with comparison with the industry averages for ready reference. It can be seen that in all items except monitoring equipment Firestone data are out of proportion with those reported by the rest of the industry.
Item Engineering
Firestone
Pottstown
Perryville
Capital $4,324,000
$1,867,000
Industry Average (Other 23 Respondents)
$275,000
Engineering
Annua^ '4,271,000
Personal Protective Equipment Capital^
487,000
Personal Protective Equipment Monitoring Equipment
Annual//^
A 1^
Annual
135,000 365,000
2,347,000 89,000 37,000
185,000
152,000 26,000
* 38,000 121,000
Part of the cost differences which-arp apparent from the table can be ascribed to inclusion to Firestone of equipment items that the rest of the Respondents did not feel necessary to include at the 50 ppm levels ~
Of particular interest is the incluSiaft' at Pottstown plant-of a flare system with a capital cost of 2.5 million dollars and an annual enginccrinjfjgqst (as defined previously) of 2.2 million dollars. This equipmem in.Snell's opinion, is not necessary to maefeothe OSHA requirements and, while it represents an environmental protection device-.-its inclusion as an answer to a 50 ppm ceiling requirement is not justified. The same can be said"for a modification to a waste water treatment system at Perryville at a capital cost of $200,000".
.Source: Snell analysis
..i
to to to
to to to -u f-o
EXHIBIT C*S (1)
USDOU/OSHA
DISTRIBUTION OP REPORTED PLANT AUDITIONS OF ENGINEERING COWTOU ESTIMATED FOR SELECTED VCM LFVCU IN POLYV(NYLQlU>RDf PLANTS
Engineering Item
VCM Standard
Number of
Plan Not
ftepot^ng Detailed
**
Number of Plant* Rfporting Detailed Co EttlmalO
Number ol
Number of
Number of
Plant* Reporting Plan Reporting Plana Reporting
ao Initial
Ero*ndlnir
an Increased Expenditure
No DcPendltute
Number
at
Plant*
Endangerodffi
Approilmaie Cumulative Capital Cot
Per Plant Reporting
*0 Eiipcnditur* <51.0001
Comment*
VCM UnlMdkiglX 90 ppm celling . tSMt ppm tclllPf (rltk 15-25 ftmTWA lft*3$ ppm celling wife 10-15 ppm TWA
l? 40 Modification* dampen equipmem may be cen^lemO bp
VCM aupplter. 13 3 40
ft 7 00
vntu*i!oM^) , 50 ppm celling
. 35-40 [Vu celling wife 15-25 ppm TWA
, 15 -34 pptn celling tA 10-14 ppm TWA
3
0 100
Ventilation It uieO at all level**
1 8 400
SkbiianiUl cb ate utlmaied to reach all target level*. Most plan have engineered ventilation at fbe so ppm
level.
ft 1 400
cleaning'9
* 40 ppm celling . 34*40 ppm celling with
15-35 ppm TWA . 15-25 ppm celling with
10-15 ppm TWA
c \i P*
ft14 100 4 of W plana InttaU reactor cleaning cguftrmenf for rh*
SO ppm level.
4 400 Mott plan have re >cyv cleaning / fee 35-40 ppm celling
* 7 (ft) wife 14-25 ppm TVA target le*cL *
NfptogW
. 40 ppm celling . 35-40 ppm telling wife
15-25 ppm TWA
14-35 ppm ceiling with lo-ISppm TWA(0>
.t
0 50014 Tbice pirn report eipeiMlIru/rt > 1340, 000 r il>e iC ppm celling
level probably for nrv >)iienn,
3 3 500 Ttcpllll.aiRiinfrceiiplior1t'ie-yjStprprpvmjliu1irWt AofU<t.J^7eOi,IOr0vurLto rTealiethtrae2vp4v-4n0dirpwpeme
1 7 4.000
repiewnt Improvement* loeklrtlng equipment. TTuee plan
estimate expr/WIturr* >ftv.Pf MU piohaMp ter new lyucn*.
At lli 14-35 pptn celling with 10-15 ppm T*A, t plan
report expenditure! > Si million for HAD and new lyiitrm.
O*<0>
. 40 ppm celling
xi>
0 100
Extenalve modification! to physical plant are eitlmatod for aU
. 34-00 ppm ceiling wife
level*.
15-35 ppm TWA
. 15-24 ppm ceiling wife 10-14 ppm TWA
7
t
*
T*ul 0)
500
At 15-25 ppm VCM celling with JO-J} ppm TWA eipendinuea el
> 5400.000 are estimate! for fuel* Hen at emergency kkm
1 7 L300
prewute relief lyucnu (to VCM Kimy) and HmpartLN
control ryiicmk
, 40 ppm celling
50
# 35-40 ppm celling wife
14-35 ppm TWA
2. 000
. 15-34 ppm celling wife 10-14 ppm TWA
ft, 150
3painiTC-i ( )
Note*
(11 Mob to 4>u uugay 4U wi hIum feulM cwi atmuiu bld. could b. kpv>u4 ton to. //, igtoito{ luau. bitud uj mi fW tngintatat emmu *u pmlM, to. uol idmMnN pDIilaAnBa ih
m, pum ft* TM*
VCM Target Level
Approximate Coat
_ Pet PUtn
(Delian in Thouaandt)
60 ppm ce . ng
25 ppm t* ; ,ig
15-25 pj m i filing
$ 200 900
10-15 p* im WA
(2) Endangered - Management vin--j rtt?uHjr conaldci plant ahutdowm c ( (imate* wi provide*.
(3) Vennlatlnn - Flant, ducting, etc*
t, 000
(4) VCM unloading * Additl.>m to uiHoadjrfjzracVi, modification* to Vv i piling, unloading pump* end umpiewn, (5) Reactor cleaning - High and low ptuwuilfwWr tyitcmj and jolvcnt " taping lyitema*
(() Only one plant reported a 3500.000 tddppona) expenditure,
(7) Stripping VCM Mapping tanka, purr.p'i, ^pi^Sfjk compreaton and condeiuert, (0) At the so ppm and 25 ppm cctling level* aDj^pAig cxpendlrurca generally addreu improvement* u preaem ryitem* io meet ln-plani requirement*. The much larger expenditure* < fa U*23 ppm teH`g - j
ufcfual free moaomtt ievcla fn the product*
Softer lAduaay Interview* and Sn*U eadmataa.
\
BFS 00S443
u
p
HO
APPENDIX D
PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE
&
QQ
5
<$> % Oj -t*
-tv
APPENDIX D PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE
This appendix presents the elements of personal protective equipment and hygiene as related to their purpose, costs, and availabilities. The appendix summarizes the relevant portions of the testimony at the public hearings and details which types of equipment have been purchased by the industry. All exhibits follow the text of the appendix sequentially.
1. REVIEW OF THE REGULATORY REQUIREMENTS PRESENTED BY TIIE OSIIA VINYL CHLORIDE
TEMPORARY AND PROPOSED PERMANENT EXPOSURE STANDARDS IN RELATION TO PERSONAL
"
'`
---------------- --- ' - ----'
----------A
---- "
--"
I -i ' I
I II I
HIM ----
This section summarizes the requirements of employers in the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) producing industffibWponcerning breathing equipment, protective clothing and personal hygiene a$ they relate to both the temporary and proposed permanent exposure standards.
(1) The Emergency Temporary Stanc
For Exposure To VCM ^
The ETS applies to any area qr operation in which VCM is:
manufactured reacted handled , processed released repacked stored
(1) 29 CFR 1910, Occupational Safety and Health Standards Emergency Temporary Standard for Exposure to VCM
D-l
BFS B08445
Wherever any monitoring sample reveals VCM at a concentration in excess of
50 ppm, or whenever any accident, such as rupture of equipment or spillage, indicates the likelihood of a greater than usual release of VCM into the ambient ait-
all employees exposed to such concentrations should be withdrawn to a safe area
- the employees should not be permitted to re-enter the work area unless they wear either
' type C continuous flow or pressure demand air-supplied respirators self-contained breathing apparatus
Work which may reasonably be expected to release VCM in concentrations in excess of 50 ppm, such^^Qh
repair maintenance cleaning
of a reactor or other equipfe4?ril containing VCM, should be accomplished only
by employees wearing type C continuous flow or pressure demand air-supplied
respirators or self-containedoiraathing apparatus. O
(2) The Proposed Permanent Standard
1 For Exposure To VCM ^
The PPS stales that engineeri
ntrols are favored methods of compliance
because they tend to avoid co,
nation of the ambient air in the workplace.
However, until these controls aS^fjhstituted it requires the use of respirators
of the continuous flow or pressure demand types only. The PPS requires
(1) 29 CFR 1910 Occupational Safety and-Health Standards, Proposed Standard.
BFS 00S44S
D-2
l
a respiratory protection program in accord with CFR 1910.134 should be established and implemented where respirators are required to be used by the PPS
respirators should bo used only in cases of emergency and where engineering controls or change in work practices have not as yet been instituted
respirators or combinations of respirators for protection from VCM should be selected from among the following types:
positive pte&sure full facepiece self-contained breathing apparatus
pressure demand full facepiece self-contained breathing apparatus operating in 1/ie pressure demand mode
combination type C pressure demand full facepiece respirator operating in tljrb pressure demand mode and a pressure demand self-contained breathing apparatus operating in the pressure demand mode ^
combination type C continuous flow respirator and a pressure demand self-contained breathing apparatus operating in the pressure demancf'mode
Employee entering regulated areas should be provided with full-body protective clothing, footwear or shoe co^gr^at no cost to the employee. The employee should be required to wear this clothing. Where PVC powder contains detectable levels of VCM in handling, employee should also be
provided and required to wear head covering
required to remove all protective clothing at each exit from the regulated area
D-3
BFS 00844
- required to shower after the last exit of the day
- clean protective clothing should be provided whenever contaminated or soiled, but not less frequently than weekly
- contaminated clothing should be decontaminated before re-use by .removal for laundering or disposal
Where employees are required by the PPS to wear protective clothing and equip ment, change rooms should be provided in accordance with 1910.141 (e).
Where employees are required by this section to shower, shower facilities should be provided in accordance with 1910.141(d) (3) .
The PPS prohibits
egulated areas
the storage of consumption of food or beverages the storage or'^r&e of smoking or non-food chewing products the storage or'&pjrlication of cosmetics
QD
2. A SUMMARY WAS DEVELOPED OF THJg&TATEMKNTS OF INDUSTRY AND GOVERNMENT REPRESENTATIVES PRESENTING pOMPARISONS OF PROTECTIVE EQUIPMENT TYPES AT THE OSHA HEARINGS ON THE PPS
This section presents summaries of s, gave test results on detailed comparisons o are presented in five exhibits.
ed statements of witnesses at the OSHA public hearings who iratory protective devices and protective clothing. These
Exhibit D-l presents the sQQnent of Karl Oelfke, Dow Chemical Company comparing the types of respiratory devices
Exhibit D-2 details the presentation of Dr. Joseph F. Tomashefski of the Cleveland Clinic also comparing various types of respiratory equipment.
BFS 0QS4
D-4
4. A SUMMARY WAS PREPARED OF SNELL INTERVIEWS WITH VCM AND FVC PRODUCERS TO DETERMINE THE COST OF RESPIRATORY EQUIPMENT AND PROTECTIVE CLOTHING UNDER THE ETS AND THE PROJECTED EXPENDITURES FOR VCM LEVELS BELOW THE ETS
In this section of Appendix D the results of Snell's interviews with the VCM and PVC producing industry in relation to present and projected costs of respiratory equipment and protective clothing are presented. The exhibits detail:
Purchased equipment and clothing types
Capital costs
Operating and maintenance posts (OfiM)
~ ~y'
Procurement lead times ':t\
Relevant industry comments regarding topics such as human factors
The information is arranged in the followtip^ manner:
Exhibit D~10 summarizes th under the ETS.
sts to the industry for protective equipment
Exhibit D-ll presents case s as a function of VCM levels a wearing time.
.es of cost profiles for respiratory equipment irojected covered workers, including expected
BFS 00S449
D-5
Exhibit D~3 is another contribution of Dr. Tomashefski. This exhibit is an in-depth discussion of human factors relating to the use of respirators.
Exhibit 0-4 is a summary of the statement of Dr. Marcus Key. NIOSH, Cincinnati discussing break-through times of VCM in air purifying respiratory equipment.
Exhibit D-5 is a general composite statement of several individuals relating to the human factors involved in wearing protective clothing.
3. BASED ON A SURVEY, SNELL ^ 'ILKP RESPIRATORY DEVICES AND PROTECTIVE CLOTHING TYPES '
INCLUDING DESCRIPTIONS , C(
RISQNS , THEIR COST AND AVAILABILITY
r
This portion of the appendix givb5=detailed description and comparison of the various typ^s of respiratory
devices and protective clothing. Also i^/uded are their costs and availability to the industries studied by type
BFS 00S450
Exhibit D-6 is a general presentation detailing the procedure for the selection of the proper type of respifrfuory protective devices as a function of use.
Exhibit D-7 is an in-depth of matrix presentation listing respiratory devices and detailing by type import^^opics including: -
function
advantage
IT
disadvantage
*
comparisorts with other types
Bureau of Mines approval
Exhibit D-8 presents the costs and availability of typical respiratory devices by type and manufacturer.
Exhibit D-9 is a comparison to Exhibit D-8 as it describes typical protective clothing types and their cost and availability by manufacturers.
D-6
i
EXHIBIT D - 1
U3X3L/031A
i STATEMENT OF KARL OELFKE
COMPARING TYPES OF RESPIRATORY DEVICES
i AT OSHA HEARINGS
Itaplmory Device Now-mouth cartridge oi cinUicr Kiplmot (N-K
FdU face canlrrer type rapUnoc (FF) w/fice mounted ciniuei
Full Uce emitter type w/chett mourned cuiltter
Contlnuoia now *lr supplied hood (Acid Hood)
Advantage!
Easy to don SmalJ size Lightweight Easy to wear-ftgfMrty
Has larger carifs;fii than N-M type
last longer ; \
Eye protection UJ&integrai pan
of mask
^
Longer breakthrough time than
bt,ve ?Jf)
Good head rplll protwjrfoh
Condnuoui How air tuppUcd hood (Acid Hood)
Ccntlnuout /low air fupplled /ull tnaik
Good protection
Besr.of air supplied apparatus
\JJ
Sclf-conulncd breathing appararut
. Mobility
Portable breathing all cylinder!
. Mobility . Long respiratory protection. Two
hours at a demand of S3 L/mhi.
Disadvantages
Interfere* with certain types of eye protection such as goggles Can't fit all faces
Wearing of hard hat becomes difficult Can't fit all facci
Bulkiness Can't fit all faces Poor mobility for worker due to air hose
Bulk (nets Vision its trie lion Lack of head movement Poor mobility for worker
Vision restriction Poor mobility for worker due to air hose
Wearing of hard hat bee ernes difficult 1 Poor mobility for worker due to air hose
Air supply is normally limited to 15-20 mlnuies in the pressure demand mode
Breakthrough Time 100 cc canister has breakthrough time of 15 min, at 1 ppm VCM and flow rate of 300 l^min.
Acme canister of 300 cc size had breakthrough time to 1 ppm of 23 mio. at 1000 ppm VCM, I ppm tftakthrough after 107 min. Same conditions as above.
(NA)
(NA)
(NA)
(NA)
(NA)
BFS Q0S451
Source; KatlOtlfke, Production Manager for Vinyl ChlorUe, Texas Div,f Dow Chemical Co, , Statement presented USDOL/OSHA Hearings on Vinyl Chloride; Occupational Bcposurc Standard, June 2.% 1974 and Snell assessment.
I
UtUUT P-
U4DOUQSIU
STATEMENT OT PR, IOSCTN I. TOMAiMEftKI COMPARING TTHi Of aBRBAfDtT KjUPb*. AT QOtA HEAMNCI
,ni_ ftoagtratncr OcvlCf
1. At#
Typa
Pmfruc
UkiI felbov* eothatnlnaiiti ftmn
Bet <mula* m edwmeu tHnuUM af ft* < > W
MtihnJ of Oiitmlfla
Work by ddrer filiation, adHfjeion,
<k dumieil walM le mwm munlHib.
AJvnt
DUadyartiagcl
Caniatcr mtiki have attached to (bent
A Camber ct'itUming u adtofbent.
Such maika ara of value la fratcc*
tloa againn.
. OigaBiC vapw*
A4A
< Amiwdi
, Carbon dioxldo
Acift/aion Intended to filter {rtlctdaki tdf.T u> pntrcrioo again* gate* or vapnn.
All purifying reipifator* protkee hlyh Kstnarec to breathing. AffMuiit lit to the (ace contour bttiiM rl di(fcr--jwe* l* Uu Ml tlupc and tnrhmpologlcal chaiant ntilct la utica a pr< fokm. Mooy flmti maiht rtiuu |c molded lo mdividua1*--at a remit leakage commonly occun.
They M vety effective end Ihcy can |*ovlJ effective aod tellable ptwdaa.
The ttanivice to beth ln|tiiilon and *xf4ieti<M camu rant worker* to diwatl I liter type muk* cirwctally If they can't ae# the du*t. yd thu time, oon-vlaibie don may be nn*< liermfwl.
Qiemlctl cartridge type meiki etc laiully of the half mu| variety, the chemical adanrbcna (duiwil. nil 11 me, or illiu gel) have very limited apfdicatirei aod an id value whan tund agalmt vapor* and gaaea of low cnaklly.
rfleiilCtiwiefB
To pnvarg cfctfm af the
aod e> (kk
Itw irairnora m breathing M la punlMhk ea r>
A* fiber wkfciA luck
ntaf pwM t|
jMitfcuUaa* la --y'--
V AU'#iippto*d
UwaiUy impl4)C4l In i|ttlll( lulu v Id kiufikw tlvInUMUh
FmUi complete reijutatory f*o iolim fee any cK<im*uoo of mk get e| 0*fgCh deficiency.
Tbit IMdut bote cnuucicil ( to untonufniaiied m aourcc, Ttrey may be w/o bktacn they may have JB^hUne atuchmeiN In ctmtlAuM H ijtlMd flow.
--A
rreMunWcmjnd type. The tUpht pit_yutoynm.itt*d hy the
InJulduiftorTnc'beginning cf intpiiatin^tritifiae the valve w that the ya wiH*fbtw * It 4j tpiedod l
apfaoprtjBS^pWl
They may be uted with full face matka, hood*. or with full body tulti. Many elr-4uppiled rci[Xfaw>ri employ lUj^n poaUiVC pt^tufe 1b order to prevent inward Uak*. They ate good for baaudoua cnviiwunciha not Immediately dangcroua to life.
Tbty ca* be ured with op all nna or aa oxygen wuree,
When blower* ate employed with pah reipireinn, It la tccruifj to havi an Individual attending the blower nt a *iadby. Such icipiraton produce ah lnCre*d retlaunct to breathing. They fretiuently have a long hntc attached, which, 1* fcaeV, may be a nuiaance or a aafety haierd.
There are Umlutiona oa tba mailmen* '.vAgTfc of boae Bet tm
be wmJ
, Uk w/o blower:
ft,
. Uae w/blower.
14ft fi. m 30ft ft.
The acU*conulMd eppetatua la heavy, bulky aal rotpalae* highly (Mined lodlvlduala for uae.
Om
be mi
freo ef CO aad GO|.
h la neeeaaery when aaa employ* tlf* eoeulrred mpnM a* bam wmauag Mhna lndaetiA| thiB Ba pMI Mppty I* fMtfng
jrwtKC. HMlbf, TmuAiIiU, M.l>, Iked of FulnWMn DiKtM IhpMUIkH uf
relatel Clinic,
pataca**d u U^OOL/OiKA baering* oa Vinyl Chloddat OccupaUohel EipMU* Habdard, fun* 24, l74 aft S*B
BFS
EXHIBIT D-3 (1)
USDOL/OSHA
STATEMENT OF DR JOSEPH F. TOMASHEFSKI DISCUSSING HUMAN FACTORS IN RESPIRATOR USE AT THE OSHA HEARINGS - PROPOSED PERMANENT STANDARD
GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE
Problem Areas 1. Safety in Terms of Fit and Improper Sealing of Mask
, 2. Perspiration
Problems
If a leak occurs at the mask, especially an inward leak, tile toxic materials may be inhaled and a false security will be provided. There is a marked variability in die contour of faces' therefore it is very important that any mask fit comfortably, otherwise an individual using it over a long pcriodSjT time may find a musk to be intolerable. '
3. Psychological
mast; ana prouiices an unpleasant eiicci, . Toxic substanceijney become trapped between the
skin and die mask causing local irritation. . Allergic reach ons^frave been known to occur.
--A
BFS 0QS453
4. Respirator and Mask Dead Space
It is very important ti;
individual not rebreadic
exhaled air, and that die dead space in die mask be
kept to <150 cc or that the mask be adequately
ventilated to flush out the dead space. Otherwise
there would be rebreadring of exhaled CO^ and a
deficiency in inspired 02- .
>
GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE (ConCd.)
EXHIBIT D-3 (2)
Problem Areas
6. Design Problems Associated With the Eyepiece on FullFace Masks
Problems
. They should not distort die vision. . They do decrease the field of vision. . If an individual wears glasses, the glasses can
become fogged or die eyepiece itself may become fogged. . The individual with bifocal vision may have
6. Speech Transmission
. All of dicse 4#\dccrcasc efficiency and be uncom fortable and vgfpfcasant for the Individual.
BF5
pirators.
. This limitation knocks out a large segment of the working population (approx. 32Tof all males and females over the age of 35).
8. Personnel Training in the Use of Respirators
> . Personnel must be trained in respirator use, workings V and care.
oo L
BFS
00 Ol
EXHIBIT D-3 (3) GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE (Cont'd.)
Problem Areas Q. Maintenance of Respirators
10. Storage
Problems
Masks must be inspected monthly. They have to be cleaned and examined after each use. The washing should be done with soap and water or with detergent and allowed to be air or force dried, Occasionally it"jjG3 be necessary to sterilize the mask, because ifjmay become a source for bacterial contamination and disease transmission. Cleaning and repatriations have to be set up Where masks or rcspirator^yic being used.
Storage is another iUcdoi that must be considered. Proper facilities must he provided to keep the respirators and theirsromponent parts in good condition.
QD
Source: Joseph F. Tomashefski, Head of Pulmonary Disease Department, The Cleveland Clinic. Statement presented to USDOL/OSHA Hearings on Vinyl Chloride; Occupational Exposure Hazard, June 25, 1974 and Snell assessment.
EX IIIO IT D--l
USDOL/OSIIA
SUMMARY OF TIE STATEMENT OF DR. MARCUS M. KEY AT OSHA HEARINGS - AIR PURIFYING EQUIPMENT TO VINYL CHLORIDE MONOMER
BREAKTHROUGH TIMES*
Respiratory Device Organic Vapor Cartridges
Canister Gas Masks
Gas Mask Facepieces
Test Conditions
. VCM concentration: 50 ppm . 50ft R. H. . Flow rate consistent with a
moderately heavy work rate
. VCM concentration: 100 ppm . 50;'oR. h, . Flow rate consistent with a
moderately heavy work rate
. VCM concentration.- 100 ppm . 50</a R. H. . Flow rate consistent with a
moderately heavy work rate
Breakthrough
. breakthrough to 75 minutes
. Sfrrfice life decreases as R,Ji, increases
fry . 10$ breakthrough in
200-35]) minutes . Service life decreases
as R. H./.increases
. 1%- leakage
Comments
Because the odor threshold of VCM ' is considerably higher titan the breakthrough concentration, it is the petition of NIOSH thn* rhe only suitable respiratory protective devices for VCM arc supplied respirators or positive mask selfcontained breathing '.apparatuses.
NIOSH Center for Disease Control, Statement presentctfC^USDOL/OSHA Source: Marcus M. Key. M.D.. Director.
Hearings on Vinyl Chloride; Occupational Exposure Standard, June 25, 1974 and Snell assessment.'"
BFS 008456
I
i
btduihy RcFftontarieo *. M. O.I(W"
r r. Hr4*
&oit>rr D-ioi
USOOL/OTtA
5TATYMINT Of (NSniSTPY PITKfSDvTATlV|i CN HUMAN fACTOIft UlATltH
to r-nxrrvt curm&rc at ihk osa huows
Nil IfliptrdM ftlMtted Mil
___ Ad*afttaRtl ijiiloii bi)l chloride
Plridvanujgci
Place! w Other in lu*aloo of kMtdpiibU heal
t--'
Nil hedy Ifflpe/'towa ab wppiled
favenit vinyl chloride from Mnticiing holy
htApAxny heat and ntoliiwr* (tom piuUtedC the *imophcr*
GarmettM>owld ^uauntcc long*
letm capture to VCM If, by
chance,
fa |u <nie<cd
the tmcft
v(n-.l UtUxlda (in ctiiiib|| built
Ctev*t t|U 4
buwU)
iptoycf'a
ftiytiolo^Ktl ('f<iililfiii|n
A tmrkcr, while wearing ty h a mil la a ten after J ihiriuUt MUrg at 85 F ambient temperatu/e, had a lkin temperature of 100. 3 f. Aftet five additional mlriutei of Uow walking the thin temperature w*i |01 8 t and the body lempctdfurc wlitch had been 98.4 f at fa beRiOMlng of the ten, tOic 10 103,6 r.
Human factort
Suit undi io be a tafet) hatted hcouH of III bulalACaa And limited viilMHry Healing It difficult Comminleatlon with oiheil b almott Jmpoutblc
fjmfawo
The wm fill rype au|i ihewM be
HmiM to emergency HMauem
The hear and dlicomfou produced will produce fatigue reducing employee alcftncia
ftrtpvarion generated by ihe auib will ciuie avere diacomfon
Seductiono( employer vlUclrncy due ro cumulative eUeert of fatigue, iftruir looting Reactor clcanen, rebutted by ihcU Job in he wire footed, will he cat)y Unpaired by tula of tul( (n*f)<>iet efficiency will drop aa much ai Tk when Urth auita are w<*n
Operaion w >11 Imd Ir rfi'Vult id operate kontmit and keep retordt, and maintenance men. particularly Inurnment aM Clecirlcal repair* men, will mi be able to perform fair |oh talc|y and properly
Ptemivm wacet will be rc^.. i induce emyk'yica io w<ar won
bcco'niiing fa fact d>a* fa min reye eni a ufe>y hara-d d e btetcury of Ufut did not teduinr fair me tit the ctrriftnfei ueiwiafa
dera Hf rear-(O' cfe*r#n e-e (dtofl* Pcd at a jr p of irjiimum gib diey d>ould he vupplted with "ptotetoee* ufar Mao impervtmn ctotlong and glovea 1 order w peoteCl ihn from ifcio contact
fe ,, i
EXHIBIT D-6
BFS 00S459
Note: Source:
Numbers In parentheses refer to Bureau of Mines SclieOules and Revisions thereof. After Bureau of Mitres information circular 1VJ2
tonliatotr OHig
a. aif rwifyiif oidiki a> Midianlnl fjlfff w
m Chemical Ctmfp Seek*.TM*
_AyHfjUn
Air ^Afylng lkvka tefttete rmMtilHWna fcom Hta atnwjdieito.
Mrrbtnul filler Itoipinton provkk Ittpirauiy p*iccltnp agalnrl partfcvlam tartar tuck mwixmlanlc iuiit, mitta. to hiatal Mci. k|r(Uan of dm ifynfniii ictfiritnr it KW on dw typo. Witcliy. and partli-% tot# of tor fMtctliir mnwt.
Chemical Canrt*h;c Kcipiiuo afford pmic* Hnn a^Jlnrl li^ht conCtnrranon* (,v^ w.i;. hy volwme. dcpamiift)* upon in* toonUmlnantf of tanain acid (iiti, illaltM gatu, Wgaitfc vapor*, ami mcKwy vapor* toy Milting urtavirlMiwal Aliaia to
Method t*f OpcfUtw
UmtKitont
Ufa
Vanoui chemical* remove ipecITie yatot and v*pnn ami me hamca) Alien #rnvc (onitiihu maiici.
Can ht v*i only la atnwtfruirt conuinltig
tuftUunt cxy^cn to imuin life (41 kan tw>- by volume ei tea level) ami vittoIn ipvclAc4 eoKtnuiqaa llnUutKm* f the ipoeiAt dcwce.
The umful life of an air purifying devte li dependent upon ih conc<MMtrn ( lb* conuir.inano, the brcaihiag voluena ( tbi wunt, end ifio capicliji M tm ill purifying Mdlwn,
tl*ey corulit riHitrlaUy of a tcfi rvnhcnt facepkee of eiiiirr half-maib lx fnil'lice d* <t ;n. to utiKh I* dliccily auji licit otk f>( m verai iypo of <llfi hjrgcil fillrn IIUliL up of n>n*c hhe'u* n*jun Jl winch n mnvet iht liar infill pimcler hy piiyui.il tupping ai ail II mltillsl lli|Oiiyl| Hit llliUrtal. f,iic<i,n rnaricr itn.ii at air tnclf will pan liimti^ii the filler, tout *oliil o# hu<ii4 pardilo arc rmppeJ in the nine manner ai mcka and pebolcl arc iep.irated from uni in a K'eening puceu. Hie filler mmi b* highly tffli ieu itnwever ti nop tiu wnill toamfot pumrici.
an
they differ (mm mechanical filler an* ptraitiit unly to that they miaii Coftridtfet cwnuioiqg chcmieali m mown toarmfoi g*Hi and vapoei.
Chemical Cartridge teipiumn ar* non* emergem y rcipiiaiory protective OcvleeiQ amt ihrttijj wui tv me*/ In hnmci/liiil)'
plUpOKVdari^en'v* alnmiphew*, except lof tteape
However, 10 clarify ihu general lUtcnicnt.
It will toe wt.ll Int (i'ui oilier major
ncgMltt rule. which apply u> < hemieat
r.iHriJf.v ih;*pifaun,
IV nut i|K rhcmk'il (_anndgc Htt pinion Mr pwinUim againii grieom
material which ti emremcly toxic In
vrty iDtiil rencemiailoM (eareinogtna
luib i VCM).
Che lifi'al Cartridge Mipiraion dumbf ivm be w<l for tipvtuKi m harmful l^jn.ou> mallei wlnuli t'annoa clearly tot detected toy'*>*"r |wk at VCM in
ronerhUMlmn < Hato ppm*.
an
UiUJlT P'7 <l|
UKPGL/AiU
COMPAftUM CV IViflMTOnr hOTtCTlCW ctvtco
luMinoa Atwnl
Ich^ul# 21
<Mwf tfmi difference lw>wt*n a naif moak fc<epr< and a full fa<e#te<, *t<h u **i tdien the pariK ulaia (if*<rk h k*n 1*1 s* imwrinf tu the ryn at vx.l *1 the H^imofy
nan, fl*f fitter u ** rnon vtwitual toitntlbea amew^ rUuai ef rviptrt<wv Tk m>i tonatt Bmpfi'flllu H nr b| i*f hrd out ftix M*k Ilia Mih rtt(wci 10 handling *m iuat, riiHM *# breathing, efficiency tk Altering parttrala^l ^ ipecihc eat mngn and Qm roguiaid M Clog the Altai.
Me- "i> c e rs-^e r r>e ^ * I 'an -*J^e ^y.itawy bile r |f'*irni'n a, ifu* ifltr n .'if m t ipcia In ll| hi rut*, mi 4I**| <*f yaw 1 an* >*prfi Ot rmybr o4 tow a>l r w *m la dtw nf 1 ia** j t*f>hr, T>t NHHiHfWTf 4tuipaiioui | comp* ihewiaih a mpitab'i natw cm- ' venirniiy tarried h) the twit" <n dufl-k all t*>r+>*'(t hvwut Or timed *ve<yr miT m-r in wwb 1TM tii<i for |wirne<Naie #**.UUl<ry,
fmrhnln.ifl p r( 1 #*erJ_n_'ll r'^i- it I flit*# Jtrprai >n uiUie d m, rt> it, *w J4'u Cl'lrt
Willi * < 1-eiTilt J| finnJi^ fa dual . m^ll.pt*
rtpiiiilT. ftoipnlrn writ* liulf yw rator ntly
repln<ahlr m<<h*wral finer* att pnkM
for lh|. type be<tUR thf dell (*l*ei W'lMtlJ
plug! hrfut the chamira) eanndye * aahaMA
One enmNnoiinn merhaiuctt-rhe'nwtl (tltn
artpuaww rmplop a bark mourned 2<Ut
,
fkmtM and |t eipceially twli uuied tm
t
ipray painting ami uthh% openusm, wbeat
tog air coniarninani it nacavutaf 11 boa <f
AW torahar.
umtmiow
. ClKirlal Cartridge Ots|vUiu^(ftfU not
be uk< igalml any gatcbtrfn, eocfttnii*tt<wv uttUh lie BittW
to the ryti.
^ s$>
Uwfttl Ufi
--KHImAmtoiI
Obvlouily, Chemical Canridgc^feifrfrajtfi Wnwi b* u4 protection ag^taflGy1' _ gaw-Oui material which h noi effect! Hopped by chemical filU utilised, \
leu of toficcfiiMtion.
tccAuK g*i miilu are Air purifying devltei detignrd K'tciy to remove tpeeific conum liunn front toe air, |i I* racnml ihei tittle vh be ftitrttlri to timoiphcm winch ctmuui wfGcieiu oeygen 10 iwppon Ufc (#i Uai 1W. b/ volume l tea level) a*] which contain generally *0 iwM than 'iy
cencieuidMi *1 mm< gutt uf vipm by
Wirt life of an air punfyliy CJtoiiei type *> mark dcpcndi on too folio wrtty^fat bm
/flY"
including ihe quality and
amount of < h*rii|d| fiU, packing Qniformiiy fni dr miry.
me rondlrlnna, i-
aiiL>n f toman inann
m rate uf tlir mm,
ni>l|iy, f-ctvtfUy,
u, brrjihi:\c taiai advene ly
affect kivicrflifcllSjflht Uif captnsm
conduit n>
m wide variation,
11 II mini difficult to Ctlimtw the verrica
Ufc of a gai mark centner. flowevcr,
for gulden*<i putpaicv. actual man itHt
performed under Bureau of Mmwi Schadtalo
UF inpulaic die fottowtng mititntuni
tcmcr v'lainiiw'iii ai m average
breadline utc ef as Ulan per rntiuu In con.f niranoiu uf Y. fnr nmt gawa
and vtpui u( ammonia'
lM\lll4l St24 ..Camiicq
io minuira
Type N. tiniwf ,.Atld t avi
Organic vapnn . .Ammonia ., Caibonlk'rbtjdc
If itdmiw*
23 m|nuwt
13 mlAutet JO nuntrica
Super Sue Caniitcn. becauw of their greater volume of chemical fill, wm lau pprAilmaiely iwtre * long a* the npdhIiHI Induiirtal !tU( Cafurtar. Chin style 0irtlticrt, became of theu una)l rttc. toriuld be uacd in q*cnuailMta out ||
IUiii of v. r-.
HWTDr1(V}
Cardwet hepUermcfil
tt It gent rally rocootmtadad that r> hoh caruitcn *f (or t 'rwrgtacy fwpean *-- bl<(|U<(4th<iiitb nut i.pntftc lalKagnm lot e muter ifplace w aqf/to hn *> fmb au am
, If latuuit with window i>4rli tow the tpocifked <o)r*t ihanpt,
, If any kataer la totorwd by oneII, tail*, (yea, twite o* torbai mutant
ll hitbbtutbihf miataiwa orwupa.
If die uiami toeif li| ia muhi
Warning * iim
SpccifK wandng w.m which rvuul UfimtdiJie rvlum in firdi air are
, I'rta'-ndonaMe Imii in the inhaled ale, lA fly i p<rai,*y i an,iwr will bri. Mve waoii m (i.eaunt rwrui* )ivi o taputi, tan ramtier wtuch ^tomei anninelf fi#i imlxaici diet cvikiiwauwo ahuev toe (Joti Ifeiui
If ewiMM, hitHu m
devetof.
*f tw
BF5 008461
-i
BFS 00S46
ho
V
Mftntwy Na % Alt Q>Hi
01 Alt Um fetofaaitol
tUmtirm
***< Air 0MB MMMi MMM far toy
Method of OpcrtUnn
UmiUTiv>a
rVt<v<r breathing alt tfimugh * rupply few connected to (te kmn becplcCc,
Shall be wJ only in atn otphriri not inimcdiaiety hJimful 10 Mfc_ AH vun tiiMi be located in clean *U tnl inonliorfe frequently.
Tfe ieiplrief it corutcetcd a Billable cwnpitwi *u touiec by i fear of iMtl tniw ilUmcw and ait 4t delivered I* fee tuer (oqtimiiMuJy or inwrntllicntly ic. oA<Ma( vojura to Med tfe M4M*I feMUUAg Ifelfea*
Alr-Ltne Meiptfiion IfitJi be med only la
atntoijibctu not yrjtfjjiiluuty harmful to
life or fmfrt whl'.h ihr^>e*rei ein t ye ape
Without the uk <>f tfe'retflf*<oi. Thl
Umltaiion l nrceviary Voium fee air
line wipt'J'oi it enJtotly'^-pewlrni upoe
an all ti, ply vMch U'not cAyned by fee bearer of fee fripiMioi, ||[ feic Mi tupply
fall*, the writer ki wtiVm^f iplriwry
protection and mtt'ht nor ti^aptf Arty) ife Immediate )y huzai.foui arAyntp^drc^'
A no(tier limitation of alr<Uh*-trtptraton
it ihai tfe aii nipply tore limit! ife mmi
to Hxctf Alliance bom tfe air Mppfej>A
Hunt,
.//
Uwful ufc Al kong tiilrii afepifed afe 1
The Bureau of Mini approver Ur'lli^
mptmon undet Schedule l'J which hat tfe
following tip,ntflcani fcqulrcmenn. tfe
minimum inw lengfe foi vtiUh approval
it granted u 250 feet, and (he maximum
jnpOUnl'le inlet prrmire li I2h fmg.
Approval it uglu ft ipcilfle Imk Irtyfei
and inlet prrMuitt. With fee lonpeii how
Irngihi tu which approval it routfu ttiembUd
to fee rr'piftuv, and the Irani inlet prrmum
imiuthiccd *o the air tupply lime, comuni
(low unit* mutt ddiver at Ic* it four eutdo
feet pu mlnuic
) inciruied at die (add*
piece. The emulation rcilrtinfe at Pd
lltcn pel minute thll not eicced o fly
Ifeh of waiei-eolumn height.
<P
Comuat flow until an normally Hied when* feci* ti an ample alt tupply an.h *l provided
by an Air eompieiiOf,
When feimeu or hnatt arc uwd, the tamo tdtutrtmenu mut fe mcl except that gw flow rate miui fe at Icati m tcl cubic feel fe minute, foi both lypei of ukaUUi with (fe higher! inlet pnuure and ifenert few lenfith, ife maaWnom flow ifeu not eoceed lf (lb) cubic feet pea minuia.
ComuM-fiov AlOLlnc feiplfaieft wife face-
piece* h>n* are d 4ici* wipiiaiory pmwelira
Alf I* nettled. A luxn) (tA be added b ife
fittpinr Aw yu'lnitio
*j<fe pi fe
Mr tl tml &NtWO>ly a feimcl t vied fur felt
appUcaora md a fefe or gape ArtU m h,
M ran oat awdl afe tm ka pitoU^.
miftH AflWnl
MIMA
Aeerwaey emdpnwto ! u |*w
to|uUnei, p*rrM |fef
*fe U
Bhery map fe atermnf to mh dm ^ air it at the faofef feiwuN efe tocthry hw fetathlng,
Air-l/u rr^truton err felfe t rooap
type*. (>< dun ttt dm hxt iltatt
Them ar*-
w. d^^wnd A afe
<''* *>>b t'w nyiiitoi
Mu>f itd vt>r, fa ( maiiw <> f>ui |a>iytaeoo. If *yt pn ufiu o u w tmaH. a luir lace*
ydai* mo fe rad. *
TV air Mfrly * ife le^raim liry d gw cr, afe gic air-Une raptranr u jupprtfe fer ra only den u >i,npUri n^mbu alt r it* miiHl yitMifr afe firw. TV w pmr til dull mail ft mow Mtw
<4 C* mpieiwd rai Awraaei bprr diitdkt i.l t h typ* I, Clra D |m vi a j. fhi LumnUy mato rfei too
evt^a tivowtlic lrl on* eitewd 2; putia per million (fpcri, gw carfen B.'xiee r nai-- I n tiiiid imir ft**, antuferai bydfo* carVfu i*o earrad a oniUgnn pa cfete malti.
VlA intaowQy UfeKaud pti*v rypr oompra I awt. rficai.^t nay pmd<w,4 ciW*a ra towiiiw wiuuy tm tartw* rhaMw *>4( * ra iaai I do* <d t tfeUO armwAng aralyger u baa j
fe t ail wirfewA ra nuubtiad gtgf- j
fell) a (inife niprtUi ar. TWy ra rampwwtoa boi uguMl aa* at vtai fe dUptwagrra lid deittcBAg fee w,
BFS 008463
A Hilublr 5rfctiita_*A,ulit<ac u teqnlrwd
<w c/wurr (Kii/M nflf *i tie proper
preituic for
Hi* urn* rewire-
tncntt fur appioyCl ijiptytto the ditnatid type ai * the c^niuni fl^v unit*, outfit
(he ii'niimui.1
rtuitanea
of iwq (2) inrhet oLwat^6*itiiim liel^lu hitamn J a( the Ittcpijjk' AjII br at 'cam
Ami (tj cubic
and not mute '
than fifteen (I5j cubicJ:ci7titifW(c With all luxe lcnj,Un wuhrai (halnleipfcutf*
rattle for vfiLh appntnfctr ojuptu, TV (iluU4(in (vtituncc at ftS llict* ou minute dtali mi ciccad oiw (ILW1) of
ll nrnu mto the him Ri|ulKniciib Vr 4emiihl lyncnu ruifl iliit^t iuuc picMn In tfw fatvpUtr tlwll iwi ecced 1. & (orlit of water. the exhalation KUiujw^tm UienfnunuiL juvl (Acted ihrVTSdcjunwie In die facepirt* by nwxc Ilian n^pcl!c*of
mwain and ifiai tfijc he at Wait
flow duHi^ inhalation before a ne|t pmiuie li developed In lb* faiejdee*;*
CP
ibxe iatl<( with blowrt\ can he ti*d with up to 2*<0 it, of Itoac. Ilic h|nwtl iltould iwayI be Hied with Uil> type of vtlulp'iifM, <Ai|y hand driven blowcn ate cumniiy ippKtl,
The airhoie muii have a lar^c intlde diameter. appfoclmjKly ur< Irwh. *, In rate of blower
Ihlxit, tliv wcJtu can breathe
die
how while cKaflA>* (pirn tlx conit<''Wuted *iea. and il mint he btpiiiy it mum to pvi/vlmm ijfkvi ai w*l| at he able to wkihuawl
cnidili^; Wtijhi, llui accownu fix due |ay
wire |(U->tcvd lotwttuctitxi wf Iiok -madt boon.
Can only be uaed up to a i/Iimkc of Jj fcL flntt uftiii, howtvrr. carry only Urtiiint dppmval and cannot be uwd to triw>tpVie luimcdMiely harnfitl to lilt. u*aw of viiah Approval
Uacftd Ufc
buMlnoa Awovol
a*uITIMtq
I
TV ante hflwc mar* aMxniM(. mt*ft*j|
fdiporb har*w*it mbaii awe Ihwm,
W uWMily
'* * porn** toe**
TV Vmi V* *** ttl*ri p m s
aodity or |taaof, ready i *nj Aw mb*
aua t t*m < Miltop.
k
\
!
fcHHWI P1
A optic-* How
Method of Operation
UmIUllOha
U refill tlfc
laMlta Aunreal
Cawwa
. ieir>caaa*w --
Aaoa/atw
hlf-CiwtlAdl breMhmg (ppimi porliii
complete ntpintwy pmicoiH in untie
|tm and 4w(t then it oxygen deftcieacy The titfti it iMt(*n4( f ikt wmindiiig
aljaiMvwfid4rainj* ihAot^awifdhHa IitMbrieiaiithiingItwatmtb *jiM
m air wppty *f dm apparent* Iwtf *nh* can
Self-coAulnod bra'pgUftr'epfconun era divided line ihitt bei<Vy|#-' -oxygen cytlraler rebreaihliw^imaiwl. and
ntf-gcorraUag,
*/
Ma)ef problem p* limitation la billdnere o4
apparent!.
r rn
Dependent on tie of alt cylinden and. la the caw of tie rebrearilag type*, oa the COj removal creauiaai.
Ithe data It
|M ltd(t) flntm Crtrin 7y--f
i
The oxygen cylinder rebreKfifftig ran*
The oxygen cylinder rrnul be refilled and the
! utc today It the " lung' pw*fjnj|r^
type which automatically for die varying breathing tfcmartlof the
carbon dioildt'itmoving chemical replaced tAcr mil me. At ti true of ail retpir>lory protective equipment, uetnlng ia proper me
kI, it ceiuliu of a relatively nnell . and matnienanee u encndal fcn the meet (IK*
cylinder rf wniprewd oiygen, redimw clent opcrllloiv and regulating valve*, a bre*thln|^%-
faceptrcc or mouthpiece plm nwtllyr^ The one hour UvtOc life let die Btlf-geroreditg
aid a chemical container 10 remay*
type apparutui la bawl On lcit procedure* (d
eaibon dioxide from the exhaled nreaA. h<t*t *t Mine* Approval Schedule IT and la VO
jAkaeev nr louger protection period my rend*
The Hlf'gfwcatlng type vki the feJ'T wjaad aa tire rear *od bia level of unrtah
principle of rebrciihlng; but it ha* mcd.anlcal opciailttg coniponcntt. n/ j, both type* function In ihr tame mannot^^A
ad will bedlicuued together.
V^. X
The type* ef cylinder rebreathing vti aow manufactured ala approved by tre bureau of Minna fae two. tine* W
Tha relf-peAerating typa appanata la
w*
The high prciotrc oxygen bom the Cylinder it icduieO in praaire to e breathing level by meara of a reduclog and icguiitlng valve, In tome unlit there la a rorotanl flow plot a lunpcootrolled valve vhlth add* any required additional (Ww. Other apparelut have only an idniiidrxi valve which deliver* tic orygtn from die breathing hap * the wcarer't l*t(.
The relf prnervtl'y NeaOilng I^iiaiv differ* bom cnorenqiHiat ry'ireWf rebreaMng apparei la thai il n Itae ft* m|c*| > at rot which vxypvo and nror*vrt tire nli*l<t <iitot d*nid> ireodivr with bna'N'ig iwoaiwib. It n. (T*ntri hiyh pwourv cyiinden, rejwUti^ v*l and mher mchavca| ooftporona
The cre'liira, t^lch envaalM pr-tawum e^oov evolve* I'vyvra vt** b'lw ut hy Ae nvMinn caikv d'Oil* In the eehalai hrtera. a ad mu the <art> diAiUc *nd rvliruf, Itamrui^m. It (mpovwnt at II aid* la ptrendag lea*
la UK, Ihr Mlf-pf rvragng *ni npcreu* a* mtk
hreeduny epptshH ettepi dial pie w*eti. v
the canlitvr, mt*n Mt owe ovypca inroad of <J
bom a ron preiinl v*i ryli'iOf,
moua*
hiturti of di|i rype an in ritnylidiy of rev
and uae, and temr wed Ire Atatntcaaoee Who*
pend with M0i prewn appaiatu*.
Thera era orenl irKritodi foe reft Blag at ik*<
high prereura all Of oxygoa cyhxdcXh Compw a*a aomtilme* arad. ket lha 4mptm and mm naem a*tfwd u ta caicada b*ra laqa mffij
wall Ifyeoat ty>afb
Exha lid breach parte* down ijuitei rubo |nu>.t|re container balding the carbon dloalde removing chemical and thin tmiudi a (Hitt, finally, the puflfli.d exhalation flow* into the breathing bag where it m|vci with the Incoming oxygen bun the cylinder.
I
The itbivtililA); principle permit* the muat cIAiIlai utiitxailuA of die oxygen tupply. )la aahalctl brcaib contain hod! oxygen aihl carbon dioxide h tire bamoh body
MwlvLxtract* only a amall pan af ilw ratygea
I
BF5 008464
I
iuMwaif Pwm
AgpDCatfcm
MiAod *f Operation
Ai Ae uki cmlalct linn container,
Ae larhott 4|u*ld* n removed by the ttitnnctl and ifrc o*)'f!en vittfh i< reft 1 rcuvd, Dial method of nperatln yrrl'`T')
ppHei to *1) ouygcfl Cylinder ttbtvuh* "8 yr *pif*mi & well *i tu Ai ,k|(- (/ j(ciw<*Ui>K lypt,
--"'
*> Eg?r! Tjb
Pjnftd-lyp* apparatus ire available ( Afferent ffhMfeti fctr gwctfic application!
Of pnrDrwUl i(^lira||<n> to tome InJmiflea i * dlOfl diMlinn Uftyl hn>wH 4* an Vh.ib hath, * <> mmnally worn by a border ai Brin when be n In apt *ia tTu re a (win* Daily Male aim>rpJicK. ahme (be capacity f * yai milk fe|ru. A rear in which hitfi ftawurc gatet art piped fall Into title category, Atmhai t)p* of AOii dotation wif it put on l Ao am* ec*p* u nercitary,
A wik m*A ttf* nf appuaiui li uwd for plawwJ tuaintenaMc work, Tit* appararut A actually a twn-Md unit,
, A irlf'(*nuiiiol r^iuilut Midi bhidi Dm wearer can n4tv* freely ahuui by eaing a mull iyllnitl in enter n leave DM vile *intift<ic<i wither murinely r l<t Ac failure ojf tba main biciAtng mppiy.
, There It pnvIilAt fut connecting a bo* iu tN Amend rc/ulan* itut the wearer t an btfaibc dminc the work period from a Urje cylimki wliidi liar a prciiuia rt Jut lug waive mat lied to yimUt lr>M pci|it tar die conrweiing bote. Mamfitld atu.ntt>l|*t can be fi*>bided w permit more Aa* one wwkea A work fipin a toynmop breathing touKc, It la Imperative Dfai Uta tmaii emergency rytiiwkr be uard wtilv Dili rypt of appara* tea; oibervtwt, a f*u* of aw toftiy fmm Ac iary;e cylinder would rlpnt Die wtaaer w* mate atmuaphna.
All coniltt of a high ^rcnute fykndci,
* dcmjnd regulator connti'i<<| either
directly or by hl^h'pretturc tu'w io Ac
tyUnder, a fitipitcc *r*l tula: an mb y
With an *kliaUhn valve nr
ag |
a method of mnunling lltc eutopic
appa tarot on tin body, in <ut tit
Wearer lumi i<n Ac cylinder valve after
putting On lb* UicpicCc. Inlialai ai
bfcaMiiojl pmwn atrough the demand
mgiilaw* to A* faccpiaee and the*
ctAalci Amugb valve m A* Uctpdei*
MtUtfmjGd apparaim an relatively tncfftctcK VKfri rywtip^red with Ac K'bieathMiR type, hc^ajCytiin^ahJU'd uvygrn It Klcawd m the
UitmphtK liuicad a( being re-uted.
r]h
Worl^mnp ippet ate limited by ibe cenriteang bo*e wHfch Umitt Ac free movement of i!m wearer to Ae lon^ot of Ar )wte. It l nut an vincr^ncy tyAdmill at. In wie, M icvtulte* KlUng up^tmi: aueiUary LUOtpinvitL
~~~Atike dtu^on of the Amaod Type ippiralwa
Dapenlt on tuch faemn ab
^lyrical activity of Aa
Typical dtmand type apparent ueb at the MIA 'Alt ('up' are certified by liMiiintt for || minuter Otbera knli at At MSA 'Air M*iV are cetitflrd for to nonuiri undfr wbedula
14 (t entry into and ruape bm
tfMpuililc airvmptKKt, lhe*
lervlce life Mi|r>r.< arc land on iciW by Ae duh.au of Hlvt on men felformtng moderate to Inavy work |
each of iltc different iypet of Work iciti or bteaAlng rtachine icm at a a* of 40 lllcn per minute, Tht taer Aould qpt upcri m obtain Ae uaci rated Kfnee Ufa tut each a> Tha w<*k being performnd may fe
The dc&tC2CAch Uw orr'i brcaAing U incwjpd >lLc)|Mcmentt fear or otlMi
motional (him^
The dt >;rej[ ^>f IfityfH w car^Dcnc* Adeb Ac uwi IdVwvUh Allot dmllu e^uip* rm-ntj Awthe i or not Ac cylinder II fully ihctyfO at Aa nan of tl*c work periods
Tit* poialbW pntMncc |a Ac comprewed air of larhon A<`K|de coftctmratleiw greater Aaa Ai , U4,. nntmally bwiul In alnmplwDc
, |li atmotplicfic prcuur*
, Tba condition or Ac apfurliui
t.rhki tiki current iiUlult 111, all Ana*! ty^i rppirrliu mutl artafy tuti cundueted at *3VnfJ althuvgli low temperalure runtponcnii Mb at mt' cwpi A reduce fcttftlna may be added If needed.
jgffA fi*D
ti Haqimmy brnrifea, Mina >*fely Appu*nc*i **l bnell TtlapAana Hiwvcy (^Bk^tnnwy AtApmvm Indtairy,
fittMlf AjbKmI
(hit im
The letm. demand irywlno*. nwaA Ait Ae air Ifcw It on inhaUitnn dermad. *Mtfv*tiijlly b|ulanny Itwlf a die Adr^ Wvcl tn compedwh b>t `iniQum inbrt *an| iwHa.
flcmand apparan* After, apmt watrkieg
ptruurr t*u^c to leant * * Ua hrvadery aippij I
hat drr,p,-Hd n a
wtarv <>< u*< nte remm
to fit A lu. A wlf`(iweum war*** dewed ia Ihtutted foa Muiuh wf Mmaa AppanvaL TW **r> I
Airv ui be rmw *ediU a* me inciaeerd
baaiAttgi itdarwi m alaM Aa weave* w km feM.W.
BF5 008465
i
EXHIBIT D-B(l) USDOL/OSHA COSTS AND AVAILABILITY OF TYPICAL RESPIRATORY l*VICO
ResbttuotY Duvlce/Mamifacturet 1. All Purifying Device*
(1) Mechanical fillet istfniM . Banach and bomb (ML) . Mia* safety apparatus (MSA)
. Scott
. Welsh
(2) Chemical cartrldga respirators . bbl . MSA
Catalog Number
R 19 R2Q 5-15-10 99000
96100 79903
79994 8201-R 8004-R 8101-R S02-R .7080 7600-8 7400 7500-6B
R 21
8-15-21 85550 44135 70853 70883
Component
Jr, srlpflon
Lot Sfae
Co# Per Unit (1974 Dolling
Availability (Weeks To Receive
A fret Ontetl
Provides protect Same as above b\s Replacement filti
dusts (single cartridge), duel cartridge.
Outline 77 provide! projection from dusts and mists
having a TLV of notti'tuhan 2.4 million partlclea/cu. ft.
Filters
H^Q
Dostfoe provides protfSrii!jr}galiist finely divided
aerosols up to 0.3 mldwto diameter (99.98^k effective). Type "II' cartridge.
' 4
Duo-seal dual cartridge t^gh efficiency dust filter (0.3 micron panicles). Replacement cartridge. Same at above rcspitaioi bfti t cartridge* Replacement cartridge,
Protcx dual cartridge icspuato
usu with TLV
more toxic than 0.1 mg/m3 ft
\ ntatk*
Replacement cartridge.
Peotex tingle cartridge half face mask*
Static wool filter replacement
Up to 50 tula Pack of 50 24-71
Pack of 50 72-143
144 and up 60-99
50-99 50-99 1 4 72-143 72-143 packages of 100 it.
Provides protection against low concentration* of organic vapors.
Organic vapor catridge replacement for R 31,
M&A chemical cartridge respirator for protection
against organic vapors (0.1%).
*
Replacement cartridge for 86S5G,
MSA tame at 86550 but with tingle cartridge for organic
vapor.
Replacement cartridge for 70853,
50*99
50*99 boxes of 6 72-143 100-149 72*143 100*149
't
* 7.36 8,90 0,26 7,25
0,13 8.35
2.55 9,00
8.99 2.80 46,76 1.34 5.50 0,13
10,70
1.51 9,70 1.45 9.30 3.65
Stock Item Stock Item Stock Item Stock Item
Stock Item Stock item
Stock item Stock Item Stock Item Stock item
Stock Item Siock item Stock Item Stock Item Stock item
BF5 Q08466
\ EXHIBIT D-8 0)
!
RMptfllory Device/Manufacturer
r Swn
*
* WcU
. 0) Cm muki MSA
. Son
L Supplied AU Device) 0) An Uoe itipluua , Couunl flow - MSA
Scott
Catalog
Number
8201-OV 82004-OV 8101-OV 602-OV
760|
2800*1
Components
Description
Duo-sel respite tor for organic vapon. Duel cenrldge Replacement cartridge for P201-OV Same at 8201-OV bui with single cartridge ^pkc^gjMj&nridge for 8101-OV
Full-fac^fcspfraior for organic vapon. Dual cartridge RcpUcemo*r?5*>tridge for 7601
457081
77708 487112 8833 9 879-1 184-OV <81-1 282-OV-L
MSA iftdustna^rtiiiPfor up to 2^ by volume
organic vapon^JJ roxic dust* with full lace mask and
body mounted canister. Replacement caniittj^r 457081
MSA chin type m^Sjoa up to 0* 5^ by volume
organic vapon 0
'
Replacement canister for 457112
Chest style gat mariTfotaj? to 2% by volume organic
vapor protection wjdrTujjJjipcplccc Replacement canisteryfff^TShl (lOOOcc)
Chin style gas mask for organic vapor protection
(full face)
^ tr\
600cc replacement canfWrflSr 656*1
487162 457161
4622-10
Ultra-Vue facepiece and low pressure control valve (10-15 psig with 50 foot hose) Same as 457162 hox with hypci-flo control valve (40*100 psig with up to 250 feet of airhose)
Zcphyrair-complctc full vision mask with belt mounird filter body and manual control valve. Adjust au treasures as follows with 3/8* ID hose
Hose length 15* to 50* 50* 10 250*
Pressure at Hose Inlet 8 to 17 pst 17 to 30 p1
Lot SLze__________
50-90 100-499 pr. 100-499 100-499
1 72-143 packs with 6 pleccs/pack
Cett Per Unit (1974 Pollen)
AvliliblUtr (Weclu To Receive
A ftet Order)
$ 9.00 2.50 8.30 2.30
45.95 1.28
Stock item Stock Item Stock item Stock Item
6-11
12*71 6-11 100 and up 16 and up 12-71 16 and up 50*09
78.05
7.45 3. 90
5.85 75,43
6.50 42.16
kio
Stock Item
Stock item Stock item Stock Item 3 weeks Stock liemi Stock Item Stock Item
1 1
18and up
82.30 82.30
80. 4
Stock Item Stock Hem
2 .acta
BFS 00846?
BFS 00S4&S
Itetpiutor, 0*vlee/Mnu/ctuftr
Catalog Number
. Demand tyjei - MSA
7600A 451151 457165
* ScoO
4631-1
. Hom m.iktMSA
451140
. Acccaorlci for u-lio* lyttemt
451142
- Compreruloa tynemi/MSA
32057
61857
46721
19030 6G716
- Prcuure rcgululon/MSA
66709 66265
68658
AU-Uott *od rtuntfoldi/MSA
455020 455021 455022 03031
Components Description
Low pressure (10-25 psl) full facepiece.
MasW-rriii}inted demand air-line respirator w/ultra-yue facep!cc^^-125 psi/15-250 ft. hose lengths. Belt riSotfflfed demand flow aii-Une respirator w/ulira* YUe 30-125 pii/15-250 ft. hose length*.T
f^i/pe Respirator w/full vision mask 60-125 pei/ 15*^5 v fty^Aoje length. One rfl.n^g^h^aiion hose mask, with hand operated
btow*j'[crjn}jiii|gal) and 50 ft. of hose. Same as 4671m)jjui is a two man unit.
"Clear f if bbTfocwfterfe-4f1^at washes. cools, and humldittet
air fof |2 ,pa$ks (Nash Co. oomptcaoi)
Air-Inns filtei for removal of dusts, mists, fumei at a
final.
Replacement cqgrpteal cartridge for 81857 filter
(2 required).
A
Particulate clemcnt^nUccment for 81857 filter.
MSA pressure tegulaitifccduccs plant compressor
air pressure io thfraif/d>alve for the equipment.
Pressure relic/ valv^i6ps|j.
Ptcssme lelicf valve-25 paig.
Required accessory when air-line respirators are operating from a high pressure cylinder O-dOOQ pii hi-pressure gauge 0-200 psi low-pressure gauge.
Air hose - 15 ft. long Air hose - 25 ft. long Air hose - 50 h. long UtnUobS-4 man (soap-tire)
Lot Size
1
1 1
18 and up
1 1
1 1 1-71 1 1 1 1 1
1 1 1 1
EXHIBIT O-S (3)
* Cost Per Unit
(1974 DoHift)
Availability (Weds To ftoccivo
After Order)
$ 57.85
95.90 95.90
15.43
668.00 972.00
Stock Item Stock Um 3 week*
60-90 lift 60-40 di;t
2,586.00
44.55
2,40 4,80 34.00
9,80 14.65
04.35
16*18 weeks
Stock itpm
Stock item
Stock item Stock item
Stack item Smck item
Slock icem
16.65 23.95 43.20 69.20
Stock lum Slock Item Stock item 30 days
BFS 00S469
___hotccrtyt ClhlfliAlwufccttW L DiipoMbte Qotkiqg
___
L Cornalb, HMAailllMiCtnclMp, Clow*
. Aow DUpowklae * Mas In.
. ftoaa Putter
t, OB'flMI fHmrild |H)
MSA
JL Peanmit dotting
I. Fall Ititpsrvfcne fmmlKii SmIb . Aimrttiifl Optical . **A
Catalog No,
Comocncma Dualtftion
roeoo
62<806
V*i 01783
>?y
ComM'iili& f' Spoilt TyvtkW with etude wile
ml nklc (oj
fu.
Shoe oovw'rUj&, i Dupont TyitkW Highiop with dnwiulnLji^W <
Hood ntid*o| flKj^nt Tyvek W with dmwiciing , ft* ti#ii Araeaund Cioe.
Coverall made of^^ont Tyvek 1*0 with elude vrtvt and inkiest d^ht fit.
Coverall madc4>f Dupont Tyvek^O *1* etttric
wrist ud ankle for thjhi At.
*
Diipwble UqufcCfJM^ovei.
v^
Aided paltive intertill jf^hture >i4t made of vinyL Complete with atuo^gj^lioM with clear vinyl face piece. Room fa respiratory protective aquipmert. Designed (ot one tee only.
im 76006 33406
*
Vapor chemical rule prexuriaed with ielf-oonajned brcaUdng equipment.
Chempruf^ itdt complete with case, hood and air upply system Used widi manifold and allline idl develops pollUre internal pressure..
RuLhedzed Protection Suit can lie warn with MSA
aif maala not tuppUed with unit.
1
Lot Site
200 300 144
1
1 1 1
EXHIBIT D-0 (I)
tliDOL/OSHA
GOST AND AVAILABILITY Of WOTECTIVI CtOfMUti
1074 Gat Per Unit (Pollan)
Note stotkliiinnMwMliiuwi) m Itm.
t 2 24 0.52 0.40 2.00 2.00 0 21
Stock Uem
Stock ium Stack item
*
lo dcvelopmets 2-9 writhe hefoe evaOsMe In quantity Stock item
30 weel*
47.00
Sack item
290.46 303.46 176.12
C-0 vede 14*J7 wik H veeki
BFS 00S4P
CD
EXHIBIT 0-9 (2)
1
Protective ClotMng/Marmfacturer 1 Add Resistant ShU
. MIA
Catalog No. 37LM
Component* flcscnption
^'tSun fU/O^'* luitv^dftyi coated nyion made to be decon
taminated afifr eacbjusc. Jacket has safety cu/fi And U fastened wItlfcbatt'and socket fasteners, Pants have bib (torn and
Lot Slsc 'I
l*/?4 Qovl Pet Unit (Dollars}
.
< 47. SO
AvallablliTy
'
2-3 >1)
.
*
. Unlioyal
t
31W4 MTQ-A27 MRO-9&7
Rubbet utility suitjackel hat iund*up collar with
storm fly (ion. tfanmi)kve bib ftooi with no fly. AU
.'4team* peisutt wektn
Neoprene coated on nYtfn\j*cket with attached hood Kith drawstring for HgtiTfact fit. Closed with storm
fly front.
Neoprene coated on
type pants Uh map
12 1 1
31.50 11,05 0.05
block lito Not lew then 2 momh* No less than 2 month*
. AimdCMOpilui
M 503-1 M2
574
4 4Acid resistant covei*ll* a<|dt f neopcene coated on
nylon.
'A
Acid resistant jacket male otfh^vy duty vinyl with norm fly front,
Acid resiitant bib type pant* made of heavy duty
vinyl.
%
Hood made of heavy duty vinyl with clear vinyl facepiece covering shoulder* and uppei chest.
1. 1 I 1
25.00 25.00 ' 32. M 40.70
4*4 <.ecki 4-4 weelo
4*4 week*
4-4 weeki
a, Cloth Wotfc Qotfcci . USA
32134
/n Coveralls made of synthetic fiber fabric Dynelv
made to covet or replace the worker's meet
clothe*.
72
18.00
2*4 weeka
BFS 0 0 S4?
ftotectUe Clothing/Hamifactwcr
4* Glow MSA
HoiiurlhiMu
CttllOi; No.
Component* Description
tot Size
3G68B
37643 N-31
Heavy duty acid rejfttSm rubber designed with curved Ungers and using high^ftuaUty Utcx for pliability and chemical rciisunceover* wide temperature range*
Flexible:, complcte^Huud with vinyl 12"
gauntlet type. \Jfj
Lightweight designed^ gfiffc,liquid tight protection. Clove U not paniculJt{4MKblc,
n
72 12
1974 Co# Per Unit (Dolino)
1 4.02
1.71 0.91
MU801 MB990 MB961
_X Knee length acid rciistaM rubber with iteel safety toe,
Knee length medium weiWjBfd resistant rubber with Uftiy IOC.
Knee length imported acid ieiwM rubber with safety " d>
12 12 IS
16.90 lS.fiS 13.70
EXHIBIT P-9 (3)
AvelUbtUrv
2-3 week*
Stock item 6-0 weeto
Stock item Stock item Stock teem
t
Source*: Dumfib 1014 ulu brochure* Mine Safety Appliance* 1074 catalogue, UnlfQyal 1074 catalogue. Pioneer tbibbei 1974 Catalogue end Snell Surrey of Pmtctin Clothing Manufacturer*.
BFS 0084
M
i
EXHIBIT D-10(l) USDOL/OSHA SUMMARY Of SNELL INTERVIEWS WITH
1 VINYL QUOJUDE/POLYVINYL CHLQKDt MANUfACTi i RELATING TO PROTECTIVE EQUIPMENT HJRQiASBD
VC or PVC Produced*) UM-lrrt.-C end lTS-Int.-W
SI SO end SIM-lnwW
40L-New-W *
IS 1L-Neu-W
411-OId-W MM-New-C
M
*8
Class of Protective Equipment
Number of Woikcn Requiring
Protective Equipment
Reiplriton, hetf fecc Ir supplied
16-IS 16-jq
Rejpiinofr. hXlf face ill tuppiled /]
<PT
1. Retpliaton, Ibitrte ,
S. Protective clothing Disposable covecalU Rubber glove#
Reipliaioo
\
Reiplriton, airline Reiplriton, airline
.
S' N.A,
18
if
16 16
Cost of Equipment (1974 DolLan)
1200,000 200,000 * 16, 000 N.A.
60,000
- 30 30
4,130 14,ooo ;
13,000 8,000
Operating and Maintenance Costs
(1974 Dollars)
8 23,000 23,000 N.A. N.A.
3,000
300 300 6,300 6, 300
5.000 6,000
Comment! Seven! tripping accldenuhave been attributed u rcipuatoa *t tame of the worken lie itinerant to vui them. Minute "by minute tupetvltion requited to cntutc tun.
6 week! procurer!*TM Iced time.
MSA type. One Incident of face end icalp nth (torn iiutfilt mailt.
Respirators, pressure demand ot conllnuoui flow
Same
G.6 * -c
10,ooo 4,000
G, 000 2,600
BF5 0QS4?
A
EXIiWlT D-10 (2)
VC w PVC riodoctt 10M -Nev-W
H.-OU-C
13
L-NcwC
14M-Ins. -W
Cltu of Protective Equipment
Number of Workers
Requiring Protective Equipment
Respirators, half face
marii
Respitatoti
Protective cku Coveralls :J Shoe coven Head coven \ Clove*
x ^
CJP
1. Respiratar
tp
A Itline mask*
,
Self-contained icspirMotv^A
Cartridge teipiraton /^_
3.- PiotccUve clothing Waterproof sutu Head coven, dun shields, gloves
Respirators Airline
Cartridge
1. Respirators 3. Protective clothing
N.A.
Cost of Equipment (inc Dollars)
* M*000
Optiaiing and Maintenance Com
(131c Dollars)
* s-000
CO,000
12.000
33,600 7,025 2.312
Disposable clothing
listed is operating
cost
t
N.A. N.A. 72, 000
2,400 1,600
67. 000
15,000 *
5.000
[ 18,600 ]
J.000
Comment. ~ --Worheo complain or dry throat and Impaired movement.
Scon type
MSA type. Welih and Scott type.
i
1. Retpltators, self-contained Cartridge
3. ftotectlve clothing eoveralla
Disposable suits
3 CO
N.A.
4,500 N.A*
N.A. N.A.
36.000
4,000
There have been complaints by woriccn oa wrarlog respUatoa,
BFS 0084?
V EXHIBIT 0-10 (3)
VC ot PVC Produce! 49M-014-C
44M-New-C
WM-Old-C 85-Ira.-C SOM-New -C 35$-Ini. < SlM-New-C 425-Int. -C and 3OS-New < SSL-New-C
Clan of Proiectlvc Equipment
1, Respirators, air supplied
Cartridge ^fTPritectlvc clothing
,/fflrd hats ^SftwaUs ^Waterproof aulta 1. R^pJ^n
2, Proiertfve Clothing Beiplriioii.^^' continuous flow airline^
Respirator
Number of Workers Requiring
Protective Equlppnera
N.A,
N.A,
N.A. N.A. N.A.
37
as
N.A.
Cost of Equipment (1974 Dollars)
Operating and Maintenance Costs
(1914 Dollan)
Comments
$ 2.S00 3,300 1,230
21.183
t 4,800
120.000 '
N.A, 72.000 14,400 30,800
. 20,000 GOO
.2
36,000 12, 000
N.A.
People with hurt or lung (voblems tuve beta advised not to wear reiptriton - have been reassigned to area* toot requiting their use.
.
8
One worker with hlnory of asthma became til whlln wearing air line mask.
f
i
Scott type. Individual uses of workers refusing to weir icsplriton.1
Reiplraton, full
maik type C contlmnM^v
flow
\J) >
Protective clothing Respirators
Rcspiiaion
Reiplraton. bottle supplied air maska fclf-oonuiacd
76
N.A. N.A. N.A.
SO
43.000
5,000
*
23,000
13,000 10.300
1,100
3. 000
26,000 N.A. N.A. 20.000 N.A.
3*5 weeks procurement lead time.
1-2 month* procurement lead lime. Problem* in fitting masks on personnel wlih beards and mutraches.
Increased absenteeism and refusal of overtime hat been attfibuublo
to me of respiratory equipment.
1
One complains of cat problem! earned by rcsfdrator use.
EXHDtT D-10 (4)
VC or PVC Producer SCM-Im.-C tSM-Old-C
Cliti of PiotecUve Equipment
PpSleetlve Clothing
l^lntulu
Wt>(ijrjlnft
Number of Wotkeit Requiring
Protective Equipment
Cost of Equipment (1074 Dollars)
N,A.
8 13.000
200*300
41.000
ANote: (1) toi meaning of froduccr code, ite^ige U*d,
Source: Raulo of Snell Interview with thfi VCM/PVC muiufieturing Indutuy, *
HA Not eppUceble.
<P
Operating and Maintenance Com
(1974 Dollari)
n.a;
Comments
$ 18,000
3 months procurement lead time* Wotken have complaint Of nasal and throM dehydration.
BFS 00S476
(
T
1 I cxHorx o*ti <t)
VCM^VCM4ie
fMfl
04 L#**|
-at*i_,
No, ftmptoyam
Vrint htinmoB
to 4 4
4 4
IS
10
4 4
SO
4
4
IS
_4
M
_ lab ritul/lomm
*Rcjeiei clctruag iLllgf cflCInffi^lldfl ' L*tgC iucioi lui o^ciildQ ^m)l it4clot lud
S<WI) tcJciar epeumtl jociei rfcpinmeot M*iA w|
tfiyti luib rpr apciBiaa
* jyW*u,lUljM "'--Dnrei >hffi uper*uof ap
Inuctnr c tuning tifge ituioi opciiion
Ur^tJi&liar 1u4 apciaun
SmwniCIM Im4
Oc^lnr ilbli mpuwitti Dryo Uidi
Onrj
DryeT
Iot
Sampling
L4<n
Tom!
31jO MlilHlMI
IS tampUng Ludmg
0 MtimtMii OtAcn
It
IIP *U jote Tnl 114
Wearing Tlw (4 of 1 Hr. D.rl
*4* 1 a P to a a a ) a
30 u a to 40 1 a a to
i - <i
it 7
1 It ia
i too u
1
lot
inmiTWMil Cajdrni CM*
(DotUn)
40.000
O^dtfaai n*4kalimn* CoNHirU tolls*)
IMM
1
ti
10,000
*.400
H*laojf* 00 ppm U>tl
MA
1 r000
HA
340.000
MA
Cmnbi *
|
Co
BFS
Q O S <4?
S
l WOUOfT P-11 (1)
i
cwrvc>Hf
Tu|
imi
Tmi
fM
TMI
Twl
vc(*vrtv)*i 0 U
It
I
I* u TVA #
?
at
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I
AII
A 13
I0
111 22
an
10
10 It ft ft
fgfr CUmlfleatbwi Ut4tr MInt*<wtc
V0
PtJ; bull f#l|T buijdlrtf ptmatl b*4llWwUOC*f tKj|tlctl
HOT
(UC'T>eiJf pO|y|
H l[*i
lull luiillnf mini
OCRing #*
MilfUriunct, ftpcf|nJii|
Mdmciuiwt, mhnict
UiiOKninti, tluimlci WtlnttntMt, IntlnuntMa
Ugjtai
I*IW A taw bri(DH(ii44
WTKAltU
Wearing Tima Dlit
It t
*1 It*
1
IN
ItotimtMl Capital c<a
------
Opuitlt* . 4M MAinu4ac
c 1191.
RW
t Imm
N. lacnw
wM
M* HA
1 a . j 10
*. tot *.*
<i,m fU
10 IS 11
t 10 0 I 1 1 1
1.0*0
MA
MIkmh
c*TMTM *
*>0
BF5 00847
inorT 0*it(4)
VCM^VC
IM
tMl I.
VCM Um| ItldUlitf
fa. wttmftaptm
lob Clmlfltartwi
4
4 4
at
u
tt4
II It 4
W
ItI
Ulci cbirfi ofHUtlM
FUulc Ulcn vpcwv
U'M Iccovcry p*M UK* tictpd Outgo opiiiPD (KOmiy tfq*n>H
^50!"\ HC u(tcUton ^Utility efwuion IS )IIktlnca sptufan *W ___ ^Jr*ruftl OputtOIV
Hblmciunce mhiafa
fftrtf finfl opcMioa
. DttJupeivUon
r*| (ortmta DcplAtaem mbfttftf
4 rb*i|e opcfbttw 4 PUMje'lfai cftritfr
4 lA(* tvottrf eptntM
t4t UtM hclh
tt
t4
4
tt
UliUty
IS
TrfjzxIf ;r4 ltt It i im fiTtiiiy nm hull
Tnk form plenum
If fenmti
ft Dy tupcrvUon tI CokmI foniiKi 1M1 Dtptmmu*
W4t1n| Tlmt gtt* Mi, t>M>
SfIt <1I
It
St
St <1 <1 <1
It St
<u1 <<11 <1
It It
f St Itft
St SB St
ft
<31ft *t Iftt i ft 41
bormpgil Ctpul Com
, 13, tt#
HA
OpufMi ii! Miiumm
OolUnI
KIM
Htt^w m M li4t4 MftiiM ill uU|*
tJH MftllMII, fw 4lft4 mfUllln M wl
fa OJVMftg bof cJt4AU| VljlWfUM *94 nw`
<<ut4| taputv*! ih nm m
*b (KHK**a*i|a b Mm KfafttffM.
r* ob*it
Wllfc * SB ppn
tft m # CMA6|
itiptmon u be iluuiftw. TWwf #v
1*4 ipfUaMl oouU ft* IkiMHl Hi lihM
M*lB# vul4 ftf mt4. lMluu*|lf
M
ftbk Ivtftf Mfc m4 tartUf motUMj,
.(
BFS Q0S4S0
kkhmt p*u (t)
Q4/rvc *-^ini
4*4-OM<
U
VCMUnl U|Cll*g)
MTWI
I
No* f Implv/Mi
Woartnj Wcip|i*iaw
>04 A
U 4
4* It
14
4
I0
14 I 1 I 934
I
m i
ti2 Coiluif *i*b Mil* otfKivit* ft4,
**> rw "*! *
*** M pg fl-,
*** "W* * ** mm* 4iImuHmt i4 vc/mc jnfMin.
II I
lob CL*(fjc*do>
UlcK cbaijc opcntof
flmk Utet opciiw
Lilt*
opti*I4*
Lite* btlpc1
chaigt opcuiflo
Ba^cn f ]Pryn operto*^
Tunjfti affiU&tf
Malniriuua"|f{cbj _ Tank (irm0^i4|4ft\
r*fmco \ JJ >3
Day wpuvtnn
(nglnrwi ^ [j^
Ccntial foieAtuvf /
Paptnmtm m*n*g*4
jA
NOT fMSilLt
SampUng
OtilfiiitH c^ttipi
Dpn,i| cqitlpri
Mpun
Abo*#. pun takingi *hlk toy Uak ob
l going UN* * fdfMlL '
on m ibni
(JD
HOT V1ASIMI
Vtaring TUn*
St*ULMl. Dayf
It 4i1f0t
40
n10 4u0
II
30fftt 4If0t ft ft <1
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frinra^
4* *U U*J (M U4M *<W*HHHWH
f
ft
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1)4,004
I*
HA
t
I
ft I I
<5 ft Qj k Qo K>
APPENDIX E MONITORING EQUIPMENT
*!
This appendix details the elements of monitoring equipment currently available to industry for the detection of vinyl chloride monomer (VCM) including their costs and availability. The appendix also reviews
relevant material from the public hearings and lists the monitoring equipment purchased by VCM and poly
vinyl chloride (PVCJ producers. All exhibi^a^pear sequentially at the end of the appendix.
1. A REVIEW OF THE TEMPORARY AND PROPOSED REGULATORY REQUIREMENTS FOR THE MONITORING OF VCM AND PVC PLANTS FOLLOWS
This section summarizes the monitoring required under the Emergency Temporary Standard for exposure to VCM (50 ppm) and the monitoring requj^ed under the proposed permanent standard (no-detectable limit).
0 111 (1) 50 ppm Emergency Temporary StandardJETS)1
. The ETS required that as soon a*?|jQssible but not later than April 22, 1974, every employer of an employee WSjSging in an area or operation in which VCM is
manufactured reacted - handled processed released repacked stored
should begin monitoring the ambient air of the area to determine whether It contains VCM in concentrations in excess of 50 ppm.
(1) 29 CFR 1910, Occupational Safety and Health Standards, Emergency Temporary Standard for Exposure to VCM
00S4S3
The monitoring should be of the nature that a sufficient number of employees be monitored so that a representative sample of exposure to the gas may be determined.
monitoring should be accomplished not less frequently than weekly until all results from three consecutive weeks are at a level below 50 ppm
after achievement of the 50 ppm level, the monitoring should be conducted not less frequently than monthly as long as the concentration of VCM does not exceetf^mppm
if a monitoring sample rfive^ls VCM in concentrations in excess of 50 ppm, weekly monitoring^rfi^ild be resumed until all monitoring results for three consecutive weesj&re at or below 50 ppm
Monitoring should be accomplished through personnel monitoring by collecting
samples by suitable device worn t
employee.
Q
the samples should be analyzedby gas chromatography or by any other
method which is of equivalenraijisitivity
the analytical procedure shall
entitive to 5 jppm of VCM in air with
an accuracy of + 20% for a ten n^j^e air sample
Employees working in an area of operation .whose ambient air is monitored, or their representative, should be given a reasonable opportunity to observe the personal monitoring described by the emergency temporary standard.
Periodic tests should be conducted for equipment leaks and for emission of VCM which may result from work practices.
E-2 i
(2) Proposed Permanent "No-Detectable11 VCM Level Standard (PPS) (1^
A program of monitoring would be required to establish whether there are detectable levels in regulated areas and to permit determination of employee exposures on an individual basis. A regulated area is where
VCM Is
manufactured reacted released repackaged stored used
PVC capable of releasing
e levels of VCM is
manufactured reacted released repackaged stored used
BFS 808485
Provision is also made for an employee to observe monitoring by them or their designated representative. The monitoring will assume that any exposure may be determined for each authorized employee with a confidence level of 95%. An authorized employee is one
whose duties require him to be in the regulated area and who has been specifically assigned by the employer
(1) 29 CFR 1910. Occupational Safety and Health Standards, Proposed Standard
E-3 <
- any employee who enters such an area as designated representative of employee to exercise an opportunity to observe monitoring and measuring ofVCM
The PPS requires that monitoring be accomplished by a sampling and analytical method capa'ble of detecting vinyl chloride at concentrations of 1 ppm with an accuracy of 1 ppm + 50d.
The PPS is, in part, based on tho NIOSH recommended Standard for VCM Exposure as transmitted to OSHA on March 11, 1974. The NIOSH recommendations are presented in their entirety in Appendix H.
2. SNELL PERFORMED AN INDEPENDE
URVEY OF AVAILABLE MONITORING EQUIPMENT AND
DETERMINED AVAILABILITY AND c6ST$ 1
Exhibit E-l and E-2 with monitoring syst
summary of highlights of the testimony dealing
. Exhibit E-3 presents the
;ed NIOSH procedures for VCM monitoring.
Exhibit E-4 presents a summary of the Snell survey ofVCM monitoring devices
currently available; the surv
iple included 9 manufacturers.
Exhibit E-5 presents a sumim devices.
:he availability and costs of VCM monitoring
Exhibit E-6 presents the results of the Snell interviews ofVCM and PVC manufacturers relating to current monitoring procedures and equipment.
Exhibit E-7 presents the VCM and PVC industry costs of purchasing monitoring equip ment in compliance with the 59 ppm standard.
RFS QBS4S6
E-4
I
BFS Q9S48?
;
i -l \i
9 V
\
*
EXHIBIT E-l USDOL/OSHA
Tvne of EoulDment Gas Chromatographs (GO
Infrared
Combustion-Conductivity Total Flame Ionization Detectors (FID)
STATEMENT OF R. H, STEHL COMPARING METHODS OF VINYL CHLORIDE MONOMER ANALYSIS `
Operating Parameters
Advantages
Disadvantages
Flame ionization
Reproducible at constant operating Cannot be used where explosion parameters; selective In identifi hazards exist; 5 - IS min. /analysis. cation; .1-1 ppm sensitivity.
Gat-cell type
Little Interference; each com pound has characteristic bands; 2 minutes to make energy absorption measurement; 2-5 ppm sensitivity.
Water vapor Interferes and reduce* sensitivity.
Conversion by pyrolysis tof'
HCj and COg ft ryi
Combustion, but not decomdpsItipn P- 1
30 secs for analysis; can be computerized.
* 2 mlnutes/sample analysis.
Interference from other compounds (Freon).
Non-specific,
GC - Mast Spectrometry
Magnetic field.
1 ppm sensitivity; no interference.
Not applicable to area monitoring; reference method only; requires trained analyst.
Personal Monitoring Equipment
Adsorption - onto media (air pump, sample tube)
NA
<p '
Non-contlnuous
Source; Testimony of Dr* R. H. Stehl, Dow Chemical Co., Midland, Mich., comparing methods of VCM analysis as presented at DOL/OSHA heatings* June 25, 1974 and Snell assessment.
NA - Hot available.
^
Type of Equipment Continuous Monitoring Equipment Sequential Monitoring Sequential Monitoring Sequential Monitoring Sequential Monitoring
> Personnel Monitors
Operating Parameters
Flammable gas detection
v# (f ,,
GC, 12 poiarTSsmlnute cycle (Monomer Plantfljl)
r/f>
GC, 10 point ^minute cycle (Monomer plantyjfy
GC, 10 point G mlnptfr cycle (Monomer plant Q
Non-specific analyz^Q combustlon-conduciivltyOv type, 18 point, 1/2 m^rfuje^ycle, alarms at 25ppm (Copolj^^-jlant)
Exposure type
EXHIBIT E-2
USDOL/OSHA
STATEMENT OF R.I* DANIEL DETAILIN'? METHODS OF MONITORING AND ANALYSIS OF VINYL CHLORIDE MONOMER
Advantages
Disadvantages
NA Only alarms at 4000 ppm level.
NA NA
NA NA
NA NA
NA NA
-.t. NA
Can only be analyzed after the fact; does not provide on the spot data; docs not give min./max. concentration in employee'* work area.
Source; Testimony of R. L. Daniel, Dow Chemical Co., Freeport, Texas concerning methods of monitoring and analysis of VCM used at Freeport, Texas as related at DOL/OSHA, June 25, 1974 and Snell assessment.
NA Not available.
.
BF5 0084SS
,/ 1
*
1. SUBSTANCE; Vinyl Chloride Gai
2. SCOPE OF METHOD;
\ < EXHIBIT E-3 (1)
USDOL/OSHA
RECOMMENDED N103H PROCEDURE FOR PERSONAL MONITORING OF EMPLOYEES FOR VINYL CHLORIDE
MONOMER EXPOSURE
Vinyl chloride is a gas boiling at - 13, 4 degrees C and having a vapor pressure of 2660 ram of mercury at 25 degrees C. The lower limit of detection for the method is approximately 1 ppm.
.3 SAMPLING EQUIPMENT;
^
(a) Personal sampling pump (b) 250 cc glass gas collecting tub&wtth teflon stopcocks.
.4 SAMPLE SIZE:
250 CC 8. SAMPLING PROCEDURE:
(P
Glass Gas Collecting Tubes
(a) The gas collecting tube is connected at one end to the personal sampling pump. Both stopcocks are opened and air pulled through at approxi mately one liter per minute.
*
(b) A sampling period of 15 minutes would allow collection of a representative sampling of the worker environment.
(c) Stopcocks shall be closed tightly* closing the stopcock neatest the pump first*
;S
BF5 00S4S9
EXH1UIT E-3 (2)
6. ANALYSIS:
The gas collecting tube simple is analyze^THeittiy by gas chromatography.
7. SHIPPING INSTRUCTIONS: ,
tjp1
The gas collecting tube thouId be wrapped wi^jlukioning material, placed in the shipping ease and shipped vi
Salt Lake City.
r* via Air Mail to the OSHA laboratory,
O
Source: NIOSH Recommended Occupational Health Standarmwy^ Manufacture of Synthetic Polymer from Vinyl Chloride, Match 11, 1974.
'CP
BFS 00S 490
EXIflVt H (1) UUXX/OilU
1 courinsOH or rrnci wwnomc ntvica reuxni AVliUiU IO>rnuOIU>IU>IHlM>MMTtCTMI
blaruttilne rVuUe
t*ampW ri Available ftalpmeoi
|
tyurnpUdwi
Mcibtul of Operation
tenaidutty
ft) CrtnUmtlrtf
` HW Uhtj Afftlwm/
Mtb 'trUIrd IlyilwtKOH
tV umpleiitfuwn through
fr tor,
unit
CKa>M| ef tvti p*m - I
tbt iktaglmraui by an tftratbi taWaAcmbiy. Tb
ruemr tube aikl gUrt
tckiTeitffuloBFn itatu wife
ikiKior ihlM, Ni{hin
pin ehtWilc*2fe|hc luV *t
fome-l u^cihci for icnln^
form a ItJfyih of aihlil lo-
ample. The tractor tub*
IkilN Which liaaiiflilcl
KIJi iwa frangible flata
ulA ih* tnMSira aipil*
ampulei remaning eh*ml* <ab which are ml> iirme4lely before u* and
(10IM 19 (IkUV^iUeMittlM 4 the kak'jfcriiMl 2
fcydmdartmtS^
U>i tt
i!< hil^ci-
f dted hydraeaitmo retelling
free
f Ity, 1M tKM
aitulor Me ii HlKial fot
<b* (itol intetat.
fpm
IttNiM MUM
Ira'h/Citlct fitt,luM fcai !`elector iyiiem. lyttem tumtiUt Nl
proven tffmltt (m(WKNl
for the foeflie MmfUnf
*i dJet.lion of mitt |IK|
*J pr-n, # AcihIiK, UAtwq|
Jirtet lulling lflM mUi. , A futonijpt ral0tnetfle pump.
Ire alt off the tlpr^p^Lfrnli
ad#lube. Iftjrri Into pump
pull tunllc whi< h^wia-
*.i wdifi
mailcilly Inthi t h*> at
.
Il>r<c Ml>tpiC.
ahicuhltiy media wUrlfiffi .)
mediately react to i/Vmw
eaj*i being amlytrd^anj.^.^
connint eoloi uain proofed which will vary length according to (he
W*lnr(vuiln bclhg me,
IQ CUkmI Tobo/
MMr***
Mil INI!
fitmerBiofti of Slrui fftrvul tai'fUi jump.
. rv.-wh |*|/a*
, width i-\nm
. length #*V*
, WtUM > i; ot.
Il la d'nril In limit pKIrl of tdlii i ihill ftH or in a pooch clipped bMb* wotfcrt belt. tump l mw4 *9 l<iv a vontlnuoualy nauml relume cf aU LMu|I| a channel uW Imd a worker* biC'thinj unr for the Juntie* uf a iU*t Ihl/t. Mure tliM
al^ht keufi t* (oiiMmi <rp*'lftw can H pro*adtd
Nl4*t rnch(> *
The equipment utilise* a |U* Can i]tfl VCM lo*|
tube |4<.kcd v/ictlvatfil
* <.! ppm
Charcoal tlwouyh which an all
ample con*(nJr<i* a apt*
'
welt at VCM Ii pumped.
1W rapnr It quantitatively
idntbtl hy |kt activated
CfltlVIL
Th* VrM nlltcitil on ihc
lube ||
With
carbon dikul/Ue, anil at
aUmioi of the reauhint mla*' lure It IniroJiKcd Kuo |*| dMmai0|nptk,
*
An ahemaiv at a*rK*M lt*n hViHif rhuic Wp ft ctllnl umptaa.
CaUhtadon Procedure
Ural of Training Itotultrd for Ope it tot
tuber at* calibrated for Ujc at attncnpherle ptawat between temperature* tf J and bo*r and rclatlvt
humidiUH of ltd fttffr, Tubea ihould bn rinuf for tie at |ow
Ttdmfcitt nv rpmti^
Hetaatnry ttpytn ^utomtnt or luppliya
fimplo It tftipftNk Mb bt MilfbManct.
Ho calikatlot Medad M
Mow dr.fttbea itould bt (Agoftltd
Ttetaklat r tptilt| foreman.
Mm
ItmpU it tpwda*. tt* m MoudetaKt.
Pump may be tikWntl Imply by checking the ce per Broke factor. Tbl* li dotfe by dtawJtf air iJvflvffc t chaicnal tube pxtJtl by a map bubble flowmeter.
Technician or foreman to collect tutea and check pump, Cbcmlai for ciUWl* tint aaf tpaailn <f tla cbananatofioyA.
Total rc'r tampted factor
Ho, t< itrobei reoiihrd
4K<A
The factor boa beet InlUnUy IcUimUrf by taUWiiMa, and H la ibowa tt Ihn pwmp
Mart ft HnntW|ia|> */fU><
Pump ryttrin * tna>Ofd f*t 0(ha atd ia wnd by moot tm Miu
bdft**!
BFS 00S491
k
----- """I
ft. Am btototniUf ill CMC (AMMiW
____
UlDflt of
Available {qinpnitia
_nuitnim/i)n:,|f |
Ckmh..
m,,kH
StntUlviit
n*hm*n imruimm
Owy--i/AMMI YH
t**ht UUA
Pmcck lj*i Cbmffui^'iAph U<ut to 4rtitK4 |( litU lOClUan in lu.!AMotf| Altai fe4 may bf Kp*/icJ Imim fto f*u{Ummta bv dlitagtAt P 1,004 fi.
Alt it drawn lw umphnj pip* by fnip #*J it filtered.
Sample it Ottvii ima C.C, and nityxvd In VCM by Damn Iwliiun
tampin tipP v lOp^Ot*
kuulo tie JHpLiycO <m bar*
entcniMliy. APJuAimJmS^ fUf* ei t * nuihefleal bade
(i^iNUfy to MwihfitijiBa
jvu a nilnkAmpotcr.
Utra if Unto p aUq^b
***** twtltgt. ^^baropto iitolyiit time to
r'f'
Mb.'lflto iMitih grade Hi 0 |u tarvatOtaf*i
tob Jatomeoc
A MtrttllccuyilJi*t k4 can be mM*
Tr 20 mlM'lfh
JJ J1
Stmt at ttoovt, TU^dncm may b vied in
vp to it 4U(cm i&cjiWhA oim ptoi* by add* t ^ 10 pjfl ilium tolHlifto valvn and pnmp.
. IM
l}*M
raifcwi, iitclWitv
, bttbman
. ftcmu Hcwlnt-kteluid
Um to rtwiiffi type fat rtuomatagtaph <<Npl0 ntlh RinflnnUj wiittwf OMfU*.
/tuniem + tlon
!Ato itoftpir^iej iisnuaU|
collected'bytn inicun
. Atliewf thintol ttobti Tbc wmptoi r buthr u h# UbatW) ito uttcctad ini*
C.C,
Calibration PmceJupr
Lani of Ttaiftfrtf ___ Unuinf fat Qpt*t<W
NMtiMty Sappen 14utflrM Bt ittpfiiur
Ayiicm to ttlitulto Otto*# |ti mUtvm wiM* VCM ccn<t(Htai|sf\i ait known, lb< mtobtiti am commercially iiitb *b| t caa W *ffto y* pi plant laborowy a|A laa.
CiiJimi (btml* lot ijfMKV CtltotM pant
pE/AiMA.
H^iMtotnC
. Ttdmiciw tot Mkaiwti
to (3)
Sam* at above, Amtline tcu#om| tan bn performed with (ha Mtotoempvto/ KHiwy.
tam w abov*.
bameeaaMva.
bnnto ta abn,
Cnduai* rhcmiM fg< tyittmt opttaiun.
fttiinUlta for main* kbiKt end utnpU
uu,.
CaliHuion OptlAllI^ |OU
* to} * *1
" Ctmpiato air
Sample coiicMon wn * * Vtoa tubs) Tedlai top
Activated (hutatl
Ah' a..4. #>lt r< pr */ t)i<r li tcMriic^ Um o* a t#p<iai > i/mtnr it a-y rW ** mawA Atti^ai,*) AMlytaib, * ntt> *wip ttOvl'a Mt^t ap* Ain't **** 4 f ta #
flpr (r> ^Utotot " plrt AU rrMy |v mi tampUi i wU ot anatoiito pn On ttnbtp myal >M***** to ammoI ytttiM.
I
UiaKTI'tft)
Sendtfiinr .l ppm
CtHbiiBwhiKcdMW
JlmiUf ptneeduf* II fe#
Cu ChmiwvpijMc
IfflrilM
L**el of TnifyA| VqmuJ f"<Qwuloi
Cr'VntitJ tpiiiitMi ****>*, iifi^i piwi( tun' RWIUIUA IMI far M*4rc
yw-toary Import
tOm.^mriif w S
i Clllhourm 44WY
O^llllAf |J4I
* u
M,
* Onpniff 10
C rVirwott
If VCX coiKiBUttoa n *#ty tc% <mjw4 h> kK^rfJ kyoraciftwt kwl, nuM( i VT44 km! iCiwta
~W">
CaUbraitoa to performed a*
in ft cNomaiO|ta)4iy
%** |iui wtih towi '
cunninilMi
CnJuitc etpniljt N a^naiton m4 im!i toiltili TuMkUi far Mil* tonifK* M aaftijto
niUttyoa
, CaUfetattna fiKi
1 Itmpti rtlt(h'A * CNanail ruhri
> (Mound ubti * TniUt kifi
MrM ti |0a tow u*
Hu cfcaa M D -<*. t
i'X *I;ai % itt| w
ctpatni* #i 1
H*M` * it*0 4k
ppm CtUMiin {>
Cflihiiito |ihi
00S493
WrtMnnlH|C QtHcl
4 look Otmmt
(fefMM* unmm |l) CnUhanh
>^1
(I) bfilftfc CilnliwUt
Mytr
Kiomfk W
ffhWnHM/UrtlH
Cuh^ l)aiv ta*,fOVA-
A*tyOea| Imam OmHwn. tar.
wIttMnnvtk#inwtawta i--
Pufilmln.
Method pf Operation
kfltlilrtty
10Li^ii eight IN. -to*
fUfiw lonliaifon
% V7 It*. -pwN mvI rh-ti, column wotN On 0>a
Foniftle lAHfbOK m, fU(M
principle / ot4 tHorf-
tonuiMOA CC aAllyiri. _r|n>-then fcoohaaio*.
lITCthr fouV..M
*)
A'ht *ijn iiMin i oa4 ,'j
taiicty riui^e, Hit
column.
/> J^w\
Completely ic|t ionutned^
puhlc gat *NnnuioffA tMk lltmi lamuqiM detector, Wn,N 49 tin.
Can i|u he htbl || i lota! hytlrnrakaA ifWjyur
. H*l lAtcrttUAgc*
able flO^C-TL
dtittun
t*iiec* ct$/rdiDocrflMd
**m
fomblc trutfumcM Clgtt V> tUe
ftl
Wti^n . j it.
When m. lei cadmiwn
fciHCMCi arc UKd
kuini'rrnl |U dl|r*
HtDrirl up 10 f hour*.
liutruAteiri u not Ipeclfie to VCM.
Avdiftlt iliift* l nt<ii*0 II Pi
ffcteOt an
idloti-W* ku
M<Nkl9LV tptum on tat heat of comtHouoii principle,
cKotMw
Idle of tnU)Mklt
Comi mt
,
t ppn tod
WkltM
CP
m (
Calibration fraceJurt
U*rlof
JfgMKdtmOm.M.
L feppxi____ farttip
.-*n,^
UM m < itiUonwy 0. C.
TxtatlM
Coitkiito* |i*W
pUkOrtf **
Mo n-LJ it do*K
poriurilTMtil
twftou **< MCNH Mi
OMU
tamo wfM AiUomij 6.C.
Tkttaldkl
U** fh i/c* coi^f packed
tannimom to c*niaid CM. tau. M ,U alnuu
^
0pf4*< Of ucluteLari
Mmmw in All mfcftto . ,,,,,,,
. Nicad kiiwry
. >11111) thoifii
Anoitv m nar.licbrrrB (MOOrivt k r-|niir#i w4 It li-.lod <0 pcit*dic Ctllf.m tkM o*0 foplOCpn ar(orota tao.
I
JS--'"iBitH
fiiinftv1 4
-tm-v
w< 0*4
IS 'MW fl W
Wilfct ttlllti'lc/ Miln I |R0*
ftMfyl**
lWftltHOW
Method of Operation
TW initrunK-ni on h* readily mihimsI iq| CilthHHJ Mi the rtnli'nUt cat tnahtl* revn*^.
YftwpkJri ll b tJfilppM
m&ieWf 'fuin-kA^h by t finals
fcMiai^k>iV ! a range of IlJ le C0tt4 metctt.
IwO
a<
rtwawtit* an* an owrpui
i Hi* i*il of *, iwq
cnctglct li provided. TUla
OUnvi one mcaturcihctM M
be uVrn on an anii}Tlea|
abtnrpnort bawd and Hm
Ik| of a neatly non*
anything wavelength to
fnvIJa a Kfetrwt ilgnat,
<V<au^T^w<iU It llptu
"n* two *n*i jy nt*uTc*
Nt OMorhuKeunlta, AtMrirtfag roem* a;* tlniiMltally lk*i^t*r U nlitlM' tuh|tact*d alter **J have
iMp a r^Jhnfditecily In
yittW ttiMM,,'ti the urn*
ftfccNlrtlm mm (onccaMa* *nal> id an* Ur* converter.
41*0 * aWj^fofriiKW.
Weigh* 3\*t.
Dtn>M'W^S
,
1.*1
*
II
Single heim. Aval ***
length phwmetci
Time
weBvh
I *oS
ry
. Wcifchf -W*
. D*.t*n*W*M.k*L^i|fM r wRtpitj
similar i* Operand* to Mtan || hut can h* me* * nalyie any gat that hwiha iba 111
Sentfilvttv MWfV*
HNp^l
|MR^.
Amhfilnl InsntmtR A HevclofervRt. W. Cau'o;. llti;
|4<IUi>'ti iMIturv^ Co. |-W S>*c| tlVC^Jb^, ITU;
kthmin lulkln |1jf. IciIiitui IvwniRi. Ik.i
1*74.
Century Sytitm, Ik. OUA-K CauIm
(InVh ktWM bikiii to U7|, |V7i,
Mpi
Ayyi'IWV b*. AUtl t`'*4* i.ate: |C4f
Nrh^diMi bR
k*<A h'd'W tm l/mom (4tii,i, VII:
WIlM i*iei|f|e, IIUMIA Nl aum. 1*74
Mill MfVf <M tfOttetiSO *tpnw I llw<kMI%
Mtxarr s-*<;t
Calibration Procedure Mw if (allhadla |iw
Lent of Tiiialff| Moulted f*f Obctator
Ofcohtit lettMhh*
Neiotary Safpa*
Imonu fee hanciy opMtwo, Cm h* eri e* 19 *vb Wtwy
CnbhmAo* |a*es.
power * n* toy *******
OCCOiaory, MWt'K
lam* a above
Same at abow*
iMWHlMl
BF5 00S495
*
K
EXHIBIT 1*5(1)
USDOL/OMIA
AVAILABILITY AND COSTS OF TYPICAL MONITORING DEVICES FOR VINYL CHLORIDE MONOMER DETECTION
Monitoring Dcvk* 1. rtDSAil Monlioilql
(I) Cckidmctric
(?) Outcttl Tabe/Pum; System (Automated)
t* Aim Monitoring (1) Automated. Sequential Gas ChronutDgmphlc Syncme
(2) Manual Gas Chromatograph* for Area Monitoring, Charcoal Tube Analyses. and Residual VCM Determinations
Manufacturer {Instrument Name)
Catalog Number
Com ^ncou Catalog Oescription/Lot Size
t RerdLi/Gsnce (Prccirioo Gas Detector)
s.m-M 191 j.ns-M
Pump kit/6 or more Detector tubes (10/box. 8 or more boxes) Spare pans kit/1
Mine Safety Appliance*
fllalogenatcd Hydrocarbon Detector)
85842 85899
lUlogeiutcd hydrocarbon detector (Group A)/l Tubes for 8S84/p*ckigc of 1?
Arutole I, Slpin
SP-lorSP-2 Personal air samptcr hit/I
(5lpu Personal S/tmpIepp- ^ -
Charcoal cubes/paekages of I?
tump)
' '`A
L...
Beclcnan fftocul Gil ChmnuiofMf^i,- ^-js.
6700
Process gas chromatograph including Leeds L Northrop Strip Chan Recorder Ten point sampling system
V'"' .
Application engineering department final system check-out
Byron Instruments. Inc. (riDC.C.)
<^fpdel 930 O'
VCM monitor 0*10 ppm, fully automated, 10 points, 2 min per point, t/har graph or strip chan recorder
Hewlett-Packard (f|D Automatic Ga Chromatograph W/ Mknlcom>jtcf)
Pcridn-^lmcr (Iftduwial Atmospheric Analyzer)
h&50
ah
Mode13339
Reporting gas chromatograph w/lC point
sequential sampling system (eomplete)-
system also includes built-in digital
processor, keyboard control center and
prlmer/ploucr
*
Model >320 CC *hh iTD. linear temperature programmer, complete automatic data handling as an option
Vartan/Aerograph
,
144010-00
00-0145-01 9370 0ul0
Single column (18J) FID, w/linear
programmer, G.n Chromatograph
Columns/l
Recorder, single pen
(
Due K integrator
DUc A automatic primer
Unit Purchase Con (1974 Dollars)
Pa cure meat Lead Time (from Time Messenger Receives i
873.00 .90
8.05
876.99
1.98
900.00
.89
Stock Uem Stock Item Stock Hem
Stock item
Stock item
0-10 Weeks 2 Wttki
6.000.00 X770.00
650.00 65.00
10,876.00
9-0 Month*
2 Month*
6 Weeks
9.075.00
60.on
1,1 '0,00
705.00 ( 995.00
3-J Month*
Stock Item
7 Months
2 Months 2 Months
t
BFS 00849S
BFS QQS49?
1 *
-.... - Monitoring Device (3) Toul Hfilnxirtna Amlyica
Manufacturer
(instrument Name)
Bcndlu/TIIA Multipoint Sjrttcm
(4) Infixed Spectmphotomctu (Auunuted)
WlUu Scientific/ Ml/jn U Amldent Alt Moniiot
(S) Milled Speetto(iiotamtiett (Manual) (oi Aiea Monltoiuig and Itilihul VCM Ociciminatlnoi
Bcckmin/Accu Ub. a
Peikin-timet 201
3. Leak Detecting (1) Cat Chtomaiographic
Analytical Instrument Development Inc./ tollable C.C.
Century Syitcmt Corp. / Organic Vapor Analyxer
Catalog Number
Componcnti ___________ Catalog Dctcrtption/Lnt Size
. Cott Include! 10 point sampling rtream lyttem
. FID oated
20G-21S0 212-2120,
Miran II l-RSy&tcm complete including: . 20M variable path cell Calibration curves for specific
analysis LAN Spccdinax H MI II'Point
Recorder
Sit sample inlet parts controlled by nylon solenoid valve. Sample pump capable of pulling
samples 200 feet through 1/2" LD. tubing . Internal plumbing System housing . Particulate filter for each line Same as above but for 12 sampling
18% Opjb jfijjiccuLab GIR Spectrophotometer
580248 630249
complete with recorder 20^1 multipath cell (sample cell) ^iOSl multipath cell (reference cell)
Model 2G7 Infrared spectrometer Single twenty meter cell \ loop circulation tyitem ct beam Hemator
Model 511 V10-C001
Pori?"G,C. equipped w/hydroRen fla:e loruMtion detector RccorUcr-Litcrlinc Anglis? mulilvolt fixed range completely portable and contains its own rechargeable batteries
SU chart spec
OVA-93
HD w/strip clurt^veindeit/metct
EXHIBIT r-S (!)
Unit Purchaie Coil 0)14 Pollan)
to,00.00
Procurement Lead Time (FronpTlme Meuenret tetentt Ordsrt
3-d Monti*
11,250.00
3 Mentha
12,GOO.00
5.130.00 2.310.00 2.310.00 fi.8CO.00 2.590.00
275.00 40.00
3,300.00 510.00
3.600.00
3 Months
3M Months
3 Months 2 Months
ft-5 Weeks
s
t
Monitoring Device
(3) Ciulyilc Combtntloa Principle
(3) laiuttd Spectrophotomtulc
Minuficturer (Irutrumcm mmc)
Ciulog Number
Component! Ciuloc Descrlptlon/Lot Size
Btchitich Imuumcnt Co./ TL? Sniffer
. - -4
Wilkt Scienuiic/MirSn^rl
23-7350 5652
/-A
WUk Sclemlfie/Mlrin4>- 201-2120
Jj
TLV portable sniffer, battery powered, linear scale readout
Miran Portable Gas Analyzer w/linear absorber readout, speettai tange 2*510 14,6 micron, variable path gas cell
Minn U w/20 M virtibte gr cell Specific for VCM
EXHIBIT E-S (3)
Unit Purclute Con 0974 Dollars) S <78,00 4.82S.00
8.800,00
Procurement Lead Time 30-15 Dips 4 3 montlu
SmiKcr. Anal)Ucil Iwtr-jmeni i. Development, Inc. Ciulog, 197ei' --,! Bichiuch IWIruT.enl Co. I-W Model TLV Ciulog. 1974?
lechmin bulletin 41171),Bcckmirt Ituuumenri, Inc.; Bcndik/Gntcc Ciulog, 1974;
__j \
Century Sjrtieiut, tic. CLM-93 Ciulog;
Hewlett Pickard SuUbtln 5330, 1771;
Mine Sifely Apparitor, Lie. Model 85342 Ciulog 19741
Perkln-Clmer On Cbramiioguptile ind In/nrcd equipment Catalog, 1974;
Awilla Sclentiffe, Mltln I II Ciulogt, 1974;
^ If
Varian Arrociaici.'Variin Amerograph Catalog, 1974;
^
Snell Survey of Ci Detection Equipment Matuifactiuert.
*
I
BF5
vcM/rvc tmumO)
Ttpc M Mo^iortiij tuuiwmn
Ham* *f Cfiduncw Mmuficnutr
Tul Innalted Urvli Ora
|1*T4 DolUa)
uHarr n (
USDOt/OSKA
tUMMAKr or SHOi IHTIJIVirv RUUtTS WITH VINTl CNLOHDl AMD KH-YVJ1Y1. QllOIUDt ttcoucttu KILADNC TO tUIOU^HI Or VINTl. OllOKDt
tONITOUHC nUltMCNTl*) FTOONAL AND UAK DCTICTKN orvtco
Operetta, ud Mitnenmcc Cora
(1974 QoUuQ
Timlii
Procuremem
SURHJO
Comm*MB
UMHiaK
HMnu*
9 ft
1* PudqiI moattaifjm
Cut IUb*
ft* Uth tklKQc* Ov^>ak vapot
CM chmrrutognjitt
I. Lwk iMctUm * Oi^ulk npot uiijfiu
I. Uik iwcUa4 . Oipik vipot *tt*lyar
1* PJB004l Pomp* ad Impfojen
C,C, for iat1y cf cfomil
ample* U U>)
f. UjkilctQClioO
* Or^iM upm iuljfwi
> PlIMUl CMb4p
4. Luk kito*j
H.A.
<***rff\
BcnUx
SIplQ
' 'A
Hewlett
|Mod*IMJ0)
Century OVA
^
W
Ciltottrtd Innunoia tic.
CeauuyOVA
t TO. OM
1ft. 000 10,000 9,000
9,000
1.350 1,400 4.0M it,ooo 3,900 3,000
t 40.000
1,000
ft.ftoo
4, *00
H.A,
H.A. N.A.
N.A. H.A,
Iton limt for delivery.
Short ilnw for daUvuy.
Short dima for delivery.
Cm a IoiiN 1 plant. AmrHniKjidtfM ef laboratory gat (bromaiogiaffc aad dkcmMil,
(01Atnoned to ft* corn ft (TVAs end pantfcne
opcrritt.
Aawnod m be com for 0 yertaOW Min and part* dm* eptaato.
H.A,
teell etAweie, OVA cm nU,0fii celt.
H.A.
1 000*. (te comment*) 3/14
See comment for OAM lu conufxm for OAM
*/74 0/74
H.A,
tee commeat foe OAM 9-5/74
10,909
1,000
1*3 wetra * week*
n tru 4/1/T4 Cwn|4eu
MM U tout m /or aa Mfowlag uirptAa*. 9 MtUti d.Mlia
Uect eln u Oauifttae VCM iHOeet Weelb
lull
1 Hill
BF5 008499
t
I
.i
CXHViri-t <)
I
J
VOA/PVC fwJwtf
.
Typc of Hoaliortni twixmm
MMhifocWfl
Toul LuullcA <M14 OsIUb)
Operating art MaldcMwe Cta
(1914 DsUut)
Timing
Procurement
Sun-Ob
CmiTHM
U.-OW-W tU4*N*v< M
*t*ow-c
lm PtnooiJ monitoring 4 Ctuictul aOtorpue* v/CX tulpk
I, fenMul&impUnf , 1 rtD%J9mttfir|fc
for * pcncoAl uKipling
f, AdJfUooaJ analytical
pciwdil monitoring
N.A,
//<s MA,
c>
1, p(vxulrmiu>rlfl| G.C. (PD) for anatyiU of charcoal itiWi Pcnonal umpl*
C. Ulk deiocfloo , Organic vapor BMljrm
1. Ptnoiil nwrJtoriA| carbon iuW pimp
G.C. milyiii of Mfliftfl art %CM *4A*Jto
MBiriioifog G.C* Mlnicom.-rter to cdrhpiu Mhl iBw.dnrim Uu
CiW
- c
ukn
D
40*000 10,000
14.000 10,000 10,500 9,000
100.000 N.A.
50* e.itipku 1/14
1/11 *
tomitTwl w ImU4< ii(5.C.`ii>4 dxukd
10,000 0.000
NM yd Imt
10,000
tn*
N.A,
N.A*
N.A,
S/14 12 IMfidU llld fO*BhB0
N.A,
N.A.
t UftlU
00
10,000 13.000 34.000
0,409
90.000
90,000 9,000
N.A.
#.A. 9 mooiht 0 month*
N.A.
N.A. 1 momh 1 ntoMb
1 codpljr .lih , M ,, mailt.
BFS 008560
A
CXHOITl-i (3>
VCM/rvC Producer
4IM-0.4-C
UM<OU<
#
mm
Hunt of
CquipmcM Manufacturer
Toul Ixuulled Unit Com
(1914 Dollfta)
Operating tuft Milflieruncc Con*
(1014 DoUtr)
Timfnz
Procurement
SttHJP
t. Utii detmlM * Orptlc vipof uil|fui
1. fcnootl Rniiwtf
Cuuiy H.A.
u Nnmal rrtnllodng
St l*ek dticrtoi
`ZJ
(hjiMlc ipw mlftm (j
ff \ ^r.
fttndix N.A,
1. ftnon*1 rrcfxttoriaf C#i chrDm#io|nj* In cl^coel pt uitncr
t. Utk dcteeffo* Oi;(Ak vi^iu)|icr
M#wicn neluid
< If *
L Ulk Otgtik Mppt iBilyttr
A
.60ft 3,30ft t.0* l\0ft
ft.Oir
13,00ft 10,000
1 34,000 3,000 13.000
33,100 M, coo
hoi jl Ion*
40,000 >
N.A.
4 mondv
l mooUr
Comfltit
In optfttttm kjlKI
tafUc.
kjUci
m.a.
n.a.
1* ftnou) moailacfaf OMlmctfn
O.C. tNoibQitubc MtljnU
Ukk tfriKtiM fHgiofc Tipv kiulytN . CHnkauis fMKlpi*
.
(f>
Vwb Actegttjfe ^
0,000 3.300 4.000
CCMltfY JAW
4,400 1,430
1,000 1,000 1,000
000 33ft
>3 ttccki 4 week* 12 week!
4 vtdu K Miilu
l V**k 1 week
Commend
Coii tuggcri ndOliiM ( ii||4nI iftj^
2 until Can rnffai oMMm W Mljilul
Cc .w
l0iMM(M^klllu4,
4 lulu
,
BFS 00S501
tXMtUt tH (4)
VCM/rvC Producer
Trtx of Maaitonnn eoui^mew MMHotlflu iqolpmcoi
Nabm of
Iwltmtw Mmrfiaro
N.A.
I. Pf*oiul monitoring * ciuKoil rube iyp
n,a.
. C,C. for ul|iii of Kibq
Viiiii icngrifk
9* lti]i (k<ct)n * O^uilc npr iul)|iu
U Penont) monitoring * hnaiil urnptef
^
Camy
N.A.
9* Luk detection * OrfiaJt tipw utljrlStr/V'^
*
C.C.
V-
at>Nc-w HM'OIK
1* Penetul monitoring
for. Ub cbfonutognph * 9*S
- OAti rut**
Leak deiacdo* infr*r4 unit . Organic npw 4Mlp|
t20L 0> r munlHtf fmhmt M, x, u-.
/ (T>^ o
o
Curay AID N.A,
Conwy
Hats **~l
kiMttam vIM w Vrn/fVC mMafKinfliix MuMy.
T>',,
NA Mm tlllWk
TouJ installed Unit Carts
S 41.000
*100 400
12.000 *50 tick
*900 7*500
10.200
*900 *4.000
OpemJog and Milmcnirve Costs
(1074 OolUa) f 70.000
-*.ooo 90 >05,000
90,000
N.A,
, N.A. N.A.
04,000
*0,000 70,000
Tlmjflf
Procurtmona
ScjMJp
tfnotfa fivn Ha
CsmpkH Complete
Complete N.A
K.A.
lot ftt Inmumus.
*500 Is for rebuilding of C.C,
*
Cmi i>ua< i44UJ Mtlytiul auff.
Tint fatnidiu*.
K.A. H.A.
M.A, N.A.
fa pbci
H.A.
H.A.
9 utu fa puts
9 MlCl August 1014
4 onto aUnty
4 Hill Com mUrn .And* (M)rflC(1 nfl
BFS 008582
\
l
VCM/PVC Pwnhicc/7* UM-'ja.-C and
m-im.-w
<0L-Ne-W
411-Old-W SM-Kre-C 38
M
l-OM-C SL-NevC 14M-1M. *W, 4MOid-C
MM-Oid-C
txTirerr r-7<u
Att)a Monitoring Device Dettripdon____________
NA
Mo. of Mum
30
USDOt/OSKA
SUMMARY OF SHEU. tMTEWtEW RESULTS MTII V1NY L CHLORIDE AND POLYVINYL
chlorant pnonuena relating to purchases or vom aiiorapr monitoring
EQUIPMENT! AREA MONITORING DEVICES/1*
Name of Equipment Manuhenuef
NA
Tout Com Including IrouLUtion (Dollanl
3200,000
Operating and Maioieiunu Cost*
fDollanl
S AS. 000
Timing Procurement stn*Up
6 mot from order
Cotta ate fee 2 planu, SO pta, pci plant
Fl**J point conttnunujy,\cm.
NA HoncjrveU 1000
38,000
1,200
8/74
0/74
rtxed point eondmimji tyticm.
Cottinuout rvai$7or 1
Y"
\ j'-.'N f s)
nD ehrewtogtaph with WnplVp^
tyittmt and computet interface -;
equipment. Sampling point located
Athreujhoui operationi and loading
area.
//
NA
34
Honeywell 1000 NA
Airncot
45,000 WO.000
60,000
2,000
m.ooo
It mot.
f-10 vka. 4/78
Com aw In 2 plana
NA
7/74
Pending 3 unltt
1
Same at above.
Amteot
Automation total hydrocarbon analyiei
;V\ y'r
Sd^jf^Bendla
Same at above.
NA Bendix
Same at above. Same at above. Mini-Computet foi Ucttdlx
S Vendtx NA Dendi*
NA
300.000
ao.ooo
10. wo
8.000 10,450 43,000
30,000,
27.300 g.oqo 6,000
12.000
3.800
18 mot. for prelect turt-up
NA Complete Complete 0 mot. S mot.
NA
6 uidu 4 onto
Sequential chtumatogtaphic tyttctn 1 Oendix
without computet.
oo.ooo
NA NA
NA NA
/
BFS 008503
EXHIBIT t-7(J>
VCM/PVC Producer S-Int. <
Atea Monitoring Device Dctcrl&tion FID gai chromatograph.
No. of HA
Name of FquIpmcAl
Toiol Coyi Including Installation (Dollars)
Operating and Maintenance Cotn
IDoltant
Peikin<`Elmcr
S 18,000
NA
Timing Procurement Sun-Up
NA NA
Commenti
30M-New*C 42$-Ini.-C
SSL-New -C
26M*Ncw-C iod ?9l~New-W
Faxed point lyjtem.
HD gas chromatograph. flO tyticm.,,^^
Automatic cWamtfBffifh with dau ryiteitv.' f \
00 NA NA Ilewlett-Parluid NA NA SO Custom nude
44M-OW-C
',
Spju(dHi] n)Ofl|(Qri^j^nurogM()|)
NA
Bcndl*
cP
----------
X
Note*; (1) Equipment Innallcd Incompliance with the temporary tundardijrto anticipation of a prominent ttandard,
(2) f*t meaning of produce* code* tee page Uh;.
/j_
200,000 NA
70-B0,000 oo.ooo
137.000
S 30,000 NA
'30*40,000 NA
lo.ooo
6 Vide NA NA NA
8 nun. total
( win. NA NA NA
2 liutnnncnti
Soufccj Mewlu of Snell Interview with the VChl/PVC Manufacturing lnduitry,
NA - Not inlUHt.
\y)C*' '
y\ Cy ri
BFS
%
<5
% Ul
<s
, ..A
w Ip;
1 ] ^APPENDIX F
A
MEDICAL SURVEILLANCE OF EMPLOYEES
G
;A ^,
4
(\
BF5 00S505
APPENDIX F MEDICAL SURVEILLANCE OF EMPLOYEES
This appendix details the elements of routine medical surveillance and their attendant costs. . All exhibits appear sequentially at the end of the appendix.
1. A REVIEW FOLLOWS OF THE TEMPORARY AND PROPOSED REQUIREMENTS FOR THE MEDICAL SURVEILLANCE OF EMPLOYEES IN VINYL- CHLORIDE (VCM) AND POLYVINYL CHLORIDE (PVC) PLANTS
This section summarizes'the medical surveillance required under the emergency temporary standard for exposure to VCM (50 ppm) anafwie medical surveillance required under the proposed permanent standard (no detectable limit). ^
U) 50 ppm Emergency Temporary"^? ard (ETS) (1)
The ETS does not recommend or reqijjiif e any medical surveillance of employees in VCM
and PVC plants. It is concerned only with thp:>4ixing of exposure levels to 50 ppm value
(127.0 in s/cm).
//
Z/--
(2) Proposed Permanent "No-detectablc" V^Mf^tandard (PPS) (2)
Comprehensive requirements for employetrOedical examination are proposed, in cluding necessary tests. Some additional guidancT^included for the convenience of physicians. The proposed requirements have been.recommended to OSIIA by NIOSH (see below) as reasonable and appropriate to detect liver dysfunction which may be indicative of, or.predisposing to, the development of liver angiosarcomas.
(1) 29 CFR 1910, Occupational Safety and Health Standards, Emergency Temporary Standard for Exposure to VCM.
(2) 29 CFR 1910, Occupational Safety and Health Standards, Proposed Standard.
F-l
90S0Q
Records of medical examination are to be kept with provision for access by appro priate OSHA and NIOSII officials. Specific requirements are made to furnish a copy of a medical record to an employee's physician on the employee request. In the event of an "emergency", that is, an unforeseen circumstance or set of circumstances resulting in the release of VCM into areas occupied by employees, a special medical surveillance by a physician shall be instituted within 24 hours for employees present in the affected area at the time of the emergency .
(3) NIOSH Recommendations For Medical Surveillance Referred To By The Proposed Permanent Standard
The following recommendations are directed primarily at medical screening to detect
liver disease and/or hepatic tumor. They should be considered in the context of routine
health screening for any general employee health problem, including non-hepatic health ..
condition potentially related to VCM exposp^. Routine health screening should include at
the time of initial employment:
/ v'
the recording of past medical ki ^
the performance of
; (f)
- a general physical examination^ - certain basic laboratory procedures including:
complete blood count urinalysis chest x-ray
\^"Ai
Provisions should also be made for routine pi
health follow-up examinations.
NIOSH, Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974.
BFS 0085B
F-2 1
Employees covered by the following specific recommendations shall encompass all persons engaged in VCM production and polymerization including personnel peripherally involved such as in clerical and management assignments. The recommendations shall be applied both as a pre-employment requirement and as a part of periodic health follow-up. Screening priority should be given to current employees with prolonged and close potential exposure to VCM, \yhether in present or past work settings.
The recommended examination protocol is:
At the time of initial employment, or upon institution of screening, a physical examination sn^ll-be performed with specific attention to detecting enlargement of'livgy or spleen by abdominal palpation.
At the time of initial employ^JrJt, or upon institution of screening an
annually thereafter, a medic;iT ff!)gtory check-list shall be completed
by the employee. This list snail include questions concerning:
/ "V
/_ _ '
- alcohol intake
O'
past history of hepatitis
1
past exposure to potential ht
oxic agents including drugs and chemicals
past history of blood transfusi^A^X, past history of hospitalization
The completed medical check-list shall be reviewed by a physician and should be acted upon as medically indicated for each individual employee.
BFS
Cl
<3
01 Ol
F-3
<3
At the time of initial employment, or upon institution of screening, a serum specimen shall be obtained for screening with respect to the following five bio-chemical determinations of liver function:
- total bilirubin alkaline phosphatase
- serum glutamine oxalacetic transaminase (SGOTJ serum glutamine pyruvic transaminase (SGPT)
- garna glutamyl transpeptidase (GGTP)
Additional tests that optionally may be considered for use in screening
include
( v, '
lactic dehydrogenase (LDI^| ^
- serum protein determinatioi^g'; '
serum protein electrophoresis /X
platelet count
U
Laboratory analyses shall be performeddirtaboratories accredited by
the College of American Pathologists, licdns&d in accordance with the provision of the Clinical Laboratories ImiWovbment Act of 19G7.
tPIf results or laboratory screening are normaT, screening shall be repeated
on an annual basis. If the person being screened has been employed
directly in vinyl chloride monomer production or polymerization for 10
years or longer, screening shall be repeated every six (6) months.
If one or more liver function tests are abnormal, serum testing shall be repeated as soon as possible, preferably within two (2) to four (4) weeks. If no abnormalities are present upon rescreening, testing should be re peated in three (3) months.
BFS 00S509
F-4
If abnormalities persist on rescreening, the employee shall be removed from contact with VCM operations and an individualized workup shall be instituted. Suggested as initial steps in tnedical workup are
- a complete physical examination
various special procedures such as
hepatitis B antigen determination liver scanning
If liver function abnormgi^ms are determined to be unrelated to liver disease (e.g. elevated alkaline Db&SPhatase in a voune. Dhvsicallv active man or
BFS 00S51
iP
F-5
,1
.2 SNELL ASSESSMENT OF THE COST OF MEDICAL SURVEILLANCE UNDER THE PROPOSED
PERMANENT STANDARD l1)
This section details the cost of medical surveillance needed by the VCM and PVC industries to comply with the requirements of the Proposed Permanent Standard (PPS) . Costs are essentially based on the physical examinations and laboratory tests recommended to OSHA by NlOSH. (2)
Exhibit F~1 presents a screening flow sheet for the physical examination
J's
and laboratory tests which nrajAbe performed. It details the screening steps which are given by the^jpFS.
Exhibit F"2 presents the time re^tryred for an average worker to spend on obtaining the needed physicdjjjlxfamination and laboratory tests by a physician under contract to the^V(^f and PVC manufacture.
I Exhibit F-3 details the types of laboratory tests which may be required as well as their normal values. It is jfrom these tests that a portion of the total cost is based,
Exhibit F-4 summarizes the itemized cosS0ir the various elements of
the medical surveillance program from Snelb-estimates based on the
detailed study. The Snell estimate is
worker.
Exhibit F~5 shows the costs which were reported by the VCM and PVC industry for their medical surveillance program. Their costs average out to $143 per worker based on sixteen reporting firms.
(1) 29 CFR, 1910, Occupational Safety and Health Standards, Proposed Standard For Exposure to VCM
(2) NIOSH Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974
BFS 008511
F-6
OO
3. REVIEW WAS COMPLETED OF THE INFORMATION BY NORMAN B. JAVITT, M.D., PH.D. HEAD, DIVISION OF GASTROENTEROLOGY, DEPARTMENT OF MEDICINE. NEW YORK HOSPITAL-CORNELL MEDICAL CENTER According to Dr. Javitt in l^s?fsjtter to Snell, shown in Exhibit F-6, he reviewed the appendix and in his iudg{fieyi^, "the proposed protocol adequately reflects both the recommendations of th'e appropriate governmental agencies, and considering the constraints of nftfpp^nd expense, is carefully constructed to
I obtain a sensitive estimate of tho^rfstcnce of liver dysfunction as well as other ancillary data on health status." ^ jO(/\ Dr, JaviR in his letter also suggestsj&rgifications or clarifications to the NIOSH recommended protocol as is seen in tbe Exhibit. , \&\. ) ip t
F-7 J
Z T 8 0 0 S jJ S
V": ;
EXHIBIT F-l USDOL/OSIIA SCREENING FLOW SHEET BASED ON NIOSH RECOM MENDATIONS TO OSHA FOR THE PROPOSED PERMANENT STANDARD
.8cresning insta
JtoxrrmL
Test every 6 months employed over 10 years
.annually if employed vaftffylO years
CP
Normal results tepeat tests in 3 months
BFS 00851J
Abnormal liver function tests Repeat tests in 2-4 weeks
Return to VCM area if medically approved
Note: (l) Source:
Abnormal Results
1. Remove from VCM area 2. Medical workup
EXHIBIT F-3 provides listing of Screening tests
elated to liver disease Additional medical
Based on NIiOSH Recommended Occupational Health Standard
evaluation necessary
for the Manufacture of SyntheticPolymer from Vinyl Chloride, March 11, 1974
Q oo
EXHIBIT F-2 USDOL/OSHA TIME REQUIRED FOR TRAVEL, PHYSICAL EXAMINATION AND LABORATORY TESTS OUTSIDE OF PLANT
Worker Completes Medical History Checklist While
Waiting
30 minutes
Blood Samples Taken
5 minutes
Urine Sample Pr^jfi4pd
V 5 miiWfe's
ip
Chest X-ray Taken
10 minutes
EKG Taken 10 minutes
Total Time Required
ip-
Source: Snell estimates
// V Examination and laboratory jests
Travel to and from examination facility
Maximum time required
V'JJ
1.5 hours 2.5 hours 4 hours
--------------
Physical Examination
30 minutes
BFS 0QS514
I
BF5 008515
Laboratory Test
Blood Chemistry
Cholesterol ^
.Calcium^
.
Inorganic Phosphorus. M
Total Bilirubin d*2)
Total Protein Albumin Uric Acid (*)
bun(j)
Glucose (1)
LDII l1-2)
Alkaline Phosphatase t**2) SCOT l1.2)
Creatinine^2) GGTpf2)
SGPT^1'2) NPN t3J
Purpose
onoiesteroi metabolism
Calci^jfcnrTpetabolism
PhosptyoYys absorption
Liver function
Liver iurrdf^an
Kidney aiVdJdijrer function
Purine met^tioMsm
Kidney function,*
Carbohydrate jffetebolism
Organ damage o
Liver function Organ damage
i
Kidney function
Liver function
^
Organ (part, liver) damage
Kidney function
EXHIBIT F-3 (1) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS
Normal Values
150 to 300 mg/100 ml 9 to 11.5 mg/100 ml 2.5 to 4.5 mg/100 ml 0.2 to 1.0 nig/100 ml 6.0 to 8.0 gm/100 ml 3.5 to 5,0 gm/100 ml 2.5 to 7.5 mg/100 ml 10 to 20 mg/100 ml 65 to 100 mg/100 ml 67 to 122 technicon units 4 to 17 KA units 15 to 45 units 0.9 to 1.7 mg/100 ml 6-28 mg /ml 15 to 56 units 25 to 38 mg/100 ml
EXHIBIT F-3 (2) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS
Laboratory Test
Purpose-
Normal Values
Hematology
RBC(2) WBC (2J Hgb(2) Hct(2J I
Differential^
v>=; Standard screi^inrg for all diseases
"W
//A
4.6 to 6.2 x 106 4.8 to 10.8 x 103
15 to 18 gm 42 - 52%
Polys Stabs Eosinophils Basophils Lymphocytes Atypical Lymphocytes Monocytes Platelets MCV MCH MCHC
II
It It
It It II
II
II II II
II
60 - 70% 0-1% 1-3% 0.25 - 0.5% 25 - 33% 0-1% 2-6% 2 - 4 x 105 80 - 94 y 3
273 y y g 32 - 36%
$
BFS 00S51
EXHIBIT F-3 (3)
Laboratory Test Urinalysis 121
Purposo
Normal Values
J
Color Appearance
Standard screening for all diseases II
Palo straw to amber Clear to slight hazy
Specific Gravity
II
1.905 to 1.002
pH *
If
5.5 - 7
Albumin
ff Negative
Glucose
II Negative
Acetone
II Negative
4 Bile
s'*A* \ "
Negative
Urobilinogen
^- II // ^ - 1
Up to 2.1 Ehrlich units
Notes:
(1) Included in autoikate^d SMA12 analysis
-Jj
7,(2) ` recommended for determination within first screening or initial examination by NIOSH to ' OSHA specifically forHlver function.
(3) included to obtain a totaTTaboratory profile of the worker -A
(4) Recommend as a special teXtJy, NIOSH to OSHA.
Sources:
Ivan K. Smith, Diagnostic Services, Irrp^, 520 Speedwell Ave., Morris Plains, NJ 07950; NIOSH, Recommended Occupational Health Standard for the Manufacture of Synthetic Polymer From Vinyl Chloride, March 11, 1974; Snell assessment of the NIOSH recommendations to OSHA
BFS 00851
N
EXHIBIT F-4 (1)
% USDOL/OSHA APPROXIMATE COSTS OF PHYSICAL EXAMINATIONS AND LABORATORY TESTS COMPLETED OUTSIDE PLANT BASED ON A MANUFACTURING FACILITY WITH 500 COVERED WORKERS
Element
Full-time clerical penson fax typing, filing, coordinating visits to labs and physicians,
etc. ($9,000 x 1.254n fringe)
.
Records, statidkaty, postage, etcy^H
Overhead t1)
f
500 examinations by physician (general, practioner) @ $20 per examination
500 reviews of physical and laboratory ^examination results by physician $15/review 500 chest x-rays @ $20 per worker ^
500 laboratory test series $24 per ser^ejs^)
500 EKU's $25 per worker
125 repeat laboratory test Series (25% of workers) $24 per series (2)
125 repeat medical reviews by physicians $1^ per review 25 special laboratory tests 5% of the workerfe^K$25 per worker ^
25 reviews by physician at special laboratorjMf.fs $15 per worker V
Total expenditures per annum for 500 cov^rfed workers
Approximate cost of medical screening per worker
Cost (Dollars)
$ 11,225 7,500 5.000
10,000 7,500
10,000 12,000 12,500
3.000 1,875
625 375
$ 81,500
160
BFS 008518
1
I
EXHIBIT F-4 (2) USDOL/OSHA
Notes: Sources:
Cl) overhead includes electricity, telephone, heating, space allocations for clerical activities, etc.
(2) ' initial laboratory^reening tests include SMA12, SGPT, GGTP, GBC with platelets and
urinalysis
'< ; '
\ J
(3) special laboratory testify include: serum hepatitis B determination, serum protein
electrophoresis
(* >
Ivan K. Smith, Diagnostic Science^ jfoe.. Morris Plains, NJ 07950; Snell assessment
H\.syj,-
\ *
BFS 0BS5l
J
1
03
$ CD 00 U|
Number 6f Worker's.
97 173 (NA)
57 222 1,137
50 325 128 420 (NA)
81 150 3,204
68 74 135
EXHIBIT F-5 (1) USDOL/OSHA RESULTS OF SNELL INTERVIEWS TO DETERMINE THE COSTS OF MEDICAL SURVEILLANCE COST PER WORKER PER YEAR
TotajApost (Dt^iars)
Cost per Worker per Year (Dollars)
1G 34,0l(0jJ>
(NA)^' (*
1G5 200 (NA)
3,000 (NA) (NA)
'A '2l --\ o
52 (NA) 200
(NA)
(NA)
(NA) 12,000
- 150 - 200
(j> ;
94
12,900
40
(NA)
(NA)
10,000
* 125
22,000
14G
224,280
70
(NA) (NA) (NA)
200 200 (NA)
J c. -------- *
EXHIBIT F-5 (2) USDOL/OSHA
,oci
Notes: Sources:
(1) Cost for examinations assumes tests are based on NIOSH recommendations. Snell review and assessment of interviews with VCM and PVC manufacturers. NA - not available
EXHIBIT F - 6(1)
USDOL/CSIJA
LETTER OF DR. NORMAN B. JAVITT TO SNELL REVIEWING THE DATA IN APPENDIX F
* SJS EAST OIH STREET, NEW YORK. N Y, 10021
Tllli: 1\I5W >JtK nosm'AL-COHNELL MEDICAL CliNTEll ;V
DEPARTMENT OF MEDICINE
division of gastroenterology
U, 'fa
t
August 16, 1974
TO:
John W. Keating, Ph.D. V^Y
Director, Biological Sciences * (T^ 03 Foster D. Snell, Inc. to to FROM: Norman B. Javitt, M.D., Ph. D.
Professor of Medicine and
Head, Division of Gastroenterology
New York Hospital-Cornel! Medical Center
to SUBJECT: Review of Appendix F (first draft) Technical Feasibility
to and Economic Impact Study to
to i-o N) I
EXHIBIT F - 6(2) USDOL/OSIIA
I have reviewed the above appendix with special emphasis on Exhibits F-2through F-5 and have the following comments:
1. In my judgement the proposed protocol adequately reflects both the recommendations of the appropriate governmental agencies, and considering the constraints of time and expense, is carefully con structed to obtain a sensitive estimate of the existence of liver dysfunction as well as other ancillary data on health status.
2. I would suggest consideration of the following modifications: A. Routine test^'^S,
1) Hepatitis B iantfigenernia (by RIA). A positive test should be an automatic exclustoW^rom working with vinyl chloride because of the possibility of<|^^erson being a high risk for developing toxicity.
Final judgement wo(jrl^Require complete medical evaluation. Expense for this test Is probably ^ninimal since now, by state law, every unit of blood obtained ppt the purpose of transfusion must be tested for the presence of Hepatitis B antigen.
B. Special tests in the ev@pi^of abnormal screening tests:
In the event of persistei^&^normal test of liver function, the
following further studies sh
be done:
*1. Alp ha i Fetoprotein (correlates with hepatoma)
*2. Alpha j Anti-trypsin deficiency (at special risk to develop chronic lung and/or liver disease).
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EXHIBIT F - 6(3)
USDOL/OSHA
*3. 2-hour post-prandial serum bile acid. (The most specific sensitive test for;4iepatoblliary disease - not as yet activated-cost j^r\est on contract basis, $20 test). o
cf 1
* Probably can be cost-^e^ounted through Bio-Science Laboratories and other ^il^Ilar laboratories. /Is
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*
APPENlfeCb
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SAFETY AWARENESS^RORBAMfi
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APPENDIX G SAFETY AWARENESS PROGRAMS An important element of the Proposed Permanent Standard For Worker Exposure To Vinyl Chloride is the requirement for a safety awareness program for employees of vinyl chloride monomer (VCM) and poly vinyl chloride (PVC) plants M . The purpose of the prograrri is to indoctrinate and educate them as to the problems associated with working with VCM. The appendix contains two exhibits which follow the text: . Exhibit G-l presents a general discussion of a sample safety awareness program. . Exhibit G-2 provides a cost estimate for the sample program for a VCM or PVC plant with 110 employees.
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(1) 29CFR 1910 Occupational Safety and Health Standards, Proposal Standard.
G-I (h
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EXHIBIT G-l (1) USDOL/OSHA SAMPLE SAFETY .AWARENESS *
PROGRAM
Upon the Institution of any new program, process or Installation, people must 'oe trained for new skills or taught to adapt and accept new conditions. To adapt and
A accept new conditionals;' not a difficult transition if the individual is motlvatedCapd encouraged.
cZ* >ri ^.A!> Of the prime mo-tiji^ators to man, none is more para mount than survival itself.' An effective in-plant training
/\
// ^ program concerning the critical nature of vinyl chloride should capitalize on the primdA^ptlvator.
Using multi-media pre'^entatlons geared . to the subject, an employee is able to vrianess and internalize the importance and significance of proper safety procedures and the use of the safety equipment provided for his or her own benefit*
A shock effect presentation instills initial fear and doubt. The images remain vivid and the fear and doubt
t
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diminish in due coursd. As a learning process, none leaves
as lasting a memory of the subject matter as a "shock
presentation". With "shock" being the prime motivator, a
three phase multi-media presentation will effectively begin
training and lay the foundation for continuous training and
re-enforcement.
^
Presentation
is the preconditioning that
teaches the individual da'tjjt./that can be recalled as a
rational thought when a
4 presentation" is used. It is
a subliminal presentation unrelated to the daily routine of
// ', the vrorker. It takes the worker from his job into the Jobs
of others who have adapted and incepted external,conditions
.that are critical with ease and f&l^ility. The viewer does not relate to the total presentatl^J^ yet many common
factors become apparent. The need -of the space suit, the helmet for the Appollo astronauts, the life support system on a submarine, proper ventilation of exhausts at a toll booth, a mask on a pilot, a pressurized cabin all show com mon need for life support and present the fact on visions of ldolic professions.
EXHIBIT G-l (2) USDOL/OSHA
The first presentation impresses upon the viewer
that the need for life support is present in many areas and
that these are important supports for important positions.
Presentation Two displays the shock and actual conditions that arrive from exposure to the substance. The
critical nature and danger are vividly displayed.
PresentationvTh'rec is a custom presentation
featuring the safety mea^res instituted by a given facility for the protection of th/^^loyees.
EXHIBIT G-l (3) USDOL/OSHA
Each presentation' p^ays an Integral part in the
total educational presentation. Independent of one 'another,
each can be used for re-enforcement on a yearly.basis. The
.
training program can be viewed'^sp-^large and small groups.
By installing a thexe
ane for the safety program
displayed In Presentation Three, an award program that seeks
to re-enforce and recognize performance can be phased in
upon completion of the initial training. Motivation is
achieved through recognition.
A program of awards that-can be presented to the
EXHIBIT G-l (4) USDOL/OSHA
achiever in full view of all and continuously displayed In
the plant not only recognizes but motivates future performance I
las well. Those who have achieved strive to continue, those
who have not are motivated to become an achiever. Peer group
pressures serve as a motivator when a department seeks an
award. Individual needs for social acceptance and self-
esteem motivates a man.
Giving pra^eHand recognition to an
employee
task well done seems
so fund amen t^Xx;that it appears a
bit pretenslows.to label the act a management te'fij&vlque. But at a tinn
when business jis^attllng a cost
squeeze, high raises of employee
absenteeism and turnover, and low productivity, sometimes the first
step towards finding a solution is
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long term goal can be establis)^^) and achieved through
A
training and a basic recognition program.
With the program, constant attention must be paid
l"Where Skinner's Theories Work", Business Week (December 2, 1972).
I
to features in in-house organs, bulletin boards, posters
EXHIBIT G-l (5) USDOL/OSHA
and all media established by a company for communication
with its employees.
4
All areas of communication should be examined as
a Texas chemical company did when it decided to send a
"season's greetings" card to the employees stating "Merry
Christmas and Happy New Year, here's wishing you another safe year.
Programs must be sequenced and developed prior to
I implimentation from trainlij^to practice. Listed are the // 1 1
items to consider as a modei^cdntalning.the ingredients
for a viable safety program, fj);
* Initial high-impact training seminar for all
employees
,
* Award for completion of seminar uniform patch
with project name
X'C*
* Poster program with con&-muous safety reminders * Supervisor's guide to motivation and continuing
re-enforcement
* Section or line awards for annual performance based upon down time, etc.
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< EXHIBIT G-l (fi) I USDOL/OSHA
Continuation of annual award of patch with color sequence
In-house organ promotion of safety awards and people at work
Annual scrolls for achievers
Monthly red and green safety plaques for foreman's area
Annual recognition gift,
1
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The above discussion presented an q^ialysis of the rationale behind safety awareness programs and a sample of such a program. For an in-dep{fi ^discussion of the concept of management awareness of OSHA rules, knowledge of testing, and evaluations procedures see source (2) below.
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Source:
\JU
HI(1) Joel D. Schaffer, Human Motivation Resources 1
P.O.Box 225
y fA
Morris Plains. New Jersey 07950 and Snell analysis.
(2J Stephen F. Nagy and Herbert Terry, Management Awareness of OSHA. presented at: OSHA and the Plastics Industry, National Conference, New York, April, 1973.
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Individual. First Year
Training Award s Klsc.
Total
$25
5 11
331
EXHIBIT G-2
USDOL/OSHA * COST ESTIMATE FOR A SAMPLE SAFETY AWARE NESS PROGRAM AS OUTLINED UNDER THE PROPOSED PERMANENT STANDARD FOR WORKER EXPOSURE TO
,, VINYL CHLORIDE Supervisors and Foremen
kj c-
Training Awards Mlsc.
To tal
.il0 15 10
m
First Year Star&-J&j!> Costs:
100 Employees, 10 Supervisors
Employees
//.--\ >>$3,100
Supervisors Klsc,
^5.L' 0
Total .
Cost Per Employee
40
Annual Budget Second Year--Contlnulng
Awards Rise.
.$500 200
Total
3300
Cost Per Employee
$ 7.50
Source: Joel D. Schaffer, Human Motivation Resources, Inc. P.O. Box 225, Mo-ris Plains. New Jersey 07950 and Snell analysis.
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Al^gDIX H NIOSH.RECOMMENPED OCCUPATIONAL HRALThJ^aRD FOR THE MANUFACTURE OF SYNTHETIC
POLYMER FROM VINYL nm.nmriE TM , ,//V/
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APPENDIX H
NIQSH RECOMMENDED OCCUPATIONAL HEALTH STANDARD FOR THE MANUFACTURE OF SYNTHETIC POLYMER FROM VINYL CHLORIDE '
1. SCOPE AND APPLICATION
This'standard regulates the manufacture of
synthetic polymer from vinyl chloride (chlo-
roethene, Chemical Abstracts Registry No.
75014), in order to protect the health and
safety of workers.
v>\
Vinyl chloride also know as vinyl chfe'^de
monomer (VCM), chloroelhylenc and chl^re^
cthene, is a colorless sweet smelling gas ^
ordinary temperature and pressure and has a^ ft
boiling and melting point at one atmosphere'^ la' i of--13.8:C. and--153.71 C, respectively. Us \t
Chemical formula is CH.CHCl'and it has a
molecular weight of 62.50. Although non-
// _\
corrosive at normal atmospheric temperatures,
in contact with water and at elevated temper
atures it accelerates the corrosion of iron and
steel. Of considerable concern is the fact that
vinyl chloride is easily ignited and has a lower
and upper explosive limit of 3.6% and 26.4%,
respective!/.
2. DEFINITIONS
For the purpose of this standard; a. "Assistant Secretary" moans the Assistant Secretary for Occupational Safety and Health, U. S. Department of Labor or any person di rected by him. b. "Director" means the Director, National Institute for Occupational Safety and Health, or ar./ person directed by him or the Secretary of Health, Education, and Welfare to act for the Director.
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c. "Authorized employee" means an employee whose duties require him to be in the regu lated area and who has been specifically as signed by the employer. d. "Detectable levels" means the determina tion that airborne concentrations of vinyl chlo ride are in excess of the limit of sensitivity of the sampling and analytical method recom mended by the Director. e. "Clean change room" means a room where employees put on clean clothing; clean change room shall be contiguous to and have an entry
from a shower room, when the shower room fa cilities are otherwisb required in this standard. f. "Closed container" is any container which is used to prevent the physical contact of cmployces with material containing vinyl chloride sXmonomer.
"Closed system" means an operation inlfJ)rolving vinyl chloride where containment pre
vents the release of vinyl chloride into regu lated areas, nonregulated areas, or the external environment.
h. "Contaminated" refers to detectable levels of vinyl chloride monomer. i. "Decontamination" means the inactivation of vinyl chloride to less than detectable levels or its safe disposal. j. "Disposal" means the safe removal of vinyl chloride from the work environment. k. "Emergency" means an unforeseen circum stance or set of circumstances, such as a rup, tured tiansfer line, resulting in the release of
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vinyl chloride sufficient to produce acute
symptoms among workers, exposed or having
contact with the vinyl chloride.
l. "External environment" means any environ
ment external to regulated and nonregulated*
areas.
m. "Regulated area" means an area where
entry to and exit from a vinyl chloride work
place is restricted and controlled.
n. "Nonregulated area" means any area under
the control of. the employer where entry and
exit is neither restricted nor controlled.
0. "Protective clothing" means clothing de
signed to protect an employee against contact
with or exposure to vinyl chloride.
p. "Waste resin" means any resin or other^//I,J
vinyl chloride reaction product which has been i f s
removed from vessels during clcan-up operations, or which has been collected os a result, of in-plant housekeeping operations.
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3. REQUIREMENTS FOR REGULATED AREAS
A regulated area shall be established where Synthetic resins containing vinyl chloride are manufactured. These regulated areas shall in clude but are not limited to vinyl chloride loading or unloading operations, storage, and transfer facilities; synthetic resin polymeriza tion processes 3rd r'-'.'i.tns; and resin han dling. ccmpou'; .. . ......waging and storage areas. Acc-.is shall be restricted to authorized employees only. All such regulated areas shall be controlled in accordance with the following requirements.
a. Routine Operations
(i) Initial concentration of vinyl chloride in all regulated areas shall be determined by per forming air measurements at strategic sam pling points under normal operating conditions. These initial sampling points must be selected by a professional industrial hygienist apd will serve as monitoring locations for future en vironmental measurements. The sampling pat tern shall be adequate to represent the en, vironment of the controlled area.
; (ii) Where detectable levels of vinyl chlo ride are measured, a Control Plan to reduce such levels shall be developed and imple mented. The Plan shall consist not only of establishing goals for reducing vinyl chloride levels by designing and introducing engineer ing and process controls, but shall als^, identify plans for developing additional (healthful) `work
i practices. Target dates shall be established for all goals and the Plan must be updated at least
^on an annual basis. Copies of the Control Plan // stiall be posted in all regulated areas and be ^provided to all authorized employees.
There shall be periodic tests for prccdissijoAequipment leaks and for emission of vimiff'fcVloride which may result from work
practioecT^The frequency of these tests shall be sucb-s to insure the integrity of equipment, adherence to proper work practices, and to de termine achievement of the goals of the Con trol Plan. Tests shall be performed at each sampling point at least daily or more frequently if concentrations of vinyl chloride are in excess of those established in the Plan. Wlu-n such levels are exceeded, additional samples to identify sources of contamination shall be taken. Results of all such tests shall be made
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available to authorized employees in such a manner as to evaluate achievement of goals contained in the Control Plan.
(iv) Until exposures to vinyl chloride are
reduced below detectable levels, employees
entering any regulated area shall be provided
with and required to wear and use a full-face,
supplied air respirator, of the continuous flow
or pressure demand type in accordance with 1910.134.
(v) In operations involving loading or un
loading vinyl chloride monomer from tank cars,
trucks, barges, or other conveyance equipment,
each transfer line and runch vapor-equalizing line shall be equippc^f'wfyh vent connections
permitting, at the completion of the transfer,
pressure to be vented ^nd the hose purged
with an inert gas in such dr-rpznncr to preclude
any employee exposure. Specific and detailed transfer procedures shall b^ ^^veloped and
provided to involved employees Tn written form.
(vi) Employees shall be proviso with and required to wear, clean, full-bo^y"protective
clothing (smocks, coveralls, or long-sleeved shirt and pants), and gloves prior tP--' entering
the regulated area.
>\
(vii) Prior to each exit from a rdgtflMed
area, employees shall be required to rtfhipye and leave protective clothing and equipment
at the point of exit and at the last exit of the da/, to-place used clothing and equipment in
impervious containers at the point of exit for
purposes of decontamination or disposal. The
contents of such impervious containers shall be identified as required under paragraph
e(2)(i) of this standard.
b. Reactor and Vessel Entry
(i) A reactor and vessel entry procedure shall be developed and provided to involved employees in written form. Employees shall be familiarized with the procedure and shall be trained and rehearsed in the techniques pro vided for in the procedure. Emphasis shall not only be placed on concern for potential expos ure to vinyl chloride but shall also include . appropriate precautions for entry into confined spaces.
(ii) Techniques shali be developed and ap plied to minimize to the maximal practicable : extent employee exposure to vinyl chloride when opening any closed vessel. Examples of effective methods are the application of heat or suction to the vessel prior to opening, or use of sufficient exhaust ventilation around the
vessel. Where operations such as cleaning or maintenance conducted inside an open vessel could result in the liberation of vinyl chloride, suitable procedures such as exhaust ventila tion shall be developed and implemented to -insure that vinyl chloride is not released into the general work environment.
(iii) Exhaust air shall not be discharged to regulated areas, nonregulated areas, or the ex ternal environment unless decontaminated.
(iv) All piping to and from the vessel shall be blanked or otherwise isolated prior to entry.
(v) Employees entering the reactor or vessel shall be provided with and required to wear and use a full-face, suppll-.d air respira tor, of the continuous flow cr pressure demand type in accordance with 1910.134.
H-3
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(vi) Employees entering the reactor or vessel where levels of vinyl chloride- are mon itored and arc found to not exceed ambient levels external to the vessel shall be provided with and required to wear clean, full body pro tective clothing (coveralls or long-sleeved shirt and pants), gloves, footwear or foot coverings, and head covering. Where vessel levels are in excess of ambient levels, employees shall in stead be provided with and required to wear impervious clothing to prevent skin contact of vinyl chloride or other materials containing vinyl chloride.
(vii) After each exit from the reactor or vessel, employees shajfebe required to remove , and leave protectiv^etptfang and equipment at
a designated point in t.hc^regulated area, and at the end of each wbrk^hift to place used clothing and equipment impervious but vented containers for TlW'pWpose of decon tamination or disposal, TBeijcflntents of such impervious containers shall be identified as re quired under paragraph e(2)(i) bf mis standard.
(viii) Employees engaged iri reactor clean ing or other operations involving v.i^sel entry shall shower at the end of the v^rfkjh ift.
c.Maintenance and Dccontaminatffffilftxhivitics
(i) Emphasis shall be placed upS^riJDhme
diate clean up of spills, periodic inspection, prompt repair of equipment and leaks, and proper handling, storage 3nd disposal or de contamination of materials to prevent airborne contamination and accidental skin contact with vinyl chloride. Because vinyl chloride is a gas
H
at normal temperatures, waste materials, equipment, and other sources of the monomer in closed containers, shall not be placed in areas of excessive temperature or sunlight since build-up of internal pressure may result in rupture of the container, fire or explosion,
(ii) Waste resins or other materials con taminated with vinyl chloride shall be placed in closed containers identified as required under paragraphs e(2)(i) or (ii) of this standard.
(iii) Appropriate procedures shall be de veloped and implemented for the decontam ination and/or disposal of all such waste material.
(iv) In clean-up of leaks or spills, mainte nance or repair operations on contaminated systems or equipment, or any operation in volving work where direct contact with vinyl chloride monomer could result, each autho rized empolyee involved in such operations shall be provided with and required to wear clean, impervious garments, including gloves, boots and continuous' air supplied hoods in accordance with 51910.134, be decontam inated before removing the protective garments and hood; and be required to shower uppn re moving the protective garments and hood.
d. General Regulated Area Requirements
1. Employee identification. A daily roster of employees entering regu lated areas shall be established and main tained. The rosters or a summary of the roster shall be retained for a minimum period of 20 years by the employer or successors thereto. The rosters and/or summaries shall be pro-
I
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vided upon request to authorized represent
atives cf the Assistant Secretary and the Director. In the event that the employer ceases
business without a successor, rosters shall be forwarded by registered mail to the Director. .
2, Emergencies.
In an emergency, immediate measures in cluding but not limited to the requirements of Subdivisions (i). (ii). (iii), (iv), and (v) of this subparagraph shall be implemented.
(0 The potentially affected area shall be evacuated as soon as the existence of the emergency has been determined.
(ii) Hazardous conditions created by the emergency shall be eliminated and the poten tially affected area shall be decontaminated
prior to the resumption of norrfe^^erations.
(iii) Special medical surveillj&qpe'by a phy sician shall be instituted within f4-^ours for
employees present in the potentiaTfyddffected area at the time of the emergency. yUrcpprt of the medical surveillance and any ^rej|went
shall be included in the incident report, in ac cordance- -with paragraph (g)(3) of this sta,rJ_^___rdX.
(tv) Where an employee has a known con tact with liquid vinyl chloride such empioyeq\ shall be required to shower as soon as possiwO unless contraindicated by physical injuries.
(v) An incident report on the emcrgenc'jr^^
shall be reported as provided in paragraph / (t)*
(g)(3) of this standard.
^
3. W/g'ene facilities and practices.
(i) Storage or consumption of food, storage or use cf containers of beverages, storage or application of cosmetics, smoking, Storage of
H
smoking materials, tobacco products or other products for chewing, or the chewing of such products, are prohibited in regulated areas.
<ii) Where employees wear protective clothing and equipment clean change rooms shall be provided, in accordance with 51910.141(e)(3).
(iii) Where employees are required by this standard to wash, washing facilities shall be provided in accordance with 51910.141(d)(1) and (2)(ii) through (vii).
(iv) Where employees are required by this standard to shower, shower facilities shall be provided in accordance with 51910.141(d)(3).
4. Contamination control. (i) Regulated areas, except for outdoor sys tems, shall bo maintained under native pres sure with respect to nonregulatod areas. Local exhaust ventilation may be used to satisfy this requirement. Clean tempered makeup,air shall replace air removed. Exhaust air shall not be discharged to regulated areas, nonregulatod areas, or the external .environment unless de contaminated.
(ii) Any equipment, material, or other item taken into or removed from a regulated area shall be done so in a manner that dees not cause contaminaticn in nonregulatod areas or the external environment,
(iii) Decontamination procedures shall be established and implemented to remove vinyl chloride from the surfaces of materials, equip ment and the decontamination facility."
e. Signs, Information, and Training
1. S/gns.
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(i) Entrances to regulated areas shall be posted with signs bearing the legend:
CANCER-SUSPECT AGENT AREA AUTHORIZED PERSONNEL ONLY
(ii) Entrances to regulated areas contain ing operations covered in paragraph 3(c) of this standard shall be posted with signs bear ing the legend:
CANCER-SUSPECT AGENT IN THIS AREA. IMPERVIOUS SUIT INCLUDING GLOVES, BOOTS, AND AIR-SUPPLIED HOOD REQUIRED' AT ALL TIMES." AUTHORIZED PERSONNEL ONLY.
2. Container contdhts identification. (i) Containers df/vaste or other materials contaminated with vinyT\ chloride shall be labelled as follows: ! . J
/ p.
VINYL CHLORIDE CONftyMINTED MATERIAL-- "
CANCER SUSPECT Ap&viT DISPOSE OF OR DECONTAM&AtE USING
APPROVED PROCEDURES k
(ii) Containers of synthetic
made
from vinyl chloride shall be labelledTjag^f&^lows:
SYNTHETIC VINYL CHLORIDE POIJitfBR VINYL CHLORIDE IS A CANCER SUSPECT
AGENT POLYMER CONTAINS __*% BY WEIGHT
UNREACTED VINYL CHLORIDE *(To be analytically determined by manufac turer and appropriate value entered on labels.)
(iii) Containers of vinyl chloride shall be labelled as follows:
VINYL CHLORIDE
DANGER! EXTREMELY FLAMMABLE LIQUID AND GAS UNDER PRESSURE
CANCER SUSPECT AGENT
HARMFUL IF INHALED
MAY POLYMERIZE VIOLENTLY UNDER FIRE CONDITIONS OR LOSS OR REMOVAL OF INHIBITOR
Keep away from heat, sparks, and open flame. Keep container closed. Use with adequate ventilation. Avoid breathing vapor. Avoid contact with skin. Keep cylinder out of sun and away from heat. Container should be grounded when being
emptied. Never drop cylinder. ' FIRST AID: If inhaled, remove to fresh air. If not breathing give artificial respiration, pref erably mouth-to-mouth. If breathing is difficult, give oxygen. Call a physician. In case cf;
Fire -- Use water spray, dry chemical, or CO,..
Spill or Leak -- For small spills, evacuate area and permit to evaporate. For large spills or leaks, evacuate area.- Dike or flush to ground and lot evaporate. Do not flush to sewer because of explosion
t
hazard. 3. Training and indoctrination.
f. Environmental Monitoring and Record keeping
(i) Each employee, prior to being autho
(i) Environmental concentrations of vinyl
rized to enter 3 regulated area, shall receive a
of'methods for sampling and analysis recom
training and indoctrination program including,
mended by the Director or by methods of at
but not necessarily limited to:
least equal sensitivity.
(a) The nature of the carcinogenic haz
(ii) Employees or their representatives shall
ards of vinyl chloride monomer, including local
be provided with the opportunity to observe
and systemic toxicity;
chloride shall be determined through the use
(b) The specific nature of the operation
environmental monitoring activities and shall
1
involving vinyl chloride monomer which could
have access to the results.
result in exposure;
(iii) Complete and accurate records of all
(c) The purpose for and application of
environmental measurements shall be main
the medical survieilance program;
tained for at least 20 years by the employer or
(d) The purpose for and application of
successors thereto and shall be provided upon
decontamination practices and purposes;
request to authorized representatives of the
(e) The purpose for and significance of
Assistant Secretary or the Directo..
I emergency practices anjjL'Aocedures;
(f) The employlsWspecific role? under
g. Reports
normal operating or emergtstcy conditions;
1. Operations.
(g) Specific infor,\ia.t^sn to aid the em
Within 60 days the following information
ployee in recognition and avaTh^tion of condi
shall be reported in writing to the appropriate
tions and situations whichNwaV result in the
Occupational Safety.and Health Administration
release of vinyl chloride moljfofjhch-;
(OSHA) Area Director. Any change in such in
(h) The purpose for and application of
specific first aid procedures end^factices; (i) A review of this standard at the
formation shall be similarly reported within 15 calendar days of such change.
(i) A brief description and in-plant location
employee's first training and indoctrination
of t'nc area(s) regulated and the address of
program and annually thereafter.
each regulated area.
(ii) Specific emergency prococJ^WVshall
(ii) The number of employees in each reg
be prescribed, and posted, and cmplo^ce^%hall
ulated area, during normal operations, includ
be familiarized with thc-ir terms, and rel^^sfed
ing maintenance activity.
in their application.
(iii) A copy of the Control Plan is developed
i
(iii) All materials relating to the program shall be provided upon request to authorized
under paragraph 3(a)(ii). 2. ,Environmental Measurements.
represented.'i_s of the Assistant Secretaiy and
On a semi-annual basis the results Of mea
,the Director.
',
surements taken at strategic sampling points,
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presented in such a manner as to identify achievement of cools established in the Con trol Plan, shall be reported in writing to the appropriate OSHA Area Director.
3. Incidents. Incidents which result in the release of vinyl chloride monomer into any area where employees may be potentially exposed shall be reported in accordance with this subparagraph.
'0 A report of the occurrence of the in cident and the facts obtainable at that time including a report on any medical treatment of aborted employees shall be made within 24 hours to the appropriate OSHA Area Director.
(ii) A written report shall be filed with the appropriate OSHA Area Director within 15 cal endar days thereafter and shall include:
(a) A specification of the amount of material released, the amount of time involved, and an explanation of the procedure used in determining this figure:
(b) 'A{fl|scription of the area involved, and the extonV~p| known and possible employee exposure and Sre^ contamination;
(c) A revert of any medical treatment . of affected empires, and any medical sur veillance program implemented: and
(d) An analysts of the circumstances of the incident, and mp^suros taken cr to be taken, with specific d^rnpletion dates, to avoid further similar releases.
h. Medical Surveillance,^}
The following reco^nLB\endations are di rected primarily at mediCgi-Screening to detect liver disease and/or hepaycnftxmor. They should te considered in the context of routine health
H-8
screening for any general employee health problems, including non-hepatic health con ditions potentially related to vinyl chloride monomer exposure. Routine health screening should include at time of initial employment the recording of past medical history and the performance both of a general physical exam ination and certain basic laboratory procedures (e.g., complete blood count, urinalysis, chest fc~ray); provisions should also be made for rou* tine periodic health followup examinations.
Employees covered by the following spe cific recommendations shall encompass all persons engaged in vinyl chloride monomer production and polymerization, including per sonnel peripherally involved such as in clerical and management assignments. The recom mendations shall be applied both os a pre employment requirement and as port of peri odic health followup. Screening priority should be given to current employees with prolonged and close potential exposure to vinyl chloride monomer, whether in present or past work settings.
(i) At time of initial employment, or upon
institution of screening, a physical examination shall be performed with specific attention todetecting enlargement of liver or spleen by abdominal palpation.
(ii) At time of imtiai employment, or upon institution of screening and annually'thereafter, a medical history check-list shall be com pleted by the employee. This list shall include questions concerning.-
(a) alcohol intake; , (b) past history of hepatitis;
(c) past exposure to potential hepa-
I
BF5
1
CD CD CD Ol
tctoxic agents, including drugs and chemicals; (d) past history of blood transfusions;
and (e) past history of hospitalizations.
Completed medical chcck-list shall be rei viewed by a physician and should be acted upon as medically indicated for each individual employee.
(iii) At time of initial employment, or upon institution of screening, a serum specimen shall be obtained for screening with respect to the following five bio-chemical determinations of liver function: *
(a) total bilirubin; (b) alkaline phosphatase; (c) serum glutamic oxalacetic trans aminase (SGOT); (d) scrum glutamic pyruvic transam inase (SGPT); and (e) gama glutamyl transpeptidase (GGTP). Additional tests that muty optionally be con sidered fer use in screenin^include lactic de hydrogenase (LDH), serum} protein determin ations. serum protein eleekophoresis, and platelet count. Laboratory 'analysis shall be performed in laboratories accredited by the College cf American Pathologist^ or licensed in accordance with the provisions of the Clin ical Laboratories Improvement Act-^f 1967.
(iv) ** results or laboratoryC^jrtening are normal, screening shall be rcp^J^d on an annual basis. If the person bcinff'stroencd . has boon employed directly in virt^ljobloride i monomer pro !.;c6on cr polymerization for \0 ly.-ars or longer, screening-shall be repeated ever/ six f6) montr.s.
(v) If one or more liver function tests are abnormal, serum testing shall be repeated as soon as possible, preferably within two (2) to
four (4) weeks. If no abnormalities are present upon rescrecning, testing should oe repeated in niree 13) months.
(vu if abnormalities persist on rescrcening, the employee shall be removed from con tact with vinyl chloride monomer operations and an individualized medical workup shall be instituted. Suggested as initial steps in med ical workup are a complete physical examina; tion and various special procedures such as hepatitis B antigen determination and livr Scanning.
If liver function abnormalities are deter mined to be unrelated to liver c.sease (e.g., jelevated alkaline phosphates in a young, phys ically active man or elevated bilirubin in 'Gilbert's syndrome) or to be transient (e.g., due to recent hepatitis or recent alcohol intake), the employee may be permitted.to return to vinyl chloride-related employment, subject to individual medical evaluation.
(vii) In view of the preliminary results of animal toxicology studies, it is recommended that no woman who is pregnant or who expects to become pregnant should be employed di rectly in vinyl chloride monomer operations.
RECOMMENDED osha sampling data sheet
1. Substance: Vinyl Chloride Gas
2. Scope of Method: Vinyl chloride is 2 gas boiling at -13.4 degree C and having a vapor pressure of 2660 mm of mercury at 2o degree C. The lower limit of detection tor the method is approximately 1 ppm.
3. Sampling Equipment: a) Personal sampling pump b) 250 cc glass gas collecting tubes with teflon stopcocks
f. Sample Size: 250 CC
5. Sampling Procedure: Class Cjs Collecting Tubes a) Ir.e /'.y^gSectin;: tube is connected at one end to true 'debaoal sampling pump. Doth stopcocks are cpt//eV ar.d air pulled through at approximaK-l/ijpe^ter per minute. b) A sampling period of 15 minutes would allow collucticn**^.a representative sampling of the
worker en^-dnfaent.
c) Stcpeocks^snal.l be closed tightly, closing the stopcock nqfirfifrtne pump first.
6. Analysis: The gas collecting tu'be sample is analyzed directly by gas chromeiogr^fiy.
7. Shipping Instructions": The gas collecting tube should be wrapped with
V
Source: NIOSH Recommended Occupational ^Health Standard For The Manufacture Of Synthetic Polymer from VCM, March 11 . 1974.
H-10
BFS QQ8544
Cl
JTi
BFS 00S545
Markets
Packaging Men.' molded bottles Closure liners and gaskets Coatings Film Sheet
Recreation Records Sporting goods Toys.
Transportation Auto mats Auto tops Upholster/ and seat covers
Miscellaneous Agriculture Credit cards Laminates Medical tubing
EXHIBIT III - 1-1(2)
USDOL/OSHA
POLYVINYL CHLORIDE MAJOR MARKETS 1970 - 1973 (million pounds)
1070.
1371
1072
1973
70.0 12.0 15.0 115.0 co.o
50.C 15.4 15.4 110.0 75.0
70.4 17.G 17. C ICC.4 83.0
19.8 10.8 120.8 77.0
0-0 k X?
<J>30.0
150.0
132.0 39.G 50.4
37.4 33.0 ICO. 4
149,6 50.6 74, S.
39.6 35.2 180.4
145.2 55.0 83.6
30. G 33.0 182.6
21.0 11.0 33^0 32.0
24.2 11.0 37.4 35.2
116.6 15.4 48.4 46.2
145.2 17.G 50.6 50.6
i i ijju .j-i -
II
BFS
Market
Novelties Stationery supplies Tools and liacdv/are
Export (Net) Other Total
EXHIBIT III - 14(3) USDOL/OSHA
POLYVINYL CHLORIDE MAJOR MARKETS 1970 - 1973 (million pounds)
A '1970)
1071
10(0 )
27.(5 10. 0- !'
}1 >
S. 8 26.4 11.0
100.0 94.0
A
" ' 1CS.0 ^196.9
3027.0
--
<
tP
1972 13.2 35.2 13.2
iGo.e
107.8 4345.0
15,4 39.6 17. C
- 133.6 33,0
4776.2
0
Sources
Modern Plastics, January 1971, 1972, 1973, 1974
$ to 0|
EXHIBIT III - 15
USDOL/OSIIA
END USE FORECASTS OF POLYVINYL C1ILORI;' MARKET, 1974 and 1973 - 1930 .
Polyvinyl Chloride End Use Market ('million lbs.)
End Uses
Construction Home' old Uses Pachaving Electrical Uses Consumer Coods Transportation Miscellaneous Exports
1974
2,250 040
^,'A 320 Y 410
^TrSP
4,750 : /, Cc
'
197S-19S0
3, 500 - 3, S00 GS0 - 735 440 - 475 520 - 540 570 - G25 2S0 - 295 . 240 - 250 100
G, 330 - G, 820 --*
Source:
Disch, G. E. . Plastics --Haw Materials irvLid-hlarkcts and Coatings- -Mew Technology American Chemical Society, Brooklyn, 1 4^''3.
(3>
B F 5 QQS54
BFS BBS54S
(P) = Projection (S) = Sales (U) = Internal Use
Fesitt I linJ {'. Use
Total Po3yviii)l Chloride & Copolymers
(Dr)- Resin Content)
Hamepolynrer PesKfei,
, /' 1
Co*ooly* ntar Rosins/Dispersion Resins, Utoxas, & Mending
(I1)
\\ >* Total Polyvinyl Cltloride & Copolymers
(S& U)
(Dr/ Resin Content)
Total Experts
Total Domestic
Calendering, Total
IrI,,Tt.oxotriiinea
" ,A A /J\P/^'yf\y
All Other Calendering Uses
> (f\
Coating, Total
Floerint'
Textile Re Paper Coating
Protective Coatings
Adhesives & Ail Other Coating Uses
tO G>
KXIUEIT III - 16(1)
USDOL/OSIIA
POLYVINYL CHLORIDE CONSUMPTION BY MAJOR FABRICATION PROCESS - 1970 TO 19,
(000 LBS. DRY WEIGHT)
1970
,115,204 ,232,003
519, 026 364,170
2, Oi-5,214 187, 991
2,797,220 705,184 247,227
457,957 53, 363
75, 074 93, 395
85,390
1971
3,437,323 2,474, 90C
504,461 457,961
3,394,135 169,454
3,224,731 835,114 274,544 86,924 473,630 '349,139 116,629 142,465 41,060 49,035
1979
4,253.719 3,149,421
gcVr.n u0uU 549, 960
4,336,S30 155, 510
4,130,970 963,404 332,681 74,519 556,204 425,273 133,645 173,237 59.358 59.033
1 0"^
4, 5 Cl, 50 r 3,432.077
539, 027 5S9,1
4,732,15" 146,361
4,535,79 913, ICt 252, 25C 72,637 513,075 483,526 150,320 190,031 71,000 71,326
Resin Kind & Use
Extrusion, Total
Wire : Cable
Film Cheer
Rigid Pipe &>Tubing (Except fittings) All Otl:es^(ysions
Molding, Total)/ \
P-titles
(
Sound Records ,/
Fittings (Rigid Bfd $KTubing) All Or:;--,- Molding i V y Pa;:e Precesres (Except CoaripjSj)
Piastisol Formulation Ah--\
All Other
All Other Lhes
\ AT
.EXHIBIT III - 16(2)
USDOL/OSIIA
POLYVINYL CHLORIDE CONSUMPTION BY MAJOR FABRICATION PROCESS - 1970 TO 10
(000 LBS. DRY WEIGHT)
1 070
1,094,775 40S,72G 193,020 492, 429 253, 9-15 1-10,580 113, 305 113,054 113,054
-
370,394
1971
i,2o;,cs4 312,919 J 7S3 5 497,002 275,703 309, 070 30,119 137. 840 135,105 105,945 105,915 330,729
1972
2,051,003 439, 055 220,145
1,003,077 331,331 410,275 77,254 148,023
(1) 134,993 150,050
91.337 5S.702 180,311
1 97C
2 2C7, CCl 413,7C 20-1,20
1,254,97 425, 02-. 511,0;. 87, 02141, n8,00 191.52: 155,577 So( 14 69,42 2C4.C0,
Notes-
(1) Comparable 1072 data not available (2) Not comparable because fittings were included in all otiter moldings in 1072
Sources; "Synthetic Organic Chemicals", U. S. Tartu Commission, Annual Reports 1071 and 1072. Monthly Statistical Report. The Society of the Plastics Industry, Inc., April C, 1073 and March 20, 1074,
BFS 0Q 8549
i
Resin Type
Typical Average
Mid-197-1 Residual VCM levels 1 fpnm)
Calendering
Suspension Hpe Grade General Purpose Copolymer Oven 11
150 than 500
- 7,000
550 290
Dispersion Latex Other Overall
bulk
High Porosity Overall
Solution Ovtnll
'1Q9 V
less thaii `is'5'
10 ' //
V
25 55
1.5
*r\ Y; I'SpYjF\p {O ^
70 910
EXHIBIT III - 17
USDOL/CSIJA
MAJOR RESIN TYPES AND TIIEIR TYPICAL FREE MONOMER LEVELS RELATED TO FABRICATION CATEGORY (Million Pounds)
Coating
Extrusion
Molding
Paste
1,255 215 840
1S5 90
All Other ICO
200 240 '155
205
70 L 8 D 2, SCO
515 J_5o
65 _22o
BFS 808550
Note:
(1) Individual data points around t!;e averages can vary by a factor of three or more. IaMOic steps were taken to comply with the Erm .cy Temporary Standard these averages were significantly lusher. Improved stripping is believed to have been acliicved using stme-et- . -art technology and operating procedures. Some major producers reported average VCM levels in general purpose resin significantly 1 500 ppm ar>d as low as 50 ppm.
Sources:
Snell estimates and Exhibit III-14 and 111-16 based on industry interviews.
i
BFS 008551
)\
:A 'tj
/
IV. TECHNOLOGY OVERVIEW
-r
IV. TECHNOLOGY OVERVIEW
The previous chapter defined the economic infrastructure of the vinyl chloride (VCM) and polyvin*
chloride (PVC) industries. This chapter presents a technological overview of VCM and PVC manufacture
to provide broad engineering and operational perspective to the information of Section V, which presents
findings and conclusions.
--6
This chapter is divided into Mvo^g\ eclions:
Section IVA, Vinyl"Chloride
Section 1VB, Polyvinyljtfrloridc
PVC is given significantly greater discdssi^^&niphasis than VCM since the study is primarily of PVC
<1>
BFS 008552
IV-1
t
'v\
IVA. VINYL CIJLORID
This section discusses tiic technology of vinyl chloride (VCM) manufacture. Exhibits appear sequentially at the end of the text.
1. THE OXYCHLORINATldk/PHOCESS ACCOUNTS EOR APPROXIMATELY CO^ OP VCM CAPACITY
The table belpitf,summarizes estimated U.S, VCM capacity in 1974 as a function of the manufacturing process.
VCM Process
Estimated 1071 h'arneplate
/ \ Capacity (Million Lbs.)
Percent of Total
Oxvchlorination
5.-1G0
Si'll)
Direct Chlorination Only
Acetylene
Total
<P
900 3.90 C.700
14
_5 loo-b
Source:
Exhibit III - 1
BFS 008553
IV-2
r' rr
>1 If) <5 Oi 01 b
Tr''"r'
The balanced oxychlorination process is described by the following equations:
Direct Chlorination: (1) CH,, - C1I,, + Clr
Oxychlorination
(2) CII2 - CH9 + 2HC1 +
C1CII 2 Cfb2Cl
---lC1^ C1CH9CII9C1 + H00
z o25r/0,0 rC
22
2
EDC Cracking
a
(2) 2C10H2CH2C1--5--- 2CH, = CHC1 + 2HC1
^ * 400 C
2
Net A*-' 2 CH, = CH9 + Cl9 + -10, 2CH2 = CHC1 + HO
_Sourco:
Browiislehi^M., U. S. Petrochemicals. Tulsa, Oklahoma; The Petrole^J Publishing Co., 107"1, p. 250.
' fley;
Exhibits IV T and 1V-2 provi$e-#cprcscnlnlive flow diagrams for the balanced oxychlorination process based on Jhe Stauffer Chemical and B. F. Goodrich Chemical designs, respectively^hynit operations are similar in balanced oxychlorinaiion plants, although dd?u5i&details can vary appreciably regarding mass and heat balances, uarticularTi|^n fractionation steps.
Exhibit IV-3 provides a general process description related to the Stauffer design. The Exhibit also provides a more detailed description of unit opera tions involving VCM.
IV-3
1
The American Chemical plant is believed to feature unbalanced oxychlorination, using only reactions (2) and (31 in the preceding table.
The Ethyl plants and Dow's Plaquairiinc plant are believed to feature direct chlorination and cracking only, using reactions (1) and (3) in the preceding table.
The Monomciiem plant, the only substantial acctylene-based process still op erating, is believed to be,balanced type employing both ethylene and acetylene. The IiCl produced by j^j\5rcHysis of ethylene dichloride is added to acetylene for further VCM product ioif, iagtead of oxychlorination.
V-
The newest process is tlidTih-^nscat process (Lummus Co. , and Armstrong Cork
Co.l with the potential to oetnapto strongly with the ethylene process. It is one step synthesis of VCM by oiyyfpmorination of ethane. VCM is produced by passing
ethane, 1IC1 and air (1 to 1 to 2. vol) through a molten catalyst of KC1 and
CuCl/CuCl2 at 875P.
\
2. VCM PRODUCTION COSTS WERE ]-ST^TATElj^gl 1074 TO PROVIDE THE BASIS FOR THE ECONO
i:.u1a c:t assi:s si ent
V^>.
Exhibit rp-;l summarizes estimaattecddCjF^ 1 VCM economics.
The data is provided in terms of unit costs of manufacture and profitability to. enable sensitivity analysis of the potential impacts upon price of various VCM exposure limitation scenarios.
JV-4
I
' rr
3. GEXEB-M.LY, VCM PKOOIICTTOM CAM PnESENT HKLATIVEt.Y LIMITED CHANGES OF HMEUSuME TO THE OPldlATLYC IhThSONNdh":ill:-; TG~ AUTOMATION AND REMOTE
CONTROL AND OUTDCON COAktTKGCTiON S1MH.AK TO IVhFINkPJhS
However, localized hazard areas arc associated on a routine basis with the loading of tank cars, the cleaning of tank cars and of other equipment. Maintenance operations may be also a source of personnel exposure.
(1) The VCM Production Plants Are Highly Automated , Continuous And Closed Systems
A typical'VCM production, plant consists of ar: island of process units,
principally fractkuiatu^Tutiud similar towers, cracking furnaces, and
sometimes comprcmorsy'''t>oy tanks, providing storage space during
testing, are also ineludatk/
\P
uong-terat storage is prov^cSSfcJ by llortonspheres which are located in
tar.;: farms and connected tunhc loading racks where the tank cars are
filled.
A
Thu How of material through the production train (or trains), is controlled fro.n control rooms, which, cs^fe^ally in newer installations, are fairly retrieved from the actual produc^igg^units.
The operators spend much of thei^Jjii^e in the control room, mostly monitoring the operation of automatic controllers and from time to time making necessary sct'poir.t adjustments. Normally there is little need for the operating personnel to bo physically present in the production area.
BFS Q0S55S
IV-5
r
However, inspection trips may be neecssary from time to time and are usually motivated by some abnormality in ihc operation. While most of tiie abnormal ities are usually traceable to instruments or control malfunction, significant leaks could be occurring and result in appreciable exposure risk.
(2) The VCM Plants Arc Usually Completely Outdoor Operations
All production ucjuip.ncrit is generally installed out-of-doors. There is limited chance of VCM accumulation and area concentrations may remain low even in the presence of significant leaks, particularly, when atmos pheric conditions are not aur^pant.
However, significant exposure "may be encountered by the greaser. Since
his function is to fill up Ihe'Ma^nuting devices of pumps and compressors,
winch in some instances mayvjpjjlvh to be done daily, he comes into close
proximity of sea.Is which may Vn^tpiking, and his own personal exposure
may be in considerable excess'tft what would be surmised from the general
background.
A-<z--
(3? :L. Car bonding And Tank Car Cleaning. r.'xuo'-uro In Monomer Plants
rent Critwal Areas Of Routine
While there arc seme "over-the-fen
lipolino del: wries and some marine
shipments, the bull: of the VCM is uvf/Sd in railroad tank cars. Significant
VCM exposure risk can result from disconnecting transfer lines and from
the historical practice to use "dip tubes" to determine the level in the tank
car.
BFS 008557
rv-G t
i
Th"dip Lube" mi,Shod conshbs ui allowing a minute amount of VCM gas continuously to canape through an adjustable; tube dipping into the tank. V.'hnn tin: level of the liquid in the ear reaches the bottom of the tube liquid VCM is thsuhargud resulting in a visible "plume" from the tube. Usual precnies has boon io raise further the; dip tube at this point and to complete 'die idling carefully at a lower rate until the permissible level was reeu hod. Under certain atmospheric conditions this method is known to have pi\a;n signihcaul^3^1 concentrations even at some distance from the tank car dome. A soh^iwh to tide problem has been to re-equip larger fleets of tank cars with mo;# "elaborate, non--temitting gauging devices.
V.
Tank car cleaning operatic'ivsjjp'ul men in close contact with cars which may contain residua; amounts uf moi^hmer. But thorough venting and incin
eration c..n bo installed and personal protection used. Thus, exposure
inward to personnel can be mhiimiVod.
\
( Xiiivdhd :_!!cCLQPS`PbrL'hdb* While Gnr inhPatential Sources Of Personnel Exposure, Can
L a (lornrolled fv Appropriate DepresSimitation And Venting Procedures
.
..
- - ,y~ ^
f.t \ Catastrophic failures involving rupLtlrte of large volume containers or
massive leaks upstream of the main ^ic^rul device are rare.
BFS 00855S
IV-7
0 i ' :er sitim!: a; him fur n pan tha fuwr.er mo ex -oscre risk
re< brln-', m.-ln:en: use action (m.ch ns pulling a unit off the divide into two catereries: scheduled and unscheduled, with candy eccump! is hoc! using proper procedures to minimize VCM
Appropriate opoi ali: m; V$Q$ edi ires and nddiiional venting equipment'can be nr,:::! to rc dune or to v;ri.yn4iy eliminate fee risk of exposure, exhibit IV-5 shows an cxnmruc oi' ourruyi operating procedure for maintenance action of die* Dow Chemical Ch m.panyj^
* ffX
-i ,.yS
*
ikon 1V1J, following, provides a similar overview of polyvinyl chloride technology.
' s, /
BFS 008559
iv -;i
-1EXHIBIT IV
USDOL/ CSHA
VINYL CLLOLIDL
BF5 008560
g' : Stjuff .T
Co.: Vinyl CbluHi.l::. Hydrocarbon i-Vccai-sii'ir; 52: 104, Govern bar 1073.
i
EXHIBIT !V--2
UCDOL/OCMA
Til ). F. GGC-iJIIICil FUCCFiiS FOP. VINYL CIILCRiDF
?Li. F. Goodrich Chemical Co.: Vinyl Chloride. Hydrocaibon Procesiiny 52: 151, November 1973.
BFS Q 085S1
,
. Jr
EXHIBIT IV-3 (1) USDOL/OSHA VINYL CHLORIDE PROCESS DESCRIPTION
I
General Description^
Description of Unit Operations Involving VCM^
Ethylene dichloride (EDC) is produced in both addition (direct)
Dry EDC is dchydrochlorinatcd to vinyl chloride as it passes through
chlorination and oxychlorination units. In the addition chlorina
the packed tubes of a cracking furnace.
tion unit ethylene and chlorine are combined to produce EDC in a liquid phase reactor. In the oxychlorinatlomijnk ethylene, air
The tubes arc normally packed with pumice, charcoal or some other "contact'' type catalyst. At 900 to 950 F and 50 PSIG, I DC conversion
and byproduct MCI from the EDC cracking unn^re-'reacted to pro
Is about SO1?!) and yield to vinyl chloride is 94 to 97 mole ". The hot
duce EDC. An efficient catalyst in the vapor {il^stETwychlorina-
effluent gases are then quenched, and partially condensed, by direct
tion reactor is used to promote high yields. High pressure steam
contact with cold EDC in a quench tower.
generated in the oxy reactor removes reaction heatyatSTjs used
Effluent fractionation and product purification are generally accom
as heat medium in other points In the process. EDCts separated from vent gas by condensation in two recovery units.Th^re are
plished in three additional towers, where each producer of VCM has its own modification of this process.
no moving parts in the entire oxy process except in the air com
Hydrogen chloride and light chlorinated hydrocarbon' arc rejected over
pressor and refrigeration units.
4'"'x
Crude EDC from the addition and the oxychlorination units
head in the "HCL" and "Light Ends" towers. The hydrogen chloride is normally recovered by water scrubbing and recycled to the EDC plant.
is combined with recycle EDC from the cracking unit and puri- ^ fled by removal of small quantities of light and heavy mattytMy
Trichloroethane, chlorinated C 's and other heavy ends are rejected from the bottom of either the "qucncti tower" or the "vinyl tower". Contained
Aqueous effluents seperated from the crude EDC are steam stms-.^
EDC Is recovered by fractionation and recycled to both the quench tower
ped and are suitable for biological treatment. Both light and
and the feed storage tank. The light and heavy ends are either further
heavy ends may be treated for further use as feed to other chlor-y' jj
processed or disposed of by, for example, incineration. Vinyl chloride
inatlon processes,
*
monomer.is taken overhead in the "vinyl" column, generally caustic
03
Vinyl chloride monomer (VCM) is produced by cracking
washed, and then sent to the product storage facilities.
'O purified EDC in the pyrolysis furnace.
i <5
00 Ol
fr,
K)
,<D
General Description
After quenching, the.furnace products are seperatcd into HC1,
which is recycled to the oxy unit, and liigh purity VCM, Unreactcd
EDC is recycled through the EDC purification system.
The overall process is balanced so that only VCM is produced
without byproduct HC1, Design is easily adapted to produce HC1 for
other uses, to use HC1 from other sources, or to make EDC as a
seperate product,
x
The process is highly automatiStTfet;stable, fail-safe operation
at high yields over a wide turn-down r^ggr^. Startup is easy and
rapid. Units combine simplicity of operation with low manpower,
capital, operating and maintenance costs;; A
t
EXHIBIT IV-3 (2) USDOL/OSHA VINYL CHLORIDE PROCESS DESCRIPTION
Notes: Sources:
A
(1) Related to the Stauffer profess;"' Exhibit IV-1 (2) Reflects generalized practice
(1) uStauffer Chemical Co,: Vinyl
de. Hydrocarbon Processing 52: 194, November 1973.
(2) Air Products & Chemicals, Inc.V;
Division, Survey Report on Vinyl Chloride Monomer Production Via Dlchlorethanc Pyrolysis.
Prepared for Environmental Protec^o^gency; Durham, North Carolina; 1972,
BFS 008563
EXHIBIT IV - 4(1)
USDOL/OSHA
ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974 (C/lb.)
Unit Production Costs For A 500 Million Lb, Ethylene Oxychlorination Plant of 1974 ' Construction With Total Fixed Capital of $20.4 Million_______ _____________
4,08
Raw Materials ff') Ethyibrie (0.49 lb/lb <S 6.0/lb) Chlorine (0^67 lb/lb @ 3. Of/lb)
Subtotal -
Labor Utilities Maintenance Overhead Taxes & Insurance Depreciation
(P
Total cost of manufacture
2.94 2.01
0.12 0.25 0,20 0.15 0,06 0.40
4.95 0.13
( .. i
EXHIBIT IV - 4(2)
USDOL/OSHA
ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974 ($/lb.)
Unit Production Costs For A 500 Million Lb. Ethylene Oxychlori nation Plant of 1974 Construction With Total Fixed Capital of $20,4 Million____________ _____
Pfofitabj.lj^
Net sclli^giprice (FOB plant) Cost of manufacture Selling, ggtfvwal and administrative expenses Pretax proS)T>
Pretax retunySh total investment ($ 1.2 plant investment)
7,41 (6,13) (0.30) 0.98
2070
Sources;
(j
w.
(1) Snell esujgajies The PetrWmn 1 Snell estintaCs^
(2) Snell estimates based on mld-1974 Chemical Marketing Reporter posted prices
BFS 0QS565
.1,
EXHIBIT IV-5 (1)
USDOL/OS1IA
EXAMPLE OF A STANDARD OPERATING PROCEDURE FOR MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS
SAFETY PROCEDURE
Subject:
BLEED-DOWN OF VINYL CHLORIDE CONTAINING EQUIPMENT
Problem,-
At pre-ent. pumps, sections of piping, and some equipment are partially or otherwise bled down to atmosphere. Tins exposes personnel to vinyl .
vapors If care Is not taken.
Situation:
,yvr,'
Obviously, there are numerous situations thataqccur in the plant, where exposure to vinyl vapors is possible when preparing equipment for repair
or entry. Most equipment is either already tied into the vent recovery system for bleed-down, or can be, with limited temporary piping. Almost all
bleed-downs can be done through the vent recovery system and all personnel exposures to vinyl vapors must be eliminated. Elimination of exposure to tlic vapors should extend to any final low pressure &teed-down of equipment that has already been relieved through the vent recovery system. Also,
preventative measures should be taken when opening equipment with stagnated vapors in it. In these two cases, proper respirators should be used to
prevent exposures due to change of wind direction or otherwise.
Solution:
All seal repair work done on vinyl furnace pumps should utilize the vent recovery system for the priptary bleed-down. Any small final bleed-
down should involve personal respirator protccrionTijiA some cases, it may be necessary to use a full face mask, rather than a mouth-hire
respirator,
<
Temporary piping to the vent recovery system should 6<i\run when necessary to vent an isolated piece of equipment, or run of piping.
3. When breaking into a vessel or piping system containing vinyl that has been depressured, use a respirator, (Hose-Line Mask). In the case of breaking vinyl containing system, the use of respirators should parallel the policy of using monogogglcs.
BFS 0QS566
MAIN'
EXHIBIT IV- 5 (2)
USDOL/OSHA
,MPLES OF A STANDARD OPERATING PROCEDURE [ OR NCE AT DOW CHEMICAL CO. VINYL CHLORIDE V.'< IRKS
All vessels will be purged to D-234 vent recovery system before opening. Consider^bjf^xposure to vinyl vapors is possible working around
these openings due to trapped liquid vaporization inside the vessel. Therefore, fresh air-supplied masks should be used around such openings
for exposures of any length.
// \
When breaking into vinyl containing equipment, the immediate supervisor of that area shoulcLadvise the type of respiratory equipment to be used, and issue a safe work permit in some cases.
Source: Dow Chemical Corporation
<P
<3
IVB. POLYVINYL CHLORIDE
This chapter discusses the technology of polyvinyl chloride (PVC) manufacture in broad terms. . Appendix A provides more detailed data from, itacts with industry, from submissions to OSHA related
'n,to the "Proposed Standard" and other source ^All exhibits appear sequentially at the end of the chapter. There are four basic processes which cafclre used for producing PVC.
Suspension Polymerization Emulsion Polymerization Bulk Polymerization
iP
/
Solution Polymerization These processes are presented in a "capsule" summary inljjimbit IV-6.
%o
1. OF THE FOUR PROCESSES FOR THE MANUFACTURE OF PVC THE SUSPENSION PROCESS IS THE MOST ECONOMICALLY IMPORTANT, ACCOUNTING FOR 78 PERCENT OF PRODUCTION
The table on the following page summarizes the relative contribution of each process to the total production for 1973.
BFS 00S5SS
IV-9
ot
Process
Suspension Emulsion Bulk Solution
Total
Source; Exhibit III-9
1973 Production (Million Lbs. 'f
3, 558 593 274 137
4, 562
Percent of Production
78 13
6 3 100%
The importance of the suspension process is reflected in subsequent discussion.
Exhibit IV-7 presents a flow diagram for a representative suspension process. Principal unit operations include^
monomer receiving an
rage. This is discussed in Appendix A,
where Exhibit A-l prese'
erating procedures while Exhibit
A-2 shows a flow sheet. polymerization
<P iP
this is also discussed in Appendix A. where a
technological assessmenb^F^s developed by Snell
addressing reactor design and cleaning in Exhibit A~3.
a comparison is also presortfEg of large versus small reactor technology in ExhiEm^Ai-4.
Exhibit A-5 shows the schemajis-pf an older polymerizer, while Exhibit A-6 shows that si'a newer design.
stripping and in-process storage drying
Stripping technology is broadly discussed in Exhibit A-7
finished product handling
IV-10
BF5 0085S9
fN
Exhibit A-8 in Appendix A provides a representative plant layout with typical operator movements.
Exhibit A-9 in Appendix A presents a flow diagram of emulsion polymerization.
It is seen from Exhibit IV-8, at the end of this chapter, providing a technological overview of suspension polymerization, emulsion polymerization and their copoly mer production variants that suspension and emulsion polymerization are very similar in terms of gross equipment used. Differences in detail are summarized in the Exhibit.
Exhibit 1V-9 presents an over
^qf the polymerization cycle for the suspension
and emulsion processes. Differences principally concern time requirements,
detailed in the Exhibit.
Exhibit IV-10 provides a checklist dfjpotontial VCM sources contributing to local or area type VCM exposure risk in^uspension polymerization. The n important potential sources are identi^ed4n the Exhibit.
Exhibit IV-11 shows a flow diagram and^riSj^ess description for bulk polymerization.
Exhibit IV-12 presents a summary discusrfidK^of copolymers manufacture, which involves the suspension, emulsion or solution processes.
IV-11
o
2- ESTIMATES WERE DEVELOPED BY SNELL OF PVC INDUSTRY ECONOMICS AND THE TIME REQUIRED TO ACHIEVE VARIOUS ENGINEERING GOALS
Exhibit IV-13 presents typical time requirements for implementing various engineering control methods.
Typical delivery times were^nlso estimated for key equipment items and these are pre sented in Appendix C. EjSfflQt C-l.
Exhibit C-2 presents Snell's^ajjfcrview of time requirements in implementing engineered controls of VCM exposure in ITVp^plants.
Exhibit IV-14, at the end of this-^hapter, summarizes 1974 PVC economics. Total cost of manufacture is estimated at 14.4<t^b. at a 20% pretax return on total investment. This cost profile is used in the ne^TTiAapter in economic impact evaluations of various VCM compliance scenarios.
This chapter discussed the technology and basic production economics of VCM and PVC manufacture. The next chapter presents findings and conclusions.
0j '*1 in
CD
.
OD Ol 'j
; IV-12
Exliibit IV-6
USD0L/0HA CAPSULE OVERVIEW OF POLYVINYL CHLORIDE PROCESSES
(1 3)
' |Suspension Polymerization
Suspension polymnzatii*n utea water as a medium for VCM with a aspens. n 4^cn: sacli as jvriyyjiyl alcohol and a catal/.t such as benzoyl sroxid;,, Buffers surh as sodium caihonatca or phosphate can be useJ 10 lAiniA n pH At f> to 'i dicing the reaction And prevent hydrochloric acid `volution. Pol) r.:rl*-iJon under nitrogen Increases reaction rate aa well a cooiioli acid release.
The charge to a reactor might be composed of:
. 100 run Vf`M < 00 parts water . 0.1-0.2 part catalyst . 0.0P3-0.1 part suspension ageot
The VCM/water ratio Is Umired by the rheology of the suspension to
liable
removal of the heat of polymerization. Vigorous agitation
Ads heat e^than-c ani maintain* V<\M as fine droplets suspended in water.
\ficrdr-*,"g the p*'l\,,,ir "jv.irls' tan.'.v- from uO to l':0 microns for general
'irpc**; applications. and t-naUt'r for specialty products*
Proem temperatures range from 30 to 45ftC, and the time to turn around i polymerise* can range from & to IS hours.
Major uses of Suspension polymerized PVC arc in calendered film; -vtmdeJ film, wine coatings, pipe and profile; and molded products.
Emulsion Polymerization (1.2.3)
Emulsion (dispersion or pane) pciymerization is very slnil.tr to the suspension process. Recipe diffcicrtcc* principally concern the use of cmul/ificrs and initiators. The rime to turn around a reactor can range from 10 to 2T lu'urs.
A colloid JiijNjrsion ofjVVC particles in an aqueous phase is prwJuced Ln this process. These particles, approximja^^rsinucmna in size, can be utilized directly from the dispersion, or
latex, either plasticirc^Wimplai.Lle./eJ, or they can be spray d.ierl io a powder for uoc In plastisoli,
rigidiuls. plast gels,
Pmciz'.'^s utilizing PVC dispcr.lon resins incUde slu-di molding,
casting, dipping, spray cdoting, ioll and knife coating, and rotational molding.
Plastisob ere vinyl dispcruori^HaUiniag little o: no volatile UwuiJs and thus arc essentially 100> soliJ;, Oryanosoh are nmulr^n coT.poi.tmn to plastisob except for the presence of volatile liquids used to extend the kqurtFJfyasopaml thus reduee viscosity,
OJ r
Polyvinyl chloride for pla;tisota-"Snd organosols is polymerized in enmUion systems that provide colloidal water dispcislons containing ultinucc particles of approximately 0.2 to 2.0 microns m size. Spray drying of the water dispi non procure: the commercial pmdjct. a dry powder of approximately 2 microns average parth lc size, with SWiii? ]urilc)cs as large as 15 to 20 microns. About lfr> of the
PVC used in the U.S, it diversion grading,
Most vinyl dispersion resins find use mu
oAbrnad areas of coatmg atul moldings.
s'E^kj^^ha rdness than can generally be c
Organosols are used to produce thin films
obtained from
pLaitlsoli,
Latex liquid systems of vinyl chloride homopo^mws^md copolymers arc abo available. These systems are colloidal dlspc.-sions in water. The ivttw^c particle Uc U usually less than 0,3 micron.
Latexes arc effectively used to coat. Impregnate or saturate fabrics, paper and leather with polymeric dlapemona of lower viscosity tfun most pLatuola.
D,;lk Pol.
fl)
rvri- i?i-n
A r>cre recently developed proves* |$ tamed ojt In specially
eh sit-iL J real :>'rs m ihc a*>. nee of wa'tr a * J k..,pcn;.. n da.tivta.
Because h..lk fis'.ni JrC jv>.>:-irrj/i-,l in a :> 't.'-irt i '.air.s, thr .ra*ei
portion of wfi.ch U t<, y, lr J. Ii>cy ; Ll L*e Co 1:f' .fit;; priw easing
residues to Lite ejivl;otu..eat as jvHgfar.lt, While vap*Ste cl yfuJjc-
ing both ger.cfal-pi.r;iris<* and Ipr, wlty types of F`V<1, tJic bulk or
mass ;])!' n/atwn pn>r-it ran aLs*' pr *s!u' e ve.-y p*.n- j rv^. the
tirji uxo of w! ,vh defers < `'nsidi . > ly from rc:-'4
cr.:ct v.*
:.spennon. Perj.xu' 13/t!: p-unii. let fH'lyn ***.:<' i in f ,`k ate f:ce <M
s i.svd .a ; 4,- nj.i'Z mi' 11 .1: ' n [
r, r\-y lack
mcr 'ii-n^us i ut.n, s. The isi-.1L. r.i i La.'.:> !..! * \---j in *)_lk :cs,aa
has made U.m preferred n n.*r.) wan. pjivftt pmdj't markets, includ
ing packaging film, bottle*, and coatings.
01
_______________________Solution h'llymtr; ,*a:____________
A pr'Vt;* L com \rroal m^ir.arit c tl^o tl^ n^icri ducusw'd has hc< n uuli. cd m f*crwi,n.` i;*r L-Uy ci.j* lyrntzv ir.d tcrpol;*:Mrs of vinyl tiilondt:, Pelyr.'.r.raticn otrm. in Oi.^arac solvon; wiiivh tlicn must be usually rem >vud and rccpvexcd. The solution futymen are generally ugher pc.< cd *nd used m product apfdlcatiom such as coatings and adl^sivei.
ourccs; (1) 1972-1073 Modern Plastics Encyclopedia, p, 104. (2) 1373-1974 Modem Plastics Encyclopedia, p. 113. (3) Snell.
if
COLD AIR
1.
USDOL/QSHA
REPRESENTATIVE POLYVINYL CHLORIDE
SUSPENSION RESIN MANUFACTURE FLOW DIAGRAM
V1NTL CHLOniOt STOBAOeT TANK...............
'
AUTOMATIC / 1 SAMPLER j) -J
LJ
tails
CHECK BIKS
0 1 _z_r
eiow
TANK
7T
Source:
Walter E. Connolly, Statement of Position of Firestone Plastics Company, A Division of the Firestone Tire & Rubber Company, With Respect to the Proposed Permanent Standard Dealing With Occupational Exposure to Vinyl Chloride to Occupatiopal Safety and Health
BFS
00S573
Proctsi Step (1) VCM Unloading
(2) VCM Storage (3) VCM Tiiiufer Ad Metering
(4) Polymerization (5) Snipping
(0) Mooomer Recovery
Pl-QCcu Whete L'ted
S, E, Co S. E, Co S, ^ Co S, E, Co S, E, Co S E, Co 5, E, Co
S, E, Co S, E, Co
Co Co $. E, Co S, E, Co St ^ Co S. Co
ixr ":r iv-*0)
USDOL/O^lA
TEQiNOLOGICAL OVERVIEW OF SUSPENSION < 5), EMULSION (E) AND CO-rOlYM.l DELATION (S& E TYPE)
Mo;t Commonly UseJ
1`pntp ,Tirm
Tank car Flexible hoses
Transfer pump
Evaporator
Evaporator feed pump Unloading compressor
Hortonspbere*
Less Commonly Used
____Equipment_______
(.ori.-.fnts
Barge Rigid pipe with flexible couplings
Some plants have pipe line delivery with or without local storage. Tank cart: 10 to 3B, 000 gall. Barger: Up to 300, 000 gala.
Vacuum pump
\ Some }ow capacity plants arc raid to uk ntooven displacement for unloading, > This practice can ca,.c venting problem* on rerum can at the VCM plana, and ) at the unloading rabidity.
Sometimes used to vent Loses prior to disconnect.
Horizontal tanka '
Hortonspheres: 500-800, 000 gala. Tanks: Up o 80,000 gala, Sometimes storage is under refrigeration I5C.
Transfer pump Day tank
Weljb litik and t
Loading pump
Line strainer Metering tank and reactor
. a. Loading pump or mewtg pump
^^rtemlx lank Addition pot
Some pl.mb particularly thorn using weigh tanks omit the day tank. Ujed occasionally. in copolyiiscrizailon the other monomer Is Introduced letc.
Sometimes used. Suspending agents and catalyst are aomerimei premised and added thrcw^h a specially deslg.ted aJJldon pot. Often Ingredients arc manually [^ruied l`to the reactoti-
SiLnred reactor (polymcrlzor. autoclave)
Snipper
Clais linzd ot stabiles* steel; From , v00 to 5,000 gals, Mt*oi ca',ly. New technology; To 25, 000 gals. *s. to 13, 000 gab, C, L,
Stepping b sometime* carried out In the reactor, most U ply thitxj.'b dcprer-J.'ijatioa and monomer recovery. The use of steam Jets Umore advanced, while vaeu-r.pur J> are also used. Heating and steam ipa.-glng Is sometimes practiced. Separa'e strippers at approximately twice the volume of the reactor are used. Developing levLnolr'^yli likely to feature multi "St;. ,*e stripping using neam to fdi.ee free irtno;ie< in the p.-tduci and lindt
in-plant and dr)tr exhaust cmbslot.i.
Foam knot Lout pot Vacuum steam Jet
Reciprocating compressor
Several frtrotoibrlea And/or vacuum Jiumps
CPCondenser
Comonomer separator Rotary corr.prcaiO;
Condenser Recovered VCM rank Chilled vent condenser Recovered VCM pump
Recovery still
Monomer recovery Is tied in to snipping. Jet exhaust it usually vented to atmosphere Vacuum pump exhaust can go through monomer reoovery unit. Mott processors do nor separate the con*onomerbut recycle the mixed
recovered sue am.
TLc most oo .riioiily used of die rotary compressor* U the Nish water seal, said to ruve less Jiulmcn.occ problem than the rccip'*xaii,ip. Slight proprietary technological differences exist b. the handling of the recovered monomer stream.
The recovered monomer b returned to die day or the vel^t lank.
BFS 00857
U
\
Rocear SieP (T) Product Transfer
_____
(A Drytag
(9) hodufit
and storage
(lft Packaging and 8>1pj>iig
EXHIBIT IV-* (4)
Process Where Used
S. E, Go
S, t, Co
* * Co
S, ^ Go S, E, Co
$
s
E E E S
S, E, S. E, 5. E, S. E.
*. E, > *
&, t, Co
eese ee
Mott Commonly Uatd Equipment
Transfer {lump SfftiW
Blend link
Feed pump Centrifuge Wet tike conveyor
Sfway dryer
Rotary dryer
Dust collector Intermediate storage Flieumatlc conveyor Grinder Dust colleen* Storage sUos
Bulk loading Hopper cart Tank trucks
Un Commonly Used Daulproent
Comments
Filler or yet Ufter
Some reictott lift gravity dropped using flexible coupling or permanent pIpInR. Basket ibataert hive been removed in some suspension plants, Open tmlnerm lomeiimei uied in cmublon plants require tlgnh>i,int operator aticnrtoo. Newer type strainer* ire equipped w|i|i backfluth. Jri tome installation^ lb# Straining equipment b pot vented/ Usually 2 to S timet die itae of the reacton, Sometimes open to die atmosphere f out-of-door*}, usually vented, sometimes with blower end vent itack.
<P
Concentrator's Confutation tarttf itoury vacuum filter Apron dryer Flash or fluid bed diftfr
If a latex product b detbed, steps 8, 9, and 10 are omitted*
Suspension slurry b 20 * nlldi*
Usually continuous solid bowl.
Wet cake contains atom 30 -
water.
Sometime! used before Ipary dryer. Usual wiped film type,
Itill equipment cooiblnirion has been reported.
.1 30,000 to 70.000 CFM of drying air. Final mobturet 0.3"0*S&,
'or holding product while Q. C. tests arc performed,
ie u a targe varies of alternate types of equipment And conflguradona for :onveylng of dry products. Several alternate tyiicrm exbt In the same
Bagging Totablna
is usually automatic or semi-automatic fluidised valve beg i>pe yuivftamers sometime* use *omo form of fluidising to unloading.
Source; SmU tilyiii baaed on Industry Interviews,
BFS 00857
tfl
Cycle Step * Charging
Water addition
- Ingredient* addition
* * Monomer addition
Reaction * Initiation * Cooling
Stripping (Blow down)
Tim*
>1oit Common Practice
Manway open, exhaust via "elephant hose"*
10-20 minutes
rill the reactor with the required amount of water. Usually by observing the level in the reactor on metering.
5 minute*
Add manually through open manway.
Close the valves, secure the manway.
10-20 minute*
Prior to monomer addition the reactor atmosphere is vented through a steam jet or a vacuum pump.
The monomer is metered through a weigh tank or other metering device.
15-20 minutes
Steam or hot water is admitted to the jacket to bring the temperature to 35-*45C.
5-20 hour*
During the reaction, cold water Is circulated through the jacket to carry away the heat evolved.
15-00 minutes
Some plants use only depressurization through the recovery unit, via foam knock-out pot. followed by steam jet.
. Reactor inspection Cleaning
5-10 minutes
To determine that rhe reactor is empty.
20 minutes
to 4 hours
In most operations this Is done every 3rd to Sih cycie.
l-l/5 hours
A man enter; the reactor and chips or scrape* away the accumulated material.
Since January I9"4 the man is equipped with a fresh air breathing device while in the reactor, and wears protccrivc clothing.
l.'wJJdlT IV"2
US!** >!./u;i!A
t
T*!G POLY Mryi/.vriON
p; th! si mY'-mo*: aw l*'i
mouses
Alternate Practice
Ounr'ir Ms
Sometimes the water is metered in with manway secured.
In most pUnts die operator is in cla;c proximity to the reactor during the charging operations. In mo;t cates the d,spliced atmospiserc is vented by means 0! die elephant |*>sc during water fill.
^remixed amount* dissolved or suspended in water are introduced to an addition pot.
Sometimes, in addition, nitrogen is used either at atmospheric or under reduced pressure.
A newer practice is to have the ingrcJunri ihvsolve J >r suspended m appropriate weigh tanhs and added dimegh a iraru/old, tom. times with computerised controls.
tn some cases die ingredients, particularly the caialysds). are held in a specially designed addition pot. After monomer adJition the atmosphere of tlx pot u connected with that of die reactor and eh* ingredient change is droppeu by gravity into dm reactor.
Direct steatn spaYg&feThto the reaction mixture.
yt
O
**
Sometime; the rate of^efiS^uUtion of the cooling water is adjusted by antiujfrroric closed loop control. Use vacuum purnp at theCLlOdeprcsiUrization,
venting to the recovery system, A
jr
A newer practice is to sparge `grua..i "ip enhance ^ the strippu.g and reduce ihe amount of free monomer going 10 the next steps.
Unreactcd monomsr is recovered either in the reactor iriclf or after transfer of the charge to a stnppcr or Mow down tank.
Sometimes the manway is opcmcdNtfprcsidual material is hosed out of the rcactor^S^^V
,, Newer methods aie used; - In-place water cleaning - Solvent cleaning
f0
Newer automatic cleaning methods have been devised to eliminate the need to open die riunw ay. or at least to minimize manual cleaning by a man entering the reactor.
The most commonly used maliods of automatic cleaning are described in Appendix A*
A man enter* the reactor and uses a hand-held high pressure water hose.
Prior to entry and while the mm is in die re-inur die atmosphere of the tank is renewed d'.ruuph an cxi.uua system connects, J >o an defiant hose. With realtors equipj-td w*d lUx.hlt. C`V.:,^n-*ri t1ic discharge ho;e is left open. With jvn.anini ly cor.no UJ re*' tor, a separate blower is lowered in die re-ctof 10 jjsiri the #ir cue Ration in the reactor.
BFS 00S5?
Source; Snell engineering assessment based on industry interviews.
Ok
/
Tank Farm (VCM Storage)
Rail car unloading
- Gasketing at hose connections - Pump seals*
Compressors * - Flanges at pipe joints - Valves*
EXHIBIT IV-10 (1)
USDOL/OSHA
POTENTIAL EXPOSURE CHECKLIST BASED ON SUSPENSION POLYVINYL CHLORIDE MANUFACTURE
. Transfer operation efforts storage tanks, to weight tanks)
Pipe flanges Pump seals* V alvcs* Compressors*
Reactor and stripper heads* ^
Reactor and stripper seals Valves*
*
Opening reactor and stripper heads for flushing*
Flushing reactors and strippers*
Cleaning reactors and strippers*
Cleaning buildup from valves, lines, etc.* Maintenance on various pieces of equipment .
o
f
<5 $ GO 0| M 00
^
EXHIBIT IV-10 (2)
2. Polymerization - Reactor and .Stripper Level (continued)
Airing out equipment in preparation for entry . Operator errors* Hugged lines resulting in gasket failure* . Ventilation of reactors during flushing operation (vapors discharged on roof)
Airing out vessels containing poorly degassed material as a result of plugged discharge line, setup, etc.* . Purging of reactors prior to charging (vapors discharged on roof) . Purging of stripping vessels (vapors discharged on roof)
3. Polymerization Building - Pump Out Level (Relief Area)
. Pump seals . Compressor" . Leaking pipe flanges resulting in spills . Leaks in VCM filtering vessels* . Drains from top floor* . Rcclaii^r^ajjer containing dissolved vLnyl chloride discharging inside building* . Drainin^oTfoam traps on compressors* . Drainingnvatcjr off tire condensed recovered vinyl chloride* . Moving pbi$ftic.r chips outside building and dumping drums . Changing ^njf^tndling VCM filters*
*V'
`Blend Tank Areaf WorC-j^-^roccss Storage)
. Monomer evoliy^ during storage* . Flushing blend tanE^ . Leaks (pump seals^hpscs, pipe flanges)
5. Rotary Drying Operation
^
.
. Rotary dryer exhauscaipv . Leaks from pump seals/ -pipe flanges
, Centrifuge liquid discharge (effluent)
'*
1
,
BB FF SS 0 0 S 5 F S
O
Rotary Drying Operation fcontinued)
EXHIBIT 1V-10 (B)
Any operation involving handling or storage of finished resin or where dried resin accumulates
Bagging Housekeeping Dried product screening Changing dust collector bags Cleaning equipment Pneumatic transfer of resin to storage or into bulk trucks and rail cars * Maintenance opecajirSfij in atcas where latgc masses of resin are stored, primarily silos
Warehouse Area
Spate where resin Is stOR , a manner that restricts air circulation
- Plastic shrouded pallets/' ,i - Resin (and compound) in sealed drums or boxes, etc, - Resin (and compound) Injprni-bulk containers (metal tote bins, etc.)
Storage of resin in bags
Lab Area
Testing of finished resin (and compound! Testing of resin slurry prior to dryL\gjptftpension resins)* Testing of VCM
BFS 00S5?
* Likelihood of relatively greatest exposure. Source; Firestone and Snell assessment.
i
00S5S0
EX!UNIT IV-11
USDOL/OSHA
TYPICAL FLOW DIAGRAM FOR THE BULK PROCESS
Ttic two-step bate!) polymerization process carried out in two reactors in scries. During the first step poly merization proceeds in a liquid medium of vinyl chloride monomer; it is a bend formation phase rate in the range of 10 to 12'^'. For tills initial phase, a stainless clad, vertical autoclave equipped with very turbulent agitation is used. Operating pressure and agitation conditions set the particle size distribution and the shapeg&ffc: bead used thereafter as a seed in the second step./
NITROGEN
__ U M
____ q |------ j COMPRESSOR
s--v Differential pressure
O^
degassing
The second step is a growing phase forljic^cds;
It is performed in stainless clad autoclaves desupitShfor
efficient agitation of a powdery medium. At the'ctyl of the polymerization cycle the unreacted mowwcjif h
recovered by condensation and directly reused for further polymerization. PVC resin is then discharged from th^
horizontal autoclave to a classification unit which screen^
the product to the desired specification. Oversize nmoimr-y
ing to 5-10r.of total is reduced in size with an approp'risfin
grinder designed not to affect the product proneriics.
m
Since mass process produces a dry free flowing resin^
prior to classification the normal capital expenditures as-
*
sociated in suspension PVC process for dewatering and
drying arc not necessary. The plant is run by a sequen
tial program; the automatic control of operating pro
cedures results in cxccllfint reproductibility of products manufactured.
| j-- r
CONfir.N\ SLR
PftrPGLYME.R Weft
r* n 'fl
COmOE fJSE ft
Uh
AUTOCLAVE
Tf-
Source.- Hydrocarbon Processing, November 19G8, p, 193.
FILTER
AIR
dust
RESIN SEPARATOR
U>
zer n -<fc>
TO PE SIN RECEIVER
i
MVC
filter
:0.
"Q
CATCc-.riLc-d
MONOMER DAY TANK
V:T
9 I Ei i
u
CXIlll.IT IV-12 USDOL/OSIIA OVCRVICW'OF COPOLVMERJZATION
COPOI.YMERS ARE MANUFACTURED BY THE SUSPENSION', THE EMULSION, OR TUC SOLUTION PROCESS
*
4
pjscd 6n Exhibit 11I-1C data, copolymers represented 12''/jof PVC resin output in 1973. Copolymers are obtained by the simultaneous polymerization of vinyl chloride and up to 15-207. of other monomers such as vinyl acetate, vinylidene chloride and acrylics. The vinyl acetate copolymers arc most important In terms of volume. The production processes differ only in details from the standard polymerization processes. Main points of difference arc in the charging and recovery areas.
(1) .^sponsion .Anil rivi ;ib.j on Copoly tv:c ri z :i t ions With. Vinyl Acetate Arc Carried Out ?TM The Same ITj'iirnKcnt As Iked for Ilrtni^TJolvi'iiori/.ition
The only differences arc the addition of recovery system as indicated below,
fine from vinyl acetate storage tank to the monomer weigh tank and a slieht modification to the
Stripping of the tinrcacted monomers is^tajjq^d out by venting the unrcactcd VCM to a recovery line modified to permit separate recovery of the vinyl acetate. When most of the unr/sacted VCM has been vented to the recovery, steam is sparged through the slurry until a vapor steam containing VCM, vinyl acetate aityj/substantial amount of water vapor is obtained. The recovery line is equipped with two con densers in scries upstream of the recovery compressor.
<\
A two phase system of liquid vinyl acetate andwnter is discharged from the bottom of the condensers. The vinyl acetate, seperateJ by decantation is returned to the process via the weudi tank and the water phase is discarded. Sonic processes are designed to recycle the mixed monomer stream hack to the reaction tefstpjjjit seperation.
(2) Copolymcrizatiotis Involving Vinylidene Chloride As A t^Brjjp^omcr Differ From Homopolymerizations In The Recovery Process
A separation column is usually incorporated in the
train to separate the'unrcacted vinylidene chloride. The column is designed to take
advantage of the lower volatility of the vinylidene chloride (B, P, rjco=3l, 1C), The recovered monomer; arc returned separately to the process and
the charges adjusted accordingly.
Source: Snell assessment based on industry interviews.
BFS 00S5S1
i
Method Major ventilation project Minor ventilation
Venting of temporary tank car connection lines
Installation of new gauging systems on tank car fleet Replacement or reconditioning of reactors (polys) Installation of solvent cleaning of reactors Installation of automatic water cleaning of reactors Additional stripping not requiring new steam generating facilities Additional stripping requiring new steam generating facilities Replacement of strainers
EXHIBIT IV - 13 (1)
USDOL/OSIIA
TYPICAL TIME REQUIREMENTS FOR IMPLEMENTING VARIOUS ENGINEERING CONTROL METHODS
FOR POLYVINYL CHLORIDE PLANTS
Rationale
Time to Complete
Increase rate of air changes in closed buildings
^18nroi^
Install spot ventilation on a piece of equipment: pump, strainer, etc.
1/2-2 months
Dccrcaserelease of VCM trapped between tank car valve, u?ira*sivacuum and/or nitrogen flush
1-2 months
Eliminate thejy/ntinuous emission of VCM which occurs with tbr d?\tube system
Reduce leakagea|fr^anholes, seals, etc.
12 - 24 months
Reduce need to cleaj^fhmually
(Alternative to solvent cleaning)
Reduce VCM emissions ^^am from the polymcrizadon step
jr>
Reduce VCM emissions dowrtstfcam from the poly merization step
Eliminate open strainers and/or substitute closed self cleaning units
CL 24 months 18 months
?
3-8 months
BFS 00S5S2
i
BFS 0085
Method
Installation of rotary compressors to replace reciprocating compressors
Modifications to the piping
Major processing change requiring R & D and demonstration
New plant construction
EXHIBIT IV - 13 (2)
USDOL/CSIIA
TYPICAL TIME REQUIREMENTS FOR IMPLEMENTING VARIOUS ENGINEERING CONTROL METHODS
FOR POLYVINYL CHLORIDE PLANTS
Rationale Reduce ^M^leakage during operation
Time to Complete
C 18 months
Reduce the
r of flanged connections, etc.
e. g. Change Llffrom the batch to a continuous process
1-12 months
A
Install a completeorcdesigned facility
EXHIBIT IV-14 USDOL/OSHA
POLYVINYL CHLORIDE ECONOMICS^1* - 1974
Designed plant capacity (MM lb. /year)
200
Plant investment (MM $)
20
Production (MM lb, /year E 90% utilization)
180
Plant investment per unit of production (d/lb.)
11.1
Cost of Manufacture Vinyl chloride moncmer (1,06 lb, @ 8d/lb.)
d/lb. 8.5
Operating laboi^mu supervision
VS
(PCapital recoveryV(siS^2Tj - 10 years)
All other costs (catarsj|^utilities, maintenance, etc.)
0.4 2.0 3.5
Total cost of manufacture^
14.4
Profitability Net selling price (FOB plantj^-^
18.6
Cost of manufacture Selling, general and administr^jj^xpense
(14.4) (1.5)
Pretax profit
2.7
Pretax return on total investment (<S) 1.2 plant investment)
20%
CD GrasJ roots olanG located on Gulf Coast, producing general purpose suspension resin, prior to the Emergency Temporary OSHA Standards.
Source: Snell estimates based on Milyrom. Tack- Incentives for Recycling and Reuse of Plastics. Washington, Environmental Protection Agency. 1972;
Industry interviews; and mld-1974 Chemica,
Reporter postedjtrices^ tor monom' er and polymer.
BF5 0Q3584
\
BFS 0O85S5
V. FINDINGS AND ECOWQ^lIC ANALYSIS U1
---A
CP
\
V. FINDINGS AND ECONOMIC ANALYSIS
This chapter presents the findings and economic analysis drawn from aggregation of plant-by-plant
economic data, and the detailed data appearing in Chapters III and IV dealing with industry structure and
technology respectively, as well as from the appendices,
.*
Information is presented in individual sections topically addressing each of the key regulatory con siderations of primary concern to the^s^udy (See Exhibit 11-1). Sections follow as shown:
(( ,
VA - Economic ImltfJlfd1t Assessment
VB Personal Pro1^|iVe Equipment Availability and Costs
VC - Monitoring Equipment Availability and Costs
A//'
VD Medical Surveillaiice"foosts
VE Exposure Data
cjr>
BFS Q085S6
v-i
VA. ECONOMIC IMPACT ASSESSMENT
This section presents the estimated economic impact of various regulatory standards on the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) industries. For this study, economic impact is defined only as the direct cost impact on the VCM and PVC industries resulting from compliance with proposed OSHA levels of VCM exposure. As shown in Exhibit II-l, study of economic impacts in other sectors and evaluation of PVC substitutability were not included iip#ie scope of work. The specific study methodology employed and the indicators of economic impact are d^^fed in the respective discussions for the VCM and PVC industries.
1. METHODOLOGY FOR ESTIMATING'yT.jff: ECONOMIC IMPACT IS BASED ON SNELL AUDITS
OF INDUSTRY ASSESSMENTS OF RffCffilRED ENGINEERING, PERSONAL PROTECTIVE AND
WMOnMNTITTOnRmIMNGP Er?Qr\rUIPMENT
CP
''""''""tTM
Information for assessing thej^conomic impact under various VCM regulatory
levels was collected througlart industry survey conducted by Snell.
The cost estimates are develcu^fi^for various compliance levels.
plant-by-plant costs reprS^gJd by industry for various VCM exposure levels provided ^hj^ylata base
individual plant information was aggregated to provide the estimated impact per pound of VCM or PVC produced for the industry
Cost estimates of specified equipment were checked by Snell for order of magnitude validity.
BFS Q0S587
V-2
I
monitoring and personal protective equipment information were compared with equipment supplier quotations
specific items such as compressors, pumps, etc. were validated with supplier quotations
Major cost items for the required engineering steps were reviewed by Snell engineers to determine their accuracy.
Exhibit V-l, on the foil
the economic impact indicators used
2. FINDINGS FROM ECONOMIC IMPACT ON SUBSTANTIAL DATA TO A TARC
THE VCM II CM CEILING
FR ARRHH' 22--55 TW
Snell assessed industry costsi of reducing VCM levels in VCM plants were separated into five categories> ^^nfifcqjihh include:
engineering costs, includ
ventilation
vapor recovery
stripping (product pu
tion)
loading for shipping
other (pumps, piping, etc.)
BFS 0QS5SS
V-3
BFS 00S589
Indicator
* Estimated Industry Costs of Achieving Various VCM Target Levels
Engineering
)
Personal Protective Equipment )
Monitoring and Other
)
- Productivity Loss
Price Impact Analysis
Industry Claimed Time to Reach VCM Target Levels
Percent of Industry "Endangered" As A Function of Target Levels
Change in Emphasis of Engineering Controls in PVC Plants As A Function of Target Levels
Source: Snell
Definition
Based on capacity weighted aggregation of industry reported costs audited by Snell
These are
in the text of the
Economic Irrfpaps^ssessrnent for VCM
and PVC plan{<Lr)ipectively
Productivity losSlsdihe cost of additional
capacity nccdcqtj/ .maintain industry
wide capacity auFc/gefs unimpactcd by
OS11A regulations-^/ *
>
-'C__ i
-
The impact of the casts of compliance
relative to a standard urji^ipacted
price element
f"
Analysis of the distributhah/ijft the times claimed for each plant
The level at which management will seriously consider plant shutdown based on distribution of industry responses
Analysis of the distribution of the major categories of engineering action in the industry responses
EXHIBIT V-l USDOL-OSHA ECONOMIC IMPACT INDICATORS USED FOR THE STUDY
Comments
Expressed as unit capital and annual costs in Exhibits V-2 to V-4 for VCM and Exhibits V-7 to V-10 for PVC
Exhibit C-3 in Appendix C provides
further explanation of productivity loss , Based on data for the plant sa:. pic at each level
Doesjio^onsid^Bi^jiTaaltiuftsin^
supply/demand configurations See Exhibits V-13 and 14 for VCM and PVC, respectively
See Exhibits V-5 and V-ll for VCM and PVC, respectively
Actual
p'lppj
are based on a complex set of factors
Plant-hv-plant
See Exhibits V-6 and V-12 for VCM
and PVC, respectively
. Sec Exhibit V-17 and Exhibit C-S in Appendix C.
i
personal protective equipment costs, including: .. shower and eating facilities
breathing equipment (respirators, air lines and bottled air) .. clothing (uniforms and protective clothing) monitoring costs, including:
personnel moBjipring equipment .. area and lea^lsonitoring equipment
the continued cost oo:$ceeping at the levels unimpacted by OSHA capacity oth^wise derated as a result of regulation the cost includes equmjpent, personnel, etc. but does not include the costs of temporary shutdowns expensed items these include consultant costs, management time, etc. out-of-pocket expenses of 0.01<t/lb are not included since these are considered as one time only costs
\T~a
BFS 00S590
9
For VCM plants, engineered OSHA compliance steps are judged to be significantly the same as those for air pollution coritrol.
Summarized estimates of VCM industry cost impacts and timing to meet selected VCM compliance levels follow in Exhibits V-2 through V-6.
Exhibit V-2 presents tSfip^se of the 50 ppm VCM ceiling
Exhibit V-3 presents th^_^,Se of the 25 ppm ceiling
Exhibit V-4 presents the Ws^ of the 10 ppm ceiling and 2 to 5 ppm TWA (time weighted avera|j^}>
Snell assessment in these Ej^iiits of VCM levels potentially achieved is based upon the exposure deta in Section VE and Appendix B
Exhibit V-5 presents the indu
aimed time requirements for compliance
Exhibit V-6 serves as a summ
scussion of these findings
BFS 008591
V-5
EXHIBIT V -2
USDOL/OSHA
ESTIMATED INDUSTRY COSTS OF ACHIEVINcQl 50 PPM/CM
CEILING LEVEL IN VCM PLANTS AS CLAIMED BTTNDGsTRY
' Snell assessment of VCM level potentially achieved'less than 50 ppm celling with 15 ppm TWA.
AND ASSESSED BY SNELL
Total plants in sample;
9
Processes represented!2); O, STO, DO, DC, G
Location of plants in sample!3); 8W, 1C
Capacity In Sample - Millions lbs, per year (Percent 1974 U.S. nameplate capacity);
5,125 (77%)
Percent Industry claimed capacity from sample for which management will seriously consider plant shutdown
at a 50 ppm ceiling VCM level:
o%
Snell estimate of percent capacity from sample for which management will seriously consider plant shutdown
at a 50 ppm ceiling VCM level:
0$
Direct Costs Engineering Costs!4) Personal Equipment Costs! 6) Monitoring Total Direct Costs! 1) Productivity Loss Total Costs
Capital
Vs/y"S? Lr Annual
Percent of Total Annual Cost
$0.66 0,03 0.38
$0.77
or9'8 f fr6/02<1) 0^3 (7* 8'9) c$0.44
43% 2 19 64%
$0.16 '"$>793
$0,24 $0.68
S6%
100%
Note; (1) Snell estimate of VCM levels achieved in plants incorporating the level of control effort represented in the Exhibit,
Monitoring data is detailed in Appendix B.
(2) O = Oxychlotination, STO = Stauffer Oxychlorinadon, DO = Dow Oxycholorinarion, DC = Direct Chlorination, G = Goodrich Oxychlorination. (3) W = Sited in warm climate, C = Sited in cold climate.
(4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.)
(5) Includes capital amortised < 12% - 10 yrs. and O&M charges.
(6) Includes breathing equipment and clothing.
(7) Includes capital amortized @ 12% - 5 yrs. and O&M charges.
(8) Includes area and personal monitoring equipment.
(9) Includes medical and recordkeeping costs.
(10) ftoductivity loss is the industry average cost of additional capacity, personnel, etc. to maintain industry capacity levels
~ . unimpacted by OSHA regulations, an example is Provided in Pvhit.tr- r--i
Source; Industry interviews ana sneil AlHJBAiM. \
|--
EXHIBIT V-3
USDOiyoSHA
I
ESTIMATED INDUSTRY COSTS IN ACHIEVING A 25 PPM VCM
CEILING LEVEL IN VCM PLANTS AS CLAIMED BY INDUSTRY
AND ASSESSED BY SNELL
Snell assessment of VCM level potentially achieved(l) 25 ppm celling with 15 ppm TWA.
Total plants In sample;
7^2)
Accesses represented^); O, STO, DO, DC, G
Location of plants In sampled); 8W, 1C
Capacity In Sample - bullions lbs. per year (Percent 1974 U.S, nameplate capacity);
3, 625 (54%)
Percent Industry claimed capacity fromsanjjjle for which management will seriously consider plant shutdown
at a 25 ppm ceiling VCM level;
0%^P
Snell estimate of percent capacity from sample for which management will seriously consider plant shutdown
at a 25 ppm ceiling VCM level;
Direct Costs L Engineering Costs (5) . Personal Equipment Costs (7) IIL Monitoring
Total Direct Costs
Capital ($/1.000 1b.)
$1.72 0,03
0.17(9) $1.94
Annual ($/l. 000 lb.)
$0.69(3) 0.04(8) 0.21(8.9,10)
$0.94
ftercent of Total Annual Cost 58% 3 17 78%
Productivity LonfU^s^A
Total Costs
YZ
$0.18
$0.26
22%
100%
BF5 00S593
Notes; (1) Snell estimate of VCM tevjfli achievable In plants Incorporating the level of control effort represented in the Exhibit.
Monitoring data is detaur (n Appendix B.
(2) Two plants npt in this co^fsji^jple did not report cost estimates for a 25 ppm VCM ceiling target but provided an analysis for
a lower target VCM level.
(3) O = Oxychlorlnation, STO = JtAiffer Oxychlorination, DO = Dow Oxychlorination, DC = Direct Chlorination, G = Goodrich Oxychlorination.
(4) W = Sited in warm climate,-^G-=J^ited in cold climate.
(5) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.).
(6) Includes capital amortized @
10 yrs. and C&M charges.
(7) Includes breatliing equipment sm^-elothlng.
(8) Includes capital amortized (S)
yrs, and O&M charges.
(9) Includes area and personal moniti ; equipment,
(10) Includes medical and recordkeep
sts.
(ID Productivity loss is the industry average cost of additional capacity, personnel, etc. to maintain Industry capacity levels
unimpacted by OSHA regulations, an example is provided in Exhibit C-3. Source: Industry Interviews and Snell estimates.
EXHIBIT V-4
USDOL/OSHA
Snell assessment of VCM level potentially achievedSame as industry claimed. Total plants in samples; 9 R-ocesses represented^; O, STO, DO, DC, G Location of plants in sample^: 8W, 1C
ESTIMATED INDUSTRY COSTS OF ACHIEVING A 10 PPM VCM TARGET CEILING AND 2-5 PPM TWA LEVELS IN VCM PLANTS AS CLAIMED
BY INDUSTRY AND ASSESSED BY SNELL
Capacity In Sample-Millions lbs. per year (percent 1974 U. S. nameplate capacity);
5,125 (77%)
Percent industryclalmed capacity from sample for which management will seriously consider plant shutdown at a
10 ppm ceiling and 2-5 ppm TWA VCM level;
0%
TO UJ kfyT
Snell estimate of percent capacity from sample for which management will seriously consider plant shutdown a; a
10 ppm celling and 2-5 ppm TWA VCM level:
0%
Direct Costs
Capital (S/1, 000 lb.)
Annual ($/1.000 lb.)
Percent of Total Annual Cost
BF5 00S594
L Engineering Costsi4)
$3.68
$1.44(5)
45%
II. Personal Equipment Costs(6) IIL Monitoring
0. 09 0.22^8)
o. 07C7) 0. 24^* 8)
2 7
Total Direct Costs
$3.99
$1.75
54%
Productivity Loss^10)
$1.04
$1. 4G
46% `
Total Costs^-* ^
W
$5.03 J
f $3.21 /
100%
Notes; (1) Snell estimate of VCM levels achieCjjli^in plants incorporating the level of control effort represented in the Exhibit, Monitoring
data is detailed in Appendix B,
f ffy
(2) O = Oxychlorination, STO = Stauffer Oxychlorination, DO Dow Oxychlorination, DC = Direct chlorination, G = Goodrich Oxychlorination,
(3) W = Sited in warm climate, C = Sited in cp&l climate,
(4) Includes ventilation, vapor recovery, stii^ng, loading and other (piping, general pumps, maintenance, etc.).
(5) Includes capital amortized (5> 12% - 10 ys#. and O&M charges, (6) Includes breathing equipment and cloth ing. __/ (7) Includes capital amortized (a 12% - 5 yrs. W$Y)&M charges. (8) Includes area and personal monitoring equipMgjttA
(9) Includes medical and recordkeeping costs.
(10) Productivity loss is the industry average annuaiecsSt^of additional capacity, personnel, etc. to maintain capacity levels unimpacted
by OSHA regulations. An example is provided'-iw Dthibit C-3.
(11) Cost estimates include analysis for two plants with a reported 2 ppm VCM TWA (8 hr.) level. ,
Source; Industry Interviews and Snell estimates.
1
EXHIBIT V-5
USDOL/OSHA
U.S. INDUSTRY CLAIMED TIME TO REACH SELECTED VCM LEVELS IN VCM PLANTS THROUGH ENGINEERED CONTROLS
VCM Target Level Claimed by Industry
Sample Total
Number
Capacity.
of Plants (Million Lbs.)
50 ppm celling 25 ppm ceiling
9 5,125 7<2) 3,625
10 ppm ceiling and 2-5 ppm TWA
o 5,125
cP <T-
Notes; (1) Percent of sample 1974 cj^rkrity.
1974 Number Percent of Plants Capacity
1975 Number Percent^ of Plants Capacity
End of Year 1976
Number Percent^
of Plants Capacity
1977
1978
Number Percent^1) Number Percent1)
of Plants Capacity of Plants Capacity
9 100%
17
6 93%
tjD 49
rUu&-A<g ^
G^ . 9%
46%
Jofb# 7
(2) Two plants did not rcportcoJf estimates for a 25 ppm VCM ceiling target, but provided an analysis for a lower target VCM leveL Source; Industry interviews by Snell?
BFS 0Q8595
CP
EXHIBIT V-G
USDOL/OSHA
SUMMARY OF VCM INDUSTRY COST IMPACTS, COMPLIANCE TIME AND CAPACITY ENDANGERED
VCM Target Level Claimed by Industry
SO ppm ceiling
25 ppm ceiling
iS
*fcV<
10 ppm celling with 2-5 ppm TWA
"No detectable"
Snell Assessment of VCM Target
Level
Annual Unit Costs. d/Lb/1^
Direct Costs of Compliance
Costs To Make Up for Loss of Productivity
Total Cost^2)
50 ppm ceiling and IS ppm TWA
0.041
0.03d
0.07 + lO^o
25 ppm ceiling and 15 ppm TWA
10 ppm ceiling and 2-5 ppm TWA
/s--\
W
0.03
0.12 + 20%
0.15
0.32 + 40%
Not feasible
D
on engineering controls,
,
Industry Claimed Compliance Period
Required for Engineered Controls
Percent of Industry "Endangered^3) Based on Sample
In compliance now
0%
2 years
0%
3 years
100%
BF5 08596
Notes; (1) Costs at each VCM level represent the cumulative costsjjncurred to reach the target level. (2) 'The percentage ranges of total costs represent Snell^SrSHmates.
131 Endangered - Management will seriously consider pllfif shutdown. Source; Exhibits V-l through V-5. V
3. FINDINGS FROM ECONOMIC IMPACT ANALYSIS RELATED TO THE PVC INDUSTRY ARE BASED ON SUBSTANTIAL DATA TO A TARGET LEVEL OF 15 - 25 PPM VCM CEILING AND 10-15 PPM TWA
Snell assessed industry costs of reducing VCM levels in PVC plants were separated into five categories which include:
. VCM unlading
ventilatihp^
.. reactor clea^Jpg
.. stripping ifr/tTyCM recovery (possibly to meet a 100 ppm
residual VGfyj/target, but definitely to facilitate meeting
the PV" ' '
target level)
other
C>
breathing equipmerlJEMrespirators, air lines ana bottled air) clothing (uniformVand protective clothing)
BFS 00S597
V-6
monitoring costs, including:
.. personnel monitoring equipment area and leak monitoring equipment medical testing,
.. record keeping
productivity loss
.. the continued cost of keeping at the levels unimpacted by OSHA capacity otherwise derated as a result of regulation the cost incl^^^ equipment, personnel, etc. but does not include
the costs of te
hutdowns
expensed items
these include
costs, management time, etc.
out-of-pocket expenses of 0.033<P/lb are not included in the cost summaries sincC^Eh^se are considered to be one time only expenses.
Summarized estimates of PVC concentration levels follow in
iry cost impacts and timing to meet selected VCM its V-7 through V-12.
Exhibit V-7 presents the (^n^of the 50ppm VCM ceiling
Exhibit V-B presents the case of the 25 to 40 ppm ceiling and 15 to 25 ppm TWA
Exhibit V~9 presents the case of the 15 to 25 ppm ceiling and 10 to 15 ppm TWA
Exhibits V-7. V-fi, V-9 follow page V-7
BFS 00S59S
V-7
F'
EXHIBIT V*7
USDOL/OSHA
Snell Assessment of VCM level potentially achieved
Total plants In sample: 23 Processes represented^): S, E, B. SO Location of plant* in sample^: 5W, 18C
ESTIMATED INDUSTRY COSTS OF ACHIEVING A 50 PPM TARGET VCM CEILING LEVEL
IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL Same as Industry claimed.
Age of plants in sample:
Range, Years
0-5
6 -10 11- 15
16 - 20
21 - 26 ]> 26
No. of Plants
2 10 2 4 2 3
Capacity of sample - millions lbs. per year (percent 1974 U.S. nameplate capacity):
3.750 (69%)
Percent industry claimed capacity from sample for which management will seriously consider plant shutdown at a 50 ppm VCM ceiling:
Snell estimate of percent capacity from sample for which management will seriously consider plant shutdown at a SO ppm VCM ceiling:
Capital
Annual
Direct Cost*
($/l. 000 Lb.)
<$/l. 000 Lb.)
Percent of Total Annual Cost
0% Negligible
I. Engineering Costs^ 11. Pettonil Equipment Cottffl
11.69 0.16
0.9S<5> 0.23m
17% 4
HI. Monitoring
0. 7q()
0.
14
Total Direct Costs Productivity Lois^)
$2.55
$1.90 S6.S3
$3.4B
35%
65%
Total Costs
ffx
$9.08
$5.38
100%
Notes; (1) Snell estimate of VCM level*
plants incorporating the level of control effort represented in the Exhibit,
Monitoring data is detailed in Appendix B.
(2) S - Suspension, E - Emulsion, Dispersion, B = Bulk, SO Solution.
(3) W = Sited in warm climate, C t
in cold climate (U.S. 26C, 10W),
(4) Includes ventilation, loading, leifctocfcleaning, stripping and other (piping, general pumps, maintenance, etc,).
(5) Includes capital amortized <$> l$% - 10 yn. and O&M charges,
(6) Includes breathing equipment and clothing.
(7) Includes capital amortized <> lffisTffjjrs. and O&M charge*.
(8) Includes area and personal moniioiidg^quipment.
(9) Includes medical and recordkeeping,
(10) Productivity loss is the Industry average Annual cost of additional capacity, personnel, etc, to maintain Industry capacity level* unimpacted
by OS HA regulations; an example is stottm in Exhibit C-3.
Source: Industry interviews and Snell
\i
I
BF5 008599
BFS
'*i
<S o co Ch $
EXHIBIT V-8
USDOL/OSHA
ESTIMATED INDUSTRY COST OF ACHIEVING A 25-40 PPM VCM TARGET CEILING AND 15-25 PPM TWA LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL
Snell assessment of VCM level potentially achieved^1) tame u Industry claimed Toul plants in sample? Processes represented S, E, 0 Location of plants in sample*4); 5W , 12C
Age of piano in sample;
Range, Yean No. of Plants
0-5
6 - 10
11 - 15
1
16 - 20
3
21 - 25
>26
1
Capacity In Sample * Millions lbs. per year (Percent 1974 U. S. nameplate capacity);
2,801 (52%)
Percent Industry clalmed.capacity from sample for which management will seriously consider plant shutdown at a
25-40 ppm ceiling and 15-25 ppm TWA VCM level:
ss 4% of original 23 plant sample
Direct Costs
Capital <*/1.000 lb.)
Annual (S/l.OOOlb.)
1Percent of Total Annual Cost
L Engineering Costs^ IL ttenonal Equipment Com^l BL Monitoring
$7.18
1.01
0.67^1
*2.19<6)
0. 7t><8)
0 76(8.9.10)
26%
8
9
Total Direct Cost Productivity Lots^1*^ Total Coin
Vi/'
SHE
*0.38
*18.24
*3.65
*4.87 >8. 52
43% 57%
100%
Notes?
(1) Snell estimate of VCM levels achlevaafc^n plants incorporating the level of control effort represented in the Exhibit.
Monitoring data is detailed in App<*ffiOx'&.
(2) Four plants not in this cost sample did not /epon cost estimates for these conditions but provided an analysis for a lower target
VCM level. Two pUnts not in this saipplq did not provide cost estimates for thlj and lower levels; one reported being endangered,
the other had not completed an anatyaj..
*
(3) S = Suspension, F = Emulsltxi, Dlsperjion. B * Bulk, SO = Solution.
(4) W = sited in warm climate, C = Sited in cold climate (U. S. 26C, 1GW),
(5) Includes ventilation, loading, reactq
Qng, stripping and other (piping, general pumps, maintenance, etc.),
(6) Includes capital amortized 0} 12% - 10 i yand O&M charges.
(7) Includes breathing equipment, cjothinfc ^shoycn. and eating facilities,
(8) Includes capital amortized < 12% - 5 (9) Includes area and personal monitoring t
i O&M charges, ent,
(10) Includes medical and recordkeeping ccec,
(11) froduedvity loss is the Industry averagj^s^f uf additional capacity, personnel, etc. to maintain industry capacity levels
unimpacted by OSHA regulations, excluding plants which reported inability to meet the standard. An example is presented In Exhibit C-3,
c; Industry interviews and Snell estimates.
EXHIBIT V-9
USDOL/OSHA
ESTIMATED INDUSTRY COST OF ACHIEVING A 15-25 PPM VCM CEILING AND 10-15 TWA PPM TARGET LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL
Snell assessment of VCM level potentially achieved^), Same as Industry claimed. Total plants in sample: 16^) Processes represented^3); St E, B Location of plants tn sample^; 4W, 12C
Age of plants in sample:
Range. Years
0-5
6 * 10 11 - 15 16 - 20 21 - 25
26
No. of Plants
1 71 3 2 2
Capacity in sample * mfllioru lbs. per year {percent 1974 U.S. nameplate capacity):
2,600 (48%)
Percent industry claimed capacity from sample for which management will seriously consider plant shutdown at a
25 ppm ceiling and 10-15 ppm TWA VCM level:
2e% of original 23 planr sample
Snell estimate of percent capacity from sample for which management will seriously consider plant shutdown at a
25 ppm ceiling and 10-15 ppm TWA VCM level;
26% of original 23 plant sample
Direct Costs L Engineering Costi^ IL Personal Equipment Coiti^) 111. Monitoring
Total Direct Costs Productivity Losi^*) Total Costs
Capital 0/1,000 lb.)
*26.44 0.48
0. 86<a>
$27.78
r Vp*'
Annual f$/1.000 Lb.)
Percent of Total Annual Cost
*7.30(6)
43%
0. 76(8) 0,9s(8.9.10)
5
6
*9.01
66%
$7.03
itt
$16,04
100%
Notes;
(1) Snell estimate of VCM levels achieved ii Monitoring data Is detailed in Appendix B.
(2) The four plant* not included tn Exhibit V- this coat sample reported endangered itaois
incorporating the level of control effort represented In the Exhibit,
rolled cost estimates for this VCM urge! level. Five additional plants not In
r this level and did not provide cost estimates.
`
(3) S = Suspension, E - Emulsion, Dispersion, ipulk, SO - Solution.
(4) W - Sited in warm climate, C = Sited in cbw climate.
(5) Includes ventilation, loading, reactor cleaning, stripping and other (piping, general pumps, maintenance, etc.)
(6) Includes capital amortized (5> 12% - 10 yn* ... -/-i
(7) Includes breathing equipmentkclothing,. ihowgft^apd eating facilities
(8) Includes capital amortized @ 12% - 5 yrs* o
(9) Includes area and personal monitoring equipment.
(10; Includes medical and recordkeeping costs, \ ---"4
(11) Productivity loss is the industry average annu^l cW^f additional capacity, personnel, etc, to maintain Industry capacity level, unimpacted
by OSHA regulations. This is based on those {Hants foat expected ability to meet the claimed level, shown in the Exhibit. An example is presented in Exhibit C-3
Source; Industry interviews and Snell estimates.
"X)
m
T0 9 8 0 0 S J a
t
'r
05 >1
0 5) GO (E
At these levels (particularly at the high VCM target levels) engineering controls reported by industry principally addresses OSHA compliance but substantial air pollution control is judged to be an indirect benent trom "buttoning-up" or the plant, improved stripping, etc.
Snell assessment in these Exhibits of VCM levels potentially achieved is based upon the exposure data in Section VE and Appendix B
Exhibit V-10 provides cost analyses based on data provided by Firestone for an attempt to reach "no detectable" target VCM levels primarily using engineering controls
Firestone was the only PVC producer reporting an analysis related to a "no detectable" VCM standard primarily using engineering tfcoSqrols
rZ Firestone commiobd that meeting a "no detectable" standard
using-engineering controls is not feasible
?K
The two Firestsna^plants were not included in the industry
summaries for Mgher VCM target levels based on the findings
from the statistical^analysis presented in Exhibit C-4 in Appendix
C for the 50 ppfnCcpiling target; at this level Firestone cost
estimates are inconsistently high with r^cppnt tn
by therest of thfajcfoustry, possibly because these estimates
include costly ei rbnmental protection measures not_directly"
related to OSHA
jliance.
xhibit V-10 follows pa
-8.
V-8
EX-------- V-lC
USDOiyoSHA
COST ANALYSES BASED ON DATA PROVIDED BY FIRESTONE FOR AN ATTEMPT TO KEACH ~MO DETECTABLE* TARGET VCM LEVELS USING ENGINEERING CONTROLS PRIMARILY
Snell assessment of VCM level potentially achieved \ This represents an analysis of an attempt to apptoach "no detectable" levels with actually achieving the level judged not feasible, based on engineering controls primarily.
Total plants in sample; 2 (Pottstown, Pa. and Pettyville, Md.) Process represented^), s and E Location of plants in sampleJ); SC
Age of plants In sample: Plants:
Range, Years
0-5
6 - 10 Perryville
11 - 15
16 - 20
21 - 25
>26
Pottstown
Capacity of plant - millions lbs. per year (percent 1974 U. S. capacity);
507 (9%
Direct Costs L Engineering^ IL Personal Equip men/) m. Monitoring
Total Direct Casts Productivity Los/*) Total Costs
Capital
Pottstown, Pa.
1Perryville, Md.
ft/1.000 lb.)
($/l. 000 lb.)
Annual____________ Pottstown, Pa. Perryville, Md. ,
(9/1. 000 lb.) ft/1. 000 lb.)
Two Plant Average
Capital
Annual
f$/1.000 1b.) f$/1.000 1b.)
$142.56 8.19 3.B5f8)
$154.60
$55.94 0.32 1.29^)
$57fei"1
$53.60<5) l.88<7)
$2S.79<5> 1.81<7>
3.20^)**)
1.4</7* 8>)
$58.68
$29.00
$88.40 3.27 2.25
$93.92
$36.21 1.84 2.07
$40.12
$139.84
7
/ $294.44"
>"7$ap.35 ^
$67.05 $125.73
$15.79 $44.79
$63.52 $157.44
$30.66 $70.78
Notes: (1) Snell estimates of VCM levels achievable in plants incorpor^thy^Sje level of control effort represented In the Esdilblt.
(2) S s Suspension, E= Emulsion, Dispersion.
(3) W = Sited in warm climate, C = Sited in cold climate,
j
(4) Includes ventilation, loading reactor cleaning, stripping and^dbef (piping, general pumps, maintenance, etc.)
(5) Includes capital amortized ( 12% - 10 years and O&M charges.
(6) Includes breathing equipment and clothing.
(7) Includes capital amortized @ 12% - 5 years and Q&M chaiges,_,,_j
(B) Includes area and personal monitoring equipment.
(9) Includes medical and recordkeeping costs.
^ ^(
(10) Productivity loss is die industry average annual cost of additionUTTaSacity, personnel, etc. to maintain industry capacity levels unimpacted by OSHA regulations; an example Is presented In ExhlbtrT>3.
Source: Firestone Case I (0*1 ppm VCM level) presentation to June 1974 O^H^^ating and Snell estimates of costs of productivity loss.
0 9 8 0 0 S jja
i
rr
Exhibit V-ll presents the PVC industry claimed time requirements for compliance , following page V-9
Exhibit V-12, following Exhibit V-ll, serves as a summary discussion of these findings
4. INCREASINGLY STRICT VCM COMPLIANCE REQUIREMENTS ARE EXPECTED TO RESULT IN SIGNIFICANTLY GREATER PRICE ESCALATIONS FOR PVC THAN FOR VCM
. Price analysis did not include consideration of supply/demand changes due to potential plant shutdowns at lower levels.
The price analyses are relative to a standardized price pro forma unimpacted by QSHA compliance requirements and assess price sensitivity of OSHA compliance steps based substantially upon engineering contro's.
Exhibit V-13, .following Extjllalt V-12, presents the estimated impact of
selected VCM standards on
prices.
. Exhibit V-14, following Exhijbil?V-13, presents the estimated impact of selected VCM standards on Ptc nrices.
. Exhibit V-15, following Exhibit V-14. presents estimated capital and annual costs for VCM target levels for J^e'VCM industry.
. Exhibit V-16, following Exhibit VriS, presents estimated capital and annual costs for VCM target leve's for tpejkVCM industry.
UP
BFS 0BS604
V-9
I
EXHIBIT V-ll USDOyoSHA
VCM Target Levels Claimed Gy Industry
50 ppm celling
25 - 40 ppm celling and 15 - 25 ppm TWA
15 * 25 ppm ceiling and 10 - 15 ppm TWA
Attempt to reach "No detectable*
Not feasible based on engineering controls
NOteS: (1) Percent of sample 1974 capacity, 23 plants reporting with a total capacity of 3,750 million lbs. per year. Source; Industry Interviews by Snell
BFS 00S6O5
i
EXHIBIT V-12
USDOL/OSHA
SUMMARY OF PVC INDUSTRY COST IMPACTS, COMPLIANCE TIME AND CAPACITY ENDANGERED BY VCM TARGET LEVEL
VCM Target Level Claimed by Industry
Direct Costs of Compliance
Annual Unit Costs. <t/LbS ^
Costs To Made Up for Loss of Productivity
Total Costs(2)
Industry Claimed Compliance Period
Required for Engineered Controls
Percent of Industry
"Endangered %3)
Based on Sample
50 ppm ceiling
0.19
0.35
0.54 + 20%
0 to 6 monihs
Negllglblef'*)
25 * 40 ppm ceiling with 15 - 25 TWA
0.36
0.49
0.85 + 35%
2.5 years
4%
15 - 25 ppm celling with 10 - 15 TWA
0.90
0.70
1.60 + 50%
2.5 years
26%'
Attempt to reach "No detectable^5) 4. 01
GO
3.07
7.08_+ 75%
2. 5 to 4 years
100%
r fh
Notes; (1) Does not include additional VCM costs resulting from OSHA standard. (2) The percentage ranges of total costs reprcsgtft Snell's estimates based on partial statistical analysis of data. (3) Endangered = Management will seriously ryjnsl^et plant shutdown. (4) Temporary shutdowns for installation of controls were reported. In addition, one plant (not in sample) accelerated a planned shutdown by six months resulting in a loss of P5 50 niiiBjioA lbs. of PVC,
(5) Economic data based on average data showtrfmfexhibit V-10 for the Firestone plants which were not included in the sample for the reason explained in the text. These figures represietifTlie costs estimated for an attempt to reach a "no detectable" VCM level, but reaching this level is judged not feasible based on engineering controls.
Source: Exhibits V-7 through V-ll.
t
b f s 00sees
EXHIBIT V-13
USDOL/OSHA
t,
ESTIMATED VINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1974 DOLLARS)
Item
Unimpacted by OSHA
50 ppm Ceiling (0/Lb.)
25 ppm Ceiling (0/Lb.)
10 ppm Ceiling 2-5 ppm TWA
(0/Lb.)
Extrapoliated Costs of
Attempt To Reach a VCM LeveP)
Plant investment^)
4.08#
4.16
4.27
4.48
11.580
Cost of manufacture
6.13
6.17
6.27
6.31
9.63
Selling, general and administrative expenses
0.30
0.30
0.30
0.30
0.30
Pretax profit on total investment @ 20?o at 1.2 x plant investment)
0.98 ^
1.00
1.02
1.08
2.78
Net selling price (FOB plant)
7.410 fy
7.470
7.590
7.690
12.710
f?''-
Notes; (1) Unit production costs for a 500 million lb. ethylene oxychlorination plant of 1974 construction with total fixed capital of $20.4 million unimpacted by OSHA costs include producuoplpss replacement.
(2) Based on log-log straight line extrapolatiori'&f.efdsting data to a 1 ppm VCM ceiling. This does not imply technical feasibility of engineering controls. Extrapolated costs are for attempting to reifch a "no detectable" level and are used for cost sensitivity analyzing purposes only.
Source: Exhibit IV-4 for basic economics and Snell estimates for compliance levels based on Exhibits V-l through V-4.
^ri in
BFS 00SS07
i
EXHIBIT V-14
USDOL/OSHA
POLYVINYL CHLORIDE ECONOMICS l>4*ACTED BY SELECTED VCM LEVEL STANDARDS (1874 DOLLAR!)
jtem
VCM Standard PVC Standard
< ( Unimpacted ( by OSIA (
Designed PVC plant capacity (million* lbs./year)
PVC plant Investment (dollars millions^3)
PVC production (millions lbs./ year g) 90% utUUatkm)
Plant Investment per unit of production (6/1b.)
Cast of Manufacture Vinyl chloride monomeifd)
200 20
180 11.1
60 ppm Celling SO ppm Ceiling
50 ppm Celling 25*40 ppm Celling 15-25 ppm TWA
25 ppm Ceiling 25-40 ppm Celling 15-25 ppm TWA
25 ppm Celling 2b ppm Ceiling 10*15 ppm TWA
200 2C0 200 200
21. 180
23,3 180
23,3 180
27.6 160
12.0
12. B 8.5
12.9 8.66
15.3 8.66
10 ppm Celling 2- 5 ppm TWA 15-25 ppm Celling 10-15 ppm TWA
Extrapolated Com* To Attempt To Reach a "No
Detectable" VCM Leve/1) Firestone Analyili of Attempt
To Reach "No Detectable" VCM ltve*2>
200 27.6
180 15.3 8.76
200 48.7
180 27.0 12.76
Operating labor and supervision 0.4
\J
'`hCapital recovery (> 12% 10 year*)
2.0
> 6.6 7.6
7.6
13.0
All other costa < catalysts, utilities, maintenance, etc.) 3.5
Total cent of manufacture
1
rjr
--U
iiir
is.
_______ 15.26
_______ 16-16
-- 16.36
-- 25.76
ProHtabQlrv Cdii of manufacture
14.46
15.26
16.16
16.26
25.76
Selling, general and administrative
1.5 1,5
Plctai profit (0 20% it 1,2 pUm Investment)
2,7
Net telling price (FOB plant) 18. fig
2.8 18. 36
m
19. if
m
19. H
21.3d
Notet} (1) Bated on log-log, straight Ur* extrapolation of tiining dm to a 1 ppm VCM celling, Thi* doe* not Imply technical feasibility of engineering centrals. Extrapolated tm are for anu^ptlng ao reach a "no detecuhle" level and are u*ed for cxnt lcncUlvlry analytli
purposes Only. (2) Baaed on Eire*tone data presented In Exhlblr V-10. Thete flgute* represent the coat* animated for an aaenpi to reach a "no detectable"
VCM level, but reaching thi* level k Judged not feaalble baaed on engineering control* primarily. (S) Gran rooti plant, located on Gulf Coast, producing general purpose nnpenden realn, (4) VCM *t price thown on Ethfbli V-U x 1.06 production Artokagc 0. (96/lb. trampori. Soutee; 8all estimates baaed on Industry interview* and price* for VCM presented in Exhibit V-li.
BFS 00SS08
I
Industry Claimed VCM Target Level (2) 50 ppm ceiling
25 ppm ceiling
10 ppm ceiling and 2-5 ppm TWA
Snell Assessed VCM Target Level (3)
Capital Costs (4) ( $ Millions) Direct Costs Productivity Loss
Total
<50 ppm ceiling
$ 5.2
and 15 ppm TWA
$ 1.1
$ 7.2
25 ppm ceiling and IS ppm TWA'
13.0
1.2
14.2
10 ppm ceiling
26.7
and 2-5 ppm TWA
7.0
33.7
Annual Costs ^^
($ Millions ) Direct Costs Productivity Loss
EXHIBIT V-15 USDOL/OSHA ESTIMATED CAPITAL ANT) ANNUAL COSTS FOR VCM TARGET LEVELS FOR THE VCM INDUSTRY AT 1974 CAPACITY (1) (1974 DOLLARS)
Total
$ 3.0
$ 1.6
$ 4.6
6.3 1.7
8.0
11.7
9.8
21.5
(0 19*4 capicirv estimated at 6,699 million lbWapetr year in Exhibit III-l
05(2) Compliance actions are based primarily on einnggfinecerni.nr g control methods-
m
(3) Based upon the exposure data in Section VE and Appendix B
,,:4
(4) Estimates include costs of engrineering controls,''p/fel #nal protective and monitoring equipment. Costs presented represent the estimated cumulative compliance costs for flic VCM level shown in the Exhibit and were estimated by multiplying the costs presented in Exhibits V-2 through V-4 ^ystji^ 1974 VCM industry capacity.
(5) Includes capital costs amortized at 12%
Source Industry interviews and Snell estimates
BFS 0QS609
<
Industry Claimed and Snell Assessed VCM Target Level *2, 5)
50 ppm ceiling
25-40 ppm ceiling and 15-25 ppm TWA
15-25 ppm ceiling and 10-15 ppm TWA
Direct Costs
Capital Costs *3)
($ Millions) Productivity Loss
Total
$13.9
$ 35.5
$ 49.4
48.1
51.0
99.1
Annual Costs *3,4)
($ Millions) Direct Costs Productivity Loss Total
$ 10.3
$18.9
$29.2
19.8
26.5
46.3
151.0
78.3
229.0
49.0
38.2
87.2
EXHIBIT V-1G USDOL/OSHA ESTIMATED CAPITAL AND ANNUAL COSTS FOR VCM TARGET LEVELS FOR THE PVC INDUSTRY AT 1974 CAPACITY*1) (1974 DOLLARS)
(1) 1974 capacity estimated at S, -4135.rnffl^ion lbs. per year from Exhibit 111-4,
(2) Compliance actions are based prirnarnp^on engineering control methods.
(3) Estimates include costs of engineering $ahirols, personal protective and monitoring equipment. Costs presented represent the estimated cumulative compliance costs for the VCM levels shown in the Exhibit and were estimated by multiplying the costs presented in Exhibits V-7 through V-9 by the 1974 PVC industry capacity.
(4) Includes capital costs amortized at 12'i.
BF5 00S610
5. SHIFTS IN ENGINEERING CONTROL METHODS WERE REPORTED FOR DECREASING VCM TARGET LEVELS IN THE PVC INDUSTRY
Exhibit V-17 on the&^iowing page summarizes the distribution of engineering controls for selectedlevels.
Exhibit C-5 in Appen<ii*>C provides a detailed discussion of the distribution of engineering control^fj^selected VCM levels.
Ji /
*A
This section presented economic impact equipment.
iis. The next section discusses personal protective
cP
o
f (p.
Q
BFS 0 0 S S 12
W
V-10
Engineering Control Method VCM Unloading (I) Ventilation (2) Reactor Cleaning (3) Stripping (4-5)
Other (6) Noses follow (Exhibit V-17 (2)
EXHIBIT V- 17 (1)
USDOL/OSHA
SUMMARY OF THE DISTRIBUTION OF REPORTED ENGINEERING CONTROL METHODS ESTIMATED FOR SELECTED VCM LEVELS IN POLYVINYL CHLORIDE PLANTS
Comments for 50 ppm Ceiiing; 25-40 ppm Ceiling with 15-25 ppm TWA; and 15-25 ppm Ceiling with 10-15 ppm TWA ______ ____________ _________
. Modification to transport equipment may be completed by VCM supplier
. Ventilation is used at all levels , Substantial costs are estimated to reach all target levels , Most plants ha^tyjssijtilatioii at the 50 ppm level
. 5 of 19 plants insj^&acactor cleaning equipment for the 50 ppm level . Most plants hav^reacW cleaning for the 26-40 ppm ceiling with 15-25
ppm TWA targerEvel
, Three plants rcport^cwsnditures > $380, 000 at the SO ppm ceiling level, probably for new sywems
, Seven plants report expenditures > $70,000 to reach a 25-40 ppm ceiling with 15-25 ppm TWjJfKarget level. These expenditures represent improvement to existing cquipmcqjr'^ftiree plants estimate expenditures >$350,000, probably for new systems.
. At the 15-25 ppm ceifefl^ ith 10-15 ppm TWA 7 plants report expenditures >$ 1 million, for R&D and new systeft
Extensive modification Uxp&usical plant are estimated for all levels. At 15-25 ppm VCM ceili(igtw4th 10-15 ppm TWA expenditures of >$400,000 arc estimated for such items as emergency reactor pressure relief systems (to VCM recovery) and computerized control systems.
B F 5 B B S S 11
'J i
Notes:'
(1) Fans, ducting, etc.
> '-sJ
(2) Additions to unloading racks, modificarfonsV VCM piping,
unloading pumps and compressors.
.
...i (3) High and low pressure water systems and sdfv^jgjt cleaning systems.
(4) Tanks, pumps, piping, compressors and condensers.
(5) At the 50 ppm and 25 ppm ceiling levels stripping expenditures generally address improvements to present system to meet in plant requirements. The much larger expenditures at the 15-25 ppm ceiling and 10-tgqsj^n TWA levels reflect an effort to also improve the residual free monomer levds^iirf the product.
(6) Non specific pumps, compressors piping, seals, etc.
Source; Industry Interviews and Snell estimated from Exhibit C-5.
EXHIBIT V-17 (2) USDOL/OSHA
BF5 00SS13
i
i
VB. PERSONAL PROTECTIVE EQUIPMENT AVAILABILITY AND COSTS
This section presents the estimated costs, the procurement lead times, and a summary of the available types of equipment as required by the proposed permanent standard.
1. TWO OF THE FOUR TYPES OF RESPIRATORS LISTED UNDER THE PROPOSED PERMANENT STANDARD (PPS) ARE READILY AVAILABLE FROM AT LEAST ONE EQUIPMENT MANUFACTURER
Two of the types of OSHA listed respirators are normally available from the manufacturer in approximately 60 days from the placement of the order. These types are:
pressure demand full-facepiece self-contained breathing apparatus (PD) combination pressu^ demand full-facepiece respirator and pressure
demand self-contairietj breathing apparatus (CPD)
If sudden orders were plac^for 500 to 700 of these units, a"\6 is quoted by one supplier hij^another indicated up/o 40 weekj
/lead time
The two other types of breathj^ig apparatus listed in the PPS are not currently produced. Interviews with manufactur^s,indicate that these devices are considered wasteful of compressed air. These types are:
positive pressure full^fjw^epiece self-contained breathing apparatus
combination continuous breathing apparatus.
respirators and a pressure demand self-contained
THE REQUIRED TYPES OF RESPIRATORS PURCHASED UNDER THE 50 PPM TEMPORARY STANDARD MAY BE USED UNDER LOW VCM CEILING CONCENTRATIONS
The purchase costs for types PD and CPD from exhibit D-8 a<
spectively.
V-ll
BF5 008614
I
The operating and maintanance costs from Exhibit
tetwee
per man per year, with an average of( data estimatecVat $900.
For example, the cost of grade D or better breathable air is $15 per 310 SCF cylinder. With an air flow of 4 CFM, this amounts to a cost of $0.20/minute.
3. INDUSTRY AND THE EMPLOYEES PREFER HALF-MASK AIR LINES,CANISTER OR CARTRIDGE TYPE RESPIRATORS OVER THOSE REQUIRED BY OSHA IN THE PPS
Industry and worker preferences and human factors are detailed in Exhibits D~1 through D-4.
Self-contained devices are heavy, bulky, and require highly trained individuals.
Air line respirators are much lighter than self-contained, but they require a long hose for the air supply and a complicated air distribution system.
Cartridge and canister typ^fgre the lightest and least expensive of the three.
but lifetime has not yet bet^hj&^ly establisKed for~atmospfieres containing VCM. Users of cartridge or canTst^rdLpe masks have no way of knowing when their air
purifier is no longer effecti
Half-fartf
type.*? moW^xWfortable to wear than those with full-facepieces.
however, they do not provide complete facial protection.
4. THE NUMBER OF COVERED WORKERS NEEDING RESPIRATORY PROTECTION INCREASES WITH A
DECREASE IN PERMISSIBLE VCM CONCENlt
3N LEVELS OR REQUIRE HIGHER RESPIRATORY
WEARING TIMES
''
The following table summarizes case studies bohe percentage of workers needing respiratory pro tection as a function of VCM permissible levels, clHQflte of plant location, and plant type (VCM or PVC). More data appears in Exhibit D-ll of Appendix.
V-12
BFS 003615
I
Plant Type
Climate of Plant Location
Ceiling VCM Level (ppm)
Percent Of Workers Needing Respiratory Protection
Percent Of Time Respiratory Protection Needed
Comments.
VCM
Warm
50 25 10 10
1
15^ 15 30 14 100
507,, 50 75 50 100
With Engineering Controls With Engineering Controls Without Engineering Controls With Engineering Controls With Engineering Controls
PVC
Warm
50 25 * 10 ppm TWA +25 ppm ceiling
1
75 100 100
NA
1 With Engineering Controls 3 With Engineering Controls 25 With Engineering Controls
NA With Engineering Controls
Cold
' 50 1
C100 100
10 Without Engineering Controls 25 ' Without Engineering Contra' 100 Without Engineering Controls
Source; Exhibit D-ll and Snell Assessment
6oo
+ ioro
T**( C* r ~t OT* ^
'y_s/
J/ r' 'I
-- ->
5. MOST OF THE TYPES OF PROTECTIVE CLOTffft^ARE AVAILABLE WITHIN FOUR WEEKS FROM ORDER
PLACEMENT
,,^
Disposable clothing, hoods,shoe covtyjs, gloves and overalls are available within one week from the manufacturers iPifclijding one piece pressurized suits, as shown in Exhibit D-9.
Permanent (reusable) work clothin
Full impervious pressurized suits least two months.
Kalso available within one month of order. er, have a procurement lead time of at
r
V-13
BF5 008616
(
6 COSTS FOR PROTECTIVE CLOTHING VARY WITH TYPE, WITH A LOW OF $3.50 FOR DISPOSABLE CLOTHING TO A HIGH OF $178 FOR A PERMANENT, IMPERVIOUS.FULL PRESSURIZED SUIT A full suit of disposable clothing including coveralls, hoods, shoe covering, and gloves costs approximately $3.50. Permanent work clothing costs in the neighborhood of $40.00 per worker for a full suit of clothing indj^pg coveralls, gloves and boots. A permanent imperviou^TuW pressurized work suit which can be worn with an air mask costs $178. InttERiftry believes that routine use of these is not feasible on grounds of human fadfo/tgl, indicated in Exhibit D-5 and concluded from the Snell industry interview^ ^ The cost of cleaning a suit of permanent work clothes is in the range of $1.00 to $1.50 per suit, per workg^ per day. ? -- *
r
^ The next section deals with monitoring e1g^^ment.
V-14 N *I
BFS 00SS1
VC. MONITORING EQUIPMENT AVAILABILITY AND COSTS
This section summarizes the available types of VCM monitoring equipment, their costs, and procurement lead times needed to determine worker VCM exposure under the provisions of the proposed permanent standard
1. THE THREE MAJOR CLASSES OF VCM MONITORING DEVICES: PERSONAL, AREA , AND LEAK, ARE ALL AVAILABLE TO THE VCM AND PVC PRODUCING INDUSTRIES
Personal monitoring, which is the technique recommended to OSHA by NIOSH (see Exhibit E~3) , is availa^fefe^fo industry from the manufacturer within two _ months from'time of order, fiffte gas chromatograph needed for the analysis of their samples can be recefve^ from the manufacturer in two to three months time.
.Area monitoring gvstems of t^^utomatic sequential or continuous type can be obtained for installation withfrf^x months from time of order. Installation could take upwards of two montlj^.
Manual area monitoring systems comprising a gas chromatograph with a flame ionization detector (FID) and f&jdat or Tedlar bags for sample collection can be obtained from the manufacturer within three months. These devices require little or no set-up time.
Leak detection devices such as patfeble gas chromatographs or infrared spectro photometers can be received from suppliers within two months.
If demand for these devices suddently increase, it is Snell's judgment that procurement lead times could double, especially for the more sophisticated types of equipment such as the area monitoring systems.
BFS Q 08618
V-15
t
TIIE COSTS OF MONITORING EQUIPMENT RANGE WIDELY DEPENDING ON TYPE, HOWEVER, MOST EQUIPMENT PURCHASED UNDER THE TEMPORARY 50 PPM STANDARD MAY BE USED AT LEVELS DOWN TO AND BELOW ONE PPM VCM
. Personnel monitoring equipment vary in cost from $300 for automated charcoal
tube/pump system to $70 for colorimetric tube devices. For the automated
system, a back-up gas chromatograph,is required at a, cpst upwards of $7,000 including basic chromatograph, columns j'yecofder,'pnd,, mechanical integrator. ;. /.>,; i '
*'
as shown in. Appendix Exhibit D-5,.
^,
'/*>'''j .
>V j
A Area pnonitorln|t!'syfct<^s of the seqttonUal'gl diVWWRtqitfep}!'type. cost4n<ihh*v .
ft ,
1
neighborhood
000 per 10 gioi{jfcinstrniqjlt system without installAtiort/", " V
Thosq op^ratijSlJ UliQer tTOpiEHtotalTlydrQcar|6on:pi:iflcipIe l^O be ptMfqhifBo^
for $8,000, agfcinVithout ii^Stailation charges.
`
' ' Leak detection equipment, w^jieh are either of the portable gas chromatograph,
total hydrocarbon FID, and ffMryred types cobt from $3,000 to $5,000,,, Nq
installation is required for tpj^ devices.
:
EXPENDITURES FOR MONITORING EQUIPM^jV FOR A TYPICAL VCM OR PVC PLANT AVERAGE
.$..1...0...0...,.0...0...0.....I.N......C....A....P...I..T...A...L......W....I..T...H.....A....N....N...U....A....L.....O...P....E...R....A...T...I.W.....c..T...e....X...P...E...N...S...E...S.....O....F...--$8--0--,-0--0---0---
Personal monitoring equipme^p^ the colorimetric types do not require a chemist
for back-up due to their instantaneous reading capability. The charcoal tube types, however, require a trained chemibal technologist for analysis of samples due to the necessity of using a gas chron^fjjSJfcraph. At least one chemist per plant is needed at an annual cost of $15,000 to $20^000. Overhead, general and administrative and chemical costs in support of the chemist could approximately double his annual cost.
BFS 008619
V-16
The cost of installation for automated sequential or continuous area monitoring systems is approximately $15,000 per 10 point unit with operating and maintenance costs of about $30,000 per year with an operator. A mini-computer can be interfaced with the system for alarming and recordkeeping for an additional $10,000 to $15,000 and 06M costs of $4,000 per year.
Leak detection devices cost in the area of $2,000 to $3,000 for OOM including a part-time operator for each instrument.
THE INDUSTRY AS A WHOLE SHOWS NO PREFERENCE FOR PARTICULAR TYPES OF MONITORING EQUIPMENT, ALTHOUGH THE CONCgB3KjOF AREA MONITORING APPEARS WELL ACCEPTED
The VCM and PVC produueeifrriirg industries employ a variety of different types of monitoring equipment inn^^eeaacchf classification.
w
In personal monitoring, Hbppth.the colorimetric and charcoal tube system are employed. However, the'cinnaaVVcoal tube type are sensitive to lower VCM con-
centrations than colorimetric devices.
j
For area monitoring, both gas chromatographs (GC) and total hydrocarbon
analyzers and combustion q
ctivity detectors are used.
gas chromatographs ^BaEaflooHHde concentration values which are specific for vinyl chloride moonnoofmWer
on total hydrocarbon analyzers, as their name suggests, are not specific for VCM but give the total hydrocarbon concentration in the sample air.
combustion conductivity detectors have also shown great utility in VCM detection at low concentration levels.
V-17
5. AUTOMATIC SEQUENTIAL MONITORING SYSTEMS (ASMS) CAN SERVE AS A LONG TERM DATA COLLECTION SYSTEM FOR AN ENTIRE PLANT
The ASMS can analyze an air sample from a particular point in the plant in 1 to 3 minutes with potential for at least 10 point monitoring.
A system installed in the polymerization building can provide warning to work personnel in that area if VCM levels have gone above ceiling levels.
Personal monitoring data can provide the statisitical basis for locating sampling points for the ASMS .
TWAs can be det^rliH'ned by the personnel monitors for critical areas
C]these values can provide a calibration for the ASMS and determine the
points within an ai^^vhere the greatest VCM exposures are most likely
to occur.
rr-
The ASMS can be used to prp^ide correlation with personnel monitoring data of actual worker exposure. -teCa^dditibn, it can be used to provide a permanent record of VCM levels, provide alarms in case of exceeding ceiling values, serve as a means to initially identify feMgeneral sources of VCM releases, and to monitor progress in complying witlyifcSHA requirements.
6. THE AUTOMATIC SEQUENTIAL MQNITorifl^SYSTEM CAN PROTECT WORKERS AND ALERT
MAINTENANCE PERSONNEL WHEN EXCESSIVE VCM CONCENTRATIONS OCCUR VCM emissions can occur from two sources:
slowly developing minor continuous leakage, such as a worn pump seal
B F 5 QQSS1
V718
0,
serious leakage, such as resulting from an operating error (e.g. valve left fully or partially open) or a serious sudden leak (e.g. blown gasket, sight glass breakage, etc.)
In both cases, the system can prove useful in alarming the potentially affected people.
In the case of a minor 1<^ owever, (with localized effects) the sample point
nearest the leak will regj&ttbf the localized concentration and alarm on the next
sampling indicating locafizod concentration above the limit.
. '.
C/5
Response to either type of al^rm can be standardized. These steps could inclu
donning of personal protective equipment, investigation using leak detectors,
isolating the point of VCM release and corrective maintenance.
CD
CD
00
Os N)
V-19 '
VD. MEDICAL SURVEILLANCE COSTS
This section presents the annual costs to industry for medical surveillance essentially based on th6 NIOSH recommendations to OSHA.
1. THE AVERAGE TIME REQUIRED PER EmIlO^EE FOR THE REQUIRED MEDICAL EXAMINATION
IS FOUR HOURS WHEN PERFORMED OUTp@^ THE PLANT
::
From the information presented in the Appefidfy Exhibit F-2, the time allowance per employee is
itemized as follows:
'
Jft^ ,,r
Travel to and from examination facility -- 2.5 hours
. Examination and laboratory tests -1.5 hours
Maximum time required - 4 hou|^Sr 1/2 working day
2. THE SNELL ESTIMATE FOR TOTAL FXAMIMAtSi COST PER EMPLOYEE IS $160 ----------- :----------------------------------------------------------------- QD . The cost estimate developed by Snell is based primarily on the tests and examination procedures recommended to OSHA by NIOSH as detailed in Exhibit F-3.
The costs were estimated for examination and tests completed out side the plant for a manufacturing facility with 500 covered workers. The total cost for such a plant would be approximately $82,000/year.
BFS 0&SS2J
V~20
V^) 6--
3. INDUSTRY ESTIMATES OF THEIR PrIsE^T MEDICAL SURVEILLANCE COSTS AVERAGE $140 PER WORKER PER YEAR It was assumed by Snell that the examinations performed by the reporting plants were based on
the NIOSH recommendations to OSHA.
V-21 b
i
BFS QQ861
VE. VINYL CHLORIDE EXPOSURE DATA
This section presents Standard and supplied to Sn together with the summary c
es of ambient air monitoring data taken under the Emergency Temporary ustry and OSHA. In addition, the limitations of these data are discussed ! worker exposure for both monomer and PVC plants.
1. INDUSTRY AND OSHA SUPi^Lj^b DATA ARE LIMITED, HOWEVER, THEIR ANALYSES BY SNELL PROVIDED AN INDICATION OF AVERAGE ycM LEVELS FOR THE MONOMER AND PVC PLANTS
The following points describe cthe data limitations:
Sample locations not clearly identil job classifications
monitoring or spot sampling within the plants are wever, the data allowed general association with
The measuring techniques employed for the OSHA data were 10 minute Sippin pump carbon tube samples with a total ambient air volume collection of 1 liter Industry data were collected by organic vapor analysers (OVA), bag samples, charcoal tube pumps, or area monitoring. Some of the data levels represent averages of individual samples gathered at random time intervals.
In general, Snell did not receive raw data from industry, but rather the averages of individual data points without data point statistics (i.e., No. of individual data points, mean, standard deviation, etc.). The OSHA data submitted to Snell are in terms of individual data points, but these are not related to job classifications or unit operations.
In both the industry and OSHA cases, the data population is small.
BFS 00SS25
V-22
The data base is judged inadequate to quantitatively differentiate suspension polymerization from emulsion polymerization which are the main processes of the PVC industry.
Snell arranged the available data in two major categories
VCM Plants PVC Plants
J
The available data were ave^ag^d and then correlated to the various job
classifications. The data pre^fented average levels of VCM for individual
plants which were then used develop an industry-wide profile of average
VCM concentrations.
F)
2. IN PVC PLANTS THE HIGHEST EXPOSURE OCQ^fos IN JOB CLASSIFICATIONS DIRECTLY INVOLVED
IN THE MANUFACTURE OF PVC; WITH VCM LEVELS AVERAGING APPROXIMATELY~15 PPM ACCORD
ING TO DATA SUBMITTED TO SNELL BY INDUSTRY
~~
The following table summarizes the average VcilLteVels by job classification as presented in
Exhibit B-22 in Appendix B.
BFS 00861
V-23 to
I. Production
VCM Unloading VCM Unloaders
PVC Processing Supervisors Senior Reactor Operators Reactor Operators Chargers Stripper Operators . Centrifuge Operators Dryer Operators Utility Men (Cleaners, Laborers, etc.) Baggers Warehouse Overall Production
II. Maintenance
III. Laboratory
Professionals Technicians Overall Laboratory
IV. Management 8 Support
Source: Exhibit B-22
Range PPM
Average
High
Low
16 40
A 10 g
^ 17 19
tP' 35
rr ''NA ' -i'! 13
A
' 25` ` 7V
22 20 30 70 90 120 51
78 20 20
24 CP
92
NA 6 63 184 42 -
<1 2
6
5 1 5 7 5 3 1
6 1 1
2
1 1 "
<1
BFS 00861
V-24 N
I
3. ANALYSIS OF THE MONITORING DATA SUBMITTED TO SNELL BY THE PVC PRODUCING INDUSTRY INDICATES THAT 92% OF AVERAGE MEASUREMENTS HAD VALUES OF 50 PPM VCM OR LESS
As summarized in Exhibit B-23
3% of averages had values of 1 ppm or less 22% of averages had values of 5 ppm or less 58% of averages had values of 10 ppm or less 67% of averages had values of 15 ppm or less 75% of averages had values of 20 ppm or less 80% of averages had values of 25 ppm or less 83%- of averages^had values of 30 ppm or less 84% of averages ^iad values of 40 ppm or less 92% of averages had values of 50 ppm or less
4. ANALYSIS OF THE MONITORING DATflb,TAKEN BY OSHA AT PVC PLANTS AND CONFIDENTIALLY
SUBMITTED TO SNELL INDICATES TMAJ 93% OF ALL SPOT SAMPLES HAD VALUES OF 50 PPM;
WITH VCM LEVELS AVERAGING APPffQ&tMATELY 14 PPM
~~
As summarized in Exhibit B-24
/Ar\ ..
0
3% of samples had valjig^-Vof 1 ppm or less
46% of samples had vali!ie pf 5 ppm or less
56% of samples had valu^sjtojk 10 ppm or less
64% of samples had values^of" ppm or less
72% of samples had values'"-! 20 ppm or less
76% of samples had values of 25 ppm or less
79% of samples had values of 30 ppm or less
86% of samples had values of 35 ppm or less
90% of samples had values of 45 ppm or less
93% of samples had values of 50 ppm or less
BFS 00862S
V-25
Overall, agreement exists between the OSHA data and those submitted by industry to Snell, er, the OSHA data contains approximately twice as many more values, on a percentage basis, in nge of 5 ppm or less. The OSHA data do not specify the unit operations or job classifications ated with each reading.
5. ANALYSIS OF THE MONITORING DATA TAKEN BY OSHA AT VCM PLANTS AND CONFIDENTIALLY SUBMITTED TO SNELL INDICATES THAT 96% OF ALL SPOT SAMPLES HAD VALUES OF 35 PPM OR LESS; WITH VCM LEVELS AVERAGING APPROXIMATELY 8 PPM
From Appendix B-108
84% of 89% of 94% of 96% of
values of 1 ppm or less values of 5 ppm or less values of 10 ppm or less sample^ figd values of 15 ppm or less samples nad^ values of 20 ppm or less samples h^'^yalues of 25 ppm or less samples had Values of 35 ppm or less
INDUSTRY AND OSHA DATA IND1CA
AT AVERAGE VCM CONCENTRATIONS IN PVC PLANTS
ARE LESS THAN 50 PPM FOR THE FOl,pgRROAD JOB CLASSIFICATIONS
The following table summarizes
VCM average exposure levels as a function of
broad job classifications in relation to industry employment in each worker category.
BFS 00862
V-26
I
Broad Job Classification
Approximate 1974 Number of Workers
Production ^ Maintenance t1) Laboratory Management and Support (2)
3,030 1,350
390 805
Total (3)
^ /j'SJ
5,575
Percent of Total
55% 24
7 14
100%
Average of Concentration
16 24 ' 42 J.
15 ^
---------- (P
'
Notes: (1) Includes line supervffc^fc, such as foremen
(2) Includes plant manages, engineering staff, clerical, etc.
(3) Personnel associated wiftAcompounding and fabrication in integrated facilities are not include
(4) Average VCM concentrautm for all job classifications
Sources: Exhibit BI-10, B-22,
essment of data.
(P
7. INDUSTRY AND OSHA DATA INDICATE THAT AVERAGE VCM CONCENTRATIONS IN VCM PLANTS ARE LESS THAN 10 PPM FOR THE FOUR BROAD JOB CLASSIFICATIONS
The following table summarizes VCM industry-wide average VCM exposure levels as a function of broad job classifications in relation to industry employment in each worker category.
BFS 00S630
V-27
I
Broad Job Classification
Production ^ Maintenance ^ Laboratory Management and Support ^2)
Total
Approximate 1974 Number of Workers
410 250
60 220
940
Percent of Total
44% 27
6 23
100%
Average VCM Concentration
4 2 4 1
3 (3)
BFS 00S6J1
Notes:
(1) (2) (3)
Includes line supervisors, such as foremen Includes plant managers.,engineering staff, clerical, etc. Average VCM concentKp||^i for all job classifications
Sources:
wExhibits HI-3, B-107, and jjtf^ell assessment of data.
(?)
A
Based on the assessment of the limi^ed'^data supplied to Snell be industry and OSHA, it appears that average VCM concentrations for the four broajJ job classifications in both the VCM and PVC producing industry are below 50 ppm. Furthermore, the averajlg^VCM concentration in vinyl chloride plants is in the range of 3 to 8 ppm while foi^_pyC plants the averagji^ncentration is approximately 15 ppm.
The next chapter provides conclusions arijSj-ticommendations.
V-2B
I
BFS 0OS632
VI. CONCLUSION^ [fftjD RECOMMENDATIONS .A
<jy
i
VI. CONCLUSIONS AND RECOMMENDATIONS
l
This chapter addresses the conclusions and recommendations of the report based on the findings and economic analysis of the previous section.
1. ACHIEVING "NO DETECTABLE" LEVELS OF VCM PRINCIPALLY THROUGH ENGINEERING MEANS IS JUDGED NOT FEASIBLE WITH PRESENT TECHNOLOGY BOTH IN THE VCM AND PVC SECTORS
Based on the industry surveys and Snell's independent assessments of the state-of-the-art of the technology, it is concluded that achieving "no detectahle" 10 - 1 ppm) VCM levels in the VCM industry is not feasible principally through engineering means. Reasons include The following:
technology, including state-of-the-art developments, is not available to eliminate VCM leaks,aAd fugitive losses
{/ existing plants have
been designed for total VCM containment
there is no design or^bjfi^rating experience in the industry aimed at
maintaining very low
levels
no direct technology transfer opportunities are known to enable development of designs f#jr_j'no detectable" levels in new plants.
Based on the industry surveys agdASnell's independent assessments of the state-of-the-art
of the technology, it is concludeet/tiiat achieving "no detectable" (0-1 ppm) VCM levels
in the PVC industry is not feasib|*!|p)j:incipally through engineering means. Reasons include
the following:
ff)
PVC manufacture is a batch operation
Technology, including state-of-the-art developments is not available to eliminate VCM leaks and fugitive losses
VI-1
9800 533
I
existing plants have not been designed for total VCM containment
there is no design or operating experience in the industry aimed at maintaining very low VCM levels
no direct technology transfer opportunities are known to enable development of designs for "no detectable" levels in new plants.
Up to four years of development is estimated to reduce residual VCM levels below 100 ppm in PVC products on the basis of output volume.
The technology includin^^te-of-the-art developments is not available to reach very low or "no detectab^t^residual VCM levels on the basis of output volume.
2. THE COSTS OF COMPLIANCE INCREAsWfAPlDLY WITH DECREASING VCM TARGET LEVELS AND
REPRESENT SIGNIFICANT ENGINEERING^^CERTAINTY OR INFEASABILITY BEYOND 10 PPM
CEILING AND 2-5 PPM TWA FOR THE ytjgq INDUSTRY AND 15-25 PPM CEILING AND 10-15 TWA
FOR THE PVC INDUSTRY
' * ----------------------- -------------------- -------------- --- "--
The analysis which follows iniUksates the cost sensitivity of attempting to reach very low VCM levels in the VCM industry.
CP
BFS 00S634
VI-2
VCM Target level (ppm)
Historical Practice
Standard Price M/lb.)
1.41
Price Index
1.00
50 ceiling
1.41
1.01
25 ceiling
1.59
1.02
10 ceiling and 2-5 TWA Extrapolated Attempt to Reach "No Detectable" Levels
1.69
1.04
12.l{ ?) 1.12 fp
------------------------
Source: Exhibits V-15 and V-13
f If) :
/,
&--;
o
Percent of VCM Industry Capacity Endangered Not Applicable
0% 0% 0%
iooi7o @ "No Detectable"
Levels
lime To Keacn , level Via Engineering
Controls (years) Not Applicable 0.5 2.5 3.0
Not Estimated
The table indicates the rapid rise in costs'^ssbciated with attempting to reach the technologically infeasible "no detectable" levels beyond the 10 ppm ceiling varrtr 2 - 5 ppm TWA target level.
Exhibit VI-1, on the following pagei5presents a similar discussion for the PVC industry.
BFS 008635
VI-3
I
IXHWT
LrtOOL < 06*4 PVG INDUSTRY CLAIMED ANNUAL COSTS TO
ACHli vt VCN TARGET LtVEU AND SUSTAIN 1974 CAfACITY 01
ECONOMIC IMPACT CRITERIA PLANTS LIKELY TO BE MOST "ENDANGERED ..(2)
Highest compliance costs Plant located in cold climate Old plant Small plant Small reactors Copolymer, emulsion or latex resin production (High free monomer) Small company Merchant sales Slackening demand PLANTS LIKELY TO BE LEAST "ENDANGERED ..(2)
Lowest compliance costs Plant located in warm climate Modern plant with automation Large reactors Bulk or suspension resin production Large company Large plant Captive use of PVC . Highly disciplined plant personnel
AfONAL WWIICTlVI AMO WONlTOAWG CGwPMCNT AS Wt,l At COSTS
m flAflTONC MOVIUtOCOSr (STIWATCS AtlATtn to NO OtTICTAPlt VCWltvLl TOM M AHdiPl MWAHl Y RA<il D m IbGiNMAl'MiOOMIftL'tS CONCLUDING SMflAStflU.fT AND INDICATING THAI HACSfOMt HANTS *OulO D( ALSO kHOANGsMQ
W (Mill OMpt A OF HACMSTUOf AO.ECT'ON FOA TMf INOUSTAV tAHOON FIAiSTfMt DATA KUH trt ItlUlATIOM* 90v*ct HMHatmvmiammG /hco*mMCMArtwnvf
t
99S00 SJ9
For the VCM industry, the engineering control steps for OSHA compliance are significantly the same as those potentially used for air pollution control. Therefore, appreciable air pollution control costs are automatically accounted for by OSHA compliance.
For the PVC industry, engineering control steps from the 50 ppm VCM ceiling level to the f5 - 5 opm ceiling wifhlU - 15 ppm TWa primarily address OSHA compliance. TujT significant air pollution control benefits are gairied, 6Sp6dxally at lower levels. "~~~'
3. AREA MONITORING, PARTICULARLY IN PVC PLANTS IS RECOMMENDED TO OSHA AS A COMPLIANCE REQUIREMENT REGARDLESS OF THE TARGET LEVEL SELECTED BY OSHA
Automatic Sequential Monitoring Systems (ASMS) can serve as a long term data collection system for an entire plant.
The ASMS can analyze an air sample f^qm a particular point in the plant
in 1 to 3 minutes with potential for a i^jQst 1 0 point monitoring.
y-\ The ASMS can be used to provide correlation with personnel monitoring data of actual worker exposure. In addrtiB^, it can be used to provide a permanent record of VCM levels, provide^alarms in case of exceeding ceiling values, serve as a means to initially ide%py the general sources of VCM releases, and to monitor progress in complying with OSHA requirements.
A system installed in the polymerization building can provide warning to work personnel in that area if VCM levels have, gone above ceiling levels.
Response to alarm can be standardized. The&ef^teps could include donning of personal protective equipment, investigation "using leak detectors, isolating the point of VCM release and corrective maint(^Jra:e.
VI-4
BFS 00SS3
4. IT IS RECOMMENDED THAT OSHA ESTABLISH PHASED REQUIREMENTS FOR REACHING VCM TARGET LEVELS TO ALLOW THE COLLECTION OF ADDITIONAL VCM MONITORING DATA TO FULLY ASSESS THE EFFICIENCY OF THE CORRECTIVE STEPS, SUBJECT TO REVIEW IN LIGHT OF CURRENT MEDICAL FINDINGS, AND AS THEY BECOME AVAILABLE
The currently available data base particularly for VCM monitoring, is relatively small. In addition, the technology required for compliance with the lower VCM levels is not yet proven. Consequently, considerable risks exist as to the efficacy of engineering controls even for levels other than "no detectable", which is not technologicslfy feasible.
A phased compliance platf^wQuld allow for the assessment of the efficiency of
corrective steps already n3cfen~hv industry. In any event, significant lead times
exist for hardware requirediaor engineering ^ontrolsT
drThe phased compliance plan Should be reviewed in light of current and emerging
medical findings.
'V-->,
A possible result of a phased compliance plan would be to spread the costs of
compliance over periods of tim&rsy'3'his may be desirable considering that the
VCM and PVC price impacts ma>r^e\of the same order of magnitude as the price
results of the "energy crisis". *
tf>
.
Developmental efforts should be encouraged to improve techniques in personal
protective devices, monitoring systems, and residual monomer reductions.
The Appendices supporting the report follow in a separate volume.
BFS 008838
VI-5
APPENDICES TO
DRAFT FINAL REPORT
ECONOMIC IMPACT b" 'UDIES OF THE EFFECTS OF PROPOSED OSHA S1#? )ARDS FOR VINYL CHLORIDE Contract No. L/A 74-167
Mif'. /^mes Kallenborn Acting Director of Planning, Evaluation and Research OCCUPATIONAL SAFE^AND HEALTH ADMINISTRATION
U. S. DEPARTMENT OF LABOR i, MNlBLAi'iBuilding floff .110 1726 M^jf^eet N.W. Washington, D. C. 20036
FOSTER D. SNELL, Inc. A Subsidiary of Booz, Allen 6 Hamilton, Inc.
Hanover Road Florham Park, New Jersey 07932
September 13, 1974
1
BFS 008S3 9
APPENDICES
A - DETAILED PROCESS DESCRIPTIONS AND PROCEDURES
B - EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER (VCM) PLANTS
C *- ECONOMIC DETAILS
D - PERSONAL PROTECTlW^QUIPMENT AND HYGIENE
C.P
E - MONITORING EQUIPMENT
F - MEDICAL SURVEILLANCE 0R\EMPLOYEES -A
G - SAFETY AWARENESS PROCftlAMS v^ci
H - NIOSH RECOMMENDED OCCUPATIONAL HEALTH STANDARD FOR THE MANUFACTURE OF SYlS^f|TIC POLYMER FROM VINYL CHLORIDE
CP
BF5 008640
,j/' i, APPEMg^ A
BFS QQSS41
APPENDIX A DETAILED PROCESS DESCRIPTIONS AND PROCEDURES
This Appendix presents design details, discussion of critical technological aspects and operating procedures regarding polyvinyl chloride (PVC) manufacture. A list of exhibits follows:
Exhibit A-l presents the receiving, storing and distributing of vinyl chloride monomer (VCM) as it reaches the Union Carbide Corporation. Monitoring for . the vinyl chloride concentration is noted. The unloading mechanism along with the storage parameterize also noted in this exhibit. The special features that are provided to minii^iye^personnel exposure is summarized herein.
Exhibit A-2 presents ailasy diagram of tank car unloading. This schematic is of advanced practice using^s^ot ventilation. Exhibit A-3 deals with reactor design showing a technological overview by Snell. Exhibit A-4 provides a cogipaVison of Conoco's large reactor PVC technology with historical reactor technology.j Exhibit A-5 presents a detaalj^diagram of an older polymerizer design. Exhibit A-6 presents a Pfauc^ft^plasteel Polymerizer, a modern polymerizer design. Exhibit A-7 is a broad discussion of monomer stripping technology. Exhibit A-8 is a typical schematic for polyvinyl chloride operator movements and plant layout. Exhibit A-9 presents a flow diagram for the PVC emulsion process.
A-l
K) I
BF5 00864
EXHIBIT a- 1(1)
USDOL/OSHA
RECEIVING, STORING AND DISTRIBUTING VINYL CHLORIDE MONOMER-AFTER UNION CARBIDE
1. DESC RIPTION
Union Carbide Corporation receives vinyl chloride at South Charleston, West Virginia in 48, 000-
#
gallon tank cars shipped from Freeport, Texas. Due to the size of the car only five tank cars are unloaded per week in an open area used for^u^poading various chemical tank cars. Monitoring this operation on
three consecutive car unloadings y^eldbd the following results:
Date June 28, 1974
July 2, 1974
WOperation
Time Required minutes
Ilookup Car _ -m
Disconnect Car ______________________ tti
20 15
Hookup Car Disconnect Car ^ (J i
19 8
July 3, 1974
Hookup Car Disconnect Car
22 5
Sample Time minutes
20 15
19 8
22 5
Concentration ppm
4 15
6 <1
8 <1
BF5 008643
(
EXHIBIT A -1(2) USDQL/GSHA
Vinyl chloride monomer is received by railroad tank car into a storage area located outside the
boundaries of the plant proper. It is unloaded into a refrigerated sphere from which it is pumped to the
consuming units.
Unloading is accomplishet^fcfjAequalizing the pressures in the tank car and the storage sphere and
' ^-1 then applying vaporized vinyl chl^fuae to the vapor space in the tank car. This provides positive suction
pressure on the pump which tran
vinyl chloride to the storage sphere. After all the liquid has been
f fr^, removed from the tank car, a com^rSbsor pumps vinyl chloride .vapors from the car to a condenser and
A the condensed liquid is then pumpecM3^|he sphere. The vapor pressure in the car is reduced to 5 psig,
Q
and the car is then returned to the v^^chloride supplier for refilling.
The vinyl chloride in the sphere^^naintained under its own vapor pressure (maximum of 29 psig) at a maximum temperature of 15 C by the use of refrigeration, with vinyl chloride serving as the refrigerant.
BFS 008644
i
EXHIBIT A-l(3) USDOL/CSHA
Transfer pumps and piping transfer vinyl chloride to the consuming units as required.
2. SPECIAL FEATURES PROVIDED TO MINIMIZE EXPOSURE OF PERSONNEL
General
.^
(1) The receiving and storage
is remote from the consuming units.
*
(2) A high degree of automation^^mployed, so that there is little need for operators to be near the tank car or the sphere while^uj^oading proceeds.
(3) Nitrogen is not employed as a pressurizing medium, so there is very little venting to rid the system of inert gas during unlading or loading by the supplier.
(4) Safety valve discharges and ot^iejq vent streams are piped to a remote, elevated loaction for discharge.
(5) All pumps handling vinyl chlor^idj^lare provided with mechanical seals to minimize leakage.
(6) Vent and drain valves not requ^^cl for normal operation are maintained in closed position and plug ged with pipe plugs.
BF5 00S645
Tank Cars
t,
EXHIBIT A -1(4) USDOL/OSHA
(7) The tank cars are provided with dip tubes for top discharge only. The dip tubes are provided with excess-flow check valves; if the flow exceeds a pre-established value, the valve automatically closes.
' (8) The tank cars are provided with a tape liquid-level device, which eliminates the need for venting vinyl chloride in deternrfcmffyg the liquid level in the car.
Sphere
(9) The sphere is located in temperately diked ar^ea, with sufficient capacity to contain the entire contents of the sphere, f f?)
(10) Lines leading into the spher^ are provided with check valves, and discharge lines from the sphere are provided with excess-ltto^ check valves.
(11) The sphere and assoc iatecLairiing is insulated for 15C maximum temperature; the insulation is such that it will not decompose if subjected to fire.
(12) The sphere is provided wit^^iter spray protection.
(13) The sphere is equipped with a refrigerated vent condenser (-20C) through which inert gases are vented to the atmosphere.
BFS 0&S646
Scavenging System
S'--'
EXHIBIT A -1(5) USDOL/OSHA
(14) A scavenger compressor sy^Tepi is provided to remove vinyl chloride from lines or hoses which must be disconnected during=*(mding or unloading operations. When scavenging is completed, such lines or hoses are purgfe^fVith nitrogen to a remote vent stack.
Q
03
V- -
m
BFS 00S&4?
Source:
Testimony of Richard T, Hughes, Vice President, Union Carbide Corporation, before OSHA, on Vinyl Chloride Occupational Exposure Standard, July 5, 1974.
i
0.000080 262 0.99
Lbs VC/Lb Prod'k
PPM VC Lbs VC/Hr
Seal Ventilation Fan
EXHIBIT A-2 USDOL/OSHA TANK CAR UNLOADING - ADVANCED PRACTICE USING SPOT VENTILATION
BFS 00864S
Wall Fan (Cl002)
0.000066 Lbs VC/Lb Prod 7 PPM VC
0.821 Lbs VC/Hr
Compressor
7777
Source: Snell industry interview
BASIS 12,400 LBS/HR PVC
<
EXHIBIT A - 3(1) USDOL/OSHA
SNELL'S REACTOR DESIGN AND CLEANING OVERVIEW
REACTOR DESIGN CAN SIGNIFICANTLY REDUCE CHANCES OF EMISSIONS OF VCM
Recent changes have
incorporated to the design of reactors which will contribute
in several ways to minimize ^ftfences of emission.
(1) The Trend To Larger
Reactors Diminishes The Number Of Leakage Points
In early design&//lJ947-1967, the reactors were kettles, usually glass lined,
ranging in size from two to five thousand gallons. The bulk of the equipment
still in use fallsijtvthis category. Q '*
However, new Resigns have been developed together with manufacturing methods
and the most
equipment incorporates reactors which can be as large as
18,000 gallons i=EFl4ss lined and even 35, 000 gallons (Shinetsu) if stainless. Hulls in Germany "^reported to be using a 55, 000 gallon reactor.
Glass lining techniques, transportion restrictions, and heat transfer considera tions will limit the size of glass lined equipment to 18, 000 gallons.
The factory cost of an 18, 000 gallon glass lined reactor is $350, 000, including agitator and drive. The cost of a stainless reactor (clad construction) of 18,000. gallon capacity shoul-' be competitive.
EXHIBIT A - 3(2) USDOL/OSHA
Exhibit A - 4, following this Exhibit, summarizes the advantages and devel opment needs of large reactor technology.
Design steps such as elimination of the manual charging of minor ingredients, the possible use of ball and plug valves, reduction of the number of flanges can hid in limiting leaks from peripherals.
(2) The Newer Design Bojjjj^gh Entering Agitators And Baffles Can Significantly Reduce Possible Monomer L
In the older design, shown in Exhibit A - 5, following Exhibit A - 4, the agi tator usually (enters the reactor from the top, so that the seal around the shaft is containing the high pressure VCM atmosphere. High Pressure Dual Seal de sign is used, Imfc'&ince the sealing depends in large part on the oil pressure in the ring, a prqDtepn may arise in case of power failure.
The same prottefA arises (with lesser severity) with the top entering baffles. Seal deterioration,around the baffles has been observed in several instances and creates a particularly insidious problem.
A newer designT Shown in Exhibit A - 6, following Exhibit A - 5, incorporates bottom entering agitator and baffles; thus the seals are containing liquid. It has the double advantage of making the containment easier and to give visual warning of leakages.
BFS 008650
.w
EXHIBIT A - 3(3)' ' USDOL/OSHA
. Furthermore, the newer design of the bottom entering seals used in glass lined reactors incorporates a pre-seal in which water at a pressure slightly higher than in the reactor is deliberately allowed to leak in at about 15 g.p.h.-, thus precluding the possibility of leakage to the outside.
. For the baffle installation, a new flush glass-to-glass seal has been developed; this design could^ not be used with the conventional no2zle entering baffle.
. In the larger sifc^;Reactors, baffles are used as an auxiliary cooling surface, adding an extra(25 Sq. feet of heat exchange area to an 18, 000 gallon reactor.
(3) The Indirect Effects OfT&titom Entering Baffles And Agitator May Be More Important From The Standpoint QfXft&neral VCM Levels In The Plant
The main reason 'which prompted the design change was the attempt at eliminat ing, or minimizing, the "Bath Tub Ring" effect.
This is the formation at the gas liquid interface of agglomerates which cling to the solid surfaceSajid tend to build up to considerable Size, sometimes break ing out in multipBiwfd chunks. This phenomenon is particularly bothersome at the comparativeiyiow clearance between baffles and wall. With bottom entering baffles and agitator these effects are virtually eliminated since there is no hy draulic dead space for the agglomerates to form and grow. The reduction or elimination of formation of agglomerates lowers the frequency of strainer clean ing and thus significantly minimizes a source of potential exposure. Pipe clogging is less frequent. Perhaps the main advantage is that the need to open the reactor for inspection and cleaning is greatly reduced.
BFS 00&S51
EXHIBIT A - 3(4) USDOL/OSHA
2. MANUAL REACTOR CLEANING IS A MAJOR CAUSE OF EMISSION PROBLEMS AROUND THE REACTOR
While the most obvious problems associated with manual cleaning of the reactor are
the possible emission of VCM upon opening the manhole and the exposure of the man entering
the reactor, these do not constitute
engineering difficulties. Adequate venting proce
dures either are in force or can be,?Hkplemented to significantly limit exposure to VCM upon
opening the manhole. Personal prpfiet^tive devices eliminate tire risk of exposure of the man
entering the reactor. .
C/3 But there are two more se^i^s and long-lasting effects of the manual cleaning operation
the deterioration of the manhole cover sealing surfaces due to unavoidable-^mpping from repeated opening and closing
the possibilly.that during hand cleaning operations a sight glass may be chippSejS leading to subsequent bursting under pressure
ISeveral methods have been propa
cleaning.
(
to reduce or eliminate the need to enter the reactor for
(1) Deterioration Of The Manhole Cover Seal Is A Significant Cause Of Leakage
Every time a manhole is opened in a glass lined reactor, there is a chance for the glass covering the outer part of the manhole nozzle to become chipped.
BFS 0 OSS52
t
EXHIBIT A - 3(5)* USDOL/OSHA
. In addition, there is a possibility of deterioration of the gasket. A combina tion of a faulty gasket and a chipped manhole lip is a frequent source of a sig nificant leak. Until recently, little attention was paid to this feature due to the comparatively high ppm level considered acceptable around the reactor.
(2) Design Improvements HavipWen Developed To Reduce The Risk Of Deterioration Of The Manhole Cover Sea^~~~^
Recently designed jjpliss lined reactors are equipped with an Inconel overlay which is fused to th^glass lining in the vertical portion ofi the nozzle.
This design elimirc^tei the chances of chipping the glass lining and permits a tighter tongue and^grciove metal-to-metal seal which, combined with a com pressed asbestos gagket, insures a much more durable and positive seal. Un fortunately this d^s^gh cannot be applied to older reactors unless they are sent to the factory for in^gjlassing. The turnaround time for this can be 60 weeks.
Replacing the cody_$j]tional manheads with Lenape's can alleviate leaks around the manhole.
(3) Another Danger Area Is The Rupture Of The Sight Glass
During manual cleaning it is often necessary to free the nozzles holding sight glasses from accumulated solids. In the process sight glasses may be accident ally chipped, which may induce an undetected hairline crack resulting in a burst ing of the sight glass when the reactor is pressurized.
i
BBS 008653
EXHIBIT A - 3(6) USDOL/OSHA
Another source of sight glass rupture is the removal of the sight glass for cleaning. Upon re-installation, uneven tightening of the bolts is known to have induced stress in^tfeaglass with the result that when the pressure stresses were added the sjgtWglass burst. A novel design incorporated in the late models of glass lined reatrtdrs eliminates this possibility.
Url 3. IN SITU CLEANING METHODS ^SHOULD PROVIDE A SOLUTION TO THE LEAKAGES CAUSED BY
FREQUENT OPENING OF THgJ^ACTORS
The ideal solution would b^ to eliminate the need for opening the reactor._ Complete in situ cleaning would provide this.aolution if it could be made thorough enough. Several methods exist or are under developmen^^pd a brief review of their characteristics is given here,
(1) Historical Changes Havlr-Already Reduced The Frequency Of Cleaning _ Q3
.
In all reactors involving a change from a liquid to a solidphase, such as encoun tered in PVC production, there is a tendency for the solid to agglomerate and ad here to solid surfaces under certain conditions. This tendency is a function of;
* - nature of the solid and liquid phase(s)
- quality of the reactor surface
presence of stagnant zones in the reactor
"Bath Tub Ring" effect
BFS 00S654
I
!
EXHIBIT A - 3(7) USDOL/OSHA
It has been observed that in the course of the development of PVC production
from its beginning in the 1940's to the present, two changes have contributed to
reduce the frequency of cleaning:
- a trend to larger reactors has reduced the tendency for the agglomerates to bridge, say between baffles and side
formula hinges seem also to have resulted in a lower ten-
` dency for fye solids to agglomerate
The result has been tha^he cleaning frequency has gone down from once every batch to once every foo^or five batches. Yet this still may constitute an un acceptable frequency.
Furthermore, with thq^ trend to large reactors (10,000 gallons plus), structures had to be erected in the reactor to allow for reaching the required areas (usually in the nozzles on the^top cover and at the liquid gas interface). A development was the use of han<H&rected high pressure (up to 10,000 psi) nozzles. This is in fairly widespread ii
(2) There Are Two Basic Memods For Automatic Cleaning With Some Variants: Water Wash And Solvent Wash
One method uses water under pressure and relies on the mechanical impact of high kinetic energy water particles.
BFS 00SS55
I
EXHIBIT A - 3(8) ` ' USDOL/OSHA
There are two variants of the water method:
- very high pressure low volume spray--a typical instance would be 6,000 psi at 50 g,p,m. for a 5,000 gallon reactor. Cleaning time is twenty minutes
low pressure^ugji volume spray--typically, for the same 5, 000 gallon^d^aqtor, 200 psi at 200 g. p. m. Cleaning ' time is tweaty^minutes
By and large the problem
water consists simply in separating the solid poly
mer from the water streq^m^In fact, for large volume applications, water re-use
may be justified.
-
The other method uses srirtvents. At present, there are several solvents in use: EDC, Tetrahydrofuran.^M^Pyrol, and one as yet undisclosed from Robintech,
The solvent method has to variants:
in one^nethod the solvent is allowed to completely fill the reactor
the other solvent method is the use of an automatically con trolled solvent spraying
The main drawback of the solvent methods is the need to recover the solvent (they are quite expensive, on the order of $0. 50 to $1. 00 a pound), and to a certain ex tent it displaces the problem to the cleaning of the heat exchangers or other solvent recovery devices. This is a major reason for which proprietary rights and patents cover these methods.
EXHIBIT A - 3(9) USDOL/OSHA
(3) The Cleaning Methods Are Proprietary But Are Offered For Licensing
At present there are several methods offered for licensing. Two of them are basically water methods:
GOODRICH HRC High Pressure Water
the method^pvolves the use of very high pressure, j^^fractable, multi-directional water sprays^ manual cleaning is required approximately after every ten batches
jthe equiprajS)t cost is about $100, 000 (one unit needed per reactor size class); there is a b66 u^age fee: believed to be nonrecurring
the methcr^ldrawback is that reactors have to be opened to install the portable equipment, causing cSiflerioration of the manhole cover seal
the timSrlag for the institution of this method depends on delays in construction of the special ized equipment, and in acquisition of the ancil lary equipment, pumps, tanks, etc. It is esti mated at about 6 to 8 months
BF5 0QSS5?
1
PFAUDLER Low Pressure Water
EXHIBIT A - 3(10) ' USDOL/OSHA
the method involves the use of a patented
retractable nozzle assembly which is per
manently installed in the reactors. Its ad
vantage is that with twenty minutes of clean
ing after each batch, at least twenty-five batches can be processed before another
type of cleaning is required. An interesting
variant is the use of solvent on, say, every
twentieth cleaning. This is claimed to make~
it unnecessary to
the reactor for other
than annual or serniy mual routine inspection
the sprayuxa^z about df25, 000
ly is estimated to cost
ancillary piping and equipment varies widely depending on the numberAf reactors and such other factors as plant layout, etc. Pr-obably $10, ODO per installed reactor is a good approxi mate figure.
installation delays may b^J^the order of 10 to
12 months
the cost of adding solvent capability may double the capital investment costs
'w
EXHIBIT A - 3(11) USDOL/OSHA
The other proprietary methods involve the use of solvents:
.
STAUFFER EDT
-
the heart of the method is the solvent recovery
unit. A drawback is that it is a soak method
in which the reactor is completely filled. Turn
around time for a 5, 000 gallon reactor is about
three hours
the required equipment involves essentially cir culation pumps, solvent storage tank and a sol- . vent recovery
a license fee basj^ff^n capacity entitles the li censee to flow diatgj?4ms, thermodynamics and energy data, opei^T^g manuals, etc.
the cost of the recfo^ry unit is said to vary from
$75,000 to $150, 000 depending on solvent hand ling capacity. This^qes not include the engineer ing costs nor the storage.^For a 5, 000 gallons per year of sol vent, ojuaification a total installed cosFof $250,000 toiyeb, 000 appears reasonable
such an installation ma# requireuip to 2 years and significant shut dowr^W productibn-fecfuties have to be anticipated
American Chemical is believed to use the Stauffer method with EDC as the solvent. This may be an interesting solution for integrated plants, where EDC is available
*
BFS 0QS659
r,
f
V Source: Snell Analyses
GAF Process SlilNETSU Process
EXHIBIT A - 3(12) USDOL/OSHA
this process uses a trademarked solvent
*
M-Pyrol and retractable spray devices per
manently installed on the reactor. The clean
ing devices are installed typically in 4" noz
zles. They retract behind a quick opening
gate valve during reaction
a problem with this equipment is that gate valves are not very reliable as closing de vices in presence of solids, so that leakage cannot be ruled oifc=tahder pressure. The de sign does not incorporate th** elaborate seals required to contaitf^CM should the gate valve not close complete!^
on
the costs of equiprneat are similar to those for the Stauffer procese^and subject to about the
same installation delays
< Q 1
this is a proprietary process which is an integral part of the Shinetsu jg^ge Reactor Technology. It requires specific Resign features which may not be economically instanwd in existihg reactors. In addition, the proc^g^cannot be used in glass lined reactors.
099S00 SJ3
EXHIBIT A-4 (1)
t,
USDOL/OSHA
COMPARISON OF LARGE REACTOR TECHNOLOGY WITH HISTORICAL
REACTOR TECHNOLOGY-AFTER CONOCO
A new Conoco PVC plant based on the large reactor technology came on
stream in 1971 in Oklahoma City, Oklahoma. Conoco also operates a small reactor
PVC plant in Aberdeen, Mississippi, and the following data are related to small
reactor plants based on our experience at the latter plant. - Approximately 32
to 34 small 2200 gallon reactors are needed to provide the same capacity that
is obtained' in 4 large reactors at Oklahoma City. This means that 8 times as
many reactors must be charged, polymerizations contained, stripped, dumped,
cleaned, etc. The number of mechanical entities (valves, fiances, pumps, etc.)
requiring maintenance (leak problems) is substa'ptffilly less in the large reactor
plant, a scrong p63lElV6 FACtdT lTi ITS fAVOT.
over, most ot the mcchanj car
steps in the new plant are carried out by remotefc&otrol while the operator
keeps all phases under observation by means of ctjggts, schematic diagrams, lights,
and closed circuit TV cameras. These comparisons^aee also based on considerations
of the cooling water availability, product mix and* the particular chemical and
engineering approach in use.
KJf*)
Host of the small reactor plants have been constructed with the reactors contained in buildings. Our large reactor plant h^i^nly a roof over the reactor building. The associated piping, instrumentation,0etc. are enclosed on the sides by a protective metal scrccn-iike structure t-/hich covgrs only about two-thirds of the vertical rise. Therefore, the reactor areattjQessenlially "open air".
The large reactor technology, when producing 'fcSn^truction type resin, re-
guires personnel entry only about once every thirty oda&s; in small reactors, entry for cleaning is about every 4 or 5 days. Reduced oih&cg frequency is obviously pre ferred until the goal of zero personnel entry can be achieved by additional re search on "clean wall" polymerization formulations. Until that time a combination of solvent cleaning followed by periodic personnel entry in the reactor to manually chip away polymer will be required.
i
EXHIBIT* A-4 (2) USDOL/OSHA
Our large reactor plant provides about a 98% yield of PVC based on vinyl chloride monomer charged whereas small reactor plant yield is only about 94 to 95~. '..'bile the distribution of the yield loss is not fully defined, wo believe a significant reduction in atmospheric emissions is being obtained. In addition to the differences in product mi x, this difference in yield reflects the fact that fewer operational steps are required in large reactor technology which minimizes the loss of both solid PVC and caseous VCtl. This should provide a workplace with a lower risk for the entjpipyeo of VCH exposure.
Large reactor manpower requircmentd^ar.0 approximately one half that of small reactors on an-equal production pasiffC^ 2Vo large reactors require two rcactorr.cn per shift. Sixteen small reactqjfs^, the -number necessary to equal
the production of two lat'gc reactors, requirff^four rcactormcn per shift. On a per pound basis, large reactors require 0*084 reactormen per million pounds per year while small reactors require 0.1C8. A
In vie w of what we believe to be positive advantages for large reactor
plants, wc plan to install additional large rea tors to replace the small reactor
Sections of the Aberdeen plant when approprii
cchnology is available. At
the present time, large reactor technology is? dted to a very specific range
of rosins which find application in the constl
ion industry. Those types of
resins co not have rigorous requirements on several important PVC properties;
e.g. "fisheyns". Although higher quality resiiw 'Suitable for wire and cable,
calendering and ether applications have been demonstrated to be technically
feasible in our large reactor technology, significant additional developmental
effort will be required to demonstrate production of these resins on a commercially
practical basis. To accomplish the goal of replacing our small reactors at
Aberdeen and of providing resins required by the market, we believe that the
following is a very realistic timetable:
r
EXHIBIT A-4 (3)
USDOL/OSHA
\
Basic BSD Program -vja=Syear.
Engineering design an&^pJptaining bids - 1 gear
............... Plant construction and
rt up - 3 years
This engineering analysis indicates that 5 yedfkare required to implement tech nology required to satisfy market demands while it$intaining our employee VCM exposure in keeping within our proposed standardIn the interim, we plan to
meet the proposed standards by restricting wortepractices (by use of protective equipment, etc.),until such time as we are able ^tg^mplement the replacement of small reactors with large reactors.
99S00 s^a
Source:
Submission to Docket Officer, Docket OSH-36, OSHA, by R. W. Genwig, Vice President, Continental Oil Co., June 27, 1974.
i
' Wi
EXHIBIT A-5 .. US DO L/ OSHA POLYMERIZER DESIGN
BF5 0086
Source: Pfaudler Bulletin 1051, Glasteel Polymerizers
EXHIBIT A - 6 USDOL/OSHA
E
it)
*
i
.
arm/ .<i i}jwhithij.i
im i i mi j ;i
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BFS
B0SS65
' Vi
EXHIBIT A-7 (1) USDOL/OSHA
BROAD DISCUSSION OF MONOMER STRIPPING TECHNOLOGY
IMPROVEMENTS TO THE STRIPPING STEP IN PVC PRODUCTION WILL MINIMIZE VCM EXPOSURE HAZARD DOWNSTREAM FROM THE REACTORS
Residual VCM in PVC slurry downstream of the reactor causes problems of potential VCM emission
through "degassing" of the finished products. Furthermo^eprthere is the possibility of emission in blending
and in-process storage, centrifugation, drying and producerHandling if there is a significant concentration
of unreacted VCM in the PVC slurry, or resin.
i
Historically, the stripping operation was tailored to ir^^niize VCM losses and thus increase the prod
uction yields. A new dimension has been introduced to this onfifcation by the recognition of the hazards
which may be created by the existence of significant VCM concentrations in the atmosphere as a result of
residual monomer.
^4
""A Limiting residual monomer in the resin can reduce expoiure risk from unit operations downstream of
stripping, limit air pollution from dryer exhausts and other dotewlf|ream sources and limit the exposure risks
of compounders and fabricators.
W"
Thus, improvements to the stripping, which are not econopiipally justified by the value of the VCM recovered, have become necessary. This discussion addresses RseTf broadly to the technology of stripping.
999800 SJS
r'i
EXHIBIT A-7 (2) USDOL/OSHA
Cl) For Economic Reasons The Stripping Method Which Was Found Historically Practical Was The Depressurization Of The Reactors Through A Recovery Unit
A substantial VCM pressure exists at the end of the polymerization cycle. The reactor atmosphere, which is essentially composed of VCM vapors, is vented through a system in which the VCM is cooled and recompressed to a liquid phase which can then be returned to the process. Up to 10-12% of the initial charge can thus be readily returned to the process. However, at at mospheric or near atmospheric pressure a significant concentration of VCM (2 to 3%) remains . in the slurry. Slow liberation of VCM occurs when the atmosphere in contact with the slurry is renewed, but the bulk of the free VCM is dissiptp|Qduring the drying step.
Additional treatment of the slurry via, for in&an^e, reduced pressure, heating, etc., requires both equipment and energy, the costs of wmS&are not justified by the value of the minor amount of VCM thus recovered.
KJx The geometry of the reactor, which is favorable to agitation and heat exchange is not the most favorable for stripping due to a low ratio of fre0f*Wea to liquid volume. This aggra vates the foaming problem which is often encountered afrcHrequires the use of knockout pots on the recovery lines. Thus, some plants have incorporated an additional vessel in which the stripping takes place. Usually this vessel has aboifcf'jtWice the capacity of the reactor and can be of a different geometry (horizontal cylindrical taJSgljwith the liquid level near the cen ter line. This offers not only a better area volume ratiovSyt also a considerable extra capac ity for whatever foam layer is formed. The stripping ra^e^d degree of completion can thus be improved.
BF5 00SSS
EXHIBIT A-7 (3) USDOL/OSHA
(2) An Improvment To The Stripping Which Has Been Implemented In Some Plants Is Pressure Reduction By Steam Jet Or Vacuum Pump
Reduction of the pressure of VCM over ttfif^ilurry will result in a reduction of VCM
concentration in the slurry itself. The advantffgl of using a vacuum pump is that the dis
charge of the pump can be handled directly viafth& recovery system. Steam jet exhaust h
to be vented to the atmosphere, thus creating aTwflential environmental problem.
w
(3) A Further Refinement Is The Sparging QfJ^ve Steam Into The Slurry,
Preferably Under A Reduced Pressure
*
A further refinement of technology consist
he application of heat to increase the
partial pressure of the remaining VCM. This, cobpled with reduced pressure over the slur-
w
BFS 00886S
EXHIBIT A-7C4) USDOL/OSHA
(4) More Sophisticated Stripping Methods Are Under Development, But This Work Is Highly Proprietary
As a result of the Emergency Temporary Standard, the industry has been engaged in a vigorous development program addressing itself to the problem of residual monomer in the finished product. In the table below are presented some typical residual monomer concen trations in the major resins since the promulgation of the Emergency Temporary Standard.
Resin Type
Suspension Emulsion Bulk Solution Copolymers
Reported Range of Residual VCSfA . (ppm) .fX
r)
50 - 4,000^1 1 - 400 \J)> 0 -_35 (P
10 - 14,000 A
0-
Representative Average (D
____
(ppm).............
500 10 20 1.5
1,000 - 7,000
(1) Average value considered by industry sources-jo represent residual VCM levels in common resins of the type indicateX==$pecialty resins, which
represent 10% to 15% of production (generally suspension resins) were re ported to contain up to 8,000 ppm.
Source:
Industry interviews by Snell
It is seen from the table that considerable reductions are needed in free VCM levels in some resin categories to reach the 100 ppm levels advocated at the OSHA Hearings.
BFS 00SSS9
1
EXHIBIT A~7 (5) USDOL/OSHA
A considerable amount of development work is being carried out, principally addressing itself to the stripping step, to achieve a drastic reduction of residual monomer levels. However, it is reported that for many products increases in the stripping efficiency, e.g., through steam sparging, results in unacceptable deterioration of product characteristics such as, for instance, coagulation of latex. Thus, the development program has also to incorporate changes in the polymerization steps, such as reformula tions . The nature and type of the information handled in this development work makes it so confidential that no technical details are publicly available.
*
Very generally, sophisticated stripping methods such as countercurrent or cascade stripping are said to be under study.
(5) Implementation Time For Stripping Improvements Ar&Variable
Introduction of vacuum stripping is comparatively ea^yahd will result in immediate improvement in
the few remaining plants which do not have this capability .^Implementation time of the order of six months
is required.
Qm
Steam sparging will require more time due to the addetr requirements of the recovery system which will have to incorporate reflyx condensers for the water vapor y^From 1.5 to 3 year implementation time can be expected. Time requirements are greatest for those pl2m$ which will require additional steam generating capacity.
Stripping of copolymer and latex products to below 100 p1 require significant technological development.
ree monomer levels is reported to
Newer, more sophisticated methods may already be in the implementation state or, on the other hand, be only at the earliest phase of development. Levels of residual monomer below 100 ppm for all products on a quality controlled continued basis are probably years away.
CD Source: Snell Analysis
BFS 0QS6?
BFS BOSSF1
EXHIBIT A-9 USDOL/OSHA
BFS 0QS6?
APPENDIX B
ar> rjP
EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL
iQRIDE MONOMER (VCM) PLANTS
BFS Q0S6?
(P
APPENDIX B
EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER (VCM) PLANTS
This appendix presents exhibits summarizing the exposure data from a number of PVC and VCM plants. The appendix also contains a confidential inventory of PVC workers for 1974 (see Exhibit B-l), used for reference purposes in Chapter IH discussion^srfjamployment.
An explanation of the elements of the codjlngjthat is assigned to the data sources follows:
Random leading numbers onlyj^roear for VCM plants . Random leading numbers appeW for pVC plants followed by possible
symbols as shown
PVC plant capacity S = small, less than 100 millil M = medium, 100 to 200 millio L = large, over 200 million lbs
PVC plant age New = 0 to 10 years Int. = 11 to 12 years Old = over 20 years
PVC plant siting C = cold climate W = warm climate
B~1
I
BFS 0Q 8S74
The exhibits presented in this appendix are arranged in the following manner for clarity of presentation.
Exhibits presenting PVC industry submitted VCM monitoring data are numbered B-2 through B-21.
Exhibits B-22 through B-24 present the Snell assessment of the industry data and data submitted to Snell by OSHA.
Exhibits numbered B-100 through 106 contain VCM industry submitted VCM monitoring data.
Exhibits B-1'07 and B-108 sH&^the Snell assessment of the industry data and data submitted
to Snell by OSHA.
? Q
The data contained herein will provide general location of VCM source in a plant, VC concen
tration in ppm, number of employees expWeu at given work posts, and in most cases the measurement
methods.
(/)
There is some evidence that data obtay^ from manual sampling versus area monitoring may be
biased downward. A PVC producer presentqfP&ata showing the comparative results of sampling in the same area by manual methods and by means of jJye twenty points automatic sequential sampling chrom atographs. The results are presented below.''
Manual Sampling
^4umber of Samples
tp
216
Average 10.14
Point Range (95%) 0 - 46
Automatic Sampling
one full day
16.30
0-64
Without a statistical analysis of the population it is premature to affirm that a bias exists be tween manual and automatic sampling, particularly since one deals with a one-sided distribution. However, in view of the magnitude of the difference of the averages a real bias is likely.
BFS 0086F5
B-2.
EXHIBIT &-1 USDOL/OSHA CONFIDENTIAL INVENTORY OF POLYVINYL CHLORIDE WORKERS'- 1974
Plant Start- L'p Date
No. of Workers
Plant Stan-Up Date
No, of Workers
1957
64
1947
140
1963
46
1959
74
1961
80
1955
150
1963
155
1950
74
1946
75
1971
30
1966
158
1953
241
1968
120
1965
200
1954
130
1947
350
1953
1965
70
1960
1965
180
1970
1942
266
1946
1969
90
1956
1955
98
1956
1968
150
1956
1965
95
1966
1967
160
1963
1957
70
1936
1949
322
5,045
DQ
>1
(1) Since the data is coded and confidential accoi
the source. It is not clear to Snell what the precise definition of "PVC
Worker" Is,
Source: Statement of PVC Producers in the United States R^jji^e to Health Experience of Workers in Plants Polymerizing Vinyl
Chloride, Draft No. 3, 5/28/74, per private communication with Snell by Arthur B, Steele, Operations Manager, Union
Carbide Corporation Chemicals and Plastics, July 26, 1974.
CD
00 Q\
M
I
EXHIBIT B ~2 (1) USDOL/OSHA MONITORING RESULTS FOR 12 - M - INT. - C
Job Classification
Average Exposure (ppm VCM)
Number of Data Points
Suspension Area Foreman Homopolymer Reactor Opterator Copolymer Reactor Operator Dryer Operator Bagger/clQner
Labor PooWeieaner
8.4 10.0 26.1
5.6 5.0 5.3
39 79 76 24 59 o5
Plastisol
'''rf (T\
Area Foreman^ Shift Foremai^Jj)
Tower Operator x
Laborer
//
Bagger
Atomizer Dryer O
Additive Dryer Op'
16.2 3.7
19.0 7.6 2.5 2.0 2.2
32 27 176 100 71 26 23
Laboratory Q.C. Lab, Supv. Analytical Chemist
iP
Colorist
Q.C. Technician/Days
Q.C. Technician/Shift
\ 2.5 0.7
16.2 0.8 3.9
6 6 6 5 46
Maintenance . Maintenance Foreman Mechanic/Shift
N
3.6 3.7 *
28 130
BFS 00S6?
Job Classification
Warehouse and Miscellaaajrous
Warehouse Supv.,/^;.
Warehouse Shippir^jgCjlerk
Warehouse Receivin^felerk
Warehouseman
\J) *
Effluent Plant OperatQfjJ^
Boiler Operator
Utility Man
^
Yard Man and Service Mgn A
(P
Average Exposure (ppm VCM)
0.5 1.8 1.7 0.7 1.9 0.9 11.0 0.3
EXHIBIT B -2 (2) USDOL/OSHA
Number of Data Points
7 6 5 '23 22 26 36 9
Source: Snell summary of industry data
I
Job Description
Supervisor Senior Operator Reactor Operator Solutions Operator Utility
Recovery Operator Finishing Operator Bulk Operator Bagger Artisan Operator Mechanic Bulk Loader Lab Technician
Duties
Number of Employees
General Supervisory
General Roving Duties
Reactor Charging, Dumping
Reactor Charging, Dumping
Reactor Clea&ipg
' (P
Stripping, Trailer Slurry
Drying
A
Bulk Loading Resirrt'ransfer
Bagging
Monomer Unloading^JJjS^ities
Maintenance
Material Handler Analytical
8 4 4 4 4
4 4 5 6 4 5 3 4
EXHIBIT B - 3(1) IISDOL/OSHA
17 - S - INT. - W
Average ^ 8 Hr. TWA PPM
Type of Exposure
5 Intermittent
8 Intermittent 22 Continuous 19 Continuous 16 Intermittent
Wear Masks 17 Continuous
7 Intermittent 7 Intermittent 14 Intermittent 6 Intermittent
3 Intermittent 7 Intermittent 1 Intermittent
BFS 00867
VO
EXHIBIT B- 3 (2) ' USDOL/OSHA
Job Description
Supervisor 3rd Floor. Operator Utility
Duties
General Supervisory Reactor Charging Reactor Cleaning
Number of Employees
8 8 6
2nd Floor Operator Dryer Dryer Bagger Area 5 Operator Maintenance Mechanic Material Handler Lab Technican
Stripping Transfl^of Slurry
Drying
Bulk Loading Reslg^ransfer
Bagging
(Jft
Monomer Unloading Unities
Maintenance
c
Warehouse Work
Analytical
Note: (1) Data collected May 1 - July 15.
4 4 4 6 4 6 3 8
Source:
Snell summary of industry data
Average 8 Hr. TWA PPM
5
m
22
16 -
17
7
7
14
6
3 7
1
Type of Exposure
Intermittent Continuous Intermittent Wear Masks Continuous Intermittent Intermittent Intermittent
Intermittent Intermittent Intermittent Intermittent
BF5 0ess80
t
Unit Operation VCM Unloading
Reactor Oper ation
Drying & Product Trans fer
(1) Current VC, ppm
How Measured
Typical = 40 ppm Ceiling =500 ppm
Gas Chromat ograph
Organic Vapor Analyser
Typical f 25 ppm-'; A
oCeiling =300 pp'ro.'v.-
"
pp,, UP Typical = 20 Ceiling = 75 ppm f jfj.
!
Historical VC, ppm
N/A (2)
N/A N/A
EXHIBIT B -4(1) USDOL/OSHA MONITORING RESULTS FOR 19-L-NEW-W * How Measured N/A
N/A
N/A
BFS 00SSS1
Mechanical Repairs (Flange Breaking, etc.)
Typical = 30 ppm Ceiling =1000 ppm
(1) Five minute average (2) None Available
N/A
Cft
N/A
BFS 00SSS
I. VCM UNLOADING AREA
Activity Area
Under Compressor Shed Cuaging VCM Storage Tanks VCM Transfer Pumps VCM Unloading Platforms
II. V-ll VINYL BUILD!NC
Activity Area
Buildi At the1 Water B( Fresh A
System xposure ip Strainers ing Reactor stem
II. V-12 VINYlf BUILDING
-A---c---t--i-v---i-t- yj----A-- jr--erA
Recovery Sy Building Exp At the Dump S' Water Blasting Charging Contr
EXHIBIT B -4 (2) USDOL/OSHA
VCM LEVEL ppm 10 - >200 80 10 - >100 10 - >200
VCM LEVEL ppm 5 ->100 5 - 7100 5 - 7100 40-180 0-10
VCM LEVEL PPTM 5 - >100 5 - >100 5-65 40-180 5-65
EXHIBIT B -4(3) USDOL/OSH0 ,A
IV. V-ll DRYER BUILDING
Activity Area
Centrifuge discharge Sifter deck Bird deck Slurry Hook-up Station Resin Hook-up Station Cleaning Dryer In Dust Collected Taking Silo Rei^aiiigs Sifter OvcrfloW^>-\ Resin Bagging Resin Warehouse
V. LARGE REACTORS fJp
Activity Area
Recovery Swefo VCM Charge Pumps
Source: Snell summary ^Sf^jidustry data
VCM LEVEL ppm
0 ->100 10-100 10-100
10 ->100 6 ->100 25-35 8-80 10-90 . 10-35 10-100 10-20
VCM LEVEL ppm
5 ->100 5 - >100
0-30
I
BFS Q0S&83
i
EXHIBIT B - 5 (1)
USDOL/OSHA .
MONITORING RESULTS FOR 40 - L - NEW - W
Uni t Opera I Lem V-12 Charge
Current VC, ppm 21
V-12 KtcqV^ry OperationN^'
V-12 Maintenance
Mechanic
^
AV-12 Utility
12
11
V-ll Charge Operation
42
V-ll Recovery Operation
V-ll Utility
50
<J>
102
Large Reactor Lead Operator
1
Large Reactor Operation
Resin Bagger
5. 13
Vinyl Area Maing. Shop
3
How Measured
Historical VC ,ppm_____
Gas Bag
N/A
Gas Chrom atograph
How Measured
N/A
BFS Q0S6S4
EXHIBIT B - 5(2) USD0L/09HA
Fork Lift Operator
17
Receptionist Office
1
Engineering Offices
1
Maintenance Shop
1 iP
monitoringjo; Note: . 1) Continuous
as yet experimental,
^
2) ABD & OKC are presented separately because of difference of equipment and technique.
Source;
Snell summary of industry
BFS BQS6S5
EXHIBIT B - 6*(1)
USDOL/OSHA
MONITORING RFSULTS FOR
Table I -- Vinyl, Chloride Levels
* i 4 - M - NEW - W
(non-respirator areas -- grab samples) May 1 -- June
Location
Operation
Vinyl Chloride --JEBB !V
*
Median LoV7
BFS Q0S6SS
Day Tank Area
Compressor IK-1
Compressor 2K-1
VP Seal Discharge
Bloyr Discharge
Popp Sampling
109/209 Blind
Warehouse - (2)
Laboratory (3)
m*
(3)
.. .
(31
Office J3) , .
Pumping VC De-gas
,
De-ga^)
During(^Ekaning Before ^O^charge
.
Changing^Slind
0
Aisle
^
WorkbenclV-^^,
Office ^ Compositing Samples Center of Area
3.4 0.0 71.6
7.0 0.0 .136. .
3.0 0.6 31.4 .
8.4 o.3 ; 159.'-
?.o 0.*9 '34.0
4.5.. 9.3 5.2
0.0" 46.5,
\
0.4 . 137. -'r' .
0.0 7.7
4.0 '
1.7
Not Applicable II II * 3. *
6.4
If
1*
2.1 , n
' " v.': '
Table H -- Distribution of Data -- 1 110 Grab Samples^)
May 1 to June 26, 1974
VC Levels
EXHIBIT B - 6(2) usdol/o$ha
Minimum Value Maximum Value
0.0 ppm 159 ppm
'
BFS 00868
10% of samples showed VC levels of
20% fl
it V
ii 'Vff "
30% II
II
II
0.5 ppm or less fi
1.1 ii
it
v
1.7 ii
, ii
40% 1 .,50% . M . 60% l
* If
' & " 2.9 n ii
II
" rp "
4.0 M
i * '
6.4 11
i
70% II 80%' II
II
II
"
9.7 II " 14.9 19
ii
<
|
90% 95% 97.5%
II
%
It
II
i. 26.2 1 '7 If ; v*
XM 39.7 II% IV
i ii
ii 71.fr II 1 . . '
ssssee s^a
Similarly:
3.64% showed VC levels^greeter than. 50 ppm
4.55%
I.).......................I.f3'
%U
tt 40 t
11.8%
l II
W"
it 25 it
30.0% 42.7% 81.8%
It It
tin-
It If
A
II It
t 10 n 5i it 1it i
EXHIBIT B - 6 (3) USDOL/OSHA
Table III -- Distribution of 8-HR TWA Levels
EXHIBIT b - 6 (4) USDOL/OSHA .
May 15 - June 11, 1974
Median
4.9 ppm ,
Range < 0.1 -- 27.9 ppm
; <I
t
BFS B0SSS9
10% of employes had TWA value^e^ 1.2 ppm or less
20% 11
II V
II ii
II B*-5 9 II i
30% fl II II ii II CP2-3 II II M
40% 11 11 11 i
V*-2 II II ti
50, % ft II 11 ii
if
4.9 If
If
, 60% II II II ii
1 M II If
" Y$
70% It <1 t ii
11 II .it:
" 10?/^
80% II
II
II ii
11
If II u
90%. 11 95% II <97.5% If
I* II 19 II tl II
II .* 11 If
II
*' 14.0 " 21.1
i
V 27.9
II II *m
II II
1 II
if
it ti
EXHIBIT B " 6 C5) USDOL/OSHA
Similarly:
None had.TWA
2.2% " "
` 22.2% " "
4A.5%: " "
91.1%
"
greater than 50 ppm
1p ..w
" ..
Q
'
"
If
1?
f If
25 " 10 "
5" 1 '
CP
B F 5 BOSS 90
Table IV
EXHIBIT B- 6(6) USDOL/OSHA '
Job Classification
*Reactor Cleaner *Poly Ax'ea Operator *Outside Operator
Finish, Bldg. Operator Loading Rack Operator Control Room Operator
** Supervisor Tech, Supt, (in plant)
TOTAL
Number of Values Vinyl Chloride'1-- ppm as TWA
\ 21
Median
Low
ilMl
1.4 ' V' 27.9
4G
4 xp
u-4'
3-4
5 W-. 1-6
4.2 23.? !*9 : 14.3 0.4 ' 3.2
4' 4 2
45
^ 3'6
0 0.9 W 3.7
^69 ' <J^~
4.9
1.2 4>.l
.9.6 6.0
2.5 4.9
Not Applicable
<0.!
. *< ` 27.9
*TWA mean for reactor building
S 8.5 ppm -- range 1.4 to 27,9 ppm ;
B F S 0 0 SB 91
EXHIBIT B ~ 6 (7) USDOL/OSHA '
Notes: M
Concentration measlJt^jBents were obtained from samples taken in 250 ml. glass tubes.
Aliquots of these sanmj^ were injected directly into a gas chromatograph. Samples absorbed on carbon t^ere) desorbed in carbon disulfide prior to injection into the chromatograph.
(2) Four samples cTnly
(3) One sample only
Source:
Snell summary of industry
BFS 0Q 8692
VINYL CHLORIDE LEVELS
TABLE I VCM TEST METERS
EXHIBIT B-7(l) USDOL/OSHA MONITORING RESULTS FOR 22-M-OLD-C *
BFS 00S693
1946-1967 i968-1971 1972-1973 1974
MSA Explosimafc^r' Lowest reading on scale, 2% of LEL, or 720 ppm not accuratjft at this level.
Davis Vaportestfc^ft, Lowest reading on a X10 scale was 0.2% of LEL or 72 ppm - not Jtipcurate at this level.
Johnson & Williams SS PK Tester Scale reads ^Lsripm per division but not accurate
* below 50 ppnn^2fero drift often in excess of 5 Ppm.
Century OVA #98 Popple FID Testers Not specific for VCM. Reads down to 1 ppm. We calibrate with certified gas at 50 and at 5 ppm.
\
TABLE 2 Vinyl Chloride Levels in Operating BuiIdin
EXHIBIT B ~7(2) USDOL/OE
-f-i-n--e-----S- 1p--a--n1946-1972 TWA
:
C-l G-2 F.-1 E-2 *F-1 F-3
500 140 500 150
20 *
K. -
1973
Number of Readings
77 73 582 597 222 73
85
TWA (ppm)
50 5 50 25 125 5 175
Maximum reading (ppm) 2800 200 3000 2800 2460 200 2240
Jan, 1974 Number of Readings
9 9 63 "80 27 8
9
TWA (ppm)
64 8 25 17 . 93 44 17
Maximum Reading (ppm) 300 60 504 168 840 300 100
April 8, Number of Readings*
1974 to i
!lay 21,
TV/A (ppm)
1974
liaximum Reading (ppffr)
7^
V-5^` 'Exclusive of Reactor CleaningQ^
306 8
246
131 4
35
935 1063 76
43 34
528 328 10 8 50 65
132 7
46
Jork Functions:
f (f1
C~ 1 - Tank Car Unloading, VC puirtbi ng, VCM production until 1967
C-2 '
E- 1 - Polymerization. Monomer Red^very
E2 -
"
" V
F- 1 - Filter, Apron driers
F- 3 - Filter, Rotary drier
K - Filter, Spray drier
BFS 008694
Table 3 -- Area Sampling Results -April 8 - June 27, 1974
(Century OVA Meter)
EXHIBIT B -7(3) USDOL/OSHA
Building Readings
Time Period - 1974 Upwind
E-l i) F-l .C-l
Reading
a-
Average of All Readings (as nDm Vinvl C^ildridel JP
.
4/8-4/17 4/27-5/7
4.9 14.7 12.6 A 38.9 6.2 11.7. 11.4 -- 10.1
5/17-5/25
6/5-6/13 **
6/14-6/27
^'
4.8 9.3 9.2 8-^5'5
3.7 7.0 7.9
3.8 7.6 7.7 9.2^ 5.5
C-2 K *
F-3
9.1 14.2 14.7 10.6 14.2- 12.8
7.9 10.3 10.9 5.7 6.2 10.5 6.0 \ 7.3 7.0
BFS BBSS 95
4/8-6/27
4.8 10.5 9.7 13.1 7.2 7.9 10.5 11.6
Number of Readings 240 1678 1229 398 310 153 154 < 215
Table 3 (continued)
EXHIBIT B-7(4)' USBOL/OSHA
Maximum Reading Recorded (as pnm Vinyl Chloride)
4/8-4/17 " 4/27-5/7 5/17-5/25 6/a-6/13 6/14-6/27
4/8-6/27
7 45 32
500 30 45 42
13 28 uSt', * 24 40 49 33
(fA
-
18 35
21 22 27 45
6 20
40 10 10 16 55
5 27 45 ip 35 12 11 50 20
% 18
---A 50 45 275 500 40 50 55
Note: Those data do not cover excursions/H^ut represent routine
conditions.
( jl}
Tablc*.4 -- Vinyl Chloride Levels April 8 -- June 27, 1974
EXHIBIT B-7(5) USDOL/OSHA
Time Period - 1974
*
Century OVA Readings ns ppm Vinyl Chloride
Average*
Maximum*
Mimimum*
E-2
E-l E-2
E-l" E-2
4/8-4/17
4/18-4/26
4/27-5/7
5/8-5/16
..
5/17-5/25.
5/26-6/4
6/5-6/13
6/14-6/27
4/8-6/27
33.0 27.5 29.8 34.2 25.9 20.8 21.8 20.3
26.5
27.1 a
115
33.W/'
iP " CP
29.8 ,
40 '* 48
45 4.6
0 45
31.0
41
29.7 -V^ 40
,QD
30.6
115
35 15 14
-- 15 M a*
46 6 ' 15
** 10
45 7
tm 10
--
7
M **
60 4 15
48 5 io
60 4 10
BFS 00869?
* A total of 193 readings were taken in E-l realtors; 98 readings in E-2 reactors.
i
Table .5 -- Personnel Monitoring Data -- . April-17 -- June 28, 1974
EXHIBIT B-7C6) USDOL/OSHA
Description of Value Number of Samples Minimum Value -- ppm Maximum Value -- ppm
250 ml 10 min All ShortGlass Carbon Term Samples
94 74
168
0.1 Nil
Nil 7
160 55
160
8-HR TWA
31
< 0.04
100
BFS BBSS9S
f~'r
VCM (ppm) -- 10% of^; samples
20 "<jy . ... .30 ' :CP
' ' 40
50 l IP
60 " "
70 - . ' 80 - 19
90 ft
CP
11 91
" .7 95 If 99
97. 5 " "
0.6 1 2 2 3 5 7 12 22 42 60
- 1 1 1
2 3
3.8 6 9
12 25 44
1
^1
1.8 2
fc 3
5
6
* 10 1.5
37
55
3 4
5 8. 12 14 16 20 24 28 100
Table 5 (continued)
EXHIBIT B -7(7) USDOL/OSHA
Percentage of values above 5%pm
fl fl
13 40f/f>
4,3 1.4 6,4 2.7
"A25H VI 13 13
9.6 4.1
91
f VI VI 10 y
20.2 16.2
519 IV If VI
39.4' '31.6
1 " **^73.4
99 IV II IV
66.2
tP
3.0 4.8 7.1 18.5 35.7 70.2
; 6.5 . 6.5
9.7 ", 51.7
67.8 93.7
SFS
oj n
BFS 80S 788
Work Area or Function
%
Reactor Cleaning Batch Transfer Reactor Area Pump Room Control Room E-Bldg. Supervisor
Bagger PfiS Dryer
Break Room Locker Room Lunch Room Main Office Warehouse Telex Laboratory Maintanance Shop
Shift Monitor
Table 6 - - Distribution of Personnel Monitoring Data By Job Function and/or Area
EXHIBIT B -7(8) USDOL/OSIIA
Ten Minute-Glass & Carbon Tubes
8-HR TWA
Total Samples
20 23 23 12 ; 11
13 9
No. No. Vinyl Chloride Total `40 ppm i? 25 ppm Ava "Max L Min Samples
apm ppm ppm
6 1. O' 0 0
0 1
9 (pr>l 160 2
2 W3 75 1
0 0
ft 2i A
0 12 2
,/A0 4.9^13 .:1 1 14.6 60 3
6 3 5 1 2 3
2 3
No. ' 25 ppm
0 0 0 0 1 1
0 0
No. Vinyl Chloride > 10 ppm Ava ria;: i-iir.
ppm ppm ppm
5 15. 7
1 7. 7
2 10.0 0 5.0 1 18.0 1 22.0
22 8 12 4 24 3
2-3 51
0 A5 3 17.3
6 24
7
0
0
1.2
2 <1
m >m
7 0 0 1.3 ^2 0.4 6 0 0 1.8 ^ Nil
-m **
7 0 0 i.7 rfo Nil 1 0 0 ^ 0.04 7 0 0 2.0 ^5 -- 1 2 0 0 2.1 3.6 0.6 10 0 0 1.3 10 -0.1 --
6
0
0
0.6
1 Nil
--
--
_
7
0
0
0.6
2 0.1
--
--
--
- -
44.0
100 16
Source; Snell summary of industry data
le s s e e s ^ s
Location
. Outside, Tank Car Unloading.
*
. Outside, Storage Area
. Reactor Building
. Centrifuge and Dryer Building
. Outside, PVC Silos
. Bulk Pack Bagging Building
. Bagging Warehouse
Total Employee
1
1 60
8
6 6
15
Note: (1) Monitoring performed with Ovaraeter Source: Snell summary of industry data
EXHIBIT B -8 USDOL/OSHA
\
MONITORING RESULTS FOR 31-M-MEW-C
Current Estimated VCM Exposure Levels (PPM)
0-5
EXHIBIT B-9
USDOL/OSHA MONITORING RESULTS FOR
45-M-INT-C
Unit OperatioftA r*
W VC Unloading
Polymerization Ci^
Current Range VCM (PfM)
0 200 10 50
Kettle Cleaning o
10 175
to Drying
5 40
>1 '/I
Packaging^
5 125
Shipping
0 70
How Measured
Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph
Note: (1) Type C continuous flow air masks required while performing this function.
CD (S Source: Snell summary of industry data Oj 'J CD f-J
Unit Operation 1. VC Unloading 2. Prepolymerizer
Current VC, PPM <50
Charging Open|aSg\ deartha#/
cj> 3. Postpolym^r^er
20 - 40 >100
25 - 100
Charging Opening Cleaning a Transfer k
4. Bagging
Note: Cl) NoTa
<25 50 - 150
<50 >50
<50
ile measurement
Source: Snell summary of industry data
EXHIBIT B-10 \ USDOL/OSHA MONITORING RESULTS FOR
30-M-NEW-C
How Measured GC
Historical VC. PPM
<200
GC GC GC
How Measured Odor (1)
GC GC GC GC
GC
BFS 008763
t
Job Description Maintenance
Poly Scrubber
Lab Technician
Bagger
Compou nd ing ,,Qj^era tor
Dryer Operator**^ '
HRC Operator
Head Operator A
Poly Head Operator^^ Poly Drop Operator Drop Operator
Number of
Samples 42 16 13 6 19 34 10 17 21 26 6
Average Worker Exposure to VCM in PPM 1.9 14.4 184.1 2.5 1.7 78.8 3.8 4.9 6.6 5.7 2.5
EXHIBIT B-ll USDOL/OSHA
*
MONITORING RESULTS FOR 41-L-OLD-W
Range of Worke: Exposure to VCM in PPM
<0.1 - 26.6
2 - 49.7
0.2 - 2375
0.1 - 8.4
0.1 - 8.7
0.5 - 915.7
< 1.0 - 18.4
1.0 - 26.4
0.3 - 45.9
0.9 - 52.7
1.0 - 5.6
BFS 00S7O4
Note: Snell average oNtata for the months of March through June 1974, Source: Snell summary of industry data
BFS 008705
Unit Operation
Current VCM Concentration Since July, 1974 (PPM)
. Polymerization and
Setting
. Centrifugation
. VC Recovery aRdQ
Unloading
y.
. Reactor Entry FqjjrCHeaning
. Transfer and Loipmg
. Warehousing
ijf ^
(P
Note:
A
4?. -A
5-10 11 - 10 . 100 - 160
7-180 27
4-42 0-3 0-3
(1) FID = Flame Ionizatic
tector
Source: Snell summary o^j^lustry data
EXHIBIT B~12 USDOL/OSHA MONITORING RESULTS'FOR
28-L-NEW-C
How Measured
Historical VCM
Concentration Since April, 1974 (PPM)
FID(1>
Carbon Tube FID FID
Carbon Tube Carbon Tube
FID FID
7 - 90 20 - 130 100 - 160 Up to 10,000 Up to 10,000 40 - 200
0- 3 0- 3
How Measured
FID
Carbon Tube
FID
*
FID
Carbon Tube
FID
FID.
FID
BF5 Q0S7ee
Job/Locration
Scrubbing
Bagger and Bag Operators
Operator and Operator Workmen
Control Man/Control Room
Sampling and Checking
Reclaim Operato'f'XJ
Waste Lake
Maintenance
fJ
Washing and Cleaning*)
Perimeters Loading Operators (jf)
River Discharge
.
Dicer
Dropping and Charging
Blending and Milling/Mill,
Intakes, Exhausts, Vent^
Dust Collectors
Office Areas
Work Areas and Decks
Dryers and Vicinity
Troduct Collectors
FCM Rotors
* ^
No. of Data Points
20 17 72 27 26
7 2 17 42 48 16 1 6 23 9 9 10 7 33 7 2 2
EXHIBIT B1-13(1) USDOL/OSHA
MONITORING RESULTS FOR 54-M-NEW-C
Vinyl Chloride
Monomer Concentrations (PPM)
Avg. fl)
High
Low
65 20 24 27 61 55 2 10 65 2 31 1 3 70 6 22 16 2 8 51 10 1827
199 70
239 343 1021 227
4 34 1389 11 213 X 8 671 36 104 76 4 74 168 16 2141
8 0.4 0.6 0.2 0.3 3 0.8 0.2 0.3 0.5 0.6 X 0.5 0 ` 0.6 0.4 1 0.3 0.7 0.8 3 1512
I
BF5
Notes:
V
X = Not Applicable
(P
(1) Snell averaging oofUrje&jported data.
Source: Snell summary of industry data
or>
EXHIBIT B-13(2) USDOL/OSHA
EXHIBIT B-14 (1) USDOL/OSHA
MONITORING RESULTS FOR 5-L-OLD-C
Atmospheric Concentration Vinyl Chloride During Cleaning of 4,000 Gal. .^___________________________________________ .
Suspension Process
Sample Location
1. Operator breathing zone when entering polytnerlzer
.2 Operator breathing zone while
scraping walls of polytnerlzer
3. Operator breath^m^ zone while scraping walls 'SK.polymerlzer
Air Concentration Vinyl Chloride ppm
19
22
19
*
Au^s^September 1967
W;
Monomer ConcentratPolymertzer Atmospheres
Polymer Type__ _
Suspension
Poly No.
120
130
151 102 124 128 150 150 121 128 136
Poly Size
1100 ^
1100
1100
noo uoo
1100 1100 1100 1100 1100 1100
Evacuation Time
20" 18" 25" 35" 20" 20" 50" 20" 40" 40" 45"
VC1 ppm Monomer
10 Min.*
30 Min.**
84 50 42
99 230
77 20
76 34 104 56
72 46 32 78 123 80 25 80 34 63 62
i
BFS 008708
BFS 00S709
" " " " " " " " "
Dispersion " " " " M " " " "
"
"
"
"
"
"
"
"
"
130 133 114 113 117 135 132 136 116
25 32 29 48 28 45 42 43 32 25
6 25
19
34 6
20 9
12 4
1100 1100 1100 1100 1100 1100 1100 1100 1100
1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100
90" 25" 25" 30" 25" 25" 40" 40" 60"
a 22"
t-'n
20"
30"
f*'. 25"
W1' 55"
<oPn Z
30" 35" ^A25"
30"
'
'3Gr
75" 30"
93 146 375 147 234 180 147 118
76
74 56 34 417 36 78 100 75 211 55 102 62 94 40 35 165 120 60 271
EXHIBIT B -14 (2) USDOL/OSH,A
32 97 250 107 264 185 104 ' 64. 59
100 114
84 3$:
68 100 189 148 279
39 37 41 88 29 44 168 99 78 152
EXHIBIT B-14(3) USDOL/OSHA
August-September 1967
Monomer Concentration In Polymerlzer Atmospheres con't.
Polymer Type____
Dispersion
|l II 11 II
Poly No*.
8 12 21 12 17
Poly Size
1100 1100 1100 1100 1100
Total Evacuation Time
60" 25" 18" 30" 35"
VC1 onm Monomer
10 Min.*
30 Min.**
27 174 102 142
38
80 320 104 168
68
SuspensIon n n
137 143 137
3300 3&"-
20" 45" 25"
374 405
62
H 141
3300
35" 138
ii 113 it 127
lloVfjfX
noo OR
15" 10" & 30"
54 32
it 116
1100 / ff> 10" 6. 5"
440
ii 106 n 146
1100 3300
k 30" //A 30*1
192 162
ii 142
3300
^ 35"
147
124 1100
30" 128
142 3300
5" 106
105 1100
52
148 3300
26
* Sample collected 10 minutes after operato{jP*ers poly.
operator breathing zone sample.
134 142
112 123
59 498 390 188 200 139
101
113 47 24
**Sample collected 30 minutes after operator enters poly or after cleaning, if cleaning time was leas than 30 minutes; operator breathing zone sample.
BF5 *08710
EXHIBIT B "14 (4) USDOL/OSHA
Monomer Concentration In Room Air
ppm VO A
VlJ
Date
Dispersion fcesljn
Suspension Resin
Bide. 4&fp
Bldg. 461
8-29-67 9-5-67 9-7-67 9-11-67 9-12-67 9-25-67
iP 53
A16 27
58 0
45
% 26
<p650 18 31
9-26-67
48
9-28-67
6 32
03
<3 % 00
I
EXHIBIT B-14 (5) USDOL/OSHA
Monomer Concentration tn Polyroerizer Atmospheres October 1967
Polymer Type
Suspension
If If M II II II If II H
Dispersion
H II H II
Suspension
Poly Mo.
25 43 33 29 41 25 30 45 34 46
16 18 14 18
2
142
3300
Total Evacuation Time
VCl ppm Monomer
10 Min.
30 Min.
71 95 59 50 48 70
73 11/ 75 38 73 98 66 114 30 23
35 43
56 55
115 156
53 58 58
210 114
74 62 56
45" 50
35
EXHIBIT B-14 (6) USDOL/OSHA
Monomer Concentration In Room Air ppm VC1
Date
Dispersion Resin Bldg. 451
Suspension Resin Bldg. 461
10-16-07 10-17-67 10-23-67 10-30-67 .
142 26 14 28 44
Ambient Concentrations of Vinyl Chloride ppm
Year
bate (/ \
Dispersion Resin Building 451
Suspension Resin Building 461
Susper'lon Resin Building 464
1967
8-29,> 9-5 iP
16
53 27
(Pft,
58
45 26
"Is A 450
18 31
9-26
48
to to to
9-28 10-16 10-17
6 142
14
32 26
10-23
28
10-30
0PM
1968
9-18
21
47
49
30
to
9-23
21
47 22
to 42
to 24
m
*
9-30
59
68
to
i
BFS 00S714
1972 Average
EXHIBIT B-14(7) USDOL/OSHA
72 88 65 76
24 18 62 61 63
14 27 15
7 29 13 73
41 4.1
3 16 41 41
72 38 16
EXHIBIT B-14(8) USDOL/OSHA
Atmospheric Vinyl Chloride Concentrations In Charging Area
Dispersion Resin Building 451
Tuesday, 8-22-72; 11 a.m.
West Side
East Side
,
Control Ro9^0.
82 ppm 155 ppm
8 ppm
Tuesday, 8-22-72; 3 p.m.
West Side East Side Control Room
West Side East Side Control Room
<P
Thursday. 8-24-72; 9 a.m.
O
89 ppm 378 ppm
64 ppm
78 ppm 13 ppm
5 ppm
8-24-72; 11 a.m.
West Side Center East Side
73 ppm 104 ppm
30 ppm
CD Thursday, 8-24-72; 1 p.m. 0
to West Side N Center
97 ppm 72 ppm
Oi East Side
10 ppm
t
BFS
BFS 0 0 S 7 IS
West Side Center East Side
West Side Center East Side
West Side Center East Side
West Side East Side Control Room
West Side East Side
Thursday, 8-24-72; 3 p,m. Friday, 8-25-72; 9 a.m.
Building 451 con * t.
Friday, 8
i p..
iP
Thursday, 9-7-72; l p.m
EXHIBIT B-14-(9) USDOL/OSHA
33 ppm 33 ppm 13 ppm
135 ppm 22 ppm
148 ppm
24 ppm 24 ppm 131 ppm
47 ppm 95 ppm 54 ppm
23 ppm 440 ppm
Suspension Resin Building 461
Tuesday, 8-22-72; 11 a.m.
West Side East Side Control Room
Tuesday, 8-22-72; 3 p.m.
Uest Side East Side Controls
c
West Sid'g^f7\ East SideU/ ,,
tPControl Hoi
West Side Center East Side
West Side East Side
Thursday, 8-24-72; 9 a.m. Thursday, 8-24-72; 11 a.m.
OPsday, 8-24-72; 1 p.m.
Thursday, 8-24-72; 3 p.m.
West Side Center East Side
EXHIBIT B -14 (10) USDOL/OSHA
531 ppm 131 ppm
49 ppm
48 ppm 32 ppm 24 ppm
29 ppm 288 ppm
26 ppm
329 ppm 762 ppm
70 ppm
20 ppm 72 ppm
33 ppm 107 ppm
87 ppm
BF5 008718
West Side Center East Side
West Side Center East Side Fri West Side East Side
West Side East Side
North End
North End Center South End
Friday, 8-25-72; 9 a.m.
Suspension Resin Building 461
Friday. 8-25-72; 11 a.m
V > >,
( 'Friday, 8-25-72; 1 p.m. Vrf''
Thtj^sday, 9-7-72; 1 p.m.
^-iAiispenslon Resin *>"^Bulldlng 464
m-22-72; 11 a.m Tuesda
Tuesday, 8-22-72; 3 p.m.
EXHIBIT B-14(ll) USDOL/OSHA
369 ppm 384 ppm 135 ppm
168 ppm 186 ppm 156 ppm
358 ppm 122 ppm
51 ppm 74 ppm
82 ppm
5 ppm 32 ppm 32 ppm
i
BFS 008719
North End Center South End
North End Center South End
North End Center South End
North End Center South End
North End Center South End
North End Center South End
Thursday, 8-24-72; 9 a,in.
Thursday, 8-24-72; 11 a.tn.
Thursday, 8-24-72; 1 p.m. W\
(p i^jf^ursday, 8-24-72; 3 p.m. /A //...x vjSrt Suspension Resin a Building 464 Friday. *Ar25-72; 9 a.in.
Friday, 8-25-72; 11 a.m.
EXHIBIT B -14 (12) USDOL/OSIJA
8 ppm 13 ppm
5 ppm
5 ppm 7 ppm 7 ppm
5 ppm 15 ppm 15 ppm
7 ppm 47 ppm 67 ppm
36 ppm 9 ppm 9 ppm
24 ppm 12 ppm 36 ppm
EXHIBIT B-14(13) USDOL/OSHA
North End Center South End
Friday, 8-25-72; I p.m.
47 ppm 108 ppm 115 ppm Area Measurements Using Portable and Fixed Instrumentation, Measuring Total Hydrocar~ bons by the Flame Ionisation Method
Building 451
Product
Dispersion Resin
Month
JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74
/J . X s*>,^
o
(f 11'\ Z Readings Averda# ` Above 50 PPM
ppm f (f
29.5^'
3.5
23.7
3.9
15.3 z
2.6
17.1 o
4.9
17.8 11.3
tA*-'
OP
X Readings Under 10 PPM
8.7 14.4 23.4 42.9 65.2 72.5
BFS
461
Suspension JAN. 74
25.6
4.7
Resin
FEB. 74
17.8
3.3
MAR. 74
19.1
2.5
APR. 74
18.7
3.4
MAY 74
15.4
2.2
JUNE-fi. 11.9
4.9
464
Suspension JAN. (u 31.4
5.1
Resin
FEB. W,1!
MAR.
3.1 1.1
APR.
0.0
MAY n
2.8
JUNE 74
2.8
*
463 rvc JAN. 74
0.0
Latex
FEB. 74
0.2
MAR. 74
0.0
APR. 74
0.7
MAY 74
0.4
JUNE 74
8.1
1.9
EXHIBIT B-14 (14) USDOL/OSHA
24.1 37.9 21.7 14.6 59.3 57.8
11.1 10.3 34.8 58.9 71.2 82.5
70.9 91.7 97.5 97.6 86.3 82.3
EXHIBIT B -14 (15) USDOL/OSHA
Location and Type
East bldg. 464 Suspension Resin
PEBSONIIKL MOJIITORIHG DATA - KAY-OILY, 1974
TWA
Operation
Charging Cleaning Recovery
No. of Samples
5 4 6
Average
10 12 14
PPM VC1
Maximum
23 23 31
Minimum
3 2 3
West Bldg. 451 Dispersion P.eein
Charging Cleaning Recovery Drying and Bagging
8 18 19 42
9 15 12
4 6 3 1
. West Bldg. 461 Suspension Resin
Charging Cleaning Recovery Supervisory
V
U
(Jp
CP
3 6 4 1
10 22 17 ' 12
22 80 26
3 5 6
i
West Bldg. 453 Latex
Charging Cleaning Recovery Supervisory
14 23 47 126 80 154
2 4 6
Motes;
. , . ,,
Evrrryone wears respiratory equipment where the wotk a
and experience show there is a risk of exceeding 25
here is greater than 25 ppm or where operations
Personnel monitoring samples are taken over a period of time generally 4 hours (some
. , data repre-
scr.ts 20 minute samples) to obtain the tine weighted average for employee exposure, All samples are collected
hj by absorption on carbon tubes and tested using gas chromatography.
K
Source: Snell summary of industry data
BFS 0087
Atmospheric Concentrations of Vinyl Chloride ;j - Building 731
EXHIBIT B-15 (1) USDOL/OSHA
MONITORING RESULTS FOR 8-L-NEW-C
Sample Location.
Vinyl Chloride Concentration (ppm)
Near Manhole, Poly Ho. 2 - Suspension Resin Near Manhole, Poly No. 7 It II
15 18
Near Manhold, Poly No. 11
IV
II
24
Near Manhold, Poly No. 21 - Dispersion Resin
muo k
2nd Floor Uldjrp
34
Tuesday, April 4
\i
12:50 PM
Zh
Aisleway paste* line proceedingijl^th to South Poly #36 & 35
Aislcway paste line proceeding North to South Poly #29 & 30 Aisleway paste line proceeding Uo&m' to South P.oly #22 & 21
1:05 PM
VC1 ppm
102 98 41
Aisleway pearl* line proceeding Nor Aisleway pearl line proceeding Nort Aisleway pearl line proceeding North t,
1:30 PM
South Poly #15 & 17 jSouth Poly #9 & 11
uth Poly #3 & 5
268 271 124
Aisleway pearl Aislcway pearl Aisleway pearl
lineproceeding North to South Poly #15 & 17 (approx.) lineproceeding North to South Poly #9 & 11 lineproceeding North to Sonrh PnTr
737 76
B F 5 QQS71
J 'J 4k
EXHIBIT B-15 (2) USDOL/OSHA
2:58 PM to 3:02 PM
Aislcway pearl line proceeding North to South Poly #9 & 10 (Approx ) Aisleway pearl line proceeding North to South Poly #2 & 1
Outside control room by metering station
3:53 PM
Aisleway pearl line proceeding North to South Poly#15 & 17 Aislcwny pearl line proceeding North to South Poly #9 & 11 Aisleway pearl line proceeding North to South Poly #3 & 5 Outside control room by metering station
4:15 PM
Aisleway paste line proceeding North to South Poly #36 & 35 Aisleway paste line proceedLtig' North to South Poly #22 & 21 Aislcvay paste line proceed%^>'orth to South Poly #15 & 17 Outside control room by meter^r^^station
4:25 PM
f fey
Aislcvay paste line between Poly Wfe & 35 Outside control room by metering Vt^tion
4:50 PM
Aislcway paste line proceeding Norttys^ft South Poly #36 & 35 Aislcway paste line proceeding North fcjlsouth Poly #29 & 30 Aisleway paste line proceeding North ^tyj/^outh Poly #22 & 21 Aislcway pearl line at South end of Poly #3 & 5
* "Paste" means dispersion resin "Pearl" means suspension resin
550 62
260
40 50
5 30
68 68 58 55
68 35
39 48 39 45
i
o
Atmospheric Concentrations of Vinyl Chloride 2nd Floor tilde,. 731
Wednesday, April 5
12:13 PM to 12:19 PM
Just inside doorway to 2nd floor poly area Aicleway paste* line proceeding North to South Poly #35 & 36 Aicleway paste line proceeding North to South Poly #30 & 29 Aisleway pearl* line proceeding North to South Poly #20 & 19 Aisleway pearl line proceeding North to South Poly #14 Aisleway pearl line proceeding North to South Poly #4
12:42 PM to 12:48 PM
Inside control room
V s*k
Outside control room by mcfgjring station
Aisleway pearl poly line be^w^n Polys #9 & 10
Doorway to compound room nearv f'reight elevator
Aisleway paste poly line by Polv!\#24
By Bldg, exit door located beh^ndicontrol room
3:00 PM to 3:06 PM
Inside control room
Outside control room by metering
ion
Aisleway pearl line North end by ^offySe $15 & 16
Aisleway pearl line South end by Polys #1 & 2
Aisleway paste line North end by Polys #33 & 34
Aislcway paste line South end by Polys #21 & 22
EXHIBIT B -15(3) UCBOL/05HA
VC 1 ppm
250 318 462 332 474 122
15 130 130 145 133 117
5 45 33 23 90 108
'i
OG
i 3:30 I'M to 3:40 PM
EXHIBIT B-15C4) USDOL/OCJIA
At manhead to pearl Poly #6; just off recovery, fumes seen
vent ins to room
(approx.)
In aisleway in front of pearl Poly #6
At nonhead to pearl Poly v2; exhaust hose had just been removed
At nanhead to paste poly #34; after HRC cleaning
At nnr.hcad to paste Poly #30; poly filled with cleaning solution
In aisleway betweenpaste Polys #27 & 38
5:00 PM to 5:15 PM
550 438 470 400
5 5
Inside control room
10
Outside control reom'lBS. notering station
45
Aisleway pearl line pfcj^eqding North to South Polys $15 & 16
40
Aisleway pearl line pr^ci-^jding North to South Polys 95 i5c (
15
I
Aisleway paste line pro'iffc4ing North to South Polys #35 & 36 Aisleway paste line prot^gjdlng North to South Polys #21 & 22
7? 65
'Paste" means dispersion r^sin 'Pearl" means suspens ion-^fe-s^n
Atmospheric Concentrations of Vinyl Chloride In Bid
Thursday, April 6
9:30 AM to 9:40 AM
CP
VC1 ppm
i
Inside control room Outside control room by metering station Aisleway pearl* line proceeding North to South Polys #19 & 20 Aisleway pearl line proceeding North to South Polys #1 & 2 Aisleway paste* line proceeding North to South Polys #35 & 36
2 8 148 268
Aisleway paste line proceeding North to South P6lys #21 & 22
25 45
BF5 0 0 8 F26
I
o
i
o
10:45 AM to 11:0Q AM
Inside control room Outside control room by metering station
Aislfway pearl lineproceeding North To South Polys #19 & 20 Aisleway pearl lineproceeding North to South Polys #14 & 13 Aislovay pearl lineproceeding North to South Polys #3 & 4 At cianhcad pearl Poly #8; opened Cor cleaning Aisleway paste-line proceeding North to South Polys #35 & 36 Aisleway paste line proceeding North to South Polys #31 & 32 Breathing rone of man hose washing #25 paste -poly Aisleway by paste premix poly
1:45 pm to 2:05 I'M.
Outside control room by (factoring station
By doorway to compounding=^on; near freight elevator Aisleway pearl 1 ine .proccSjctf^g North to South Polys #15 & 16
Aisleway pearl line procectit^ North At nanhend of ,near I Poly #9j; J` At manhead of pearl I'oly #14 a Aisleway paste line procecdig^North
Aisleway paste line proceediijg North Aisleway paste line proceeding _Ngrth At manhead paste Poly #31 At manhe.ad paste Poly fi34
to South Polys #3 &
to South Polys #33 to South Polys #29 to South Polys #23
4
34 30 24*
By bldg, exit door behind contt'oji-jrocTn On mezzanine level by #9 blowdown rteynk On mezzanine level by #6 blowdowte/t'ank On Mezzanine level at South end paste blowdown area
EXHIBIT 13-15 (5) USDOL/OSIJA
15 28 25 28 27 300 30 30 100 18
32 27 i4 30 33 22 30 26 31 163 168 35 20 31 26
* "paste" means dispersion resin "pearl" means suspension resin
>i
Oo
EXHIBIT 13-15 (C) USDOL/OSIIA
Thursd.iv, April 6 -- Con't.
VC1 ppm
1
8:40 PM to 8:50 PM
1
Outside control room by meterv^8F*6tation
108
At doorway to compound room; nWnr freight elevator
95
Aisieway pearl lineproceeding rtC^h to South Polys #15 & 16
43
Aisleway pearl lineproceeding Wrth to South Polys #5 & 6
72
Aisleway paste lineproceeding Nor|A to South Polys #33 & 34
98
I
Aisleway paste lineproceedingNcf&k!,to South Polys #23 & 24
/'l
BFS 008728
i
O
j i
o
MXMIHIT 13 -15(7) USDOL/OSHA
VCL MONITORING. DATA
Area Measurements Using Portable end Fixed Instrumentation, Measuring Total Hydrocarbono by th^Flace Ionization Method
Building 731
Product
Suopen sion and
Dispersion ke.sins
VJ
OP
o OP' Average
<u ppn
JAN. J4
90.7
FEB. 74 x 31.4
MAR.
0) 18.3
APR. 74^416.8 MAY 74^>>8.6
JUNE 74
Z Readings Above 50 PPM
33.0 10.0
2.0 4.8 2.3 2.9
Z Readings Under 10 PPM
20.3 17.4 27.9 69.1 82.0 79.1
BFS 00
GO M *0
I
O oo
EXHIBIT B -15(8) USDOL/OSIIA
PERSONNEL MONITORINC DATA
May - July, 19 74
Location and Type
Suspension Resin 1
Dispersion Resin
Operation
Charging Cleaning Recovery
1?
Qiargl Cleaning Recovery^Jp.
tf>
No. of Samples
7 7 4
5 3 3
TWA
Average
6 4 6
5 12
4
TPM vci
Maximum
13 8 9
8 26
5
Mi nlmun
2 4
2 2 3
Everyone wears respiraCory equipment where the wArk atmosphere Is greater than'25 ppm or where operations and experience show there is s risk of exceedi((fjjfe4!5 ppm.
,,^
Personnel monitoring samples are taken over a perlsd\of time generally 4 hours to obtain the time weighted average for employee exposure. All samples arc oojJl'ected by absorption on carbon tubes and tested uslnR gas chromatography.
Source: Snell summary of industry data
BFS 00S730
O
EXI'ILIT I; 11(1) ilsdoi./osiia
O
MONITORING RESULTS FOR
49-M-OLII- C
CHROMATOGRAPHIC ANALYSIS DATA
BF5 9QS731
Ambient Concontrations Vinyl Chloride, ppm
N
OLYMKR
SUSPENSION
SUSPENSION
DISPERSION
r=i :sin
RESIN
RESIN
RESIN L LATEX
ing Building
Building
Building
1 111 121
Year
Date
3r<if fflW
3rd Floor
1
IP1965
10-27
11-10
17 > 117 _
11-10
51 0
11-11
183
182 >
12-8 12-10
99 75
ip
1966
1-10 1-12 1-13 1-14
9-2 9-13
47 30 18
2 38 98 97 63 55 28 111
i
BF5 0087
I A
i
Ca|
Ye nr. 1967
1968
D.Uu
2-8 2-14 ' 2-15 2-17 12-9
11-2 12-11
12-12 12-15
12-18
1-9
12-16 12-17
COPOLYMER RESIN
Bui Id inj; lb
3rd Floor
SUSPENSION ri:sin
Building 1
SUSPENSION RESIN
Building 111
O
EXHIBIT B-1C (2) USDOL/QSIIA
DISPERSION RESIN 6 LATEX
Building 121
3rd Floor
80 231 632
52 374 110
135 130 138
97 85 81 72 114 26 23 36 2 20 42
i
o Oo EXHIBIT B-1G (3) USDOL/OSIIA
Ye nr 1969
Date
1-31 2-3 2-14 3-26 9-30
Anh ie;it Concent rat ions Vinyl Chloride, ppm
COPOI.YMKK RESIN
Ku i Id itip. B>i i Id in;; Eviilding
15 15
15
3rd Floor 2nd Floor 1st Floor
SUSPENSION1 RESIN BuiId in: Building
111 3rd Floor 3rd Floor
DISPERSION RESIN 6 TAT EX
Building 121
3rd Floor
1972
3-21
3-22
1973
3-22
4 1 5 2 2 6 2
132 57 44 33 23 12
10 19 22
1 1 0.5
7 5 0.5 2 4 4 3 1 4
0.5 0.5 1 7 1
7 3 5 10 9 10 12 11 12
2 4 1 1 6 0.5 6 5 4 3 5 3
3 6
B F 5 QOS 733
I
to >1 A
Si S
to
N U u
o
EXHIBIT B-16(4) USDOL/OSIIA
t
Year 1964
1965
Polymerizcr Vapor Concentrations:
Exhaust Time - 15 Min.
Vinyl Chloride, ppn
" 30 Min.
Suspension Resin ' Euildine 1
30 30 30
11-3 11-9 11-10 12-8 12-10
77 134
29 21 55 48 132 92 32
<
Oo
I-XMIH1T U -1C (5) USDOL/OSHA
V ear
Date
Copolyrncr Resin Bvjildinr,
Suspension Rcoin Eulldtn^ 1
1966 i
ISO.
1-14 3-29
9-6 9-13
<y K
//JLi--
3
A
26 50 18 23 94 49
00
\
1967
2-8
2-9 vv>79
I
2-10
' (IS
2-14
2-15
20
2-17
126
2-20
129
106
4-14
40
6-30
20
4-26
100
BFS 008735
l
i
o oo
EXHIBIT B-16 (C) USDOL/OSHA
i
1*1
CD <3 QO N
Year 1967
Folyr.erlzer Vapor Concentrations: Vinyl Chloride, ppm
Date 5-15 5-16 9-8
9-14
9-18 9-27 12-4
10-26 11-1 11-2 12-18
Suspension Resin
Building
Building
t 111
Dispersion Renin & I-itcx
Building 121
46 v>. 14
55 105
<3 if
^34
79 109
75 hb 122
18 74 134
36 34 60
32 55 70
67 100
58 105
55 30
59 59 36
13
20
19
16
77
628 555 490 219
Year 1969
Date
1-31 2-3 2-14 3-26 9-22
9-29
Copolymer Resin
Building 13
o
Sunpenoion Rcoln
Building
Building
1______
111
EXHIBIT B-16 (7) USDOL/OSIIA
Dioperoion Renin & Latex
Building 121
9-30
1
1973
3-22
3
l
O
VCL MONITORING data Area Measurcnents Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons bysAshe place Ionization Method
KXiiiJUT IJ '10(3)
usnoi,/osiJA
Building
Product
LJ/ X'
Month /^A^erage
Z Readings Above 50 PPM
Z Readings Under 10 PPM
(
121
Dispersion
Q 11K
JAN. 74
10.9
0.2
Resin and
PU3. 74
3.2 5.9
Latex
MAR. 74 APR. 74
12.4<J>
0.6 1.7
40.8 62.0
MAY 74
9.5
1.0
86.2
JUNE 74
4.2
0.9
88.3
111
Suspension JAN. 74
35.6
9.1
Resin
FE3. 74
20.8
2.0
MAR. 74
15.6
1.5
APR. 74
12.1
1.8
MAY 74.
8.9
1.7
JUNE 74
3.4
1.5
0.2 5.9 36.0 71.0 90.2 90.5
BF5 00SF3S
O
i:>:!ii!:: I n . u, USUOI./OSHA
E ul ldlnf.
1
Product
Su ;>'*nsiou
P.osln
Month
Aver c'.-c ~Pi' -
24.9 16.9 16.6 12.1
2.1 5.5
a Ren dir ns Above 50 PPM
3.0 0.6 1.3 1.3 1.2 1.1
I Rending Under 10 PPM
0.4 7.8 21.0 73.8 90.9 91.2
15 Copolymers
6.4
0.7
2.2 5.1
MAR. ?4 <1" 11
1.2
29.4
APR. 74
MAY 74
2.2 64.7 4.6 62.9
1
JUNK 74
1.7 78.6
115
VC1 Recovery
JAN. 74
- Data Not Taken -
Purification
PUB. 74 MAR. 74
27.0 T?r\3.0
29.0
iP 5.0
0.5 9.3
APR. 74
15.5
1.9
34.7
MAY 74
20.2
5.4
33.3
JUNK 74
17.6
0.8
25.2
BFS 0057J9
I i
o oo
EXHIBIT B -1G(10) USBOL/OSHA
PERSONNEL MONITORING DATA - MAY-JULY, 1974 -
Location and Type Building 121
Latex and Dispersion Resin
Building 111 Suspension Resin
Building 15 Copolyner Resin
Operation
Giarglng Cleaning Recovery Plpefitter
No. of Samples
4 2 2 1
TWA Average
5
**
4
Charging
on.
Cleaning
OVv
Recove ry
Bagging and Drying
^3 h,
hL
4 1
Charging Cleaning
Baling Pipefitter
-
iP 14
PPM VC1
Maximum
5 2 6
19 7 3 1
4 11 10 -
Mln1num
2 1 1
7 2 <.5 . <.5
2 6 7
Building 1 Suspension Resin
Charging Cleaning Recovery Bsgglng
2
\3
2
11
3
15 . 42
1
1 3--
i * o t f t ?; i fcveryonc wears respiratory equipment where the work atmosphere is greater than 25 ppm or where operations and experience show there is a risk of exceeding 25 ppm.
Personnel monitoring samples are taken over a period of time generally 4 hours Co obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography.*
Source: Snell summary of industry data
*
<
Oo
EXHIBIT 13-17(1) USUOL/OSHA
MONITORING RESULTS FOR 44-M-NEW-C
Attnospher lc Vinyl Chloride Concentrations Suspension and Dispersion Resins
I
Middle We s t South Aren East Middlc West
Vinyl Chloride Concentration,
___________ PPrci
11:20 a.m.
1. 6. 4.
6. 4. 8.
27. 19.
6.
BFS 0QS741
0
J-XilliilT ii 17(2) L'SIJOL/OSIIA
Wednesday, 7-19-72; 3: 30 p.tn.
North Area F. a s t Middle Wet
Center Area
K
East Middle "W . (f;
South Area Eust
V>
Middle
rf \V
i West
4. 6. 6.
4. 4. 4.
2. 4. 6.
9:30 p,m
North Area East Middle West
Center Area East Midd le
South Area Middle We s t
96. 19. 55.
78. 29.
.110
78.
BFS 00
fe f-j
I
O
EXHIBIT B -17(3) USDOL/OSI1A
Suspension and Dispersion Resin con 1t.
Thursday, 7-20-72; 10:00 a.m.
PUt L II Art* <1
hast Mi dd ,, West ^ I[ff ^ Center Area! j
16. 4. 8.
i
East Middle West
'<^7J>
d>
South Area
12. 8.
12.
East MUd 1c We s r
j.
2102..
20.
i^>-20-72; 4:00 p.n Thursd
Mass Poly Building
iP
Botton of Prcpoly (Charging VC1) First Level of I'repoly Second Level of Propoly liurd Level of Prepolv
9. 6. 12.
Near Vinyl Pumps (Outside)
Tank Farm Near Vinyl Pumps Under Vinyl Storage Sphere
6.
1. (N.D.) 23.
BF5 003743
o oo
USIJ0L/0S1IA
VCL MONITORING DATA
Aren Measurements Using Portable and Fixed Instrumentation, Measuring Total hydrocar bons by the Flame Ionization Method
Building
Product
Month
Average ppm
X Readings
Above 5v PPM
7. Readings Under 1U PPH
4
512
Mass Ss.
JAN. 74
23.8
Polymerlzat
FEB. 74
15.5
MAR. 74 ATR. 74
11.5 10.5
74 8.7
74 8.9
5.1 2.0
1.1 0.6 1.4 0.6
35.7 46.5 69.3 76.2 79.3 80.7
CD
IF
513
Suspension
JAN. 74
17.1
3.8
39.1
and
FEB. 74
14.5
2.4
66,0
Dispursi on
MAR. 74
11.0
1.0
81.3
Resins
ATR. 74
8.8
0.7
78.8
<S
MAY 74
9.4
1.2
75.2
CD
JUNE 74
8.8
0.5
75.9
00
N u
L
oo
EXHIBIT B - J 7 (5) USDOL/OSHA
PERSONNEL MONITORING DATA
LocatIon and Type Mass Resin
> Operation
Charging Cleaning Recovery
No. of Samples
4 5 4
Average
WA PPM VC l Maxi rrura
Mini quo
9 27 22 46 11 23
2 6 2
Nuspcr.slor. and Dispersion Pen in
^CN'hrg ing Craning RecW^Ky Dryi/nM&nd Bagging
Tank spp^p>
7
3 3 2 2
11 20
1
33 32
4
785
1
Ml
Everyone wears respiratory equipment wher^tfee work atmosphere is greater than 25 ppm or where operations and experience show there is a risk of exceeding 25 ppm.
Personnel monitoring samples are taken over
d of time generally 4 hours to obtain the time weighted
average for employee exposure. All samples are' collected by* absorption on carbon tubes and tested using gas
chromatography.
\J)
Source: Snell summary of industry data
HArilBli b-18uj USDOL/OSHA
MONITORING RESULTS FOR
3-M-INT-C
Sample Point' Number 38 39
&0
41
42
43 44 45 46 41
Location
SE Corner, Lower Polymer Building
SW Corner, Lower Polymer Building
SW Lower Polymer Building
Center of Lower Polymer Building
NW Lower Polymer Building
N Comer, Lower Polymer Building
NW Comer, Lower Polymer Building
Outside NE Polymer Building
Front of Polymer Pit - Outside
Lower Polymer Outside
Breathing Zone
Fans
Facing Toward Center of Building
On 2 off
Facing Toward Center of Building
On 2 Off
Fan Level, in Front of Small Exhaust Fan
On 2 Off
Breathing Zone
evel, in Front of Exhaust Fan
On 2 Off
On 2 Off
FaiSipg Toward Center of BuildingV^
On 2 Off
Facing Toward Center of Building
Facing Toward'T^jj^'^
On 2 Off
On
<P
In Front of 4 ft. Fan^^ Facing Toward Fan
On
In Front of 4 ft. Fan Facing Toward Fan
On
No. Of Measurements
4 17
4 17
4 17 4 17 4 17
4 17
4 17 21
21
21
VCM Concentration^ PPM
Average^
High
Low
6 19 1 a 19 1
1 10 6 23 0
6 15 1 5 28 0
4 81 27 325 0
4 81 15 175 0
3 30 8 38 1
1 31 7 31 0
6 43 0
10 32 0
12 115 1
B F5 QQS74S
t
iLA.
'.X l
UJ
USuuL/Oan/i
Sample Point Number 48
49
SO
SI
52* 52 S3 S3 54
55 56 56 57
58
Location
Breathing Zone
On Slurry Platform By Shack - Westside
Breathing Zone
Upstairs Polymer Center of Locker Room .
Breathing Zone
SE Corner, Upstairs Polymer Breathing Zone Across From Locker Room
SE Corner Upstairs Polymer By Ice Tank
Facing Toward Center
SW Comer Upstairs Polymer Facing Toward Center
SW Corner Upstairs Rpl^ovCr Facing Toward Center
Center Polymer Control l|6om.; Breathing Zone
Center Polymer Control Rooni Breathing Zone Is (ZT'\
Center of Upstairs Polymer Bre&tKin^ Zone By Reactor 307-308
NE Corner, Upstairs Polymer Facing'Toward Center Facing Tow^^Center
NW Corner, Upstairs Polymer
NW Corner, Upstairs Polymer Facing Toward^nier
West Center Monomer Pump House
Breathing Zone
Center of Monomer Pump House
Breathing Zone
Fans
No. Of Measurements
21
On 16 Off 5
On 21
On 21
On 3 18 3 18 21
On 21
On 3 On 18
On 17 Off 4
On 17 Off 4
VCM Concentration^ PPM
Average^
______ Range
High
Low
28 105. 0
5 17 1 3 52
7 25 0
16 134 1
16 22 6 17 52 2
2 21 14 101 0 16 100 2
12 45 2
7 11 4 22 325 0
6 24 1 27 52 1
4 16 0 24 62 2
BFS 008?
fc M
t
EXHIBIT B"18 (3) USDOL/OSHA
Sample Point Number 69
19
80
Location
East Center Monomer Pump House
Hose Conner House on Slurty T^ftU^atform Wind Vector'jpj>{>$JiUe Side of Property j (O
Breathing Zone Breathing Zone
Breathing Zone Facing Toward Wind
Note: (1)
(2)
Measurements taken by Centuiy Organic Vapor Analyzer Snell average of data submitted
Source: Snell summary of industry data
Fans
On Off
No. Of Measurements
n 4
16
5
VCM Concentration^ PPM
Average^
9 37 46
High
23 62
186
Low
1 9 3
1 10
SJS
BFS 0B8749
Ptoceti VCM Tank Car
Blowdown
Centrifuge & Drying
<3 ^V> <9
Bagging
Source: Snell summary of industry data
EXHIBIT B-19 USDOL/OSHA MONITORING RESULTS tOR 9-S-INT-C Exposure U) (ppm - VCM}
unloading up to 100
up to 100
25-30
25-30
EXHIBIT B-20 (1) USDOL/OSHA
MONITORING RESULTS FOR 42-S-INT-C
4 Shifts - Textile Workers
Classification
Production
Reactor Operator (clean reactor) Dryer Operator Lead Operator \^S^-vice Operator (material handling)
Operator (reactor guard) K^(t\ Maintenance Maintocr 'ii\lr^T'c-c' Workers Hstrumer.: ^jdamtenance (part time) Electrical^Maintenance
Supervisory ant
Q. C. Supervh
Q. C. Technic.arr ^
Engineer
\J)
Plant Manager
f oreman
Safety Engineer
Lab Technician
Analytical Chemist
R & D Resin Chemist
Number
16 12
8 4 8
5 4 3
1 4 4 1 5 1 2 1 2
% Exposure
100 100 100 100 10U
100 50-60 10-20
30 100 80 - 90
BF5 008750
EXHIBIT B-20 (2) USDOL/OSHA
Location
Monomer Hump Station (open air) Pump House (open building) Storage Tanks (underground outside) Day Tank (outside) Reactor Room #1 Reactor Room #2 Open Manhole-reactor (momentary) '"`pen Manhole -exhaust in place
sactor during rinsing 7$acjtor during scraping
(open once per shift) Slurcy Tanks (open manhead) Slurrj(jT'anks (closed) Slurry Ta^ks while rinsing Centrifug^--- Dryers a Bagging 'Xjfx Storage Area"^^^
walkway ' <r\ between bags vi* Bulk Storage Transfer Vessels
Source: Snell summary of industry data
Level ppm
0 0 - 150
0 0 0 - 40 (30 avg,) 35 avg. 70 - 80 5-6 0-20 600 1000 3000 - 10,000 0 200 0-35 less than 20 0 - 100
0 85 10 - 20
I
BF5 00S751
Area Measurements Using Portable and Fixed Instrumentation, Heaaurlng Total Hydrocerbooa bv the Plane Ionization Method
EXHIBIT B-21 USDOL/OSHA
MONITORING RESULTS FOR 14-M-INT-W
Building 812
Product
p
Susnen-. (i'r, Rf<! In
--^Tjf) Average
S'" v (f^ PP"
JAN. FEB. MAR. APR.
74 74 74
27.4 ,#4.8
1
MAY 74
JUNE 74'
A Readings Above 50 PPM
2.6 1.8
2.4
2.2
0.5 1.3
X Readings Under 10 PPM
25. X 24.4 57.0 49.5 23.1 90.7
BFS
EXHI9IT l<3
USDOC/04HA AVERAGE VINYL CHLORIDE MONOMER CONCENTRATIONS (PPM)
JOO CLASS IfCATION AND POLY VINYL GMU>*OC n>NT<1*
Job Claidftcation
i. VCM Unloading VCM UatoaOaa
0. rvC PMdacdo*
SuforrlNKl Itdoi tuctu OpaaioQ Rcactf* Oponton
Chaigut HrttywOpmiwi
Centrifuge Opwittn Pfjot Op**atMv Utility (CIhmi, ubomn, on.)
*l|w
to. wirrbow Qpowiiam W
IV. Uiioiut(3)
12M4M.-C rtt-lQL-W 18L-Neu -W
HA
HA
II
HA
^
S
HA
%
5
HA
9 1 4
<iV"
34 ( 4,
IM-Neu-W 22M-OM-C 31M-New-C 411-Old *W 2BL'Nw< MM-New -C SL-OldC 4L-Nev-C 49M -OU-C 44M-New< dvvrag ,, w
HA
HA
a
HA NA
NA
NA
HA NA'
NA td
49
4
22 NA HA NA NA 1 NA NA
NA 10 23
HA
NA NA
S 9 20 NA NA NA
NA 9 20
U
NA 30
NA NA
34
NA
NA NA
NA 11 90
NA
HA NA
1 NA
70
10
44
10 If TO
NA NA NA NA 90 6 30 S NA
9 39 00
HA NA 3 NA 120 NA NA NA NA NA NA lit
HA
IT
a
NA NA
91
1 NA NA
1 19 i
14 NA 11 84 NA 24
0
14 tl ti
HA
I
3
33
80
1 NA
1 1w
4
NA
NA
NA
2
NA NA NA NA
NA f 30
NA
NA NA 92 NA
3 HA NA NA
NA 34
98
V* UhtdouMttkeviay >
TooJmVcMm
()VI. MJUUfemcM ud SupfoN
Am>|i of kpmtN Diu
NA
1
HA NA NA
1 19 ST
NA 1 HA NA NA NA NA NA NA
NA
NA NA 114 NA 41
NA NA NA
AI <1 .Sa IT 14
NA ;
NA NA 2 41
3 3ft
NA NA NA 13 4 1
NA HA
4
NA 43 194
HA <1
t
19 m
ii?
JlgUK (1) 0>u bcUcrod to bo obtained from ova, bag umptaa, cfeaicoal tube pomp oi ana monitoring cn a mirad
(9) InclndM wpctvfaon and cledn. ** band primarily on warahnMmoo. (3) Inckidei mporrlMa and malmtaanro nn. (4> ladtdn nperriaen and cHMtn. (S) Inrbidn plant manages, inglnttfi and dedeal fwin--al
|oncm EiddMn B*t ibatrigb 1*91 and I
f ladniuy* nada wing data.
1 <1
a
BFS
EXHIBIT B-23
USDOL/OSHA
SUMMARY- OF POLYVINYL CHLORIDE PfiODUaNG INDUSTRY VINYL CHLORIDE MONOMER MONITORING DATA SUBMITTED TO SNELL
Plant
12-M-lnL -C Index 11)
22-M-OId-C index <1)
41-L-Old-W Index!D
S4-M-New-6 Index (1)
5-L-Old-B Index (1)
S-M-Int-6 Index (1)
Total No. of Polntx Total Index Value
$ of Total Index Value For
Concentration Range
oi
76 6.45 '0
0 0 0 1 0.26 4 3.64 13 3.99
#4 15
>i<8
Number of VCM Concentration Measurements Giving Values In Concentration Range (PPM)
>5<10 >10<15
>15i20 >20i 25 >25-- 30 >30 <35 >35 <40 >40S 45 >45< 50 >50
Total Points Fot Plant
Type of Data Bast)
449 38.12
131 3.82
327 22.76 3.297 96.18
36 3.06
0 0
160 47
HIM
22.18
61
IVrO/?' . 15.14
i 16
/,v18
15 < P>
16 7.62
0 ,0
24 21.24
S3
4V4.60
19.33
758 3,086 }\ 139 111 213 L K61
214 18.17
0 0 0 0 27 6.70 13 11.50 42 12.88
296 49
0 0 0 0 0 0 81 20.10 6 5.31 18 5.52
105 31
76 8.45
0 0 0 0 27 5.70 0 0 21 6.44
124 SO
00 00 00 00 00 00 0 . 15 0 3.97 00 00 0 .0 00
0 16 04
0 00
0 00
0 00 0 00
0 00
0 0 23-38
0 0 127
0 0 31,51
0 47
2
0 41.59
1.77
0 16
0
0 4.91
0
0 63 176 0 47 56
1.178 100
3,428 IDO 210 100 403 100 113 100 326 100
5,656 600
Average TWA Values. Average TWA Values. Average of Imtantineous Readings. Average of Instantaneous Readings, Average Twa Values, Average of Instantaneous Readings.
3* 19$ 36$ --
8$ ... .......
5$
3$ 0
1$ 0
8$ 9$ - 100$
03
'n
<$) IS) oo Ul
>15<, 20 >20<. 25 >25130 >30135 >35140 >40145 >45150 >50 VCM Concentration Range (PPM)
Notes; (l) tndex(l) developed from die formula; No. of Points in range/total number of points reported by Plant = 1/100. (2) Data believed to be obtained from OVA, bag aamplea, charcoal tube pumpt or area monitoring on a mixed time baiia.
Sources: Exhibits B-4, B-7, B-lJ, B-13. B-18 and Snell assessment of reported data in exhibits.
i
EXHIBIT B-24
DSDOL/OSHA
SUMMARY OF OSHA VINYL CHLORIDE MONOMER MONITORING DATA OF POLYVINYL CHLORIDE PRODUCING PLANTS
r
BFS 008755
Plant
oil
>ils
Number of VCM Concentration Measurement 1) Giving Values in Concentration Ranee (PPM)
>SS 10
>10! 15
>15l 20
>20 <25
>25130
>30l35
>355.40
>40< 45
1(2) IndexO)
u<2> Index*
3 3.87
13 16.77
\4 }
>
6 7.74
4 5.16
2
6.66
,l 3.33
1 1.29
0 0
1 1.29
0 0
1 1.29
0 0
0 0
0 0
01 0 1.29
00 09
7(2) lndexf3)
0 0
Total No. of Point* Total Index Value
% of Total Index Value For
Concentration Range
3 4
3*
1 4
.,,,2l
21
43 " "A.
0 0
5 8
43% *) d;-
21 84
32 95
8% 4%
i' 2 48
22 48
3% 7%
0 0
0 0
0
1 4
2 5
4%
-i >45150
>60
01 0 1.29
01 0 3.33
11 44
13 49
3% 9%
Total taint* Far Plant
31 40
12 40
10 ` 40
53 . 120
100%
Average VCM Concenttation for Reported 53 Sample* 14 PPM
3a
oI
100%
90
g 80
21 10
a| w
gl 60
si40
g3 30
20
& 10
0
mm////77/Ty
T7TTTTT77 W/////A y//%7&yJ V///////A 777/77777,\/rrrr///A ////////,
0<1
>1<5
>5110
>10l 15
>15l20
>20l25
>25i30 >30l35
>351.40
VCM Concentration Range (PPM)
*
C
Y7Z77ZZZZ '77/777722'. Y/////Y6,
>4t>l45
>45l50
>50
Note*.- (1) l)au based on approximately 10 min. tippin type {ample* with 1 liter ambient alt collection over charcoal tube* analyzed by the NDSH method.
(2) Plant code* are thaw developed by OSHA. (3) Index (1) developed from die fomula; No. of Point* in range/total number of point* repotted = 1/40, Santee** OSHA data tubmltted to Snellt Snell anenment of data.
't
EXHIBIT B-100 USDOL/OSHA MONITORING RESULTS FOR 13
Operation
No. of Samples
Average
TWA PPM VC1 Maximum
Minimum
Furnace^Operator *
EDO Sy n thaj^^%
13 5
2 0.2
11 Nil 0.4 Nil
<f Purification
(k*
17
1 4 Nil
tank Farm
10 10 25 1
NOTES: Everyone wears respiratory &)*lpment where the work atmosphere is greater than 25 ppm or where operatlons^-and experience show there is a risk of exceeding 25 ppm.
Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography.
Source: Snell summary of industry data
BBS 00SF5&
I
Control Room
EXHIBIT B-101 (1) USDOL/OSHA MONITORING RESULTS FOR 24
~ -EmPloyees Exposed^
20
2
N.A.fl)
VCM Exposure Level ippmi 10 - 15 6 - 16 < 0.3
EXHIBIT B -101 (2) USDOL/OSHA
Location and Type ^^>ension Resin Notes; (j5-
PERSONNEL MONITORING DATA MAY - JULY. 1974
TWA
Operation
No. of Samples Average
Charging Cleaning Recovery
33 33 32
N.A. =
Available
//>
(1) Operations personnel spend 75% of time in control room
PPM VCL
Maximum
6 4 4
Minimum
1 2 1
Everyone wears respmlWy equipment where the work atmosphere is greater than 25 ppm or where operations and experi^nj^e show there is a risk of exceeding 25 ppm.
Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography.
Source: Snell summary of industry data
BF5 00SF59
Area Block I Block II Offsites Control Room Office Maintenance Laboratory Ship Loading
TABLE 1
Current VCM Exposure Levels (TWA)
VCM. (ppm ave.) 2.0
VCM (ppm range) .1 to 15
1.2 .1 to 8.6
4 V'
3.5
0.7 !L^ 1.4
.1 to 66 .1 to 9.5(1) .1 to 29(1)
4.31P 3.1
.1 to 50 .2 to 50 1.4 to 5.5
EXHIBIT B-102(l) USDOL/OSHA MONITORING RESULTS FOR 15
No. of Data Pts. Measuring Device 28 (2) 24 (2) 43 (2) 56 (2) 52 (2)
129 (2) 42 (2)
4 (2)
TABLE 2 Current Results of VCM Area Monitoring1 2
EXHIBIT B-102 (2) USDOL/OSHA
Area 4 Block 1
Block II
Offsites
Control Rqctfjy
Office
C"N *f(C>
"3ff>
Maintenance
K
Laboraotry
Ship Loading Notes:
VCM (ppm ave.) 8.6 6.8
* 15.3 1.6 4.9 1.4 3.7 13.7
VCM (ppm range) 0 - 119 0-124 0 - 898 0 - 16.2 0 - 2.1 0-4.9 0-28 0 - 278
No. of Data Pts. 270 270 260 18 25 14 23 73
(1) Employees in these areas are periodically in the process unit.
(2) The measuring device used is a Bendix Environmental Science Division Permissible Air Sampling Pump. This device is worn by employees for time periods of 20 minutes to 8 hours. It detects VCM by carbon adsorption and is analyzed by flame ionization GLC.
Source: Snell summary of industry data
BFS Q0S7&0
*' 4
!
EXHIBIT B-103 (1) USDOL/OSHA MONITORING RESULTS FOR 34
INDUSTRIAL hYGIELE SURVEYS OF VINYL CHLORIDE
ibels in i-mw pm io, i
job aflssiFirjTiffl
m
A Control - Section I
C $|Sol - Section I A ContC^j^ectjon II
B Control ^SIectiqn III
3.7 8.2 1.8 14
A Control - Section IV
\f\2 'Cuss I Operator
( ) No. OF SAMPLES
<jf>
6.9 1.8
IT^\/ ppm Vinyl Chi drrnr
w.
0.7 G)
1*3 n.d.*G) 0.6 G)
hi
2.1 (2)
3.6 1.0 G) 0.6 G) 8.9 ft)
*W.D. *= NON DETECTED
BFS 00SFS1
i
fI :
r
EXHIBIT B-103 (2)
JOB aASSiFirfflrjfflf
A Control - Section V ^ Control - Section V
^ SST, Cheh, JJ Supers sq&n l'kmcNANos:
uh lowilio Q'CMfSP ,
Overall Average ^jp ( ) ft). OF S/ViPlS
H.D. = NON DETECTED
8
m
1.6 3.5 5.1 2.8
JM' PPM VlKYL Chi nr? i nr
12Z2
i:
> 0.2 0)
1(1 0) 1.3 0) 1.7 0) ` 45. 0) 7.0 (27)
122 5.2 (2) 3.3 17.6 (2) 1.2 0) 2.0 (5) 1.1 0) 4.2 (29)
I
BF5 008763
EXHIBIT B-103 )
INDUSTRIAL HYGIENE SURVEYS OF VINYL CHLORIDE
Mtmimm
lmls in m\ra plant no, i
M/ .prm Vinyl Chi nftipF 1974
1st Otr
2nd Otf
A Section I
C Camo^jpSccTiaj I
f0 A . ConTROL^SecTIGN II
B Control - Section III A Control - SeSSLiv
(Jf)-Class I Operator
A Control - Section V C Control - Section V
I
v
EXHIBIT B-1Q
""M
M, PPH Vim 'famine
1st Otr
m
2nd Otr
Sr, Asst, Chem, B F^VISION Mm^^nce
(JO LdadjW Operator
Dev. Lab* Overall ( ) No. of iifes
12.7 2.9 (4) 1.7 (4) . 16.5 6)
. 0.9 (4) 4.4 (24)
*
2.7 (5) 2.5 (4) 6.8* 0.9 0) 1.9 (20)
"Peak Exposure measurement ivere made FOR THIS JOB.
BFS 00S764