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 BFS 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 BFS 00 CO u u BFS &0S540 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 BFS 00S341 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 BF5 0B&343 * 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 BFS 008344 < 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 <$> 00 Cl b 0| f i BFS 00S346 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 BFS QQS348 .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. BFS 008349 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. BF5 008Z5Q 1-3 II. METHODOLOGY i BFS 00S351 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. BFS 008353 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- BF5 00S355 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 BFS 0BS356 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 BF5 00S357 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 BFS 0O8359 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 BFS QQSZ&1 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 BF5 0QS3&4 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 Mt. *f V--rtoe tripimow 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 Incremuiil CylUtC*| _ (Poiuni Opcattow 4 bUliU4M4 Co* tl OoiUwl frinra^ 4* *U U*J (M U4M *<W*HHHWH f ft Ml. loo 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). BFS &0S523 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, $20 test). o cf 1 * Probably can be cost-^e^ounted through Bio-Science Laboratories and other ^il^Ilar laboratories. /Is BFS 00S52 NBJAq * APPENlfeCb X/ fF\ M> SAFETY AWARENESS^RORBAMfi <$> 00 Ul K) 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. \t, (1) 29CFR 1910 Occupational Safety and Health Standards, Proposal Standard. G-I (h BFS 00S52 i 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 BFS 00S52 BF5 00S52 - i*. f Oj 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 BFS 00S53Q 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. BFS 0Q 8531 i i < 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 <5> c$> CO Cfl 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. c i jj ^ 11 --\ O 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. BF5 ! 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. BFS 008533 V 5 j J to >1 in <3 co 01 -L 'C'J Al^gDIX H NIOSH.RECOMMENPED OCCUPATIONAL HRALThJ^aRD FOR THE MANUFACTURE OF SYNTHETIC POLYMER FROM VINYL nm.nmriE TM , ,//V/ < >> fr 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. H-l * 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 *\ 00S5J5 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. i'T*^ \J)J ( 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 BFS Q0S5Z6 K-2 JS00 * f*' f 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 I SFS 00S53S (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 ' Wf 1 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. BFS 008539 (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, BFS Q 08541 H  rr i 1 CD CD CO 01 4k *0 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 / r t t \i i J 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