Document 1xV8Do7K9a2V7ZNVEvbw7jyZ

X cT^tk'fyac/ueti- anct C%e*nieaL INC. CHEMICALS GROUP CALVERT CITY PLANT P. 0. Box 97, Calv#rt City, Kentucky 42029 Telephone 502 395-4181 26 March 1980 received. ( RPR 9 1980 J. c. NOVAK Mr. George Schauberger Kentucky Department of Labor Division of Occupational Safety and Health Compliance U. S. Route 127 Frankfort, Kentucky 40601 Dear Mr. Schauberger: This letter is to provide you with the information you requested regarding two emergency vinyl chloride releases reported to your office by B. D. Helms. An emergency release of vinyl chloride occurred on IS March 1980 when the rupture disc and relief valve opened on the monomer recovery decanter. The operating department using proper protec tive equipment was able to switch the relief system to an alternate relief system, reduce the monomer level in the decanter and stop the release. Approximately 347 pounds of vinyl chloride was re leased. No injuries or symptoms of exposure were determined as a result of the release. The release was attributed to a failure in the level control instrumentation due to a polymer buildup. The system was cleaned in a two-day shutdown. Preventive measures will include more frequent inspection and cleaning of this system. A small release of vinyl chloride occurred on 18 March 1980 when a gasket leak developed on the charge header to one of the reactors. The leak was sufficient to develop an area concentration of vinyl chloride above normal for several minutes. An instrument technician walked through the area and was exposed to vinyl chloride. He has received medical surveillance and the results have been negative. No other injuries or symptoms of exposure were determined. The gasket was replaced. Sincerely, AIR PRODUCTS AND CHEMICALS, INC. J. J. Baliker Plant Manager AP00031619 (z^<^ck^/u?duct\ Date 9 April 1980 INTEROFFICE MEMORANDUM Subject Regulating the Access to the Calvert City PVC Plant To J. J. Baliker From J C. Novak _______ _____ CalveTt City (Location, organization, or oaeartmami Chem. Mfg./Trexlertown (Location, Organization, or O*0*rtmnt) cc: A. F. Cantor T. L. Carey R. E. Davis J. w. Gentile B. D. Helms R. C. Lietzau T. R. Low E. K. McIntyre W. T. Rector H. J. Smith ' Conclusions 5 Recqnmendations: It is recommended that the following four areas of the PVC plant: 1. Poly Building 2. Monaner Recovery 3. Slurry Stripping, and 4. Gas Holder/VC-1 Storage be regulated and the access to these areas be controlled and limited to those who are authorized. A program to maintain a pool of authorized contractors should be initiated. Work practices and the USE of protective equipment shaild be strictly enforced. Discussion: The subject of regulating the PVC plant has been debated for several weeks now, with decisions being made subjectively on whether or not to establish a regulated area. No proper analysis has been made of the need for regu lated areas and no consideration has been given to factors other than OSHA in making such a decision. In reality, we should be addressing the broader question of whether or not to restrict access and activities in the PVC plant. In this broader con text, the "Regulated Area" requirenents of the OSHA VCM Standard beccme almost inconsequential. It must also be realized that the "Regulated Area" requirenents are based on the long standing industrial hygiene principal of limiting the number of people exposed to highly toxic materials in order to reduce the overall risk. (3201 AP00031620 J. J. Baliker 9 April 1980 Page 2 Regulating the Access to the Calvert City PVC Plant Basically, the reasons for restricting access to, and activities in the PVC plant are these: A. Health 1. Limiting the nunber of employees exposed in order to reduce the overall risk. \ 2. Controlling releases of vinyl chloride which might result in overexposure of employees. 3. Controlling liability resulting fran exposure of contractors, visitors and other non-APCI personnel. 4. Canpliance with OSHA VCM standard. B. Prevention of Fire and Explosion to protect both personnel and equipment: 1. Controlling sources of ignition (e.g. hot work, vehicles, electrical equipment). 2, Controlling releases of VCM which may result in flammable concentrations. From an economic standpoint, the most compelling reasons are the control of liability and the prevention of fire and explosion. Losses in these areas would easily dwarf any OSHA fine. There are other, more subjective, reasons also, such as the negative publicity arising fran liability suits or major fires. In addition, the lack of good safety and health practices and their enforcement is clearly contrary to corporate policy, and promotes loss of credibility, distrust, poor productivity, disloyalty, etc. .lierefore, even if a decision is made not to "regulate" the PVC plant for OSHA purposes, it should still be "restricted" for the many other reasons cited above. It may also be enlightening to examine the requirements for restricting access and activities. It can easily be seen, that "restricting" the plant automatically takes care of OSHA requirements for "regulating" th plant. The corresponding requiranents for access/activity restriction are these: A. Health 1. Establish criteria for "authorized" onployees. Enforce access restrictions on all but authorized employees AP00031621 J. J. Baliker 9 April 1980 Page 3 Regulating the Access to the Calvert City FVC Plant 2. Establish and enforce standard operating procedures and safe work practices. Establish and enforce clearance work permit system for mainten ance/repair work performed by APCI employees. \ Control the work of outside contractors through close super vision and permit procedures. 3. Inform all visitors and contractors of the hazards of materials they may possibly encounter, necessary protective measures, and emergency indications and procedures. Ensure that contractor employees receive OSHA. required training. Ensure that contractor employees are not predisposed to effects of VCM exposure by ensuring adequate medical surveillance. Ensure that contractors are aware of and adhere to plant safety rules and practices. Ensure adequate insurance coverage by contractors. 4. Provide training for authorized employees. Provide medical surveillance for authorized employees. Post signs to designate area. Enforce access restrictions. B. Prevention of Fire 5 Explosion 1. Establish and enforce hot work permit system for both APCI employees and non-employees to include non-approved electri cal equipment in hazardous areas. Establish and enforce procedures to shut down all hot work and prohibit vehicle operation during emergency release of vinyl chloride. 2. Requirsnents same as A. 2. Finally, based on the area monitoring results, tabulated since 18 March 1980, the VCM concentrations in the monaner recovery area, poly building, slurry, stripping area and the gas holder area are in excess of the permissible AP00031622 J. J. Baliker 9 April 1980 Page 4 Regulating the Access to the Calvert City PVC Plant exposure level on a routine basis. The anployee personnel monitoring results show VCM exposures above one part per million at too high a frequency to consider it occasional. JCN/fgw AP00031623