Document 2q6kN16empjmkLxJ52ypxo5aN
Rev!sod
7/3/75
Methods of Compliance
to the Permissible Exposure Limits OSHA Regulation 1910.93 q - Standard for Exposure to VC1
BFG Technical Center
OSHA regulation 1910.93requires that employee exposures to vinyl chloride shall be controlled to 1 ppm or less of VCI averaged over any 8 hour period and that no employee shall be exposed to vinyl chloride at concentrations greater than 5 ppm averaged over any period not exceeding 15 minutes. If exposures are above this, feasible engineering and work practice controls shall immediately be used to reduce exposures to at or below the permissible exposure limits.
At the Technical Center we have on going programs in both the engineering and process departments. Written plans for these programs are attached and will be furnished upon request for examination and copying to authorized representatives of the assistant Secretary of Labor and the Director of OSHA. These plans will be updated at least every six months.
These plans will also be shown to enployees who are exposed in excess of the permissible exposure limits to show them the steps being taken to reduce their exposure to within the permissible exposure limits.
LAB:jj
Lee Bennett VCM OSHA Administrator
NGC 22825
SPECIAL OBJECTIVE A. Enoineerlna Projects Divert VCM vapors now vented to room
Disperse exhausted vapors higher in atmosphere
Insure adequate bldg, ventilation
Replace high emission source pi lot plant equipment.
Minimize regulated areas.
Reduce or eliminate environmental emlssIons Same as above
PROJECT Spot Venti1 at ion
Bldg. 414 exhaust stack
VON LAKE TECHNICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT
COMP. DATE
PERSONNEL ASSIGNED
ENG
COST
TOTAL
3-1-76
Gary Wi1 son Jim Ego
$50,000
$150,000
Hold
Gary Wi1 son Jim Ego
$33,000
$120,000
Building vantilation a) B/414 E Emergency ;
Norma] b) B/414 W c) B/414 S " d) 8/417 "
7
12-75 12-75
7
Gary Wilson Jim Ego
$75,000
$600,000
Replace present 15 gai
polys with 55 fc HO liter polys.
1977
Gary Wilson Jim Ego
Consolidate VCM using laboratories a) construct analytics
addition to B/423 b) Move 3.1 1 Iter pol',
to B/414
cl Move aeneral lab tc RD fr RV discharge coni a) smal1 polys
bl iaroe oolvs Design fr construct a V recovery system for Wt process.
HOLD lab , ab i/414 >1 197S
1------ T57S--------
R. Cahill E. Webber
G. Wilson
Smith
Glock Hubbard
$150,000
$50,000 $35,000 $50,000 $40,boo
$600,000
$500,000 $115,000 $200,000 $lbt>',QQ0
REMARKS
Integral part of general building vent fr exhaust stack. Estimate covers design t installation of spot ventilation hoods t droos. 75% comoleted. A general exhaust system is being designed. We plan to pipe fresh air to point of need and exhaust air from point of contamination. We may or may not use a large stack. May use several smaller ones. Replace present heating-ventilation equip ment with new heaters V emergency exhauster. Use spot ventilation where practical. Elimlnate windows a repair ail major air leaks in building. Emphasize good air distribution. Temporary Is completed. Permanent is started. Detail estimate almost complete. Hope to submit EA In Julv. 1975. Installation of two new 55 liter polys with blow down tanks and stripping and drying system. I0X complete. Reectors on order. Process engineers are seeking a better definition of the oroeess. a) Detailed design put on hold by top
management. b) Detailed design put on hold by top
management. c) Hold. Thus far this area does not
require regulating.
No action.
No action.
NGC 22826
. e. - -rr'.vysx'M
SPECIAL OBJECTIVE Reduce or eliminate environmental emissions
Same as above
Eliminate employee exposure
AVI LAKE TECHNICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT
PROJECT
Design construct a VCM monomer disDOsel system Spot ventilation exhaust Install a safe sample analysis station in B/414
COMP. DATE 1976
------- T37E-------
10-1-75
PERSONNEL ASSIGNEO Clock Hubbard
Wi1 son Eoo
Smith
COST ENG $30,000
TOTAL $130,000
$25,000
$ 100,000
$ 2,000
$ 12,000
Eliminate use of buckets of solvents for poly cleanlna. Reduce VCI in air
a. Install a Bendix GC monitoring system In B/4I4 for VCI ECH.
b. Install a Bendix total hydrocarbon monitoring system In B/413 for PVC laboratories
Space for analytical groups
B. Process Projects Eliminate VCH exposure while sampling a reactor subsequent weighing of sample.
Design Install a saf solvent cleaning syste in B/414 Leak control
Monitoring System
12-75
Sml th
Cont.
Process
Maint.
7=P7T" Forsythe
Coordinate 8/412 West lab modifications
1976
R. Cahill E. Webber
1. Taka sample in clos containers
2. Wear respirators rubber gloves.
3. Weight sanple In we ventilated hood
i
ContIn.
F. ZIeber
$ 2,400
$ 24,000
$6,400
$44,270
$9,800
$98,241
0
REMARKS No action.
Small Improvements being made.
Awaiting flush bottom valves for 15 30 gal. reactors. Will need ventilation for fume hood Installed on 3rd floor west side. Need EA or GPO to cover labor costs. 20% comolete. 20% complete.
Continuing
a. Installed operating. Wilt not measure ECH. Personnel monitoring has shown level of ECH Is vary low. Three horns lights are missing. Computer program Is operational,
b. Installed and operating. Computer program warning system ere also ooeratlonal.
Complete
Procedure Is working sat 1sfactor11y.
NGC 22827 ]
---
AVO. LAKE TECHNIICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT
COMP.
PERSONNEL
SPECIAL OBJECTIVE
Eliminate VCM exposure while transferring a charge from poly to
PROJECT 1) New stainless steel
lines with sweeping bends have been
DATE Done
ASSIGNED F. Zieber
wash tank. M
Instalfed to el(min ate plubs & leaks.
2) If line plugs, wi1I
Contin. F. Zieber
use impervious suit
air masks, rubber gloves S rubber foo
wear while unpluggli
Eliminate VCM exposure
line. Strip charge in wash ti k Small
F. Zieber
while transferring resin from to eliminate residual
Polymerizers
wash tank to filter box and transfer of wet cake to
VCM
9-1 -75
containers.
Prepare SOP's for PVC processes
in 6/414
tlimlnate VCM exposure
After blowing down diet
while removing manhead
boil out reactor with v
9-1-75
3, b//5 ter
F. Zieber f, zieber
from reactor.
and use a suction hose t
manhead while loosen Inc bolts. In addition, ate i phere near manhead will ?e
tested with an OVA matt
while loosening bolts, r
test shows VCM present, DOl 1
out reactor again.
Eliminate VCM exposure while centrifuging and
Properly strip charge ; wash tank to eliminate
6/1/75
F. Zieber
traying resin from wash tank.
residual VCM
Eliminate VCM exposure while cleaning reactors.
1. Before entering a pc /, 4/1/75 take OVA readings of :he interior,-If above 2 ppm.
F. Zieber
boil out again.
2. When entering a pol>
wear an impervious i and air line mask, i>
covers, rubber glove
rubber footwear.
COST ENG TOTAL
0 0
0
0 0
REMARKS Procedure working fine.
Procedure working fine.
Must design fr install stripping unit. Also trying to correct with procedures. Some progress made.
A number have been written and are readv for aooroval. Kaactors art being completely tilled with water and boiled out. Working very well.
We have not been centrifuging.
If we get any "OVA11 reading above the background, we boil out again. Protective clothing is beirgworn.
NGC 22828
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