Document 2qJmv5VXe3qj2Kozp4R9jD2Qg

MM TENNECOINTER-OFFICE ME,MO CHEMICALS, INC. \ TO F ROM P.R. Scarito F.W. Kanzler/W.W, Heal Subject OSHA Inspection at Burlington at Burlington Summary Date May 18, 1976 Copy to W. F, Gabel P M. Reed F.X. Ritter G. I. Rozand A. C. Siegel F. Toca /File bcc R.A. Lojewski The Burlington Plant site has undergone an OSHA industrial hygiene in spection since April 26, 1976 with one more inspection in the Compound Plant - for carbon black particulate testing - outstanding. Inspection dates for the Resin Plant were April 27, 1976, May 3, 1976, May 6, 1976 and May 10, 1976 at which time personal VCM monitoring, dust monitoring and area VCM monitoring were performed. Inspection dates for the Compound Plant were May 27, 1976 and May 29, 1976 at which time personal particu late measurements were taken to characterize lead, cadmium and barium exposures of operating personnel. In addition, an initial meeting with the two OSHA inspectors (OSHA CSHOs) and plant management as well as Com pound Union representatives was held on April 26, 1976 and an interim meeting with plant management and Union representatives from the Resin Plant was held on May 7, 1976. Listed below is an outline of the meetings and inspections for the above dates: I. Initial Meeting and Plant Tour On April 26, 1976 Messrs F. Lewis and R. Hanlon, OSHA CSHOs from the United States Department of Labor, Camden Office, visited at the Burl ington Plant requesting an industrial hygiene inspection. As a preliminary to the actual inspection, the CSHOs requested a meet ing with Tenneco representatives in the Compound Plant. Messrs W.W. Heal, P.N. Thomas, P.R. Scarito and F.W. Kanzler were present to meet with the CSHOs. The discussion centered primarily around the Tenneco biological testing programs including frequency of testing, type of testing and actions to be taken if an overexposure should occur. Also discussed were respirators and their mandated use by the various plant personnel, general housekeeping practices and safety meetings conducted the latter item in particular, as related to an instruction on safe handling practices of lead and other powdered stabilizers. Mr. Hanlon requested and was provided with the OSHA log 100 for 1975 and 1976 to date. Formulation recipes were requested by Mr. Hanlo'n for the comppounds run during the time of the expected particulate monitoring. Following a meeting with a Compound Union representative - R. Horvath the CSHOs requested a plant tour of the Compound Plant. Both lines, all levels and the exhaust area on the plant roof was inspected. COLORITE 012139 Page 2 After the plant tour, the CSHOs were given the opportunity to meet with the plant physician, Dr. M.C. Venditti, to further discuss the biological testing program and test data. A second meeting was requested for the Resin Plant with Messrs W.W. Heal, P.R. Scarito, A.C. Siegel and F.W. Kanzler representing Tenneco. Topics covered were (1) a review of deregulated areas including data generated, (2) mode, type and frequency of personal monitoring samples, (3) reviewed in detail the status of the Engineering program at which time Mr. Lewis requested a monthly status report for this program to be sent to the Camden office, and (4) the personal VCM results as listed in the alphabetical personnel roster were reviewed in detail by Mr. Han lon. Mr. Lewis was provided with copies of AOPs M-5, M-6, M-7 and M-8. In addition, a copy of EOF 11, the OSHA log 100 for 1975 and 1976 and a copy of the OSHA summary 102 for 1976 was given to the CSHO. A detailed review of the standard was conducted by Mr. Lewis to clarify possible areas of misinterpretation. The only differences of opinion, as Mr. Lewis pointed out, were found to be in the area of fifteen-minute ceiling samples, which should be taken on a regular basis along with the eight-hour TWA samples; personal exposure samples exceeding 1 ppm should be retaken on the same employee and not for the same job classification with a different employee. There was no request made by the CSHOs to meet with Resin Plant Union representatives. II. Hygiene Inspection - Resin Plant A. Copolymer - VCM On April 27, 1976 a personal VCM monitoring survey was conducted by Mr. Lewis in the Copolymer Plant. Mr. F.W. Kanzler took parallel samples for Tenneco. The CSHO used Sipin pumps at a flow rate of about 50 ml/minute. SKC pumps with the same flow rates were used for the Tenneco samples. Eight-hour TWA, as well as fifteen-minute ceiling samples, were taken. The following is a listing of the personnel mon- itored: Number of Samples * Fifteen-Minute Eight-Hour TWA Ceiling Name Job Classification OSHA Tenneco OSHA Tenneco J. Webster I. Raymond II. Wallace reactor oper - chg reactor oper - dmp bagger - cleaner 1 1. 11 11 33 44 44 (Tenneco results are summarized in the attached Table I.) No other type of inspection was made, neither was any attempt made to establish work patterns for the people monitored. COLORITE 012140 Page 3 The Union representative present all day was Mr. W. Comegno who had very animated conversations with Mr. Lewis throughout the day. 'N B. Homopolymer - VCM On May 3, 1976 a personal VCM monitoring survey was conducted by Mr. Lewis in the Homopolymer Plant, Mr. Kanzler took parallel samples for Tenneco. The CSHO used new DuPont pumps at a flow rate of about 50 ml/minute, while SKC pumps were used by Tenneco. Again, eight-hour TWA, as well as fifteen-minute ceiling samples were taken. Due to a pump malfunction, only a limited amount of fifteen-minute ceiling parallel samples could be taken. All Tenneco pumps were in use for the Homopolymer Plant survey and the "A" Plant survey - see below. The following is a listing of the per sonnel monitored: Number of Samples Name R. McFadden R. Espenschied A. Anicic Job Classification reactor oper - chg reactor oper - dmp bagger - cleaner Eight-Hour TWA OSHA Tenneco 11 11 11 Fifteen-Minut Ceiling OSHA Tenneco 43 41 42 (Tenneco results are summarized in the attached Table II.) No other type of inspection was made. No work pattern was established by the CSHO. The Union representative present for all day was Mr, F. Roessler, C. Dispersion - "A" Plant Also on May 3, 1976 a personal VCM monitoring survey was conducted by Mr. Hanlon in the Dispersion rtA" Plant, Mr. W.W. Heal was present as the company liaison and Mr. R. Laws to take the parallel samples. Mr. Hanlon used Sipin pumps at a 50 ml/minute flow rate and SKC pumps were used by Tenneco to conduct the survey. A shortage of pumps al lowed only a limited amount of fifteen-minute ceiling parallel samples to be taken. The following is a listing of the personnel monitored: Number of Samples Eight-Hour JWA Fifteen-Minute Ceiling Name Job Classification OSHA Tenneco OSHA Tenneco J. Canterbury W. Simpkins W. Navarro tower oper - chg tower oper - dmp tower clnr - jet clnr 1 1 1 1 1 1 32 43 32 (Tenneco results are summarized in the attached table III. ) COLORITE 012141 While no work patterns were established by Mr. Hanlon, he re quested information on the types of chemicals charged to the batch mix tank including the catalyst types. The Union representative present for all day was Mr. F, Roessler alternating between the Copolymer and Dispersion Plants. It may be of interest to note that prior to preceding to the plant, Mr. W. Comegno accused both CSIIOs of failing to have an opening meet ing with the Union. Mr. Lewis pointed out that an opening meet ing was held with the Union at the inspection on December 24, 197S, Bagging, Dryer, Warehouse and Atomizer - Dust On May 6, 1976 a personal dust monitoring survey was performed by Mr. Lewis covering operating personnel in the bagging, dryer, ware house and atomizer areas. Representing Tenneco were Dr. F. Toca and Mr. W.W. Heal. OSHA took respirable dust samples utilizing MSA pumps at a flow rate of 1.8 l/minute fitted with a 0.5 micro filter and a cyclone attachment. Due to a lack of availability of a cyclone attachment, parallel samples taken by Tenneco represent total dust samples using a Bendix pump set at a flow rate of 1.5 1/minute fitted with a 0.8 micron open-face filter. The CSHO used four pumps, while only three pumps were available for Tenneco. The following is a listing of the personnel monitored: Number of Samples Eight-Hour TWA Name Job Classification OSHA Tenneco R. Paxton E. Dever J. York D. Motta plastisol bagger atomizer operator suspension dryer operator warehouseman 11 11 11 1 (Tenneco results are summarized in the attached table IV.) A general inspection was conducted by Mr. Lewis in all the above areas. The following pictures (attached) were taken during this inspection tour: 1. plastisol bagging area 2. plastisol bagging machine 3. plastisol bagger wearing sampling pump 4. two pictures of the general warehouse area 5. suspension dryer panelboard with operator wearing sampling pump 6. plastisol bagging machine, east view 7. plastisol bagger wearing dust mask The Union was represented by Mr. F. Roessler for the whole day. COLORITE 012142 Page 5 E. Atomizer Room - VCM On May 10, 1976 Mr. Lewis made an area VCM monitoring survey of \ the atomizer room to confirm justification of deregulation of this area. Eight-hour area TWA samples were taken at the north and south ends of the atomizer room. In addition, three fifteenminute ceiling samples were taken at the south end and one at the north end of the atomizer room. Mr, Kanzler took parallel samples for Tenneco which are summarized in Table V. In addition, the CSHO used a Gastec grab sampler. Both the OSHA sample and the Tenneco sample taken with the same type of sampler showed a VCM level of 0.2 ppm. The Union representative for the day was Mr. W. Mayer. An apparent complaint by the Union, using asbestos insulation on blend tanks, was investigated. A picture was taken of blend tank #3 (attached), showing exposed asbestos insulation at the outside bottom of the blend tank. Additional pictures were taken of the sample pump loca tions at the north and south areas of the atomizer room. Also, the "A" fine products bin and the primary screw areas were photographed. III. Hygiene Inspection - Compound Plant A. Compound Plant - Airborne Particulates On April 27, 1976 Messrs F. Lewis and R. Hanlon (0SHA-CSH0) with Messrs F.W. Kanzler and W.W. Heal proceded to sample the following personnel for lead: Sampled for Lead Eight-Hour TWA Name Job Classification OSHA Tenneco K. Elberson R. Tomaszewski B. Cunningham F. Anstey R. Lessard J. Fate mixer - line #1 mixer - line #2 mill operator - line #1 line operator - line #1 utility services operator short weight operator 11 11111 1- (Tenneco results are summarized in the attached table VI.) The equipment used by OSHA was MSA pumps set at 1.5 liters per minute using 0.8 micron filters. Tenneco used Bendix pumps set at 1.5 liters per minute using 0.8 micron filters. Both OSHA and Tenneco used closedface filter cartridges (button sample). Messrs Lewis and Hanlon introduced themselves to fhe Union representa tive, Mr. Anstey and explained to him what they would be doing. He chose not to stay with the group. Once the initial pumps were placed on the personnel, CSHO Lewis and Mr. Kanzler returned to the Resin Plant to monitor for vinyl chloride. COLORITE 0X2143 While the personnel monitoring was taking place, CSHO Hanlon took the following pictures (Tenneco was unable to take parallel pictures): 1. three pictures of mixer on line #1 dumping bags of resin into blender 2. lead weighing booth - line =1 3. #2 blender, south view - line #1 4. short weights setting on pallet 5. blenders, north view - line #1 6. clean room, from door 7. blenders, east view - line =*2 8. blenders, northeast view - line #2 The lunchroom, shower room and locker room were inspected, CSHO Hanlon's comment during this inspection was he felt that the employ ees should not travel through the lunchroom to get to the locker room and shower area with contaminated clothing on. He also stated that the washing up facilities should be separate from the lunchroom. CSHO Hanlon also indicated that these facilities should be cleaned up on a per-shift basis, rather than once.every twenty-four hours. Compound Plant - Airborne Particulates On April 29, 1976 Messrs F. Lewis and R. Hanlon returned and indica ted they would be sampling for the following: lead, barium and cadmium W.W, Heal was present representing Tenneco. The following personnel were sampled: Eight-Hour TWA Name Job Classification OSHA Tenneco K. Elberson R. Tomaszewski B. Cunningham K. Jenkins F. Anstey R. Lessard mixer - line #1 mixer - line &2 mill operator - line #1 mill operator - line #2 line operator - line #1 utility services operator 11 11 1 1 1 1 (Tenneco results are summarized in the attached Table VI,) Equipment used by OSHA was MSA pumps set at 1.5 liters per minute, using 0.8 micron filters. Tenneco used Bendix pumps set at 1.5 liters per minute using 0.S micron filters. Both OSHA and Tenneco used closed face filters (button samples). COXiORXTE 012144 Wipe samples were taken using Whatman #41 filter paper, ash less 11.0 cm diameter. This paper was moistened with deionized water before sampling. The following areas were sampled: 1. Lunchroom a. top of lunch tables b. catch tray in cigarette machine c. catch tray in snack machine d. catch tray in bottled soda machine e. shelving in refrigerator, plus crisper and meat drawers f. shelves in refrigerator door g. faucets on bottled water fountain and inside cup dispenser h. can opener, wiped cutting edges i. top of bottled water on fountain j. top of refrigerator 2. Clean Room a. top of operator's desk b. telephone mouth piece c. bottled drinking fountain, faucet and bottle top - also in side cup dispenser d. dispensing unit for salt tablets The CSHOs were given the opportunity to listen to the taped talk Dr. Venditti had given to all Compound personnel as related to personal hygiene while working with lead. The effectiveness of the ventilation was checked for the following exhaust ducts with smoke tubes. % 1. lead weighing booth - line =1 2. #1 and #2 blender exhaust ducts - line #2 3. lead weighing facility at line #2 Checked ventilation of the following exhaust systems with a velometer: 1. lead booth - line #1 COLORITE 012145 F ace 8 2 . exhaust duct, #1 blender - line #1 s 3. tjl blender at fill grate - line #1 "\ 4. lead scale - line #2 A drawing was made of each scoop, sections were drawn in and velome.ter readings were entered for that given area. The CSHO took pictures during the time of the velometer readings from the following areas: 1. clean room through the door, two pictures 2. lead weighing facilities, line #2 3. storage of raw materials on line #2 mixing floor 4. lead weighing facility including lead short weights at line #2 5. air conditioner intake for clean room in relation to exhaust dis charge from #1 mill line at roof area 6. line operator and mill - line #1 7. mill operator and mill - line tfl 8. mill operator on forklift at line #2 The following pictures were taken at the lunchroom: 1. vending machines and refrigerator 2. soda machine 3. line operator at lunch table 4. general picture of lunchroom including both lunch tables Tenneco was unable to take pictures at that time. IV. Interim Meeting and Inspection of Hygiene and Analytical Facilities On May 7, 1976 Messrs Hanlon and Lewis met with Messrs P.R. Scarito and W.W, Heal to give a status report on the inspection to that date. No comments were made whether any citations will be issued. With the ex ception of the dust data taken on May 6, 1976 in the Resin Plant, no an alytical data was available from OSHA. In the case of .the dust, no numbers were released to Tenneco, however, the CSHO indicated the dust readings were well below the standard. The CSHOs then met with representatives from the Union - Messrs 1L Stellwag and F. Roessler. COLOR!TE 012146 Page 9 Following the meeting, the CSHOs requested a tour of the mask washing facility and the Analytical Laboratory. Mr. Lewis reques ted to be provided with the following forms: daily respirator inspection record, weekly mask cleaning record and monthly char coal tube report form. In addition, a copy of the analytical charcoal tube method was requested. Attachments FWK-WWH/jst F.W. Kanzler/W.W. Heal < COIjORITE 012147 TABLE I OSHA INSPECTION parallel samples A COPOLYMER PLANT Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Eight-Hour TWA - VCM Date Sampled 4/27/76 4/27/76 4/27/76 Time in Air, min 0 1 120 TWA, ppm VCM 0.65 0.63 11.1 Standard, ppm VCM 1.0 1.0 1.0 Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Fifteen-Minute Ceiling Date Sampled 4/27/76 4/27/76 4/27/76 Time in Air, min 0 0 0 0 0 0 %0 15 15 0 0 ppm VCM 1.9 0.4 0.5 1.2 0.9 0.5 0.6 64.0 38.0 0.5 0.8 * Standard, ppm VCM 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5,0 5.0 F.W. Kanzle 5/17/76 COLORITE 012148 TABLE II OSHA INSPECTION PARALLEL SAMPLES S \ HOMOPOLYMER PLANT Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Eight-Hour TWA - VCM Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 14 16 20 TWA, VCM ppm 0.54 0.31 3.1 Standard, ppm VCM 1.0 1.0 1.0 Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Fifteen--Minute Ceiling Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 0 0 0 2 15 .0 ppm VCM 0.9 0.7 1.0 0.5 46.0 0.4 Standard, ppm VCM 5.0 5.0 5.0 5.0 5.0 5.0 F.W. Kanzle 5/17/76 COLORITE 012149 TABLE III OSHA INSPECTION PARALLEL SAMPLES DISPERSION - "Av PLANT Job Classification Tower Oper - chg Tower Oper - dmp Tower Cln - jet cln Eight-Hour TWA - VCM Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 24 40 210 TWA, ppm VCM Standard, ppm VCM 0.29 1.0 0.45 1.0 0.73 1.0 Job Classification Tower Oper - chg Tower Oper - dmp Tower Cln - jet cln Fifteen-Minute Ceiling Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 0 12 10 0 0 15 15 ppm VCM 0.3 0.5 1.0 1.7 1.3 0.5 0.3 Standard, ppm VCM 5.0 5.0 5.0 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 COLOR!TE 012150 TABLE IV OSHA INSPECTION PARALLEL SAMPLES RESIN PLANT Eight-Hour TWA - Inert or Nuisance Dust (Total Dust) Job Classification Plastisol Bagger Atomizer Operator Dryer Operator Date Sampled 5/6/76 5/6/76 5/6/76 TWA, mg/m3 0.126 2.799 0.208 Standard, mg/m3 15.0 15.0 1S.0 W.W. Heal 5/17/76 COLORITE 012151 5 \ TA3LE V OSHA INSPECTION PARALLEL SAMPLES RESIN PLANT - ATOMIZER ROOM Area Atomizer Room - N Atomizer Room - S Eight-Hour TWA - VCM Date Sampled 5/10/76 5/10/76 TWA, ppm VCM 0.05 0.12 Standard, ppm VCM 1.0 1.0 Area Atomizer Room - N Atomizer Room - S Fifteen-Minute Ceiling Date Sampled 5/10/76 5/10/76 ppm VCM 0.5 0.4 0.4 0.1 * Standard, ppm VCM 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 !< COLORITE 012152 TABLE VI 'pSlIA INSPECTION PARALLEL SAMPLES \ COMPOUND PLANT Job Classification Mixer - line #1 Utility Services Mixer - line #1 Mixer - line #2 Job Classification Mixer - line #2 Job Classification Mixer - line #2 Eight-Hour TWA - Lead Date Sampled 4/27/76 4/29/76 TWA, mg/m3 0.543 0.159 0.342 0.286 Eight-Hour TWA - Barium Date Sampled 4/29/76 TWA, mg/m3 0.061 Eight-Hour TWA - Cadmium Date Sampled 4/29/76 3 TW7A, mg/m 0.016 Standard, mg/m3 0,2 0.2 0.2 0.2 Standard, mg/m3 0.5 O Standard, mg/m 0.2 W.W. Heal 5/17/76 COLOR!TE 012153 PICTURES TO II. D Plastisol Bagging Area Plaatisol Bagging Machine Plastisol Bagger V,'earing Sampling Pump COLORITE 012154