Document 2vJrK897pE6odd244y4q2Z1a

C. Cooper J. L. Nelson November 20, 1975 Attached is a copy"'<5f the report^ of the Industrial hygiene survey made at the Henry plant in July, 1975. Note that Mr. Sheper~has made a number of recommendations. I would appreciate your advising me as to their status within 30 days. Please contact me if you have any questions concerning this report. E.b. i^atze^nmeyer, Jr. Manager, Industrial Hygiene v cc: G. Smith, Henry G. Pow H. Waltemate W.C. Holbrook R.W. Strassburg M.N.Johnson/A.V.Gold Ov lN>-' o ^GC Of f 99 C. Cooper Henry Plant Thomas W. Shepler D/0020, 5-H, Akron INDUSTRIAL HYGIENE SURVEY - HENRY CHEMICAL PLANT 11-20-75 On July 29, 30 and 31, 1975, an industrial hygiene survey was performed at the Henry Chemical Plant. The Henry plant exhibits an aggressive attitude,as demonstrated by the Henry employees, toward diagnosing and resolving workplace health problems. Current reports emanating from the plant show intense ventilation studies in the Polymerization and Polymer Chemicals buildings. These reports are of excellent quality and provide a good basis, in conjunction with personal exposure, for the determination of the magnitude of the problems and what modifi cations or additions are necessary. The plant's major problems, aside from the ventilation of the Poly merization building, are moderately high concentrations of benzene vapors on the third floor of the Polymer Chemicals building (X-70 process), lack of local exhaust ventilation for the welding operators in the old boiler house, and the need for an eyewash fountain and shower at the cooling tower. These and other items are discussed in Section I-Recommendations and Discussion and Section II-Tables. I wish to convey my appreciation to you and your staff for your assistance and cooperation in this survey. Thomas W. Shepler / Industrial Hygienist v N'GC 01200 SECTION I. RECOMMENDATIONS 1. Make certain that your written respiratory protection program is in total compliance with OSHA 29 CFR 1910.134. 2. Make certain that you continue to perform complete blood counts on those employees routinely exposed to benzene. The blood tests should be run on a quarterly basis. 3. Reduce the benzene concentration at the X-70 process, third floor of the Polymer Chemicals Building. 4. Make certain that the compressed air system used for breating air meets the requirements of OSHA 29 CFR 1910.134. Also, reference BFG Chemical Company Engineering Standard STt404.6 "Breating Air Supply for Areas not Immediately Hazardous to Human Life". 5. Make certain that employees routinely assigned to jobs involving the handling of leaded chemicals continue to receive semi-annual lead blood and urine examinations. 6. Increase the hood performance at the pre-compounding station located on the second floor of Bldg. 741 - Compounding Building to approxi mately 175 fpm (feet per minute) face velocity. 7. Repair the non-operational ventilation system associated with the weigh hood located in the pigment room, third floor of the Poly merization Building. 8. Install an eyewash fountain and shower in the immediate vicinity of the acid handling area at the cooling tower. 9. Make certain that all workers handling asbestos materials (new and rip-out) receive annual chest x-rays and pulmonary function tests, and that all precautions as outlined in OSHA 29 CFR 1910.1001 are being followed. 10. Color code, or permanently label, all new or unused asbestos insul ation; thereby properly identifying it as asbestos when it is removed from pipes and vessels. 11. Whenever possible, purchase only asbestos-free insulation. 12. Provide additional ventilation in the old boiler house to control the welding fumes and gasses generated there. 13. Purchase only those welding rods which do not contain fluoride c oinpound s . 14. Replumb the transport lines Irom the VCM. cylinder to the vinyl hood in the Lab Building such that the outlet is inside the hood and pointing vertically, or away from, the front of the hood. Presently all plumbing, terminates outside the hood. NGt \20\ w- ce o u 2. 15. Require that cuber room doors in the Compounding Building be kept closed at all times when cuber is operating. 16. Maintain a six to ten foot clear distance around all external exhaust fans located in the Polymer Chemical Building. Presently these fans are being blocked by stored raw materials. 17. Replace the exterior wall panels in the Polymer Chemicals Building to increase the effectiveness of the present ventilation system. 18. On the purchase of all new cartridge respirators, be sure that they are NIOSH approved. 19. Develop a new bag disposal procedure to minimize dust exposures to employees at the hopper filling operation on the fourth floor of the Compounding Building. 20. Place all recovery operators who work on the first floor of the Polymerization Building on the hearing conservation program. This is to consist of issuing and enforcing the wearing of hearing pro tectors and preplacement, annual and termination audiometric examinations. 21. Improve the ventilation in the Polymerization Building such that dead air areas could not exist in high potential VCM leakage areas. Specific areas would include the metering lines on the third floor and the compressors on the first floor. DISCUSSION Due to the illness of the Safety Supervisor on the second and third days of my visit, I was unable to adequately review some of your safety/industrial hygiene programs. It was mentioned that the plant does have a written respirator program; however, it should be reviewed and made certain that it meets the requirements set forth in OSHA 29 CFR 1910.134. Also of concern is whether employees exposed to benzene (X-70 process and Geltral process) are receiving complete blood counts quarterly. As Table III indicates, employees working with the. X-70 process experience high benzene concentrations which approach or exceed the TLV. These high concentrations are attributed to process leaks and lack of ventilation. Two temporary solutions are possible until permanent controls are implemented; one is the use of appropriate respirators and the second is the use or floor fans to dissipate areas of high concentration. Your OVA should give an indica tion of the effectiveness of this system. Oil the second floor of Bldg. 7A1-Compounding Bldg., a hood is used for pre compounding a variety ot pigments including lead. As Table TV and Table Vdocument, the hood is no!, adequate. Face velocities should be 150-175 fpm to adequately control, fugitive dust. It. should also be ascertained as to whether the employee is receiving semi-annual blood lead test;;. q Co o NGC 01202 3. The breathing air systems Polymerization Building, BFG Chemical Company has for breating air systems used in the plant, especially so in the must meet OSHA 29 CFR 1910.134 requirements. recently prepared an engineering specification which fully meets the OSHA requirements. An eyewash fountain and shower is needed at the cooling tower. Pre sently both chromic and sulfuric acids are being handled and stored there. Both acids are used in treating the water supply in an operation that involves only one employee. This employee is provided with a face shield, but does not have an eyewash fountain or shower within any acceptable distance. Those employees working with asbestos, either installing, removing, or bagging, should be provided with adequate protective equipment and be fully advised of the safe handling procedures necessary with asbestos. OSHA 29 CFR 1910.1001 adequately describes what is needed for an effective asbestos program. Employee's not previously exposed to asbestos should not be assigned to handle it except as a last resort. All unused asbestos material should be color-coded or labeled as such for proper identification as to its hazard, if and when it is used, and removed at a later date. During the survey, welding was observed in the old boiler house. Under the operating conditions prevailing at the time (open double door, one floor fan and ceiling fan operating), no problem exists as substantiated by Table V. In winter months, however, it is anticipated that the doors will be closed, the floor fen turned off or removed, and the ceiling fan possibly turned off. Under these circumstances the work area would be unsatisfactory. I recommend that a local exhaust system be installed. This system could be portable, or permanent, and would primarily consist of an air mover, transport duct and small hood attachment. The exhaust air of this system should be vented outside the building, regardless of whether it is filtered or not. Because of BFG's philosophy of minimizing potential health problems when practicable, I recommend that only those welding rods and fluxes that are fluoride free be purchased. At present, the stock of rods containing fluoride may be used, but only under localized exhaust ventilation. The vinyl hood located in the Lab Building presently has plumbing running from VCM cylinders over to, and terminating in front of the vinyl hood. This should be corrected such that the plumbing terminates inside the hood with the tubing opening pointing in a vertical plane, or toward the back of the hood. The reasoning behind this is apparent in that If the rubber tubing running from the plumbing into the hood is removed or comes loose and the cylinder is venting, then monomer could contaminate the laboratory, possibly with significant exposures. N'G( 01203 4. As Tables I and II show, Che recovery operators working on the first floor of the Polymerization Building are being over-exposed to noise. These employees should be : ed hearing protectors and required to wear them in high noise areas as well as receive pre-placement, annual, and termination audiometri.c examinations. Care should be taken that the employees are thoroughly indoctrinated as to hazards of high noise. It was observed that many dead air areas exist in the Polymerization Building. Ideally, with a substance as toxic as vinyl chloride, a 50 IX--per minute air velocity should be maintained in all areas where VCM leaks are likely to occur. Further, this air movement should be of uniform flow and continuously exhausted from the workplace with fresh air being continuously brought into the work area. At present, air flow is minimal at best in the area of the metering lines on the third floor. On the first floor in the compressor area, the air move ment is in the vertical direction at approximately 10 to 20 ft. per minute, and could account for, at least in part, the high VCM levels on the mezzanine floor. Thomas W. Shepler Industrial Hygienist v V;< 01204 O cc 3 ri / / November 20, 1975 / . C. Cooper / J. L. Nelson / Attached is a copy of the report of the industrial hygiene survey made at the Henry plant in July, 1975. Note that Mr. Shepler has made a number of recommendations. I would appreciate your advising me as to their status within 30 days. Please contact me if you have any questions concerning this report. E.b. Katzenmeyer, Jr. Manager, Industrial HHygiene v cc: G. Smith, Henry G. Pow H. Waltemate W.C. Holbrook R.W. Strassburg M.N.Johnson/A.V.Gold Xcc 01205 C . COOJK' L` Thom's W. Eheplcr Henry Plant l 'I D/0020, 5-H, Akron . * . I I (Cl 11-20-75 INDUSTRIAL HYGIENE SURVEY - 1IENRY CHEMICAL PLANT On July 29, 30 and 31, 1975, an industrial hygiene .survey was performed at the Henry Chemical Plant. The Henry plant exhibits an aggressive attitude,as demonstrated by the Henry employees, toward diagnosing and resolving workplace health problems. Current reports emanating from the plant show intense ventilation studies in the Polymerization and Polymer Chemicals buildings. These reports are of excellent quality and provide a good basis, in conjunction with personal exposure, for the determination of the magnitude of the problems and what modifi cations or additions are necessary. The plant's major problems, aside from the ventilation of the Poly merization building, are moderately high concentrations of benzene vapors on the third floor of the Polymer Chemicals building (X-70 process), lack of local exhaust ventilation for the welding operators in the old boiler house, and the need for an eyewash fountain and shower at the cooling tower. These and other items are discussed in Section 1-Recommendations and Discussion and Section II-Tables. I wish to convey my appreciation to you and your staff for your assistance and cooperation in this survey. Thomas W. Shepler ' Industrial Hygienist v NGC 01206 SECTION I. RECOMMENDATIONS Make certain lh.it your written respiratory protection program is in total compliance with OShA 29 CFR 1910.134. Make certain that you continue to perform complete blood counts on those employees routinely exposed to benzene. The blood tests should be run on a quarterly basis. f*1 Reduce the benzene concentration at the X-70 process, third floor of the Polymer Chemicals Building. /a/3 r?yijtrz>i*7 . ^ jisz&y" 'S' j Jtypj} ,j<r 7** ' /1/rZ'rC^fis'ttS /Off ' ^ JTl Malcecertain that the compressed air system used for breating air meets the requirements of OSHA 29 CFR 1910.134. Also, reference BEG Chemical Company Engineering Standard ST-404.6 "Breating Air Supply for Areas not Immediately Hazardous to Human Life". `9tuJ & /flSASjf Off A) ft- <z* fpTfJ, Make certain that employees assigned to jobs involving .nnual 6. Increase the hood performance at the pre-compounding station located on the second floor of Bldg. 741 - Compounding Building to approxi mately 175 fpm (feet per minute) face velocity. 7^ Rep a ir the non-operational ventilation system associated with the weigh hood located in the pigment room, third floor of the Poly- t1^ merization Building. Install an eyewash fountain and shower in the immediate vicinity of the acid handling area at the cooling tower. UA*Jt/recv/y? Jt i*,'#, Tr&v? ~ &c '& cs /rte Make certain that all workers handling asbestos materials (new and rip-out) receive annual chest x-rays and pulmonary function tests, and that all precautions as outlined in OSHA 29 CFR 1910.1001 are being followed, qx- ^-9^5 Color code, or permanently label, all new or unused asbestos insul ation; thereby properly identifying it as asbestos when it is removed from pipes and vessels. 11. Whenever possible, purchase only asbestos-free insulation. de?1-*- sj&Vt. Provide additional ventilation in the old boiler house to control tl if* llr/fr^urchase only those welding rods which do not contain fluoride r)0- * compounds. 14 .^Ji-Rcplumb the transport lines from the VCK cylinder to the vinyl hood .fit- in the Lab Building such that the outlet is inside the hood and jjfi pointing vertically, or away from, the front of the hood. Presently all plumbing terminates outside the hood. M1 - NGC 01207 XVV 2. 1'). Require cubor room door:; in the Compoundi ng Building be kept closed at all times when euber is operating. . 16. Maintain a six to ten foot clear distance around all external xiiaust bans located in the Polymer Chemical Building. Presently these fans are being blocked by stored raw materials. Replace the exterior wall panels in the Polymer Chemicals Building to^jjnercase the effectiveness of the present ventilation system. On the purchase of all new cartridge respirators, be sure that they are NI05H approved. evclop a new bag disposal procedure to minimize dust exposures to employees at the hopper filling operation on the fourth floor of the Compounding Building. Place all recovery operators who work on the first floor of the ^-- Polymerization Building on the hearing conservation program. ThiS"1''- is to consist of issuing and enforcing the wearing of hearing pro-'*** tectors and preplacement, annual and termination audiometric *' examinations. -- -- 21. Improve the ventilation in the Polymerization Building such that"ciel air areas could not exist in high potential VCM leakage areas. Specific areas would include the metering lines on the third floor and the compressors on the first floor. DISCUSSION Due to the illness of the Safety Supervisor on the second and third days of my visit, I was unable to adequately review .some of your safety/indus. hygiene programs. It was mentioned that the plant does have a written respirator program; however, it should be reviewed and made certain that it meets the requirements set forth in OSHA 29 CFR 1910.134. j Also of concern is whether employees exposed to benzene (X-70 process am | Geltral process) are receiving complete blood counts quarterly. As Tabl< | indicates, employees working with the X-70 process experience high benzei ^/^concentrations which approach or exceed the TLV. These high concentrate i '-^are attributed to process leaks and lack of ventilation. Two temporary /solutions are possible until permanent controls are implemented; one is the use of appropriate respirators and the second is the use of floor fai . . to dissipate areas of high concentration. Your OVA should give an indie; tion of the effectiveness of this system. On the second floor of Bldg. 741-Compounding Bldg., a hood is used for p: compounding a variety of pigments including lead. As Table XV and Tabl> document, the hood is not adequate. Face velocities should be 150-17 5 f'; to adequately control fugitive dust. It should also be ascertained as t< whether the employee is receiving semi-annual blood lead tests. 0120H 3. The birc.i t'i n^air system:; ]3o 1 yi'icr i.:;, i L i. on Bui 1 d i n;\, BEG Chemical Company has for bcenting ai.r systems list'd In (:hc plant:, especially so in the raur/i meet C C1IA 29 ClrR 1910.134 requirements, recently pr eparod an engineering specification which fully meets the OSiiA requirements. An eyewash fountain, and shower is needed at the cooling tower. Pre sently both chromic and sulfuric acids are being handled and stored there. Both acids are used in. treating the water-supply in an operatioi that involves only one employee. This employee is provided with a face shield, but does not have an eyewash fountain or shower within any acceptable distance. Those employees working with asbestos, either installing, removing, or bagging, should be provided with adequate, protective equipment and be fully advised of the safe handling procedures necessary with asbestos. OSfLA 29 CFR 1910.1001 adequately describes what is needed for an effective asbestos program. Employees not previously exposed to asbest should not be assigned to handle it except as a last resort. All unused asbestos material should be color-coded or labeled as such for proper identification as to its hazard, if and when it is used, and removed at a later date. During the survey, welding was observed in the old boiler house. Under the operating conditions prevailing at the time (open double door, one floor fan and ceiling fan operating), no problem exists as substantiate by Table V. In winter months, however, it is anticipated that the door will be closed, the floor (an turned off or removed, and the ceiling fan possibly turned off. Under these circumstances the work area would be unsatisfactory. I recommend that a local exhaust system be installed. This system could be portable, or permanent, and would primarily consis of an air mover, transport duct and small hood attachment. The exhaust air of this system should be vented outside the building, regardless of whether it is filtered or not. Because of BFG1s philosophy of minimizing potential health problems whe practicable, I recommend that only those welding rods and fluxes that are fluoride free be purchased. At present, the stock of rods containi fluoride may be used, but only under localized exhaust ventilation. ' The vinyl hood located in the Lab Building presently has plumbing runni from VCM cylinders over to, and terminating in front of the vinyl hood. This should be corrected such that the plumbing terminates inside the hood with the tubing opening pointing in a vertical plane, or toward th back of the hood. The reasoning behind this is apparent in that if the rubber tubing running from the plumbing into the hood is removed or comes loose and the cylinder is venting, then monomer could contaminate the laboratory, possibly with significant exposures. NGC 0U(V> As Tables T and II show, the recovery operators working on the first floor of the Polymerization building arc being over-exposed to noise. These employees should be issued hearing protectors and required to wear them in high noise areas as wall as receive pre-placement, annual, and termination audiometric examinations. Care should be taken that the employees are thoroughly indoctrinated as to hazards of high noise. It was observed that many dead air areas exist in the Polymerization Building. Ideally, with a substance as toxic as vinyl chloride, a 50 ft. per minute air velocity should be maintained in all areas where VCM leaks are likely to occur. Further, this air movement should be of uniform flow and continuously exhausted from the workplace with fresh air being continuously brought into the work area. At present, air flow is minimal at best in the area of the metering lines on the third floor. On the first floor in the compressor area, the air move ment is in the vertical direction at approximately 10 to 20 ft. per minute, and could account for, at least in part, the high VCM levels on the mezzanine floor. Thomas W. Shepler Industrial Hygienist v 01210 SECTION II. TABLE I. NOISE MEASUREMENTS HENRY PLANT Location Poly Building 1st Floor Compressor Area Rest of area Third Floor Mezzanine dEA______ (emergency fans off) 90-92 88-91 84-88 86-89 Dryer Building 1st Floor - east of granulator room 88-90.5 - pumps east of granulator room(air leaks) 92-93 - bagger stations 85-86 Boiler House (steam leak at north door) 89-91 Compounding Building 1st Floor <3 Cuber Room (cuber room doors open) in other areas 2nd Floor @ Henschel (intermittent) 96-99 85-88 90-95 OSHA limit for noise = 90 dBA for 8 hours. NGC 01211 TABLE II. DOSIMETRY MEASUREMENTS HENRY PLANT Name Sample Time (min.) 8-Hr. % Henschel Operator, Bldg. 741 339 55 QBTS Bagger, Bldg. 712 340 15 Boiler House Operator 334 77.6 Recovery Operator 1st Floor, Poly Bldg. 305 118 dBA 88 91 OSHA Limit for Noise = 100% or 90 dBA. ngc OU'2 TABLE III. ORGANIC VAPOR MEASUREMENTS HENRY PLANT Name Location CBTS Process Polymer Chemical Bldg. IT H a-/U Process if n OBTS Process it i Geltral Process Geltral Process It M "" a-/u Process Sample Time (min.) Compounds Concentrate (ppm) 75 Cyclo Hexane 1.1 Toluene 0.6 70 Isobutylene 0 Benzene 13.7 81 Isopropyl Alcohol 0 87 Benzene 4.6 123 Benzene 2.5 oo 127 Benzene Isobutylene 9. OSHA TLV for Benzene = 10 ppm " " " Toluene = 100 ppm REDACTED NGC 01213 TABLE IV. VENTILATION MEASUREMHlITS HENRY PLANT Location FPM Maintenance Shop West Voiding Station Flex Hose with Cone 300 @ 10-12" East Welding Station 250-300 @ 10-12" (cooling fan dis rupts effectivenes Lab Building ka'w Materials Lab North Hood 160-170 (door open 12". Hood does n operate efficiently when ho brings in supply air) South Hood (vinyl hood) 150-200 (door open 12") Polymer Chemical Lab WortK Hood Middle Hood South Hood 125-150 150-170 125-150 (door open 12") (door open 12". with supply air (door open 12") Works well and door do Compounding Pjuilriing ind i'lrT compounding booth 4th fir. hopper filling hoods 50-100 (hood is not effective) 200-600 (at capture zone) Polymerization Building it fir. compressorarea <^50 (some vertical migration) 3rd fir.-between metering lines <<r50 -by 26 poly 50 -pigment room hood Not operational Mezzanine, on east side 50 (extremely poor) * Polymer Chemical Building ------ 1st fir. Stalite Operator MBTS Bagger OBTS Bagger Bleach Pump Dike Caustic Decanter <C50 200-400 (cooling fans which may not be present during winter) 60 (flows back toward bagger) <$r50 (dead area) <<r50 NGC TABLE IV. (Coa1t) VENTILATION MEASUREMENTS HENRY PLANT Location FPM Polymer Chamicals Bldg. (con't) 3rd Fir. Northeast Corner Southeast Corner 5Q <<50 (no air movement) PNA Dump Chute Area 50-100 (air flow is back toward operate X-70 Area 50 (no air movement) Lightning Mixer Area &50 (no air movement) * On the 3rd floor of the Polymer Chemical Bldg., the only exhaust fans operating.were two emergency fans. Also, exterior wall panels were removed in conjunction with the fans being blocked by raw material storage which results in loss of effectiveness of the fans. NGC 01215 Name - TABLE V . D U S T M LA SIJ REME N T S HENRY PLANT Location Dispersion Bagger Bldg. 732 P r e comp oun d er Bldg. 741 ' 0BXS Flaker Bagger PC Bldg. PVC Bagger Welder - Old Boiler Bldg. Dumping Powders 4th fir. compounding Bldg. 712 PPD Operator Bldg. 712 PPD Operator Bldg. 712 Sample Time (ruin. ) 282 336 334 300 231 151 312 269 Concentration (mg/M3) 1.3 3.0 1.0 1.2 3.44 4.1 < 0.2 - PNA <r0.2 - PNA OSHA TLV for nuisance dust = 15 mg/M^. REDACTED NGC 01216 spr.cii-'u: o v'mons S-S'J PORTABLE EXHAUST Plain duct Flange or cone X, inches cfm cfm up to 6 6-9 335 755 250 560 9 -i2 1335 IOOO Face velocity =1500 fpm Duct velocity= 3000fpm minimum Entry toss= 0.25 duct VP Also see "Granite Cutting" VS-909 GENERAL VENTILATION, where local exhaust cannot be used: Rod, diam cfm/welder 5/32 3/16 1/4 3/8 IOOO 1500 3500 4500 For toxic materials higher airflows are necessary and operator may require respiratory protection equipment <! OTHER TYPES OF HOODS Bench: See VS-416 Booth: For design See VS~4l5fVS~604 J Q=(00 cfm/sq ft of face opening AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS WELDING BENCH j j ! * date j-74 | VS-416.1 I " 01217 i4.' August 10, 1978 C. B. Cooper A. W.Clements G. F. Krcmar INDUSTRIAL HYGIENE SURVEY - HENRY PLANT In June, Mr. Thomas Bialke conducted an industrial hygiene survey at the Henry Chemical plant. A copy of Mr. Bialke's report is attached. Please note that he has made a number of recommen dations concerning asbestos insulation, respirator program, ventilation, etc. I would appreciate being advised as to the status of these recommendations as they are implemented. v cc: H. Waltemate E.W. Harrington R.A. Kelley H.W. Dietz R.A. Guyton R.W. Strassburg A.W. Otto J.D. Krumholz N.L. Kuchenmeister D.E. Giffen NGC 01218 TO FROM SUBJECT C. B. Cooper T. S. Bialke FIELD POINT OR DEPT. 4 8LDG. NO. Henry FIELD POINT OR DEPT. & BLOG. NO. Akron - D/0020, 5-H INDUSTRIAL HYGIENE SURVEY - HENRY PLANT DATE YOUR LETTER DATE miS LETTER 8-9-78 On June 19-23, 1978 an industrial hygiene survey was conducted at the Henry Chemical plant. The plant's program for controlling vinyl chloride and the medical surveillance program for all workers are functioning adequately. Procedures for handling and disposing of asbestos insulation must be developed and implemented as quickly as possible * A plant-wide respirator program must also be written. The plant management is to be complimented on the enthusiasm of its staff. I would like to thank the Henry plant manage ment for the consideration given to me during my visit and I look forward to working with them in the future. v CC: A.W. J.D. N.L. D.E. Otto Krumholz Kuchenmeister Giffin T. S, Bialke Industrial Hygienist BFC-i55-0 ?/' I _ S A NGC 01219 IH Survey - Henry June 19-23, 1978 1. recommendations 1. Asbestos Remove and properly dispose of all 2'* I.D. preformed pipe insulation designated by sample #1 stored in carpenter shop as it contains asbestos. Develop and implement asbestos insulation removal procedures requiring the use of approved respirators, wet methods, bag labeling and proper disposal (see Appendix I for example of asbestos insulation procedures and OSHA 1910.1001). Restrict purchase of insulation to asbestos-free types. 2. Respirator Program Develop and implement a written respirator program and provide for ongoing review of the program by placing one individual to be totally responsible for the program's maintenance and enforcement. Provide for periodic review of the serviceability and clean liness of those respirators assigned to individuals. Provide maintenance personnel who carry respirators with them with storage bags that can be hung on maintenance carts. 3. Install hydrocarbon and CO removal devices in breathing air lines at reservoirs leading into PVC, PC and 3114 process buildings. - 4. Implement a program for periodic cleaning and maintenance of all local exhaust ventilation systems in the compounding and polymer chemical buildings. 5. Maintain a stock of toxic dust respirators and require them to be worn when compounding toxic pigments i.e., Pb, Cd, Sb pigments. If the use frequency of such pigments is increased, the compound weigh booth ventilation system must be reevaluated and increased to provide at least 100 fpm across workers breathing zone. 6. Poly Building Repair steam and compressed air leaks in poly building. Conduct additional noise dosimeter monitoring of baggers and others. NGC 01220 XH Survey - Henry June 19-23, 1978 *> - RECOMMENDATIONS (con't) 7. Polymer Chemicals Clean local exhaust ventilation systems. Develop plans to upgrade existing and provide new local exhaust ventilation at dry compound addition points and bagging operations. 8. 3114 Process Modify local exhaust ventilation hood over manhead to provide higher capture velocity across manhead opening. Provide hoods and hangers at the end of flexible exhaust ducts provided for sampling point spot ventilation that will allow for easy access to sample sites, 9. Supply noise dosimeter data to the plant nurse so that comparisons with individual audiometric results can be made. DISCUSSION AND FINDINGS Five bulk samples of various types of insulation were collected and analyzed for asbestos (see Table I for results). Two samples were found to contain asbestos; sample #1, a preformed 21* type of pipe insulation discovered in the carpenter shop storage room and #5, a sample of insulation found in a 55 gallon drum outside the polymer chemicals building which had been removed as a result of repair work on the MBT crude reactor. The material found in the barrel was disposed of improperly and had not been wetted down upon removal. An asbestos handling procedure similar to the one prepared by Avon Lake (Appendix I) must be developed and implemented by the Henry plant. The preformed insulation corresponding to sample #1 must be properly disposed of (see Appendix I or OSHA 1910.1001 for procedure). All pipe insulation, unless known otherwise, should be handled as if it were asbestos. The Henry plant uses a number of respirators of different types. During my walk-through, I observed many practices such as improper storage of respirators, failure to clean respirators and nonapproved airline respirators that were in violation of OSHA. The plant needs to develop a written respirator program with responsi bility for the program assigned to one individual for the monitoring of its effectiveness. The program has to provide for the periodic review of the serviceability, cleanliness and maintenance of all respirator equipment by an individual or individuals trained in and impressed with the importance and necessity of such a program. \TCc XH Survey - Henry June 19-23, 1978 3. DISCUSSION/FINDINGS (con't) Respirators assigned to maintenance personnel were found to be draped over the handle bars of their tool carts. Such practice is improper as far as OSHA is concerned and .will eventually lessen the service life of a respirator. Small canvas bags are being used at other plants to store respirators assigned to maintenance personnel. Avon Lake General Chemical plant obtained canvas pouches that do the job from Salem County Rehabilitation, Mannington Road, Salem, New Jersey 08079. Cost is $7,50 per pouch and they are called "canvas respirator pouch with belt". Currently CO and hydrocarbons are being removed from instrument air at the airline stations to provide approved breathing air. Such a dispersed filtration system is hard to maintain and is expensive when replacement of many filter cartridges is required. Centralizing the production of breathing air by filtering instrument air before it enters either the PVC, PC or 3114 process areas would reduce the frequency of replacing filters and reduce operating costs. The certainty of supplying adequately filtered breathing air to all airline stations within a building would be assured. Such plans are under consideration by the plant and are encouraged. The local exhaust ventilation systems of both the PVC compounding building and Polymer Chemicals building were found to be in need of a clean-out. A branch of the local exhaust system over the bin in the compounding building was totally plugged, A require ment for routine cleaning of all ventilation systems was described to me. Such a procedure, to be effective, must be properly implemented and maintained to insure adequate ventilation. - The handling of toxic pigments (Pb, Cd, Sb) in the PVC compounding building is very infrequent. However, when such pigments are used, the employees must wear toxic dust respirators such as the 3M 9900. Respirators are required as the ventilation in the weigh booth and Henschel area is not adequate to control toxic dusts. The system is adequate, however, for nuisance dusts. If the use frequency of toxic pigments is increased to weekly, the ventilation system must be upgraded and monitoring for toxic pigments begun. The Poly building has a potential for overexposing workers to high intensity noise. More dosimeter work is needed in this area to adequately characterize the exposure, especially for PVC baggers. Steps can be taken to reduce noise and save energy by initiating a program to plug steam leaks, compressed air leaks and sealing faulty switches and agitators, all of which are sources of high frequency noise in the area. > |N|GC 01222 IH Survey - Henry June 19-23, 1978 4. DISCUSSION/FINDINGS (con't) The polymer chemical building has numerous sources of dust exposure to both raw materials and final product at the packaging sites. Dust monitoring has not shown any overexposure to nuisance dust. Most, if not all, compounds used or bagged in the PC building are characterized as such. Even though no overexposure exists, as defined by present standards, it behooves the Henry plant to proceed with plans to upgrade existing local exhaust systems and to install additional exhaust ventilation at other sources of dust exposure; the packaging operations for example. Steps must be taken to close up existing sources/leaks of dust as much as possible. As noted in the 3114 process start-up review, the local exhaust ventilation drops at the sampling points are in need of modifi cation. Various suggestions have been made to provide adequate ventilation at the sample site to remove any vapors produced and yet allow for easy access to the sample site. Whatever design is decided upon will certainly provide for better conditions than now exist with the free hanging flexible ducts with no hoods or hangers. The exhaust hood over the manhead also is poorly designed. It needs to be lowered or modified to provide a higher capture velocity across the manhead. Here again, various design changes have been suggested. Any of these will do a better job. When a design is decided upon, its installation must proceed rapidly. Noise dosimeter results are to be provided to the plant nurse so that she can compare them with an individual's audiometric examinations and properly counsel him/her on whether a hearing problem is a result of on or off the job noise exposure. Air sampling for vinyl chloride, benzene and acrylonitrile was performed (Table II) . All readings were within published or recommended standards. The plant's physical examination require ments were reviewed and found to be in order. TSB sooB esez i NGC 01223 TABLE I. INSULATION BULK SAMPLE RESULTS Henry Plant Sample No. 1. 2" I.D. preformed pipe insulation 2. 6" I.D. ditto Collection Site Carpenter Shop storage ditto 3. 6" x 1%" x 32" preformed pipe insulation ditto 4. Eagle-Picher Super 66 ditto 5. MBT crude reactor insulation Uncovered waste barrel outside PC bldg. Constituent Asbestos Fiberglas synthetic fiber ditto Rock wool Asbestos ^0096632 NGC 01224 Location PVC Milling PVC Milling Polymer Chemicals Polymer Chemicals 3114 Building TABLE II. AIR SAMPLING'RESULTS Henry Plant Tyre General area Over mill PC operator General area, 3rd fir. slurry tank General area 3rd floor 3114 dryer Sample Time (min.) Pollutant 284 VC 260 VC 245 Benzene 250 Benzene ppm cO.l 0.2 0.1 0.1 239 Acrylonitrile <0. 2599600S NGC 01225 APPENDIX I. B. F. GOODRICH CHEMICAL COMPANY Avon Lake General Chemical Plant Department Managers General Foremen SUBJECT: AIRBORNE ASBESTOS GENERAL NOTICE: EM-2 Issued: September 17, 1976 Page One Purpose: The purpose of this procedure is to identify asbestos and the methods required to handle it safely by BFG and contract personnel. Definition: "Asbestos: includes chrysolite, amosite, crocidolite, tremolite, anthrophyllite, and actinolite. "Asbestos fibers" means asbestos fibers that are longer than 5 micrometers. Limits: ~ The eight (8) hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic . centimeter of air. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeters of Types of Exposure; This procedure deals only with airborne asbestos fibers. Ex posure would be through the respiratory system. Physical contact with the skin is not considered hazardous as long as the asbestos is removed and-does not enter the respiratory system. Methods of Measurement: All determinations of airborne concentration of asbestos fibers shall be made by the membrane filter method at lOO - I50 X (magnification) ( 1 millimeter objective) with phase contrast illumination. 6009G 6S2 Use of Asbestos Containing Material Usage of asbestos containing material will be limited to the following: a) Fire blankets b) Packings and gaskets c) Gloves Pipe or equipment covering materials containing asbestos will not be allowed. Disposal of Asbestos Containing Material .^ All asbestos containing materials where the- asbestos can be exposed as free fibers must be placed in an impermeable con tainer and buried in a land fill. The impermeable container . must be tagged with a ta^ bearing the following information: CAUTIOTN Contains asbestos fibers . Avoid creating dust Breathing asbestos dust may cause serious bodily harm'. ^GC 01226 Department Managers General Foremen SUBJECT: AII&OkNE ASBESTOS GENERAL NOTICE: EN-2 Issued: September 17, 1976 Page Two Probable Contact Areas: Asbestos containing materials will possibly be encountered in the demolition, renovation or removal of pipe or equipment coverings. The following precautions will be taken in the demolition, renovation or removal of asbestos containing material. a) All material that is suspected of containing asbestos must be treated as asbestos. b) Any material identified in (a) above must be adequately wetted before it is removed or handled. Where this is not practical due to damage of the equipment from, the water it must be removed, carefully, placed in an impermeable con tainer and lowered to the ground. c) All asbestos containing material must be handled in such a manner that dust eramissions are eliminated. It must not be thrown from one level to another. d) Personal protective equipment must be worn by anyone handling asbestos-containing materials or by those in the area where possible exposure may be made due to the handling of asbestos. It will consist of the following: 1) Respirator - dust mask - for normal exposure AO R9100T or equal. This can be used if the expected exposure is not over 10 times the 8-hour time weighted average. 2) Fresh Air Respirator - with a full face piece shall be used if the concentration is expected to be from 10 times to 100 times the 8-hour time weighted avers 3) Type "C" Supplied - air respirator (Scott Air Pak) for concentration above 100 times the allowable . 8 hour time weighted average. 4) Clothing - Working clothing win be provided by the employer. It will be handled as follows: a) If a man has worked in an area where the level of asbestos air-borne contamination is above the acceptable 8 hour time weighted average his uniform must be placed in an ^ impermeable container and tag attached. k - to . - CG . - '& o -H* - o NGC 01227 bepar traent Managers General Foremen SUBJECT: AIRBORNE ASBESTOS GENERAL NOTICE: EN-2 Issued: September 17, 1976 Page Three Probable Contact Areas - continued b) All contaminated clothing must be tagged vith a tag bearing the following information CAUT I 0N Contains asbestos fibers Avoid creating dust Breathing asbestos dust may cause serious bodily harm. General If questions arise concerning the above procedure, they should be directed to the Safety Department. Written by: D.J. McDonald Approved by Operation Council 9/16/76 D.E. Fisk, Plant Engineer DJM rwml cn CS C: O H* -- / VGC 01228 Inter* organization Correspondence \^BEGoodrich^ TO FtCLO POINT Oft AKA04 DEPARTMENT ft El.DO. NO. OATS TOOK CETTCR T. W. Shepler____________ FROM C. B. Cooner tUOJCCT _____T)/007n R/S-H__Akrnn_____________________________________ PlCLO POINT DA AKRON OCFARTM^HT ft LDG. MO. UAlC THIS L6TTCR Henrv Plant $EP i>7 injc *' wo Q/73/76 Reply to Henry Plant Industrial Hygiene Survey - Your Letter of 8/5/76 In your report of the Industrial Hygiene Survey conducted last summer, you listed four areas in need of immediate attention. All four of these have been corrected or are being aggressively pursued. These were of a general nature. The twenty specific items recommended are largely complete, with a few requiring design work or further study. Three of them appear undesira ble or impractical to us: Item 13. "Re-locate the third floor compacter in the Compound Building closer to the hoppers". The present location appears to us to be the most practical con sidering the movement of materials to and from the hoppers. The compacter would definitely interfere in any other location on this floor. Item 18. "Establish a larger selection of cartridge respirators to accommo date employees with unique facial structures". Ray Ehnle, our Safety Engineer, has looked into this and assures me that the flexible aluminum base of the half-masks can be shaped to fit any facial structure. Item 20. "Re-plumb the transfer lines from the VCM cylinders to the vinyl hood in the Laboratory Building". The air flow in the Laboratory is from the ends of the transfer lines to the hood. Many samples have been taken in this area and the amount of vinyl chloride escaping from these lines is very low so that the concentration never exceeds the allowable limit. If you would like a detailed summary of all the work going on, I would suggest a telephone conversation or another visit to the plant. John McCool and Jim KLupar spent a couple of days earlier this week taking samples and looking at the current program to eliminate leaks of all vapors in the Polymer Chemicals Building and were complimentary about what has been accomplished. Most of their samples were of Benzene. Perhaps John McCoo] will give you a summary of his findings. CBC:vck C. B. Cooper (^ Cl f* 3 Cl o c A. W. Otto D . W. Dotv D - E. Gil fin R. L. Ehnle pi le 229 August 6, 1976 J. L. Nelson A. W. Clements E. W. Harrington C. Cooper Attached please find Mr. Thomas Shepler's report concerning the industrial hygiene survey of the Henry plant. X would appreciate being advised of the status of these recommendations. Please contact me if you have any questions regarding this report. \ v cc: G. Pow H. VJaltemate/B .Johnson W.C.Holbrook/K. J.Kaminski R.W. Strassburg A.V.Gold/M.N.Johnson