Document 4QBmeoyQ0n7rbmzeJ7rz1wn21

INTER-ORGANIZATION H.E. Jewett C. Reynolds H. Graff D. Jenkins FROM: R. Lilly SUBJECT: Reactor Ventilation Fan. The reactor ventilation fan was started on August 26, 1980 and a reactor was cleaned using it on August 27, 1980. The Bendix was hooked up so that Reactor R313 could be monitored continuously . Before the fan was started the reactor showed levels of 10 to 12 ppm MVC. When the fan was run for a few minutes these levels dropped to .5 to 1 ppm. However, after work cleaning the reactor began the level increased to 2 to 3 ppm HVC average. The fan was shut off during lunch break and the level in the reactor returned to the 10 to 12 ppm level. After lunch the fan was started again and the levels returned to 2 to 3 ppm average, while the reactor was being cleaned. The air velocity at the reactor manway was found to be an average of 2200 Fpm. Allowing for the suction hose displacement, this calculates to an air volume of 1850 CFM. A temporary procedure has been written for the ventilation fan. This will be modified as needed for any changes in procedure that may occur. In conclusion the portable reactor ventilation fan is operational and can be used to collect data on reactor ventilation. RL:pn BETTER Service Is Our Business 6ENC 00 331';. (1,1'J-o^' INTER-ORGANIZATION TO: ATTENTION: FROM: DATE: SUBJECT: (U1 -0* H. E. Jewett A. D. Jeffrey, G. E. Brumbaugh E. R. Senra July 23, 1980 Ashtabula Plans to Improve OSHA Compliance During the meeting with Mr. Pompeii (OSHA Inspector) to review the findings of their visit to the Ashtabula plant, Mr. Pompeii stated that the existing 200 CFM air ventilation of the reactors during manual cleaning was insuf ficient. We agreed with OSHA to increase ventilation by October 1st. Also, we believe that the occasional VC excursions and high levels of VC in the Polymer Building must be better controlled through a containment/ventilation system. The following is a brief description of the engineering projects that we have agreed are necessary for improving OSHA compliance. Short Term Solutions: 1st Phase -- We will install a 2000 CFM fan mounted on a moveable base to be used to exhaust vapors from the reactors prior to and during manual cleaning. ALL THE EQUIPMENT IS AT HAND and installation of it is scheduled to be completed by the end of July, thus complying with OSHA requirement that we increase reactor ventilation by October 1st, 2nd Phase -- We will prepare and submit one appropriation, by the end of July, to install a permanent duct work system with takeoffs for each reactor pair and for fugitive leaks. A 10,000 to 12,000 CFM capacity fan will ventilate two reactors at a time (5,000 CFM) per reactor and few leaks. Based on a delivery of 16 weeks for a fan, the completion of this project will not be sooner than February 1981, and the cost estimate is in the range of $60,000 to $70,000. Long Term Solutions: A. Increase Polymer Building ventilation to eliminate dead zones, by installing additional wall exhaust fans and increase the fresh makeup air and heating. B. Install a high pressure water system to clean the reactors, thus minim-1 zing the operator exposure to residual MVC. The system will consist of two pumps with controls and water distribution piping. These two projects combined will range from $180,000 to $200,000. Central Engineering is working with Ashtabula on the ventilation projects, and they concur with these plans and approaches. !*' ERS;sm V.*.*. FORM ONO E. R./Senra, Plant Engineer "BETTER Service Is Our Business" GENC 003317 HOUGH DRAFT To H. cc: J. From 1. July 23, 1980 Subject: Ashtabula Plan* to Improve EBA/OSHA Compliance Curing tbe meeting with Mr. Pompeii (OSHA Inspector) to review the finding* of their visit to tbe Ashtabula plant, Mr. Pompeii stated that the existing 200 CFM air ventilation of tbe reactor* during manual cleaning was Insufficient. We agreed to increase ventilation by October 1st. Also, we believe tbat tbe occasional VC excursions and high levels of VC in tbe Sblymer Building must be better controlled. improve 1SA/DSHA oosylisnoe. SHORT TBH aOLOTIDMi 1st PHAM -- We will install a 2000 CM fan mounted on a movable base to be used to axbaust vapors from tbe reactors prior to and during manual cleaning. ALL THK Bauman! a AT HARD.and Installation of It is scheduled to be completed by tbe end of July, tbue copying with OSHA requl rmesnt tbat we Increase reactor ventilation by leptoeber 1st. and submit one appropriation, by tbe end of July, work system with takeoffs for each reactor and for fugitive leaks. A 10,000 to 12,000 CM capacity fan will ventilate 2 reactors at a time (3,000 CM) per rotator and few leaks. Based on a delivery of l weeks for a fka, tbs ODMPIfBDl or tutm, HpJlCf will ict m woonm tbam rmrarr 1961. aa* the cost eatimt* is in the of $60,000 to $70,000. GENC 003313 I -2IDMG tmmwnam A. Increase ftilymer ftriia*ng ventilation to eliminate dead zones, by Installing additional wall exhaust fans and increase the fresh makeup air and beating. B. Install a high pressure water system to clean the reactors, thus minimizing the operator exposure to residual MIC. The system will consist of two piaqps with controls and water distribution piping These two projects combined will range from $180,000 to $200,000. GENC 00331? JJ-\. L. W' ETZEL FROM: DA TE: SUBJECT: A. D. JEFFREY JULY 15, 1980 OSHA & EPA PROBLEMS AT ASHTABULA On 7/3/80 R. Laundrie, T. Shepler and myself met with the Ashtabula plant people to finalize a program in answer to the OSHA citation and the EPA citation on relief valve discharges, OSHA - We were cited for exposing reactor cleaners to high levels of VCM and have until October 8, 1980 (6 months) to be in compliance. There is no way we can meet the 1PPM standard in the immediate future, but propose the following program which will be submitted to OSHA: 1. Increase reactor ventilation while cleaning. The plant will submit by the end of July an appropriation to install an exhaust system that will handle three reactors plus provide a means of exhausting specific leaks until they can be repaired. The cost is estimated at $25M-$30M. 2. Begin work on designing an improved reactor building ventilation system which will be included in the 1981 budget. 3. Replace existing vent compressor with a chiller and condenser. This is an approved appropriation and necessary tie-ins were made during the current plant shutdown. Due to delayed deliveries, the project will not be completed until August, 1980. 4. Change procedure for opening reactors for minor repairs to reduce VCM levels. This was completed in June, 1980. 5. Revise leak detection and repair programs by changing the location of the Bendix pick up points and insisting on faster response of repairing leaks. 6. Investigate replacement of frequently leaking equipment. These are valves, etc. that will be done with normal maintenance money. 7. Investigate different methods of cleaning reactors such as B.F. Goodrich clean reactor technology and/or using high pressure water. A demonstration of a water system will be made on 7/29/80. After evaluation we will need to decide if either of these methods are suitable. ; FQBM 1 8ON0 "BETTER Service is Our Business GENC 003320 J. L. WETZEL JULY 15, 1980 PAGE -2- 8. Stricter enforcement of wearing respirators will be done so that we cannot be cited for actual exposure. Some jobs may always require wearing respirators. EPA - Legal has made the recommendation that we answer the latest correspondence from EPA, give them the definition of terms they requested, but make no further comment on the relief valve discharges. This is still being discussed and a decision has not been made as yet. Meanwhile, we did decide to pursue the following items to minimize future discharges: 1. Change cooling tower electrical supply to eliminate the chance of one breaker failure causing the loss of cooling water. This has already been done. 2. Issue a procedure for using Ashco water directly in the reactor jackets in case of a cooling failure. This will not control the reactors but will provide more time to shortstop. 3. Engineer a pressure alarm system and submit an appropriation. This will be set to alarm at approximately 20 PSIG below the relief valve setting and it will be mandatory that the batch be shortstopped if the' alarm goes off. 4. Discussed the need for a standby emergency electrical generator to run the reactor agitators and shortstop pumps in case of a total power failure. Since the plant is supplied power from two different power plants it was decided not to pursue at this time. 5. Discussed the possible benefits of an automatic shortstop system using nitrogen pressure, but decided there were too many problems involved and discarded the idea for now. ADJ/jh cc: R. Laundrie T. Shepler H. Jewett G. E. K. Kolinek A. D. Jeffrey GENC 003321 INTER-ORGANIZATION FROM: CENTRAL ENGINEERING DATS: SUBJECT: U. I980 Project #3461 Polymer Building Ventilation The above project has been initiated per your verbal request on July 10, 1980 to prepare design drawings, specifications, and a bid package for a first and second floor ventilation system in the Polymer Building* I will call you early the week of July 21 with a schedule of when this work can be done, keeping in mind your deadline of October 1. Time spent will be charged to Plant Expense. Robert V. Bowes Design Engineer Piping - HVAC Design RVB:bas CC: F. E. Palmer D. C. Fetchu R, K. Shape/A. R. Bowin H, Jewett - Ashtabula R. J* Snyder - Ashtabula R* Lilly - Ashtabula *BETTER Service Is Our Business' GENC 003322 TRIP REPORT ASHTABULA. OHIO July 10, 1980 The purpose of the trip was to provide engineering assistance to develop ventilation to control vinyl chloride exposure to employees in two areas: during the reactor cleaning operation and in the Polymer Building in general. Met with E. Senra and Dick Lilly to discuss these problems. 1. The plant has been cited by OSHA for vinyl chloride exposure during reactor cleaning in excess of 70 parts per million. The OSHA standard for vinyl chloride is one part per million on an eight hour time weighted average. The citation requires abatement of the procedures that cause these high levels of exposure by October the first. 2. The plant is proposing to install an exhaust system which would provide a flexible hose drop from a manifold system into the open , reactor being cleaned. This hose would exhaust air from the bottom of the reactor tank to a fan located outside the building. Calculations of the rate of vinyl chloride generation from the surface being stripped out of the reactor indicate that 5,000 CFM of air would be necessary to reduce the exposure below one part per million. This air flow may be difficult to achieve for several reasons: A. The volume of the tank is 500 cubic feet, with a 19" diameter opening in the top. B. It will be difficult for any exhaust system to move this large volume of air through such a small opening. C. Noise may be a factor within, the enclosed reactor vessel, particularly if a powered make-up air system is used. 3. The plant has a 2,000 CFM fan which they plan to set up on a test basis to determine if this method is feasible; however, since the plant will be shut down until at least July 21, it will be several weeks before this determination can be made. The proposed exhaust system would also Include pick up points on the first floor so that a local exhaust drop could be placed at a leakage point: a pump seal, valve packing, etc. This would serve to reduce vinyl chloride concentration in the building and also to turn off the vinyl chloride alarm which now sounds continuously until a leak is fixed. The plant now has a policy to repair all leaks when identified within twenty-four hours. GENC 003323 V2 A, The exhaust fan for this system would be selected with enough capacity to allow for the exhaust t be taken from two reactors and from several drops on the first floor* All other drops would have a locking cap to prevent leakage. It may also be necessary to provide a relief damper or air bleed to prevent fan surge when most of the drops are closed. The Polymer Building is presently ventilated by propellor exhaust fans located in the east wall on the first and second floors drawing air in through Wing steam coils mounted in the west wall. Because of the configuration of the building and the fans and steam coils there are some "dead" areas where vinyl chloride concentrations exceed one part per million. Nameplate data on the fan and Wing steam coils was obtained so that the current building ventilation rate can be calculated. 5. Rick Senra requested that Central Engineering initiate a project to provide ductwork drawings, specifications, and a bid package to install the exhaust system for the reactor ventilation and first floor ventilation. This would also include any make-up air requirements determined to be made necessary by this exhaust system. Because of the need to have the system installed by October 1, it was decided to proceed with the duct layout based on the information known now. Changes can be made later if tests with the 2,000 CFM fan show that thay are necessary. 6. The Ashtabula Plant will handle the appropriation request and subsequent work after the drawings and bid package have been prepared by Central Engineering. RVB:bas CC: F. . Palmer D.-C. Fetchu R. K* Shape H. Jewett - Ashtabula E. Senra - Ashtabula R. Lilly " Ashtabula Robert V. Bowes Design Engineer Piping - HVAC Design GENC 003324 r INTER-ORGANIZATION M\ O 0 TO: H. E. Jewett ATTENTION: D. Jeffrey, T. Shepler, R. Laundrie K. Kolinek FROM: Jerry Brumbaugh DATE: June 17, 1980 SUBJECT: OSHA Compliance Program cc: R. Jackson W. Staples D. Jenkins S. <} H. Graff E. Kierstead C. Reynolds Based on this memo I am requesting Tom Shepler to arrange for a review of this proposed program with at least Jeffrey, Laundrie, Jewett and myself. After this meeting, a meeting to discuss the approved program should be arranged with OSHA. Proposed OSHA Compliance Program Increase reactor ventilation prior to and during reactor cleaning as agreed to with OSHA representatives. Must be completed by October 8, 1980. This will be the immediate, temporary solution to the OSHA citation. 0 Increase the roam ventilation -- find areas that have low air flow and correct. -- Complete in October, 1981. Provide for a method for spot ventilation -- a system that can provide local exhaust for leaks that are large but cannot be repaired immediate ly or small leaks that are difficult to correct. -- May be completed with reactor ventilation system. Replace vent compressor with chiller and condenser. Vent compressor v> > is a source of VC leaks. Tie-ins for the condenser will be made during plant shutdown in June, 1980 and job completed in July, 1980. Procedure changes. Change procedure for opening reactors for minor repairs. (Completed June 1980) 6. Revise Leak Program a. Move Bendlx points out of areas that are never over 1 ppm and do not have a source of vinyl chloride (Lab, Warehouse, THF area, etc) b. Separate OSHA points from ERA leak points. Have OSHA points located in people work areas with multiple pickups. Use only OSHA points to activate warning light systems. Use rest of points to detect and locate leaks by placing these pickups next to high frequency leak points. c. Reduce frequency of leak detection on equipment that "never leaks." Increase frequency of leak detection in known problem areas. IOND *BETTER Service Is Our Businessm GEWC 003325 OSHA Compliance Program 2- - d. Increase response to Bendtx data. Use Bendix readings to detect and identify leaks more rapidly. 7. Investigate permanent replacement of frequent leaking equipment. a. Automatic valve in VC charge line. b. Recycle valve on weigh scale line. c. Cover seal water storage tanks for Uash' compressors and vacuum pumps. . d. Repair or replace charge header valves. 8. Investigate_clean.xeGffiE_iechnology for future use. a. B. F. Goodrich technology.- - b. High pressure water-cleaning of- reactors-. ' JB:sm irry Msrrt. ibaugb 6ENC 003326 INTER-ORGANIZATION TO ATTENTION FROM DATE SUBJECT .y 2-<d Ashtabula H. E. Jewett D. L. Jenkins June 16, 1980 Reactor Ventilation Study CONCLUSION AND RECOMMENDATIONS; A study was performed on reactor ventilation to determine how to lower the VC1 concentration inside the reactor. The conclusions and recommendations follow: 1. Two/thirds of a gram of VC1 is released from the sides of the reactor every minute before men enter it. A reactor will release up to two (2) grams of VC1 every minute while manually cleaning. 2. We should adopt certain techniques to significantly lower VCL levels inside of a reactor. These include: (a) A ventilation system capable of withdrawing at least 1500 cubic feet per minute. (b) A push-pull ventilation system which forces at least 400 cubic feet per minute into the reactor. (c) Use of a clear cover over the manway to gain efficiency. (d) Proper placement of the elephant trunk at four (4) feet into the reactor. 3. Lowering exposure inside the reactor to 1 ppm is difficult because of the high ventilation required. An average level of 25 ppm is probably obtainable. In accordance with the above, I will have a clear cover for the manway constructed. I will also determine if our breathing air system is capable of safely delivering air for the push-pull ventilation. DISCUSSION: It was decided that the best method to lower the levels would be through different ventilation techniques. The levels were checked using the Bendlx system. ***STf" AftA *BETTER Service Is Our Business - 2- The current technique is to open the reactor, have the lab and foreman inspect it and authorize a permit to enter tag. The laborer then lowers a six (6) inch flexible hose to the bottom of the reactor. This hose, called an "elephant trunk" draws about 200 cubic feet per minute out of the reactor and out the roof. The laborer will leave this hose in for about fifteen minutes, which lowers the VC1 level in the reactor to approximately 100 ppm. Then the reactor cleaner will remove the hose and enter the reactor with a constant-flow mask on. The reactor watch will Insert the elephant trunk to about three (3) feet. This ventilation system will usually maintain a 100-150 ppm level with a cleaner working in the reactor. However, if the reactor watch does not insert the elephant trunk far enough, the ventilation system will draw too much air directly from the room into the reactor and not provide efficient ventilation. Also, if the plant air supply pressure drops, it will correspondingly lower the elephant trunk's volumetric flow because the elephant trunk operates on the venturi principle. Smoke tubes were used inside the reactor to determine the ventilation pattern of the current technique. Using the elephant trunk alone, either at the top or bottom of the reactor, produced no noticeable air movement along the reactor walls. Ideally, a ventilation system would pick up the VC1 as it escaped from the walls and draw it out of the reactor. A system was then devised to introduce air at the bottom of the reactor and draw it out the elephant trunk at the top. A hose was attached to the breathing air system and lowered to the bottom of the reactor. This hose produced 80 cubic feet per minute at 40 psig. Smoke tubes were used to determine that this setup did not blow high VC1 laden air into the polymer building. This system performed better than the elephant trunk alone. Smoke tubes indicated greater flow along the walls of the reactor. A nonmanned reactor which had obtained a steady state level of 110 ppm using the elephant trunk at the top dropped to 70 ppm using the "push-pull" system. The push-pull technique is more effective. The VC1 levels were monitored with men in the reactor using the pushpull technique. In one reactor, level rose from a steady 25 ppm before entry to 75 ppm. In a second reactor, the levels dropped from 80 ppm to 40 ppm. This indicates that the VC1 released due to men working in the reactors is up to three times that released due to normal diffusion. More study on this is planned. According to theory, a plot of concentration vs. time on semi-log paper should yield a straight line for a ventilation problem like this. Any generation of VC1 would eventually reach steady state equilibrium. The attached graph shows that the theory agrees very well with actuality. - 3- More work is required on ventilation with men in the reactors. However, there are some practices that seem likely: 1. Use a ventilation fan capable of drawing a larger volume of air consistently. The current system suffers from depending on the plant air system, which fluctuates greatly. It probably cannot power a device capable of pulling 500-1500 cubic feet per minute required. 2. Use the push-pull technique. Install a system capable of blowing out 200-400 cubic feet per minute. (The breathing air system may be capable of doing this.) Orient the outlet in the radical direction as this was found to produce the greatest flow along the reactor wall 3. Cover the manway with a clear cover. In one case covering the manway quadrupled the efficiency of the system. 4. Use the elephant trunk effectively. The elephant trunk can be misused if it is placed so the inlet is only a couple feet from the reactor opening. In this case, the ventilator is drawing most of its air directly from the polymer building. Placing it in four (4) feet seems to encourage better mixing. D. L. Jenkins Safety Engineer DU/ikb cc: Staff R. Lilly '-'ENC 00 5,-: -ir-g 3/s" s&i _ -'jfc 53 - TT* ,jz. / zM ^Te ,W' .u Xu f/76 ` = . -3,^?-V / X $3SL^Ql -^r~~., : #r" Y: ,i' .ijftfcgwgre .: - -" -drtJrut) ______ x -:/./? -,--35k"' n~^ 'JA - "i-_- ; - . , ?' 'a^^?'awr*,"7 ';' - ".:L'.-^' ` =- r = /H 7~ poo - ~------- /jloQ-Cx}- X ~ /.Q .. _______ CftweflXD_1Z_ 7445: X RTK Z/O) . ' '/ft? , , "" , - --^set' - : Flo uJ r flTS _ ~ jX J?:7--___ 3/T V/ j?r-g 3g>^ _ ^T_____ kz?' Djujjo \J ft 0 : Z. -sic S3C- X .;QV j/a ..Cou &.,.... -rl'::. JCgj^iX .^3.r., X / ..^Z- CFP/j " LZJ .:.C^P///.. '::.:"^ /SS C-fph ' :'Y-; GENC 00 33SI ha/juM/n? " /tKrisr/o'Zj'j C&?m ^^jl: ~ S^ftSsa5:^r^j .Xg 3A3 ^STT^ZX-' r*rsS,^ l/CL. %sa&- ~f:' = -- i.fc 32^Cuj 'ij&R 3/0 ^ ^>^r-r = fro ~.C XJA ^ ~..... XXX JaVJWftr* -3 Hpa?^ 4 y^g g. 6,$X/o UJ/ST FlOt^j RATS. /S gg/?i>/gCD TO OftTAir-l JJZ8M st.3J> PEM VCL_______ .IfeJiBte. &ulZxL JPP*1 * --------------- %:%Sx/t>^ - / pp* ) .F - ^ ^ FT^/mjaJ 2o pp/i ^ \ y. flS&LUU. ~Tl?rf-- .a. />5S*jntoG\ 7t<% SrF/CEAjry, I y<? FT3s6M1m T&S'^gir5. eAJt&.i' ____ ApPOfiX /ASJTL ly /f on FT2* /* y V r- ,, _ ,, bEN*-` 0U;o^ ^3 , ;*&- -.-. -' -^-r.rj.^twr.-j.'B. : _-,,' . -. _-.a.. v-^i;jt- ' . ~ -J-JPSKTp- T; *: yrrxj^r-. --. 7!7^r~?v&&&rS&'siZ.Z727Ir. - ~~~ "- T'l-~~Jf.^g.irB^%^rr:r-i-:;~ mum/ ./itA/ " Jfc- iiiiW V^T , ZZOZ-d-Stt L6 mo it - T " "i"-', * >r,-T.3S-rin^**?-^ --^------";. "x 1 * Miaj . .."" ' :.- " --r .illfe. - . _-.-; . ;7~" '-' r '^r~r-Ffe?*-- * ", ""."V "r .*'- KDftrfr - -:^-;r-- rf v' . '.- - ^-w-'ur1" . r- - ` . v:'';/`. .l . ,, _ ,, t^w.- fvw-W'tt; ' ^ 1'" ' ... '- Ti-viSF.'-''- >'* 1 - - .1,''"-<.-- 3 P. " ~ ,' .'SirS3ra}' '. - 'Vf- r^'l-*1- '<3>J1^'* <?*- tXG;F--: - - S-i~n-3 ': -':SsS^ - V-' ZJ-EPHA/OT NOS2_ ftex^RATt. JfdO .FPh --* ' i .' ' 1 t' 1 u - J^^pOSL? g UJflV v'LAD UaJT 2 S~0 PPM - "r - Put* h Pull. ::: BCLp^AM'iF^ciL ^ *_S - /CAZL ^ AO TPM t /J0 pp^ --- ,'-'--- ., . ^ ..72,. -7> .;r .r. One Par, f v&Srimf>o*if?F*>r, <iy^4L .. - ! <n^ g ~. ttr ->>r a*- i/cr~_____ _... i.Mllfl".... J!1 - --*--. ?-.** :*r***-*" !/ WALL*. -i> t. ,'U r. - la. y**/*&f& _JL(AU/*JQ. ACTM^L ^L.Ct>DK E*D~ u s UAJCQQEPr.f) MA/UujAY __ 0-- Gr&Arf /*4/*J 5{o' /%__-- // /o Ftj?uA----B)?{ IfiMVT %Q CFPAf GENC 003333 s * INTER-ORGANIZATION fflgl iui.cs TO; R. Lilly ATTENTION; G. Brumbaug FROM; e. Kierstead DATE: June 11, 1980 SUBJECT; Location of New Fans and Hake Up Air The following recommendations are made for locating new fans and make up air in the Polymer Building from previous studies made in this building: 1. Exhaust fans Additional exhaust fans should be located: a. East wall of the first floor of the Polymer Building: 1. Opposite Reactor 312 2. Opposite the VCH Refiners b. South wall, south end of the second floor of the Polymer Building: 1. Between the double doors and the east end of the building 2. Or on the east wall between the door and existing fan 2. Make Up Air At least as important as additional fans, additional intake air should be supplied at the following locations: a. West wall of the first floor of the Polymer Building: 1. Opposite Reactor 301 2. Opposite Reactor 305 b. On the west wall of the Walkway of the first floor of the Polymer Building: 1. Opposite Reactor 302 2. Opposite Reactor 316 c. Second floor of the Polymer Building - all on the west wall: .1. Opposite Reactor 304 2 Opposite Reactor 301 and Colloid Tank in corner 3. Above the Polymer Control Room 4. Above the Locker Room ?*. FO*M t QND "BETTER Service Is Our Business* GENC 003334 Page 2 - Location of New Fans and Make Up Air 3. Seal the east wall of the second floor, especially at wall-roof junction. Heated air blown through ducts might work as well or better than in wail units. An air exchange about every 15-20 minutes would be suitable and correspond with the 15 minute TWA test. EK/jd E. Kierstead GENC 003335