Document 6BRgwZ3w2EBJ6OZD8myGBBZpo

6/29/79 Copied ----- ... i'NlON C/-';S:D CORPORATION CHeiv;K;/-ho \ ;D PLASTICS P, fj. BC/i 'I Ex.\S CITY, TEXAS 77S90 April 2, 1979 Dr. V. Alexander U.S. Department of Labor Occupational Safety & Health Administration 200 Constitution Avenue, N.W, Room N-3673 Washington, D. C. 20210 Dear Dr. Alexander: The following Information is being supplied in response to your requests during your March 15 visit. These observations are provided for your back ground and research information only, and not in connection with any compliance review. They are subject to review and revision. Employee Death Certificates Dr. Glenn reports that we now have death certificates onjkfof the 35 "unknowns". There are no primary brain tumors among the^6. Ethvlene Purity The most common commercial specification for pipeline ethylene on the Gulf Coast is 99.8% minimum purity; ethane content 0.2% maximum; for all other components, the maximum is normally 50 ppm or lower. Thus, it would be reasonable to assume that even a maximum ethylene release would carry with it probably nothing above the limits of detection. Ethylene Production Ethylene production in Texas City can be summarized as follows: 1941 - 1942 <100 million lbs./yr. 1943 - 1948 Avg. 200 million lbs./yr. 1949 - 1968 1969 - 1979 Avg. 600 million lbs./yr. Avg. 1100 million lbs./yr. Personnel Exposures to Ethvlene After restudy of the work histories of the eleven employees described in Dr. Glenn's letter of February 28, to you, we can divide the employees into two groups: Ucc 047975 Dr. V. Alexander April 2, 1979 Page 2 ( (1) Employees who spent considerable periods in areas making or using several hundred million pounds of ethylene per year and (2) Employees working in areas (or plant-wide) where exposure levels were essentially at the plant ambient air level (well under 50 ppm ethylene). High Usage Areas Minimal Exposure Elder Liles Mitcham Pope Tuttoilmondo Wurzlow Burck..Hinson Malone Perkins Remme & Area Monitoring Data To provide some order-of-magnitude data on total hydrocarbon levels in various parts of the plant, see Table I. The most likely area for high ethylene levels should logically be our "world-scale" Olefins area, and you will note they are very low indeed. The only TLV for ethylene I am aware of personally is 1,000 ppm (ACGIH); because we have been so far below that level,.only limited data exist. Ethylene Usage You requested that we identify the areas or units listed in the product list (our letter of February 26 to Mr. Miller) which handled large volumes of hydro carbons. These are in Table II, and the page references are to the above letter. Please note that this information would be useful to our competitors, and we request its confidential handling. I have also attached a tear-sheet from a recent issue of "C&E Mews" which provides you a bit of commercial background on ethylene. DLE/gt cc: Dr. D. H. Glenn Mr. J. B. Leverton D. L. Engle Plant Manager 1 UCC 047976 DATE 1973 1975 1976 1976 c TABLE I AREA EXCURSION MONITORING TOTAL HYDROCARBONS AREA Fuel Gas Area MEDIAN <20ppm No. 2 Olefins (3 buildings) lOOppm No. 3 Olefins (All buildings & areas) 80ppm Vinyl Acetate 50ppm RANGE N/A 25 - 300ppm 15 - 450 (3 above 200) 25-85 (3 above 75) 1976 1979 1979 ETHYLENE - SPECIFIC No. 3 Olefins 20ppm Vinyl Acetate (converter operators) Diethyl Sulfate (operators) 0.07ppm to 4.98ppm 0.45ppm to 4.0lppm 10 - 30 ( ( 8-hr twaJ ( ( 8-hr twaJ A/2/19 ucc 047977 f TABLE II HYDROCARBON USAGE PRODUCT Ethylene AREA TYPICAL ANNUAL THRUPUT, MMLBY No. 2 Olefins (when operating) No. 3 Olefins Ethanol Oxo - LPO Vinyl Acetate Diethyl Sulfate Ethylene Dichloride 140 1,100 470 60 125 5 15 o Propylene No. 3 Olefins Solvents & Acids (Isop) Marine Terminal 95 400 290 LPG/Refinery Gas (Liquid Petro Products) No. 2 Olefins No. 3 Olefins "Dripolene" No. 2 Olefins (Heavy Hydrocarbons) No. 3 Olefins Marine Terminal 120/0 1,550/150 15 130 150 Butadiene No. 3 Olefins Marine Terminal 45 170 Butylene Oxo 45 LEVERTON LIST PAGE 7 8 1 9 18 3 19 8 14 26 7 8 7 8 24 8 24 10 ucc 0419^8 4/2/79 Key Chemicals Ethy!ene ch2=ch2 Capacity expanding Demandgains slowing Prices holding PRODUCTION/CAPACITY Billion* ol lb HOW MADE Cracking various hydrocarbons from ethane to gas oil by catalytic processes or In the presence of steam MAJOR DERIVATIVES Polyethylene 45%; ethylene oxide! glycol 20%; vinyl chloride 15%; styrene 10% MAJOR END USES Fabricated plastics 65%; antifreeze 10%; fibers 5%: solvents 5% FOREIGN TRADE Exports end imports negligible PRICES Contract--13 cents per lb with slight shading; spot market small COMMERCIAL VALUE \^$$33.i5 billion for total production, 1978 Success Is quite relative these days for basic olefins. For example, insiders say that the kingpin of this group, eth ylene, will have an outstanding year In 1979 if the price merely holds, even in the face of a huge wave.of new U.S. production capacity. In other words, ethylene producers are really in trouble. A quick look at capacity and demand forecasts leads to no other conclusion. In 1978, nameplate ethylene capacity increased at a rate one and two thirds times the forecast demand increase of a billion pounds or so in 1979, when this capacity will first be available for fullscale use. For next year, capacity ad ditions amounting to almost four times this demand increase will be coming on stream. Operating rates will fall during 1979 as they did in 1978. Pessimistic fore casts for the U.S. economy in 1979, if accurate, could mean oven lower growth in ethylene demand and yet tower operating rates. Some faint hope for ethylene pro ducers is that recent official production estimates have proved to be too low. Far example, the 1977 final production fig ure for ethylene from the International Trade Commission is 25.4 billion lb. This is up nearly 1 billion lb from preliminary ostimatss of Just a few months ago. Annual production for 1978, based on the first eight months of preliminary ITC estimates, runs well over 27 billion lb. This is again some 12% over similar estimates at this tlmejn 1977. Company officials forecast that pro duction during die fourth quarter cl 1978 will slow for several reasons. As a re sult, 1978 production would be about 26.5 billion lb. Such production would give a reasonably good gain over pre liminary estimates for 1977 production. In fact, this increase could exceed ca pacity additions that went fully on stream during the year. However, the higher final production total for 1977 suggests that a higher than expectod total also will result in 1978. Ethylene production probably has bean running along watt enough to reach a 1.5 billion lb gain this year. Some of this added production hes gone into inventories, which may be nearing 2.5 billion lb. Although large, this volume is not considered excessive. The reason is that considerable product is needed just to fill pipelines and to meet contract needs during times of plant operating problems or maintenance shutdowns. Next year, some additions to inven tories also wilt be necessary. However, these probably will not be largo. Com panies adding major capacity next year--Exxon Chemical, Shell Chemical, and Texaco--are all current producers of ethylene and hence have storage and pipeline systems already in operation. As a result, inventory additions will be about 200 million lb. The forecast growth tn consumption of ethylene in 19/9 at n billion pounds or slightly more assumes slower growth in the U.S. economy, but not an outright decline. This ethylene growth, called "conservatively optimistic" by one In dustry source, will lead to a 1979 pro duction of 28 billion lb. up about 5%. This consumption will come mostly from ethylene's most important uses--polyethylene and vinyi chloride for polyvinyl chloride. High- and lowdensity polyethylene and ethylene di chloride. precursor to vinyl chloride, account for G0% of ethylene demand, tn spite of their size and maturity, these uses are forecast to grow at a rate above ethylene's 5%. Offsetting good growth in ethylene domand for polymer products, including styrene, ere slower rates for use in ethylene oxide and its derivatives, especially ethyiene glycol. (Direct pro duction of ethylene glycol trom ethylene Is just getting under way with apparent difficulties, so its growth rate is not meaningful.) The other large-size use of ethylene, conversion to ethylbenzene for styrene, has declined in growth for some time. Growth In 1979 probably will be halt the average rate for all uses of ethylene. Use of styrene in polymers and in sty rene-butadiene rubber (SBR) has rela tively low growth. Use in acryionitrilebutadiene-styrene resins and other resins is growing at rates of more than 5%. However, their base is small and total consumption small compared to that of polystyrene and SDR. With only modest hopes for increas ing demand in 1979, It may be a year of strategic planning adjustments in eth ylene. Since feedstock and other costs continue to increase, price cutting seems unacceptable. Hov/evc:. much new efficient capacity will be in opera tion. The obvious solution is tor planners In 1979 to shut down old capacity in 1980. ucc 047979