Document 6BwyNGOZYB0gLp6wORb4oyMyR

Interoffice Communication To L. N. Vernon, Saddle Brook From D. V. Porchey, Ponca City Date June 3, 1974 Subject SUMMARY OF MEETING DISCUSSING CONOCO'S POSITION ON THE PROPOSED PERMANENT STANDARD FOR VCM EXPOSURE--MAY 29, 1974, SADDLE BROOK /= The meeting was held to review and discuss the objections to the PPS form ulated in Aberdeen on May 16, 1974. It was also necessary to redefine our plan of response to the Government in light of the new procedures outlined in the May 24, 1974, Federal Register. In attendance for all or most of the discussion were: R. W. Gerwig J. J. Langford J. D. Bums F. Kennedy L. N. Vernon J. D. Bryan J. F. Gabbett K. L. Schurter E. M. Smith J. Alix D. V. Porchey The following action steps were decided upon: 1. Conoco will continue its cooperation in the industry-wide response being formulated under the auspices of the SPI, but does not support the 1000 ppm-hr concept as discussed in Report No. 12. (KLS) 2. Conoco will attempt to obtain an informal audience with the Assistant Secretary of Labor, John Stender, to explain our position, etc. June 14 is the tentative date. (FK) 3. Conoco will file official objections to the PPS prior to June 17 for entry into the record of the June 25 OSHA hearing. (RWG) 4. Conoco will request the opportunity to present its case in person at the June 25 hearing. This decision regarding participation will be made at a later date based on whether or not the industry is well represented at the hearing. (FK,RWG) x5. A portable analytical unit adequate for fence line monitoring will '-- be identified for and specified to the plants. (FK) 6. Comments and changes made to the PPS objections will be written and transmitted to Legal, Safety, the plants, and attendees by May 31, 1974, for review and comment. (DVP) 7. Comments of R&D statisticians will be incorporated into the objection draft under objection 5, provision (e), if appropriate. (DVP) VVC 000002521 L. N. Vernon June 3, 1974 Page 2 8. An attempt will be made to have our objection reviewed by June 5, approved by H. Hardesty by June 7, and submitted to OSHA by June 11. (KLS) Discussion: K. L. Schurter discussed the position on exposure to VCM being taken by other members of the industry as discussed at a recent SPI meeting. Dow proposes a 10 ppm TWA/25 ppm Ceiling (C) value. Goodrich proposes the following schedule: 15 TWA/30 C by Oct. 5, 1974 10 TOA/20 C by April 5, 1976 5 TWA/10 C by Oct. 5, 1977 The SPI is apparently going to propose a 1000 ppm-hr concept, a concept that Conoco decided it cannot support. Data from Aberdeen was reviewed by E. M. Smith. These results and our analytical procedures were discussed at length. It was decided that without accurate, VCM specific data, we could not confidently estimate what VCM levels our plants could realize in the immediate future. We expect to get this type of information when the Honeywell gas chromatographic analyzers are operational, but this is not expected prior to August. Consequently, the following position was decided upon: Compliance with a "no detectable limit" exposure requirement will force a shutdown of the U.S. VCM and PVC industries, including Conocors facilities. Exposure limits of 25 ppm TWA and 40 ppm C are feasible. Conoco will continue to strive to reduce exposure below these levels and expects to be successful in our VCM plant and in our large reactor areas by October, 1974. It is estimated that exposure limits of 15 ppm TWA can be reached in all our facilities by October, 1975. Available technology will not allow confident commitment to operation at VCM levels below these values at present time. This position was incorporated into our formal objection list by R. W. Gerwig. The objections to the PPS formulated in Aberdeen were discussed and modified as appropriate. The results of this portion of the meeting have already been incorporated into revised objections and transmitted as required in action step No. 6. They will not, therefore, be discussed herein. Other items discussed during the meeting are summarized in the action steps listed above. VVC 000002522 L. N. Vernon June 3, 1974 Page 3 (/ /' Dave Porche Research Chemical Engineer Engineering Research Chemicals Research Division cdp cc: Attendees RTF RDG VVC 000002523