Document 7MvdeyQQmOLG3N2v3RzE9pN1V

s/S) Interoffice Communication To From D. A. Kuhn - Houston W. V. Henry Date December 2, 1975 Subject O.S.H.A. Visit - VCM Regulations On November 10, 1975 at 9:30 AM Glen R. Brown of the U. S. Department of Labor Health Administration) arrived at the plant in regard to our re ported emergency VCM condition on November 7, 1975. After show ing proper identification they held an interview with the Plant Manager and myself for approximately one hour. They stated they were here mainly to investigate the release of VCM but would also like to look over our plant in general. The compliance officers asked questions in regard to the details involved in the massive release of VCM. They then requested to look at our records. These records included: daily personnel rosters for regulated areas, VCM monitoring, physicals, compliance manuals and also our general in- dustrv records i( , The compliance officers also stated they would like to talk to the union stewards. They interviewed James Couch (maintenance) and Rodney Little (operations). After this they requested to talk with James Sherwin (V-40 operator) and Larry Underhill (shift supervisor) who were on shift at the time of the release. Both of these em ployees were unavailable at the time. The officers stated they would contact these individuals later to discuss the incident. To my knowledge it was never done. After viewing our VCM Health Training slide show they took a brief tour of the plant. They looked at such items as our fixed point monitor, respirators, and J & W gas detectors. At the exit interview, they requested a written report of the emer gency incident (see attached). They commented that they were im pressed with our program and stated that as far as they were con cerned there would be no citation issued, but that the O.S.H.A. Area Coordinator has the final word on whether a company receives a cita tion. Both compliance officers were Industrial Hygenist and seemed to have a limited knowledge of a PVC plant. They mainly were concerned with complying with the OSHA regulations on VCM. In fact, during the inspection one of the officers constantly referred to a copy of the standard and followed it thru paragraph by paragraph in essen tially all aspects except they took no gas samples for VCM measure ment. W. V. Henry Safety Director bm achment VVC 000020589 Conoco Chemicals Continental,Oil Company P.O. Box 15360 Oklahoma City, Oklahoma 73115 (405) 672-4551 November 17, 1975 Mr. L. A. Warren, Area Director S- Department of Labor - OSHA Suite 408 - Penn Place Northwest 50th & Pennsylvania Oklahoma City, Oklahoma 73118 Dear Mr. Warren, This is the additional information you requested in regard to the emergency condition'at the Conoco Chemicals Oklahoma PVC Plant on November 7, 1975. Synopsis At approximately 1000 hours on 11-7-75, a seal ruptured on a VCM com pressor in the V-4Q building. The V-40 operator was the only parson in the building at the time the rupture occurred. Ills first reaction was to notify the panel operator who immediately blocked in the sys tem. Ilis next action was to manually close the valve on the discharge side of the compressor. This was done on his way out of the building. Only a few seconds after the rupture, the audible alarm on the J & W gas detection system sounded, followed shortly thereafter by the de luge' of water. (The audible alarm is triggered at 20% LFI, and the deluge activates at 40% LEL.) It is a standard procedure for everyone in the V-40 area to evacuate on the sound of the audible alarm. The area was monitored approximately 5 minutes after the rupture. Levels of 100 - 110 pom were present by the exhaust fans on the west side of the V-40 building. It took approximately 15 - 20 minutes for the leak to subside. \\1hen the J & W gas detectors indicated 0%, the inside of the V-40 building was monitored. Levels of 25 - 50 ppm ware evident within 5' of the ruptured seal. No one was alloV7ed to enter the building without fresh air masks. The seal was repaired by approxi mately 1400. Employee Exposure Only the V-40 operator was exposed to the vapors without respiratory protection. His estimated time of exposure was 10 *- 15 seconds. vve 000020590 November 17, 1975 U. S. Department of Labor - OSHA Page 2 Medical Surveillance Because of the operators short time of exposure and the absence of physical effects combined with his routine blood tests twice a year and physical examination once a year, our Medical Division reconsrended that no specific iredical attention was needed. Cause of Rupture The high Level Indicator was inoperable on the VCM receiver tank. Liquid VCM overflowed into the recovery compressor causing the seal to rupthre. Preventative Measures :-> Another VCM receiver tank was put in service after the rupture. The broken High 'Level Indicator will be repaired as soon as the receiver tank is emptied and cleared. The High Level Indicators will be in cluded in the plants preventative maintenance program. VVC 000020591 Uniroyal to Close Plant In Painesville, Ohio, Due to jPVC Standards By a Wall Stuxt Journal Staff fteyoMer NEW YORK--Uniroyai Inc. said it in tends to close its only polyvinyl-chloridemanufacturing plant, at Painesville, Ohio, and quit making PVC. The company said it couldn't economi cally satisfy stringent government regula tions that limit worker exposure to vinyl chloride, the gas from which PVC plastic is made. Uniroyal would become the first com pany to close a PVC resin facility because of standards put Into effect last April. Those standards limit worker exposure to vinyl chloride to one part per million parts of the air they breath, one-fiftieth of the level al lowed before vinyl chloride was linked with a rare liver cancer in PVC workers. In addition to the standards of the Labor Department's Occupational Safety and Health Administration, Uniroyal also cited proposals of the Environmental Protection Agency, to limit plant emissions of vinyl chloride into the environment, as a reason for its "tentative" decision to close the painesville plant. A spokesman said the decision was termed tentative "to give a chance to ex plore all possible alternatives with the un ion." If the plant Is closed, Uniroyal said, about 230 employes would be laid off. The 29-year-oid Painesville facility is one of the nation's oldest PVC-manufacturing plants. When the OSHA standards were pro posed last year it was assumed that some of the oldest PVC plants would have to close because of inability to meet the restrictions. But other companies with older plants have been able to effect engineering changes to enable them to meet the OSHA regulations. Uniroyal isn't a major factor in the PVC market. Industry sources said the Painesvilie plant has a capacity of about 120 mil lion pounds of resin annually, or about 2.2 of total U.S. capacity. Uniroyal said that its plans to stop PVC production won't affect synthetic-rubber op erations at Painesville, or the production of Naugahyde vinyl-coated fabrics in four other company plants. A spokesman said vi nyl would be purchased from other compa nies. The company' said it also would con tinue to make vinyl chloride gas at a facility Jointly owned with Borden Inc. at Geismar, Lft' VVC 000020592 VVC 000020593 j THE WALL STREET JOURNAL, iq I Friday, Oct. 10, 1975 Vinyl Chloride Curbs Are Stiffened in Britain Under Voluntary Plan 8j*rp<ai to Tilt Wall Street journal LONDON -- A British industrial health and safety group announced guidelines that tighten vinyl chloride vapor limits at six plastics-making factories owned by major British concerns. The guidelines are voluntary but were ar rived at in coordination with the plastics in dustry. The companies covered are units of Imperial Chemical industries, Ltd.. British Petroleum Co., VUa-Tex Ltd. and Turner A Newall Ltd, They account for the bulk of plastics production in Britain. Under the new guidelines, an average of 10 parts of vinyl chloride gas per million parts of air will be allowed over an eighthour work period, compared with 25 parts per million previously. Also, the new ceiling tor any one time is 30 parts per million, compared with 50 parts previously. The health and safety group that prod uced the code comprises representatives from various government agencies and em ploye and union representatives. Polyvinyl chloride plastic is made from vinyl chloride monomer, a gas that has been linked to a rare liver cancer. In the U.S., worker exposure is limited to one part vinyl chloride per million parts of air. and no more than 15 parts per million averaged over a 15-minute period.