Document 8VEnnx0BQMo6RokE1a7zr56qZ

2^cd&$tcducZ& iA INTEROFFICE MEMORANDUM l l/J Date 16 DECEMBER 1975 Subject OSEft COMPLIANCE AFTER APRIL 1. 1976 To G B. H. SPEED/E, A. PRIM5AU _ __________CALVERT. CITY/PENSACOLA (Location, Organization, or Dapartmant) From J- T. BARR _________________________________________ VATXEY FARCE (Location, Organisation, or Oapartmant) cc: J, E. Greasel -It. Ei iTuifga J. D. Kramer A. K. McMillan G. F, Tillsaa H. L. Watson Mr. Carey would like to have the operating procedures that will be changed for OSHA compliance on April 1, 1976 revised in time that the operators have asple training before the changeover date. Please advise me when you will have these revised procedures available. /mjv R E P ^r Z 3 DtC a ^ 1975 R. E. HONES (320) AP00043082 INTEROFFICE MEMORANDUM To T. L. CAREY From J. T. BARR Date 25 NOVEMBER. 1975 Subject COMPLIANCE WITH OSHA VINYL CHISRIDE STANDARD AFTER APRIL 1976 VALLPf FORGE (location, organization, or oapartmant) VAT.T.EY FORGE cc: R. I. Jouufc J. D. Kramer A. K. McMillan E. A. Prlmeau 6. B. H. Speed E. J. Stock G. F. Tillson H. L. Watson RECEIVED DEC 1 1975 R. E. JONES I have reviewed with the PVC plant superintendents their plans for operation under the second phase of the OSHA standard for vinyl chloride. It is their opinion that they will find it necessary to require masks to be worn most, if not all, of the time after April 1, 1976. Area monitoring results are averaging between one and 2.5 ppn on a monthly basis. Daily averages for individual points show a wider Tange. Personal monitoring on an 8-hour TWA basis, without regard to respirators are running 60-804 below 1 ppm, with almost all below 5 ppm. Again, the shorter period results from 15-minute tests show higher figures. In view of the number of excursions recorded, and the known probability of short, high-concentration exposures before a monitoring system can recognize leaks, the superintendents believe that only the wearing of masks will give adequate assurance of compliance. Several projects remain to be completed that will provide some improvement, but probably not enough. At Pace these include the expansion of the leak patrol system to give more frequent patrols, and further training and cross-training of the newer operators. That plant has just completed the installation of a wastewater collection system, and increased the elevation of the reactor relief piping. The expanded plant at Pace will contain many additional safeguards, but it is not scheduled for completion until the end of the year. Calvert City is moving the monomer recovery system outside the building; this will be of great help, but this will not be in operation until September. That plant also is in the process of installing additional point source ventilation at the 19th reactor, increasing the elevation o the blend tank vent stack, improving the vent condenser portion of the recovery system, and installing relief valves after the rupture disks on the charge pots. High temperature alarms on all of the reactors are in the engineering phase. Che area of concern is the excursions seen in the PVCH and emulsion plants due to releases in the PVC operation at Calvert City. Efforts are underway to (320) AP00043083 -T. L. CAREY 25 NOVEMBER 1975 PAGE n SUBJECT: COMPLIANCE WITH OSHA VINYL CHLORIDE STANDARD AFTER APRIL 1976 reduce these upsets by improving equipment and instruments, and by operator train ing, but we need further improvement here before April. The men in these plants are supplied with masks, and the area alarms will be set at 5 ppm in April. AP00043084 12:22:75 j NEWS quire an approach "that is adapted to the political and economic situation in which we find ourselves and other countries that seek linear tariff cuts. But circumstances are chang ing. The Europeans are less in sistent on a harmonization ap proach; and the U. S. is taking a softer line on linear cuts. (Harmonization involves trim ming a number of tariffs by varying amounts to achieve a relatively lower level; linear re ductions mean an across-theboard slash of a fixed per centage). Furthermore, U. $. industry is telling Mr. Dent and the other U. S. negotiators that it is more concerned about nontariff bar riers (NTB) to trade than the tariff items. Business Is asking the bargainers to look at the quality of the tariff cuts--as well as the quantity---with an eye toward making tradeoffs against the more onerous NTBs. Trade points -- Among the other elements of the U. 5. pro gram: a "framework" for ra tionalizing export subsidies and countervailing duties; a draft statement on health, safety, and other standards which can block trade; a means for liberalizing import quotas: and a set of principles for a "safeguard" that will let countries temporarily moderate imports when tradi tional markets are upset. "There is a considerable amount of joint analytical work to be done, and a considerable effort to be made to develop a common understanding of mu tual problems and opportunities related to trade," Mr. Dent re minded his colleagues. "The fact that our economies have not fully recovered cannot excuse us from completing this work, although we fully recog nize the need for an approach to our work that is adapted to the political and economic situa tion in which we find our selves," he added. Significantly, that comment was the closest the former Com merce Secretary got to a major concern of several of 'the par ticipating nations: the 1976 U. S. Presidential election. An impression has persisted since the preliminary GATT talks last spring that the Jap anese and the Europeans would not bargain seriously until after November 1976--when It be comes clear whether President Ford and his trade strategy will still be around in 1977. Relax rules--Another Ford Administration official. Treasury Secretary William E. Simon, wants action on another trade front. He has asked Congress to reconsider U. S. restrictions on export credits and nondiscriminatory tariffs for the USSR. The Administration request comes at a politically sensitive time. Unrest over detente with Mos cow is growing in the U. S., and President Ford's challenger for the GOP Presidential nomina tion, former California governor Ronald Reagan, has taken a hard anti-detente line. The trade controls were im Industry Wsek / December 22, 1075 posed in the hope they would encourage Russia, and other East European nations, to ease emigration policies -- primarily for Jews seeking to go to Israel. That has not happened, most analysts of the USSR say. But beyond the emigration matter, Mr. Simon indicated, the curbs have cost U. S. companies a considerable number of con tracts. Just how many dollars worth have been lost to foreign firms the Treasury Dept, is now trying to calculate. Mr. Simon reported to Congress earlier this month that the Russians put the figure at $1.6 billion for the last nine months. The Administration is making a low-key approach to Congress --not sending it draft legisla tion, but offering to work with the lawmakers on a measure to modify the current restrictions. Many legislators are reported ready to rethink the matter and to look for a formula that will open up commerce without making them also appear to be anti-human rights. Timing will be critical for the White House. Agreement early next year on language liberaliz ing the curbs would not be politically harmful over the longer run. But, as even the most ardent backers of change concede, having the issue drag on until the summer conventions and then into the fail campaign could be serious. Steel tries to `sell' price, capacity views WAS IT an exercise in futility? That's the question steel in dustry executives may well be asking themselves in the wake of an unusual symposium on the industry's problems held by the Council on Wage & Price Sta bility (CWPS) last week in Washington. At stake is the industry's abili ty to finance the capacity ex- AP00043085 NEWS 12:22:75 pansion steelmakers say is nec essary to meet future demand. The council, in the minds of stee! company executives, al ready has thrown one roadblock in the path of those expansion plans. Whether the Industry's side of the story as expressed at the symposium will change conclusions about the industry already reached by the council, and thus prevent similar road blocks in the future, is open to question. The "roadblock" came In the form of a "Study of Steel Prices" which CWPS issued in July. It criticized steel price increases announced for Oct. 1 as unjusti fied in a depressed market, and contradicted most of the claims baste steel has been making on the need for and the cost of capacity expansion. George C. Eads, CWPS as sistant director and acting chief of the agency when the study was prepared, went so far as to say that "domestic firms can't be allowed to take advantage of their market power to raise prices during periods of weak demand" and then expect the government to protect them from foreign competition. To the steelmakers, that was a clear danger signal that they would have a difficult time achieving the price increases and profit boosts they contend will be required to install 30 million tons of new raw steel capacity by 1983 at a cost of $2.4 billion a year. The conclusions of the coun cil's study were: profits, cash flow, and access to capital mar kets are adequate to finance the needed expansion; the expansion requirement over the next five years is only 15 million tons; and the cost of adding that capacity by "round out" will average only $900 million per year. \ It is those conclusions, and I their supporting arguments; that I' steel industry executives at[ tempted to counter during the RECEIVED DEC 29J975 one-day Errors--Steel company repre sentatives pretty much restated the objections to the council's study that they had made previ ously: its 15 million ton esti mate is based on a "simplistic" method of extrapolating the long-term trend of raw steel out put: it makes no provision for replacement capacity or pollu tion abatement spending; it makes an error in arithmetic in pegging the industry's cash flow in 1973-74 at a $3.4 billion aver age, rather than the actual $2.8 billion. By contrast, Frederick G. Jaicks, chairman of both Inland Steel Co. and the American Iron & Steel Institute (AISI), characterized the AISI's own capacity expansion needs study as detailed, exhaustive, and spe cific. Mr. Jaicks says the AISI's in dustry capacity figure for 1976 is 158 million to 159 million tons. He notes that if domestic mills had not shipped 8 million tons from inventory in 19731974 the industry's raw steel ca pacity then of 155 million tons would not have been enough to produce the 111.4 million tons delivered in 1973 and the 109.5 million shipped in 1974. George A. Stinson, chairman, National Steel Carp., asserts: "Industry is not saying you must give us money to expand. We're not asking for an expan sion surcharge. But if We're not permitted by reason of govern ment policy to realize profit lev els close to the average of Amer ican manufacturing, then we'll have a difficult time competing in the capital market for expan sion funds.'4 The value of the symposium, in Mr. Stinson's view, was to enable the council and others to assess "whether we're talking through our hats." He adds: "It is beyond their competence to tell us . . . how we should expand." Some 23 million tons of new capacity has been announced in the last year for installation by 1980. Some two-thirds of that will be through rounding out of existing facilities. Some of those projects already have been subject to "stretch out" by steel firms and, executives say, the remaining one-third Is subject to nearly daily review as to their feasibility at current profit margins. uPVC makers expect I to meet OSHA rules IN THE TWO YEARS Since vinyl chloride was found to be a cause of liver cancer in work ers, substantial progress has been made in reducing employee exposure to the chemical. Next April, final Occupational Safety & Health Administration (OSHA) rules limiting average individual worker exposure to 1 part per million (ppm) of vinyl chloride take effect. Since April 1, 1975, workers have not had to wear respirators to limit their exposure -- if the vinyl chloride in a plant's air was kept below 25 ppm. By April 1976, however, respirators or other means must be used to meet the 1 ppm level. It now looks as though poly vinyl chloride (PVC) makers will be able to meet those rules. (PVC is made from vinyl chlo ride monomer, and is In turn used to make a wide variety of products.) The main PVC producer, B. F. Goodrich Co., with 20% of the U. S. output, will end up spend ing some $42 million to protect workers In its five PVC plants. Containment programs arc keep ing average levels of vinyl chlo ride at its plants between 1 ppm and 3 ppm in work-area air. Goodrich points out that these are average levels, and that in dividual employee exposure is considerably lower. i December 22, 1975 / Industry Week AP00043086 NEWS Supreme Court shuns air standate-appeaK. Even though.workplace concentra tions of vinyl chloride have been cut sharply, respirators may be needed some of the time. Two technical developments are helping the company to reach those levels. One Is a scrubbing process that produces PVC resin with such low levels of residual vinyl chloride that firms making end products from the resin probably will not have to take special steps to protect their workers from excessive exposure. The other tackles a knotty problem in making PVC itself. Reactor vessels used to make PVC had to be cleaned frequent ly. a job resulting in high ex posure levels for workers. Good rich is now using a coating on the reactor walls that reduces both the frequency of cleaning required and the amount of un reacted vinyl chloride gas re maining in the vessel. Other producers have also ef fected solutions. Tenneco Chemicais, Saddle Brook, N. J., re vealed earlier this year that it had developed a technology that removes over 98% of the resid ual vinyl chloride in PVC res ins. And Robintech Inc., Fort Worth, claims it can meet ail federal regulations with an oxyphotolysis process that keeps vinyl chloride in plant air be`llow J pthe 1 ppm level. Inuustbv Wick / December 22, 197 INDJJfffllY's campaign forj gvdater consideration of tne eco-^ momic aspects of antipollution requirements was^galt q-blow -warllar this ingntfiby the U. S. Supreme Court. The high court refused to re view a lower court ruling which upheld the Environmental Pro tection Agency's (EPA) actions in setting air emission standards for new cement plants. A pivotal question in the case --which prompted a brief by the National Assn, of Manufacturers (NAM) -- was whether EPA must conduct cost-benefit anal yses in promulgating stand ards for new plants. In essence, the District of Columbia Circuit Court of Appeals had endorsed EPA's contention that such anal yses aren't required or justified.* In its brief, NAM noted that the issue is of '`great concern" to many industries subject to federal New Source Perform ance Standards. It argued that the Clean Air Act provisions dealing with new sources do re quire cost-benefit studies. The district court ruling, NAM said, allows the EPA administra tor to "ignore or reject all evi dence relating to cost versus benefit" and to "predicate emis sion standards essentially on en vironmental considerations, as long as the involved industries are able to `bear the costs and survive.' " The Portland Cement Assn., which Initiated the suit against EPA, argued that the cost of meeting the standards was grossly disproportionate to the environmental benefits. An as sociation analysis indicated that the EPA regulations would Im pose a 20% cost increase to achieve an emissions reduction of 1/10 of 1%. "The circuit court very cava lierly brushes the economic is sue aside," contends Daniel W. If cutting costs in cleaning is your problem... Oakite helps you do Itl WeVe never met a plant manager who didn't want to reduce coals while maintaining quality. That'e why we've spent 65 years working out efficient and economical industrial cleaning methods to aid in coat control. We help establish regular titration procedures to maintain and control solution strengths. We help see that solutions aren't dumped until the end of their effective life has been reached, and supply buttered detergents to re sist contamination, We supply special compounds for equipment mainte nance, conveyor lubrloatlon and the like. Just as Important, we've developed cleaners and surface treatment prod ucts that work without heat, or at low temperatures, permitting economical cost reductions. Oakite service means individualized advice on the economies of industrial cleaning. has the 9 solution OAKiTE PRODUCTS, INC.. BERKELEY HEIGHTS, N. J. 07922 11 AP00043087 * AP00043088