Document 9pVyqjno0k3nrJBvXGY3kzKL

jnC3F'dr;-" Niagara Fal_s, N. Y. INDUSTRIAL CHEMICALS DC'1 AFT M ENT p>-^3C --.CH cZ jSV'Si-j?>vCKT D?V;S)ON waynes WBElakey, FI :-R `Waynes FZBowers, FI R Cam-den At- vl JCeoghegan, FI BY C ?. w u JMLoether-DL iettle .?. WGerla.cn F.FRichards C-o(oo / TRTurnbuli v :j alar a FFMcRar land Ml a a on IDMa cAdam .NIL every October 21, 1974 TO F . L . .-.DAM Ziir.ployee Relations Wilmington Central Research Haskel 1 Wilmington FROM : 5EZ3E VC1 STANDARD EFFECTIVE 1/2/7 5 The A-20C grout has carefully reviewed the new VC1 Standard. This review -was supplemented with' information gained from a recent ORC meeting with OSSA officials in Washington (L. D. MacAdain will issue trip report) . Objectives of our reviews were to.: 1) develop a basic understanding of the standard, 2) specify what we believe is intended by the standard, and 3) define actions needed no comply. You are asked no critically review our summary of the standard and action elements for adequacy (attached) . Recognizing that this is only the first step, I propose than we hold a meeting at Niagara in November to finalize our plans for complying with the standard and to reach agreement on the key assumptions. Any comments' or assistance you can provide refers then -would be helpful. Attach RECEIVED OCT 3 3 or HASKELL LABORATORY EID10765 E iw ; kj ~ -r.a erttre i r./iMft r- s* -- w' ]v 7 .mo s oo G rr. oe or. tiooous 0rjoOC 3 >ARA' ACL I Develop proposal for monitoring program GABAFA/MacADAM/?- and gam agrearner.t vitri S F and ri.ask.ell. 4 Monitor Building 411 laboratory to determine GABAPA .VCl exposure level and decide whether this needs to be designated as a regulated area. 5 . Define respiratory equipment meeting the standards specified. Based on information on concentration limits, and service life, designate the renewal program. Formalise procedures for operating manual. LAVERY 6. Identify operations and conditions that constitute a "hazardous operation" and develop procedures to implement, e.g. isolation and identification of contaminated area. MacADAM 7. Provide a written emergency clan to cover "Emergencies" and "hazardous operations" . MacADAM 8 . Establish format for specifying regulated areamonitoring records, authorized personnel roster, and notification of personnel in event of VCl exposure. Gain necessary approvals. MacADAM 9. Compile list of authorized persons and determine procedure for temporary authorization to enter Pilot Plant.' MacADAM I EID10766 12. Document work background on all A-20C' LAvxkY (10/15 - 10/18) (3) (b) DEFINITIONS (1) (2) (3) (4) (5) (6) (7) Question: is pecked fiber considered co be the rubricated i--* Hone Hone None None None Emergency is loosely defined as a massive release of VC1. vfe internret this to mean those situations such as a rupture of storage and feed vessels,' where large amounts of VCl can be lost. This part of the Standard appears to allow interpretation, i. e. performance versus specification language. See comment (a-2) above. Note stipulation on further processing at temperatures 'which could result in-release of VC1. Can we guarantee that no VCi is released during Turbo processing cr fabric drying? Filet Plant operations and conditions that constitute a "hazardous operatic will be specifically icencufied to permit appropriate action by operations. - Hazardous operations will include routine procedures such as reactor dismantlement as 'well as any unusual situation that leads to atmospheric concentrations above the EID10767 PZ-. V_EW Q 9 (10) None (c) PERMIS EXPOSURE. LIMIT Lone (a ) M Oil I TOei. iv 3 Twice daily atmospheric analysis via MSA tubes and gas chromatography has been a continuing program in the Pilot Plant since startup in February, 1974. However, our current methods for analyzing VC1 are not sufficiently accurate to monitor at the "action level" of 0.5 ppm or even an the "permissible- exposure limit" of 1 ppm. An acceptable method (discussed below) will be very expensive to implement if used -as often as is our current practice. We will develop a proposal for monitoring the Pilot Plant by next month. It is essential that all parties be in agreement with, this proposal before year-end. (1) This will be done for both the Pilot Plant and Building 411 Technical Laboratory. (2) We will establish a program for determining exposures for each employee in the Pilot Plano. Our intention is to show that this program will not be required in the Technical Laboratory. (i) The 'Government requires at' least monthly monitoring where any employee is exposed in excess of 1- ppm. In cases of fabricators where 7C1 level will likely be < 0.5 ppm or PVC manufacturers where VC1 level will likely exceed 1 ppm on a routine basis, once/month monitoring probably serves the Government purposes. EID10768 1A w (M (a) (ii) (iii) (3) (4) c ed) M>-/r`r'lvrT1S -1 V -V` Tic. iTi wl V'' m me o establishing a monitoring program which will msec, our goals. hone None We assume this includes those circumstances involving "hazardous operation". It has been our practice to require proper protective equipment until we can confirm negligible VCl in the atmosphere. The only change we will make in current procedures is to use a more accurate mevhod of measuring VCl. At this time we do not have the capability o measuring VCl in air a t th e a c c ur .cy cf - 5 0% f r om 0.25 through 0.5 ;pm required by the Standard. f ;e Mira n I?. analyzer can measure down po 0.7 ppm but our experience v .th ahe portable unit has been the ; an as subject to electrical n use at lev; rantes in our area. Our intent is to use the continuous analyzer to monitor proces equipment at some pre-set higher levs to alert operations to potential hazards which could result in buildup of VCl. It is improbable, that these readings could ever be correlated with the very low "action levels" of 0.r> ppm. r7vv 0u-. the OtC n ee ting we o of CL 0 ned a copy of cLU 0X1-0 J_Y~ 0 C al method f or ITl6c. surang VCl O M =' 7 3),. method: 1) air is drawn through a desorbed in CS-., 3) desorbed sample /-- is injected in gas chromauograph and EID10769 r-: w "INC M' (4 1 (5) (e ) REGULATED APIA (1) (2) V _i\! COMMENT ail toe equipment: teecea to carry out the analysis. Roue that this method is extremely time consuming end additional analytical resources may be required. This method was issued on S/3/74 and yet precision is designated as unknown. we assume that the Government will issue revisions before the compliance date.- None The Pilot Plant facili designated as a reguls The decision uo classi Laboratory as a reguls pending the results of monitoring programs.. y will be ed area. y 31d g 411 ed area is current A list of those persons authorized to' enter the A-2 0C Pilot Plant area "will be compiled and formalised in writing. The list will be posted in the area and only those persons listed will be permitted to enter the Pilot Plant without escort. Authorised personnel "will sign a daily roster upon entering the area. Persons not included on the "authorised person" list must 1) receive permission to enter, 2) be escorted by an auuhorised person, and 3) sign the daily.roster. EID10770 i~- z nx_y'J-. O' : ok? 11an: COMMENTS (c) RESPIRATC :d V POCP, (2) (3) September period was < 1 ppm VCl. we wgIIL gs"t.62TiT.i-riS v:i}'hr Curr^r.t sndLnssGiLr controls end work practices coupled vith installation cf the continuous analyzer and improved ventilation, by year end will permit consistent operation at exposure levels below the permissible limit. If this turns out to be the case, then we will not be required to formalize plans for future programs to reduce VCl level. Respiratory protection requirements are clearly stated. What is lacking is a statement of the specific respirators which meet these requirements. This was pointed out in the ORC meeting and the OSHA officials replied that acceptable air purifying respirators would be designated by the compliance date. It remains to be seen whether these respirators will be available in time. We do not agree than the use of respirators at VCl exposures of < 25 ppm curing 1975 should be left ro the discretion of the employee. N one Respiratory protection must remain in use until'monitoring shows personnel exposure to be below the permissible limit. Protection is recruited only in those areas which contain VCl concentrations above hi permissible limit. These areas mu: be identified as contaminated area: requiring resciratorv crorsction. intention is to limit respiratory protection to only two types: 1) . Lisl. tCeir aaJ"n. d 2) air-supplied from the approve: s . vc. g r.g mcr EID10771 NIAGAFA .jW J- r;s_. SUBHEADIN 3 (g ) ?.E?I?ATO?.Y FRC'TEITIONS gommznts rnued) !, 3 I than two tvoes would increase diff z cuItv cf ensuring chat operators o om.ply with the r Procedures spelling out vhe c"ot ec tion rs required and respiratory is recurred vil f ormarized. We request than S S F provide a copy of 1910.134 for our use. (4) None (5) None (6) An inventory system will be employed to insure that ell respiratory equipment is within the allowable service life. ' Our continuous analyze: will be alarmed to alert personnel of VC1 concentrations in excess of allowable limit for canister type respirator. (7) (h) HAZARDOUS OFF FA? ZONE None We currently require use of protective garments/respiratory protection under conditions of possible exposure to VCi. (i) EMERGENCY SITUATIONS (j) ? PAINING An operational plan for handling emergency situations is currently being developed. The scope of this plan will be expanded to encompass procedural action required for all "hazardous operations", including those developed in Sections (g) and (h) of phis Standard. The current training program in the Pilot Plant includes: o Operating procedures are detailed and operators are given extensive training. e Protective equipment including self concerned breathing apparatus is provided and operators have' been instructed in their use by the plant Safery Group. EID10772 COMMENTS e Doe = rA / I'M . (k) MEDICAL SUEVZILLANC (1) SIGNS AND LABELS (1) (2) (4 (5) (M monitoring program.. The existing program will be reviewed end undated to comely with this section of phe Standard. The complete program will be documented and reviewed with operators by /ear end. Vfe have initiated a medical program for A-20C personnel and physcial examinations meeting this standard were completed to establish a base line healzh profile. The Niagara Plant physician reviewed the examination results with individuals upon request; no problems related to VC1 toxicit w?ere uncovered. The next annual examination, is scheduled for April,`1975. All entrances to the Pilot Plant facility will be identified with the specified sign. Procedures.detailing proper isolation/ identification of areas containing "hazardous operations" will be formalized and posted. All drums/containers containing waste contaminated with VC1 will be labelled as specified. A list of A-20C wastes meeting this classification will be compiled and posted. we wj.ll review with S a F the need to label container of A-20C filter cake and dried polymer which have been analyzed as being free ox /Ci monomer. All cylinders cf VC1 and our VCl tank None EID10773 o V ~ivnv'*^\Tr V rrlcl l. j. or ci miospner x o moniic-rinc ^ m- i end authorized personnel records V". selected and reviewed wiih 3 & F .re compliance with the Standard. ( W ion recrair ed In :C 6 17c vil, We vrj i i lev e 1 ct> s assistance Nl and Level ( We will comply with all aspects of the Standard by 1/1/75. EID10774 10/21/74