Document DDDBMGB45yKgQ5B2mQabRY12a

INDUSTRIAL HYGIENE SURVEY: 1. VCM Program Audit 2. Noise Evaluation 3. Respirator Fit Testing Conducted At: Illiopolis PVC Facility Thermoplastics Division Illiopolis, IL February 1, 1982 By: M. Gruenwald R. Hackman Corporate Industrial Health Borden Inc. 990 Kingsraill Parkway Columbus, OH 43229 BOR 00S376 SUMMARY On January 19, 20, 21, 1982, the Illiopolis PVC facility was visited for the ollowing purposes: a. To conduct an audit of the VCM Compliance Program b. To evaluate employee noise exposures c. To perform quantitative respirator fit testing on the PVC Paste Bagging Operators. A summary of this survey is as follows: . vrM COMPLIANCE PROGRAM AUDIT: An audit of the VCM Monitoring and Control Program at the Illiopolis PVC manfacturing facility was conducted by the Industrial Health Department to evaluate arious program elements directed at worker protection practices and controls, he major program elements evaluated included leak detection and prevention proedures and controls, respiratory protection, employee training and personnel montoring. The evaluation was conducted by discussing program objectives and accomlishments to date with plant personnel, by reviewing various procedures, monitorng data and records, and by observing the response of plant personnel to the pro ram requirements. The results of our audit indicate that the VCM Monitoring and Control Program s functioning in a properly organized and professional manner to reduce the emloyee exposure potential to the vinyl chloride monomer. It is apparent that the pproach taken by the plant to implement the complex requirements of the program as been effective. Continued emphasis on employee job awareness and education hould further contribute to the success of the VCM Program. II. NOISE DETERMINATION The results of the sound level survey conducted at the Illiopolis PVC facility can be found in Section II of this report (page 1&2) and indicate most production and related areas (except Polyco, Resinite, and the Chemical Prepar ation Building) in the 85-90 dBA range. Plant locations/operations with noise levels in this category would be affected by the new OSHA hearing conservation amendment necessitating the follow ing actions: 1. Hearing protection must be provided to all affected employees (the actual use of the hearing protection becomes mandatory with noise exposures above 90 dBA). 2. Annual audiometric testing must be provided to affected employees. 3. Noise exposed employees must be trained in the proper use of the hearing protection, and on the contents of the OSHA hearing conservation amendment. BOR 005377 In addition to those areas found to be between 85 and 90 dBA, seven specific jlant locations were identified as having noise levexs significantly above the current OSHA 8 hour limit of 90 dBA: 1. Reactor building, first floor - PVC I, II 2. Vibrator on centrifuge chute to PVC I dryers 3. Paste department grinders 4. Blow-down area - PVC I 5. Chemical storage area, first floor - PVC II 6. Outside fans for paste dryers 7. Utility building Employees working in these locations must be required to wear hearing protection and signs must be posted at the doors to each area, indicating that hearing protect ion needs to be worn. II. QUANTITATIVE RESPIRATOR FIT-TESTING Quantitative respirator fit-testing was performed on Paste Department Bagger nployees to determine the overall respirator effectiveness of the 3M dust masks arn by these Individuals. The results of this testing can be found in Section III f this report and indicate that all workers tested had total respirator efficiencies f 70-100%. These efficiencies would likely provide adequate protection against he PVC dust exposure excursions realized during the normal work shift, The results f this testing also show the adverse effect of beards and other prominent facial air on negative pressure respirator fit. BOR 005378 TABLE OF CONTENTS SECTION I: VCM COMPLIANCE PROGRAM AUDIT A. Introduction B. Leak Detection & Prevention C. Respiratory Protection D. Training E. Personnel Monitoring F. Compliance Program G. Recordkeeping H. Breathable Air Analysis I. Special Problem Areas SECTION II: DETERMINATION OF NOISE A. Introduction B. Results C. Discussion D. Conclusions & Recommendations E. Appendix A SECTION III: QUANTITATIVE RESPIRATOR FIT-TESTING A. Introduction B. Results & Discussion C. Conclusions PAGE 1 1 2 2 3 3 3 3 4 1 1-2 2-3 3 4 __ 1 _ 2_ 2 BOR 005379 VCM COMPLIANCE PROGRAM AUDIT Conducted At: Illiopolis PVC Facility Thermoplastics Division Illiopolis, Illinois February 1, 1982 BY: Corporate Industrial Health Dept. Columbus, OH 43229 BOR 005380 Page 1 CTION I: VCM COMPLIANCE PROGRAM AUDIT A. INTRODUCTION The Vinyl Chloride Monitoring and Control Program was established at the liopolis PVC manufacturing facility to meet the federal requirements of the vinyl loride standard and, ultimately, to reduce the risk of any adverse health problems sociated with this type of operation. The VCM Program at Illiopolis consists of a unber of program elements associated with worker protection practices and controls, oper worker protection is reflected in appropriate implementation of the above asures, and the following is a summary of our observations and comments concerning !e effectiveness of such practices to date. B. LEAK DETECTION AND PREVENTION The success of the VCM Monitoring and Control Program is greatly dependent i rapid leak detection and proper response to minimize worker exposures. It allows ,e timely containment and/or repair of leaks before large emissions of vinyl chloride velop and it assists in reducing exposure by activating audible and visual alarms dictate the necessary respiratory protection requirements. The basis of the system is a fixed area monitoring network consisting of 39 rategically located air sampling heads linked to three Bendix gas chromatographs, is system is tied to a Hewlett Packard computer so that any level above 1 ppm 11 trigger the warning signals. Once an alarm is activated, a safety technician will use a Century OVA portable tector to determine the exact location of the leak. Immediate containment is complished by local exhaust or other measures. A leak sheet is filled out and rwarded to the proper supervision for appropriate corrective action. From our observations employee exposure potentials to occasional fugitive issions of vinyl chloride monomer are being properly minimized by the complex tection and control system in operation at Illiopolis. The monitoring system is pably directed by a designated monitoring coordinator who oversees a number of ained safety technicians. The safety technicians are responsible for the day day operation of the system. Proper operation is achieved through pre-programmed calibrations that are rrently performed after every 960 counts. Additionally, the system parameters, such cylinder pressures, GC conditions, and sample and purge flowrates/ are recorded fore the beginning of every shift. Regular checks of the alarm system are likewise rformed. All necessary data is properly recorded and maintained for a reasonable ngth of time. Both eight hour and twenty-four hour time-weighted averages (TWA) are computed d distributed for review by supervision. With this approach, production is kept are of the current conditions and can respond accordingly. Another important aspect is the performance of the safety technicians in conibuting to the overall reduction of employee exposure potentials to VCM. During r brief discussions in the monitoring trailer, it was noted that the safety techs monstrated a good understanding and awareness of the current conditions in the ant. Their timely response to the alarms and subsequent detection of the leaks a significant step in minimizing the length of an excursion above 1 ppm. The fety tech faithfully fills out a MVC Leak Sheet for each leak detailing the urce and level of the emission. This information is brought to the immediate tention of the area foreman who acknowledges and initiates corrective action. BOR 0 0 5 3 8 1 Page 2 -Lew of the leak sheet master file, which was very thorough, showed that, for ^h^most part appropriate follow-up and corrective action is being accomplished In a timely manner. Additionally, in order to detect leaks early when they are small and the exre areas are not extensive, the safety techs conduct daily plant monitoring Posu 0 the regulated areas with the portable OVA detectors. Potential emission t0ints on reactors and other equipment are checked and levels are recorded on specific leak check sheets. The extensive data that is collected daily is analyzed and summarized on a recular basis. The emission data is broken down into mechanical errors and operational errors so that both engineering and maintenance control improvements and work practice procedure modifications can be prioritized for subsequent corrective actions. From the summary data we reviewed, priorities that have been established should lead to further reductions in employee exposure potentials. C. RESPIRATORY PROTECTION Since the respiratory protection program is keyed to the monitoring and alarm ystems,several alarm areas in the reactor rooms of PVC I were entered to evaluate compliance with this requirement. For the most part, full compliance was achieved. However, there appeared to be a slight disregard for the requirement by the more transient workers (maintenance) during these specific alarm periods. Additionally, it was noted that several employees had either improperly placed the respirator straps over hardhats or had failed to buckle the bottom strap of the mask. It is probable that the protection afforded by the masks is reduced by these practices. Although these situations are not uncommon in typical workplaces, continued employee education is necessary to minimize these occasional problems. The respiratory issuance, cleaning and maintenance procedures were likewise re viewed for complaince. The set-up appears to be operating effectively. The location of the mask room near the central time clock simplifies the issuance and return of the respirators. An inventory of all respirators issued for a particular shift is faithfully maintained as noted by the 15 masks issued on January 20, 1982 for the first shift. The safety techs responsible for this part of the program displayed a good working knowledge of respirator cleaning and maintenance tech niques. A random Inspection of several respirator bags found facepieces to be properly stored in clean plastic bags and straps and hoses to be in good shape. Therefore, it was apparent that if the respirators are returned to the mask room at the end of a shift, they will be properly inspected and cleaned for the next day. D. TRAINING Annual training of all VCM workers assigned to regulated areas is required by the OSHA vinyl chloride standard. It was learned that this training requirement for 1982 was in the process of being conducted during the month of January. In addition to this required training, the plant has initiated a comprehensive program designed to reduce the number of operational errors that result in emissions above 1 ppm. The training coordinator appears to have a good grasp of what needs to be done as exemplified in the recently completed training tape concerning correct filter change procedures in the vacuum system operation. This particular operation had been a source of emissions in the paste facility until operators were shown this tape. A drastic reduction in the number of excursions above 1 ppm have resulted. The approach of utilizing department supervision and BOR 005382 Page 3 erators in the film has a positive effect on those who view it. Continued Bphasis directed towards specialized training tapes should contribute to emloyee job awareness and.ultimately, to the success of the VCM Program. PERSONNEL MONITORING Since there are designated regulated areas at Illiopolis, all personnel routinely ssignsd to these regulated areas are monitored monthly. This personnel onitoring is being conducted consistently over all three shifts by the safety tests nder the direction of the monitoring coordinator. The method followed utilizes he Bendix Model H/S 10 Flasher unit and Sipin vacuum pump which allows for ccurate sample collection and direct analysis by gas chromotography for vinyl hioride in air. Although the sampling and analytical procedures were not valuated in detail by means of parallel sampling during this audit, consistent >esults continue to be obtained as evidenced in the weekly personnel monitoring eports reviewed regularly by the Industrial Health Department. A more detailed valuation of this program aspect will be conducted at a later date. >. COMPLIANCE PROGRAM A general review of the written compliance program indicates a thorough dosumentation of all aspects of the VCM Monitoring and Control Program. The written ilan has been consistently revised and updated every six months. In order to lemonstrate that the program is dynamic, all modifications and improvements (e.g. urchase of two timers for the fixed area monitoring system in PVC I) should jerhaps be logged and briefly described in the written program. This could pro vide a mechanism for easier review of the program as it changes over time. J. RECORDKEEPING Although no in-depth analysis of the recordkeeping system was conducted during this audit, some area monitoring data and leak sheets were reviewed. A consistent and thorough logging of information was noted. Other required records, such as Eor personnel monitoring, medical surveillance and training, are likewise believed to be maintained in a consistent and orderly manner. 3. BREATHABLE AIR ANALYSIS OSHA requires that breathing air shall meet at least the requirements of the specifications for Grade D breathing air as described in the Compressed Gas Association Commodity Specification G-7.1-1966. The constituents in the air for which concentrations must not exceed a specified maximum include percent oxygen, hydrocarbons, carbon monoxide, carbon dioxide and odor. Since breathing air is an important commodity for worker protection under the VCM Program, verification tests, as described in specification G-7.1, were performed. Breath ing air is produced from two Joy compressors located in the utility building, and air samples for the verifications tests were collected from an air supply line in PVC I. The results, as shown below, indicate that the breathable air meets Grade D quality under the conditions tested. BOR 005383 Page 4 Air Constituent Comment Oxygen 21% Carbon Monoxide None detected Carbon Dioxide None detected (lower level of detection of indicator tube - 200 ppm) Odor No detectable odor Hydrocarbons (VCM) None detected Additionally, the plant has incorporated a sampling point in the breathing air system as part of the fixed area monitoring for VCM and have identified it as stream #1-10. Any level above 1/2 ppm triggers an alarm and appropriate action Ls initiated. Also, the safety techs regularly check the intakes to the breathible air compressors with gas bags and the OVA. [. SPECIAL PROBLEM AREAS The extensive monitoring that has been conducted has indicated the compressor irea of the tank farm and the PVC II weigh tank area to be potentially high sources of VCM. The plant is currently conducting special monitoring to better lefine the extent of the problem areas before controls can be proposed. Appropriate respiratory protection is required for employees who must work in these areas rtiich is understood to be very infrequent. Continued progress in further control ling the potential sources is anticipated. BOR 005384 DETERMINATION OF NOISE Conducted At: Illiopolis PVC Facility Thermoplastics Division Illiopolis, Illinois February 1, 1982 BY: Corporate Industrial Health Dept. Columbus, OH 43229 BOR 005385 Page 1 rTPjj Tl: NOISE EVALUATION jODUCTION: On January 19, 20, 1982, sound level readings were taken throughout the iopolis PVC facility to assess employee noise exposures, and to determine the act of the new OSHA hearing conservation amendment. The current OSHA limits for noise exposures (29 CFR 1910.95) are as follows: Sound Level (dBA) Allowable Duration 90 8 hours 92 6 hours 95 4 hours 97 3 hours 100 2 hours Exposures above these limits require the mandatory use of hearing protection, ;ineering controls (if feasible) and annual audiometric testing. The new amendit to this noise standard requires that annual audiometric testing be provided I that hearing protection be made available (but not necessarily required) for iloyees exposed above the following criteria: Sound Level (dBA) Duration 85 8 hours 86 7 hours 87 6 hours 88 5.5 hours 89 4.5 hours All noise measurements were taken with a Quest Sound Level Meter (model 5) calibrated on the days of the survey. Integrated noise measurements over me were taken with Metrosonics sound measuring equipment. SULTS: Listed below are the results of the noise evaluations performed at the liopolis location. A more detailed graphical representation of these measurents can be found in appendix A at the back of this section. Location South End, First floor North End, First floor South End, second floor reactor room North end, second floor reactor room Dryer #9 & #10 area Vibrator on centrifuge chute (east end of of dryers #9 & #10) Control panel - dryer #9 & #10 Paste bagging area (equip, on) Paste dryer control panel Paste grinder area Outside fans for paste dryers(at 15') Blow down area Activator floor Sound Level (dBA) 87-96 88-95 84-88 84-88 92-96 99-101 89-90 87-88 86-88 102-105 97-98 92-94 85-86 BOR 005386 Page 2 Location Product bin level Sifter level Homogenizers Recovery building (upper floor) (lower floor) MVC pump house & tank farm area Cn Reactor building, first floor Reactor building, third floor Chemical storage area, first floor Chemical preparation area, second floor Dryer building Centrifuge room Dryer feed tank area Product bin level Sifters Utility Bldg, (lower level) (upper level) (break area) Catalyst prep. bldg. Polyco Reslnite Sound Level (dBA) 85-86 89-92 not running 87-90 88-89 76-78 90-95 84-87 89-98 83-84 84-91 88-90 82-83 86-88 89-91 87-93 85-87 75-77 65-70 84-86 (peaks to 89) 80-87 Dosimetry Data PVC #1 - Dryer Operator Station 88 dBA (equivalent dose) PVC #2 - Dryer Operator Station 88 dBA (equivalent dose) SCUSSI0N: As can be seen from the above data, with the exception of the Polyco, Resinite id Catalyst preparation operations, most production and related areas have noise ivels in the 85-90 dBA range, and would be affected by the new OSHA hearing conirvation amendment. This fact is further underscored by the recent personal isimetry data collected by the plant showing the following job categories to be i the 85-90 equivalent dBA range: Maintenance operators, utility operators, polysrization operators, dryer operators, water blaster operators, production workers, :ouP leaders, stripper operators, and plant supervisors. Additionally, several :her areas have sound levels significantly above the current OSHA limit of 90 dBA: a. Reactor building, first floor - PVC I, PVC II b. Dryers - PVC I (from vibrator on centrifuge chute) c. Paste grinder room d. Blow-down area - PVC I e* Chemical storage area, first floor - PVC II f. Outside fans for paste dryers g* Utility building Hearing protection (approved muffs or plugs) must be worn in these areas, and Lgns need to be posted stating this fact. BOR 005387 Page 3 With respect to engineering controls for the noise, compliance will be It m several areas. On the first floors of the Reactor Rooms, much of the ' is the result of pump and compressor operation. The vibrator on the cen, e chute is the most significant noise source in the PVC I dryer area. e grinder in the paste department emits sound levels between 102 and 105 dBA. fTrTn<UONS AND RECOMMENDATIONS: Sound level measurements conducted throughout the Illiopolis PVC facility owed most production and related area, (except Polyco, Resinite and the Chemical eparation building) in the 85-90 dBA range and would be affected by the new HA hearing conservation amendment. This amendment requires annual audiometric sting and the optional use of hearing protection. Employee training in the ntents of the amendment and in the proper use of hearing protection is also commended. In addition to the above, seven specific plant locations were found to be gnificantly above the current OSHA 8 hour limit of 90 dBA: a. Reactor building, first floor - PVC I, PVC II b. Dryers - PVC I (from vibrator on centrifuge chute) c. Paste grinder room d. Blow down area - PVC I e. Chemical storage area, first floor - PVC II f. Outside fans for paste dryers g. Utility building Employees working in these areas must be required to wear hearing protection, d signs indicating that hearing protection must be worn, need to be posted the door. As we discussed during the visit, several options for having the audiometric isting performed are currently being considered. It is hoped that one service Lll be able to provide the testing (through the use of mobile vans) in a cost ffective manner for most of the Borden plants throughout the country. We expect resolution of this issue in the next few weeks, and will keep you iformed of our findings. BOR 005388 Page 4 SECTION II Appendix A Sound Level Readings By Area Illiopolis PVC Facility Illiopolis, IL February , 1982 BOR 005389 iBt FLOOri, CH5KICA1 STOxtAGE AREA 2nd FLOOR, CHEMICAL PREPARATION AREA t DRYER BUILDING k AREA t BOR 005390 OUTSIDE, SOUTH. RVCM TANKS & AREA N 1st FLOOR. REACTOR BUILDING. PVC 2 -i i o 10-E n10-F BOR 005391 13-D BOR 005392 1 3~ T' BOR 005393 r rt-33& VE-^231 VE-U232 MVC S c a le s Salt solution tank BOR 005394 6-0 RE-3203 bor 005395 QUANTITATIVE RESPIRATOR FIT-TESTING Conducted At: Illiopolis PVC Facility Thermoplastics Division Illiopolis, Illinois February 1, 1982 BY: Corporate Industrial Health Dept. Columbus, OH 43229 BOR 005396 Page 1 A. INTRODUCTION On January 19, 20, 1982, quantitative respirator fit-testing was performed on those paste department employees involved in the bagging operations who are required to wear dust respirators. Quantitative fit-testing is the process by which exact respirator fit can be determined, and involves placing an employee in a bag-like enclosure while wearing a respirator (see figure 1). Within this enclosure, a fine mist-like aerosol of com oil (particle size less than 3 microns) is generated. Two sampling probes are Located in the enclosure, one inside the respirator, and one outside the respirator, ahich are connected to a photometer that measures the amount of com oil from each nrobe. Any leakage getting into the respirator can thus be determined. Due to the iigh filtering efficiency of the respirator media, any com oil measured in the respirator is largely a product of penetration around the face seal. The overall ability of the respirator to remove the test aerosol can be listed is the respirator efficiency (usually a percentage) or the protection factor, ihich is the contaminant concentration outside the respirator divided by the con.aminant concentration inside the respirator. Protection Factor? concentration outside respirator concentration inside respirator Factors which adversely affect the fit of a negative pressure respirator include eard or other facial hair, extremely narrow faces, broken or crooked nose, scars, tc. Exact fit is not a factor on positive pressure (air-line) respirator perormance. During the fit testing, the employees are requested to perform several xercises which are designed to simulate work movements. This is done to assure hat respirator fit is not impaired during normal work activities. BOR 005397 Page 2 IsULTS AND DUSCUSSION listed below are the results of the quantitative fit testing that was conducted ie Paste Department Bagging employees on January 19, 20, 1982: Name >avid Turner iary Smith lough High jan Williams .eon Caffey .andy Negley an Lyons ill Crouse ric Mendenhall Total Respirator Efficiency Protection Factor Comments 70-97 80-96 82-95 96-100 95-98 80-97 96-99 91-98 95-99 3.3-33 5-25 5.5-20 25-100 20-50 5-33 25-100 11-50 20-100 very narrow face ] full beard moustache & stubble some stubble partial beard small beard small goetee During the above testing, the 3M 8710 (currently in use at the plant) and 3M dust masks were evaluated. The 9910 model is similar to the 8710 in appearbut has elastic-cloth straps (instead of rubber) and a thicker filter media, experience at other plants indicates that many workers prefer the 9910 because he cloth straps, thus reducing the number of employees removing the bottom irator strap because of discomfort. The removal of any respirator straps com ely negates the effectiveness of the respirator. loyees using the negative pressure Scott Gas Masks for vinly chloride (VCM) t given quantitative fit tests because the VCM cannisters would not adequately er out the test aerosol (corn oil) in the chamber. It is our intention to jpriately modify such a cannister so that quantitative fit tests on these Jiduals can be performed some time in the future. CONCLUSIONS 'he results of the quantitative respirator fit testing performed on the >polis Paste Department Bagger operators showed that all workers tested had .rator efficiencies between 70 and 100%. These efficiencies would likely provide late protection against the PVC dust exposure excursions realized during the il work shift. These disposable respirators tested, however, would not be mended for operations such as baghouse cleaning/changing which would overwhelm liter media. The results of this fit testing also show the adverse effect of Is and other prominent facial hair on the effective fit of negative pressure rators. 'he quantitative fit testing of those employees wearing negative pressure vinyl ide gas masks will be performed at a later date after appropriate modifications been made in the filter media to allow suitable testing. t BOR 005398 Figure I Quantitative Fit-Test Unit BOR 005399