Document DMkb0d70j26L8MVV84v5bZpgN

AR226-2003 &% k . aiins/o. v. ^auga.i J. G. Loschiavo - D12022-3 J. E. Crum R. D. Lanyon _,V. A. Ott sJ' L. Post ,,D. A. Schneider W. M. Stewart July 7, 1987 TO: C. A. DYKES J. A. SCHMID PROM: R. J. ZIPPEL C-8 COTOOL PROGRAM My review on this issue with Dr, Bruce Karrh on June 11 1987, went very well with little change required to our present control program. Dr. Karrh was most interested in the presence of C-8 outside the plant boundaries. Be stated that we need to place the highest priority on these environmental issues. Dr. Karrh also accepted the position that our employees will continue to have C-8 in their blood. My charts and the specific comments made during the review are attached. The following is a restatement of the specific program items in our C-8 control plan with the necessary action steps indicated. . 1. ADMINISTRATIVE CONTROLS A. EQUIPMENT DESIGN 1. IMPLEMENT AN IMPROVED FINE POVDER DRYER GASKET DESIGN (RESP - KLINE) B. PROTECTIVE EQUIPMENT 1. AUDIT WASHINGTON WORKS C-8 IN BLOOD AND C-8 IN AIR DATA TO DETERMINE IF CURRENT PROTECTIVE EQUIPMENT (AND OPERATING PROCEDURES) ARE THE OPTIMUM AVAILABLE (RESP - LOSCHIAVO) 003855-1 - RJZ:kst EID09137S RJZ026552 EID091375 C. A. DIKES / J. A. SCHMID C-B CONTROL PROGRAM PAGE 2 JULY 7, 1987 . C. C-8 MONITORING 1. SEDUCE EMPLOYEE BLOOD TESTING TO ONLY THE FOLLOWING JOBS: RAW DISPERSION AUTOCLAVE OPERATOR DISPERSION OPERATOR FINE POWDER DRYER OPERATOR ENVIRONMENTAL OPERATOR (SUMP) DISPERSION PACKOUT OPERATOR GRANULAR POLYKETTLE OPERATOR FINE POWDER PACKOUT OPERATOR FEP POLYKETTLE OPERATOR FEP WET FINISHING OPERATOR FEP DISPERSION OPERATOR FIRST LINE SUPERVISION OF ABOVE PERSONNEL (RESP - LANYON) NOTE: BEFORE WB CHANGE OUR BLOOD SAMPLING PROGRAM, WE WILL WANT TO HAVE AN INTERNAL BTO COMMUNICATION (RESP - ZIPPEL) 2* PERSONAL C-8 IN AIR SAMPLING - MONTHLY SAMPLES SHOULD BE REQUIRED OF THE FOLLOWING JOBS: RAW DISPERSION AUTOCLAVE OPERATOR GRANULAR POLYKETTLE OPERATOR FINE POWDER DRYER OPERATOR .. DISPERSION OPERATOR FEP POLYKETTLE OPERATOR FEP WET FINISHING OPERATOR FEP DISPERSION OPERATOR . (RESP - POLYMERS - OTT COPOLYMERS - POST) 003855-2 - RJZskst EID091376 RJZ026553 EID091376 C. A. DIKES / J. A. SCHMID C-8 CONTROL PROGRAM PAGE 3 JOLT 7, 1987 3. AREA C-8 IN AIR MONITORING - AS NEEDED BY AREA AROUND CRITICAL EQUIPMENT (e.g., FINE POWDER DRYERS) AND TO RESPOND TO HIGH LEVELS NOTED WITH PERSONAL SAMPLES (RESP - POLYMERS - OTT. COPOLYMERS - POST) NOTE: IN'GENERAL, WE ARE TAKING FAR TOO MANY AREA SAMPLES AND NOT ENOUGH PERSONAL SAMPLES 4. DOCUMENTATION - EXPLANATIONS OF REASONS AND ACTION RESPONSE FOR AIR LEVELS (PERSONAL SAMPLES ONLY) ABOVE SO% OP THE AEL (0,56 MPB) REQUIRE IMPROVEMENT IN THE DIVISION'S ENVIRONMENTAL SAMPLING BOOKS (RESP - POLYMERS - OTT COPOLYMERS - POST) ' D. C-8 CONTROL LEVELS 1. ESTABLISH MAXIMUM SAFE C-8 IN BLOOD AND C-8 IN DRINKING WATER LEVELS (RESP - G, L, KENNEDY - HASKELL) -- NOTE: ONCE A SAFE LEVEL IS ESTABLISHED, THOSE PERSONNEL EXCEEDING SOX OP THIS LEVEL WILL BE REQUIRED TO BE REMOVED PROM THE EXPOSURE ARM II. PROCESS CHANGES - A. IMPLEMENT USE OF PURCHASED LIQUID C-8 AS IS BEING DONE AT DORDRECHT AND CHAMBERS WORKS (RESP - POLYMERS - CRUM COPOLYMERS - HERRIDGE) B. NEW SURFACTANTS 1. TBSA IN FEP - REDUCE PRIORITY ON THIS PROGRAM TO THE POINT WHERE BUSINESS NEEDS JUSTIPY FURTHER USE (QUALITY AND COST) (RESP HERRIDGE) 2. C-9, C-10, C-12 - NO ENVIRONMENTAL LIMITS ARE PLACED ON THE USE OF NEW SURFACTANTS C. C-8 RECOVERY ,- 1. FINE POWDER DRIER VENT - DEVELOP BASIC DATA TO IDENTIFY RECOVERY PROCESS BY 4Q87 (RESP - SCHNEIDER) 2. FEP AQUEOUS STREAMS - APPLY ABOVE TECHNOLOGY IF ECONOMICAL (RESP SCHNEIDER) D. LUBECK WATER DISTRICT CONTAMINATION . 1- ELIMINATE SUPERNATE PONDS - GOAL IS NOVEMBER 1987 (RESP - FLENSBORG) 2. DETERMINE MODE OF CONTAMINATION (RESP - STEWART) Attachments 003855-3 - RJZ:kst EID091377 RJZ026554 EID091377