Document EvdwJZajb8YqMY1gDMBOX0DMR

T*>"c lEFGoodrich V INTER-ORGANIZATION CORRESPONDENCE TO FROM SUBJECT T. S. Bialke M. W. Reynolds FIELD POINT OR DEPT & BLDG NO Cleveland FIELD POINT OR DEPT. & BLDG NO. Henrv Fourth Quarter 1980 Industrial Hygiene Report DATE YOUR LETTER DATE THIS LETTER ____- 8-10-81__________ The following report is an update of the progress made during your Industrial Hygiene Audit of the Henry Plant during November 6-8, 1979* 1. Obtain Personnel Monitoring Samples during Asbestos Removal }J^ rr# The pit.ant has all the necessary monitoring equipment to conduct the monitoring. However, no source of asbestos exposure has been identified in the plant. To assist in the identification of asbestos, the Henry Plant Chief Chemist has trained two Environmental personnel to identify asbestos. Upon determining an asbestos source the Henry Plant will conduct the monitor ing and supply the monitoring cassette to you. Until that time, this project will not be shown on the status report. 2. Document Nickel Catalyst Exposure Completed. Exposure below permissible levels. 3. Reduce the Number of Benzene Personnel Monitoring Samples Completed. 4. Use OSHA Dust Monitoring Procedures Completed. 5. Use "3-M" Gasbadge Rattier than "Abcor" The switch in badges is being made. The Corporate Environmental Laboratory is evaluation the "3-M1' badge, at this time. The plant is switching to the "3-M" badge prior to the completion of its evaluation as recommended by the Brecksville Laboratory. 6. Supply Noise Dosimetry Data, to the Medical Group Completed. To assist in the evaluation of hearing loss. 7. Install Noise Reduction Material in "Cuber Room'' As mentioned in. the previous audit this project is no longor needed and has been dropped. install Hew Laboratory Hoods Completed. Exhausts check out good. 1001009 NGC 01255 2 Notes: 1. The Henry Plant has received your letter foretelling your upcoming audit on May 19-21, 1981 and are looking forward to it. 2. A summary report detailing the results of the Henry Plant 1980 Personnel Monitoring program is nearly complete and will he forwarded. If there are any questions or comments concerning the above information, please call me at extension 330, Henry. M. W. Reynolds MWR:ksp cc: L. V. Goode A. W. Otto K. D. Konter/D. W. Lou/D. G. Friesz J. D. Krumholz/M. E. Brummitt R. V. Tebbutt G. E. Higby H. Lanese - Cleveland H. Waltemate - Cleveland W. C. Becker - Cleveland E. C. MartineHi - Cleveland N. R. Aquino - Cleveland P. T. Whitmire - Cleveland File cr. o o 4. -J NGC 01256 FROM SUBJECT T. S. Bialke FiaO POINT OR DEPT. & BLDG. NO. Akron - D/0020, 5-H DATE THIS LETTER 6-26-81 Industrial Hygiene Survey - Henry Plant During the period May 19-21, 1981 I conducted an industrial hygiene survey of the Henry Chemical plant. The plant's VCL monitoring and leak detection programs, chemical review com mittee, monthly reports and action on previous industrial hygiene recommendations were found to be excellent. Attention needs to be given to extending personnel sampling times to at least 10 hours for a 12 hour shift, reviewing the plant's breathing air system, enclosing a hopper in Poly mer Chemicals because of noise and initiating a job hazard inventory- I wish to thank Ken Konter, Mark Reynolds, Ken Willings, Diane Friesz and Jim Krumhol2 for making my visit profitable and memorable. T. S. Bialke cc: K.Konter J. Krumholz E.Martine11i/E.Harrington H.Waltemate W.C.Becker/W.C.Holbrook N.Aquino/W.Lodge R.C.Kaminski/J.F.Malone P.T.Whitmire/G.Krcmar/R.Krueger 10020092 ">FCf - II iC Ll'H'J IN J $ /> : 01257 XH Survey Report-Henry May 19-21, 1981 ^ X. Recommendations: ,,v> 1. Increase the sampling time period for personnel monitoring to ten (10) hours minimum when evaluating exposures for a 12 hour work- shift. y 2. When using a passive organic vapor dosimeter (3M, Abcor, duPont, etc.)^' enter only those results obtained for benzene or toluene. The use of these devices for other air contaminants has not been approved by the Environmental Health Department. Review the plant's breathing air system to define the frequency of and responsibility for filter changes. Label each air filter cart- datfJ {{* fhe dat-_j=> of chanqe and iexpected replacement or inspection ** MAAf AM'4 *** cU^c*** w' ^ Enclose Tine 2 hopper on the second f.loor of the PC building with noise shield. t, n ^ 5 . Review implementation of the respirator maintenance procedure, i.e. cleaning and inspection, to#ensure it is being followed. J^***-" -*#- op U^cckf , uv Uj Initiate a job hazard analysis of each job class for the developing a job hazard inventory relating all potential and physical agent exposures to each job class. / AST />w t-------L purpose of chemical Discussion: The Henry PVC operation is experimenting with 12 hour shifts to replace the traditional 8 hour shift. To properly assess an employee's exposure to environmental workplace contaminants, the personnel monitoring time must be increased to sample for the full period of the shift. When workers are on an 8 hour shift, sample times of 6 hours are sufficient. When 10 hour shifts are worked, 8 hour sampling periods should be con ducted and during 12 hour shifts, samples must be taken for at least 10 hours. Sampling for the full shift is, of course, the best way to determine an employee's time weighted average exposure. Sampling two hours less than a full shift and calling it a full shift TWA exposure albws the sample collector one hour at the beginning of a shift to set up and distribute the monitors and one hour at the end of the shift to collect and prepare samples for the laboratory. The Henry plant is currently using passive organic vapor dosimeters for routine benzene and toluene sampling. Occasionally the devices are used for other organic air contaminants. Data obtained from the use of the badges for chemicals other than benzene or toluene are not to bo placed in the computer data bank. Only benzene or toluene results are to be entered. The Environmental Laboratory in Brecksville and the Environ mental Health Department pass judgment on air sampling and analytical procedures. As the badges or other sampling and analytical procedures are found reliable, they will be approved for use within the BFGoodrich Company and the plants will be so informed. If you have special moni toring requirements or wish to use a procedure in a novel way, communi cate your desires to the Environmental Health Department for review. OOZ0 0 9 Z NGC 01258 IH Survey Report-Henry May 19-21, 1981 2. Discussion (con't) During my walk-through the plant's breathing air system was discussed. There was some uncertainty on the part of plant personnel on the exact location of breathing air filter stations established in various buildings, how often they are to be replaced, what constitutes a requirement for replacement and who is to do the checking and replacing of filter cartridges. Also noted during the system review was that the cartridge placement made them very difficult to check and replace. Maintenance checks of the system would benefit by placing the filtration bed in more readily accessible positions. In a separate letter I have mailed to K. Konter some reference material on breathing air systems. During discussion of the implementation of the BFG medical policy on hearing conservation and the requirement for posting as "noise hazardous" areas greater than 85 dBA, the Line 2 hopper on the 2nd floor Polymer Chemicals building was mentioned. When the hopper's vibrator is operating, noise is generated that creates a zone of 85 dBA or greater some 25-30 ft. away. No other excessive noise sources are in the immediate vicinity. Instead of declaring the whole area as being noise hazardous, it would be much simpler to enclose the hopper in a sound barrier. KoroKlear strips should attenuate the noise sufficiently to eliminate the hearing protection requirements. Rigid, durable prefabricated sound absorbent panels, however, would be more effective and would certainly last longer. On the 2nd floor of the P.C. building, just outside the entrance to the control room, is a respirator storage box. The respirator inside this box was in poor condition. The plant has a well written respirator program, but assurances are needed that it is being implemented. Prior to the next IH survey, it will be necessary for the Henry plant to develop a hazard inventory for each job classification in each de partment. Such an inventory will list the chemical or physical agent exposure by job class. This project will require a hazard analysis of each job to determine what chemical or physical agents a person working in that job class may be exposed to. Not only will such a job hazard analysis fulfill the requirements of the medical surveillance system, but it will present the opportunity for the Health/Safety team to become more cognizant of potential hazards within the plant. It will be a learning experience and hazards heretofore unrecognized may be identified. During my next visit the degree of hazard will be assigned and data entered into the medical surveillance system. Table I contains VCM personnel sampling results. Each value is a com posite result of two partial period samplings that, when combined, represents a full shift sample. The 8.1 ppm result is quite high, however the individual worked on hazardous tasks requiring the wearing of a respirator. j,*. ^ ^ Table II shows the results of benzene and toluene monitoring. All samples O were collected with a 3M organic vapor passive dosimeter and all results were below the lower detection limit. Toluene results also indicate no O CO excessive exposure. 01259 Ill Survey Report-Henry May 19-21, 1981 3. Discussion (con't) Review of the plant's monitoring program for PVC dust indicates no excessive exposures. Polymer Chemical dust monitoring occasionally reveals exposures above 5 mg/M*^. Although there is no published TLV for the type of dust exposures encountered in the P.C. building, it is recommended that employees be encouraged to wear at least a nuisance dust respirator. The plant's VCL leak detection and VCL sampling programs are functioning well. The access to medical records and chemical MSDS policies are in order. The new chemical review committee is functioning properly. Replies to previous surveys have been timely. Particularly noteworthy are the plant's monthly operating close-up and VCL task force meeting minutes as well as the VCL and P.C. safety and environmental operations procedures. TABLE I. VCM PERSONNEL MONITORING RESULTS Henry Plant - May 19-20, 1981 Area Job Class. Sample Time (min,) Poly Bldg. SOP Oper. 010 393 U Valve 019 491 Cleaner If LOW SOP 010 501 Oper. ir Plant 009 501 Chge. Op. Respirator Worn Yes VCM (ppm) 8.1 IV <0.2 IT 0.37 IV 0.76 TABLE II. BENZENE PERSONNEL MONITORING RESULTS B/718 045 390 B/713 11 054 050 390 390 B/712 640 390 B/713 052 390 B/718 B/711 046 TOLUENE RESULT 071 390 390 redacted Benzene <r o. 3 <0.3 < 0.3 -<0.3 00Z0092 <0.3 <0.3 Toluene (ppm) 1.9 cn NGC 01261 TO FROM SUBJECT L, V. Goode K. D. Konter FIELD POINT OR DEPT. & BLDG. NO. Henry FIELD POINT OR DEPT. & BLDG. NO. `'Henry m.i --' in lliiyl DATE YOUR LETTER DATE THIS LETTER 7-30-81 1981 Industrial Hygiene Survey - Henry Plant luso * 198'. On May 19-21, 1981 an Industrial Hygiene Survey of the Henry Plant was conducted by T. S. Bialke of the Corporate Industrial Hygiene Staff, After careful review of the Survey Report we have prepared the attached action plan. Plan 1, Increase sampling time for personnel monitoring to 10 hours for individuals on 12 hour shifts. Response: Complete.., 2. When using passive organic vapor dosimeters, enter only those chemicals (i.e. benzene and toluene) which have been approved by the Environmental Health Department, Response: Complete, 3. Review the plant's breathing air system and label each air filter cartridge. Response: Will be complete by 9-1-81. 4. Enclose Line 2 hopper in Polymer Chemicals with a noise shield. Response: We are currently investigating alternative control measures. A decision will be made by 9-15-81 on the particular control we will install. 5. Review Implementation of Respirator maintenance procedure. Response: Complete. 6. Initiate a job hazard analysis for each job class in the plant. Response: Will be complete by 9-1-81. 261)03001 KDK:k s p K. D. Konter cc: A. W. Otto R. K. LaCosse R. V. Tebbutt W. B. Bispeck R. L. Russ G. P. Smith File F G .1 ", A O i / T! n 0s* NGC 01262 C9Z10 60C 4001 w,/ * / 0>(XETg X auox^w * d * r/Txsututp^ * 3 * y a&poq ' tA/ouTnby ` N ^ooaqjOH'D *M/JS^oag* d *m 0qamaqxT?M*H/TTT9UTX2ew*3 ZSTJj*a/s5UTXITM*a oqqo `V too 'q t sta Aui fiuTjnp aoup --qsTSS' jrtaqq a.03 zssTa.H *a pup s&uqxXTM *X X^Pqq oq aXTT PinoM 1 spjepupqs p0ZTuBoD9T Moxaq XTSM aq oq saxusodx paqpoxpuT siipaA x^^^abs qspd aqq jbao pauTpqqo sqxtisaa sp 1 paqpuxuiTxa aq upd buTxoqTuoui xsuuosaad aui^noa arnos `bsib DAd aqq ut uaATfi aq oq spaeu uoTquaqqp azrorn qnq * paquauiaxduiT AxqpTq -jpd st ureafiojrd uot;baj9suod buTJtpaq aqx 'B9JB x^oTuiaqo qamAxod aqq ui qsxxa XXT^S aoupuquTPui pup 6psn joqejjdsajr qqxw suiaxqojtd bsjb apTaoxuo iAuta Apod aqq ui STo^BJtdsei jo aouBuaxuTBui pup sxOTm3tt .rauiAxod ut uoTqpxT^UQA buT^oaqo aoj uieaBoTd poo5 p spq qupxd >qx *qupjd X^T010^ Ajuoh aqq qe paqonpuoo sbm AaAjns auajfiAq x^T-r^snFuT up "I ^Tnr-63 ounj? poxaad aqq fiuTJtlQ Z8-S2-8 1331131 SlH^jiv/ aiUJl 8f ZL Ajuqh - AsAins 9U9TBAh xE7-*3-Snpui "H^ 'OZOO/Q - UOJXV _______ ON 0QT9 B TcSO ao INlOd q~Bjd -Ajiush * ON SOTS 'B 'l<fia 80 lNIOd CI13U 9XIeT9 *S 'X apooo *A *1 iC/feT, IN083 Henry IH Survey 1982 findings Items from Previous Survey 1. Common use respirators in polymer chemical area were observed to be dirty and improperly stored. One worker in 3114 process seen not wearing dust respirator properly. PVC area respirator usage was :.;ar isfactory . 2. do hazard inventory available. ^ , .. Recommendations Exp.Date Completion 1. The Henry plant has a well written respirator program; however, as noted in the 1981 IH survey report, the program needs to be reviewed. More attention should be given to proper cleaning, storage, and wearing of respiratory pro tection in the polymer chemical area. Common use respirators must be cleaned and sanitized between wearings; when not in use they must be sealed in plastic bags and stored in boxes provided to ensure procedures are being followed. All respi rators must be inspected monthly. 2. The 1981 IH survey report requested that the Henry plant develop a hazard inventory prior to this years survey. The inventory was unavailable at the time of the visit. As soon as the inventory is complete, for ward a copy to me in Akron, at which time I will contact the plant to discuss assigning the degree of hazard and enter the data into the medical surveillance system. Responsibility - NC,C 01264 -0010092: Henry IH Survey-1982 i;'ind:nqs Recommendations Exp.Date Completion Items frorr, This Survey :. A]1 VCM employees monitored 1. Monitoring frequency for chemicals monthly; benzene, toluene and aceto listed can be reduced to the following ne tri'.e workers also being checked frequency: monthly. Colormetric badges being VCM - OSHA sampling requirements for used for r^S monitoring. VCM are as follows; all employees with exposures greater than 1 ppm are to be checked monthly? all employees with exposures between 0.5-1 ppm are to be checked quarterly. Monitoring may be discontinued for any employee when two consecutive samples collected not less than 5 days apart are below 0.5 ppm. Benzene - Employees with exposures greater than 10 ppm to be monitored monthly? exposures between 5-10 ppm monitor quarterly? less than 5 ppm, no monitoring required. Toluene - employees with exposures greater than 50 ppm are to be checked monthly? 25-50 ppm are to be checked quarterly? less than 25 ppm - no need to monitor. Acetonitrile - Employees with exposures greater than 40 ppm are to be checked monthly; between 20-40 ppm check quarterly, less than 20 ppm, no need to monitor. H2S - Since there is area monitoring for H2S, there is no need to conduct routine personnel monitoring. The colorometric badges used for H2S monitoring are not reliable. Polymer Chemical Dust monitoring - no ` > change is recommended. c 1 o '2. Responsibility Henry III Survey-1982 3'. :. (con't) 2. All respirable dust measure ments taken with improper air flow- rate of 1.4 Lpm. 3, Some signs have been posted in PVC c-oly bldg. 731, PVC dryer bldg. 732 and"boiler house bldg. 714 indi cating areas are noise hazardous, hot all areas within these buildings are pasted. The basement of water treatment bldg. 724, the mill and Jlonschcl area of compounding bldg. 724 not posted as noise hazardous. 1. The OSHA VCL standard allows for the discontinuing of monitoring when exposures drop below 0.5 ppm, 1/2 the TLV or action level. Although it is permissible to discontinue monitoring below that level, it is recommended that yearly checks be made on all employees routinely exposed to VCM. It is up to the plant's discretion in conducting yearly monitoring for the other chemicals listed? however, when there is a process or work practice change that may have an impact on any employee's exposure to any chemical, that employee or job is to be re-moni tored to determine if exposures have changed. 2. Respirable dust sampling requires Date of Completion the use of a small cyclone to collect airborne particles in size range respired by the human lungs. To properly function, the airflow through the cyclone must be at 1.7 i .05 Lpm. The plant calibrated the cyclone at 1.4 Lpm flow rate, thus invali dating all respirable dust values obtained. These values must be deleted from the com puter, the employees' medical records and repeat monitoring must be conducted. 3. The Henry hearing conservation program is well written, but to ensure that workers know in what areas hearing pro tection is to be worn, all areas must be clearly posted with appropriate warning signs. All entrances to PVC poly bldg. 731 must be posted. The PVC dryer bldg., in cluding bagging area, are to be posted. PVC compounding mill and Henschel areas also must be posted. Responsi bility 99110 ) 0 \ Henry IH Survey-1982 Findings Recommendations Exp.Date Completion "4 Responsibility 4, Laboratory Draeger pump tube joule leaking. Safety shed Draeger pump with chain broken. 4. Draeger pumps, which are to be used only with Draeger brand indicator tubes, are engineered to draw a known volume of air through the tube. To meet these specifications, they must be maintained. A repair kit is available from Draeger which will allow the plant to recondition each pump. The pumps described here need to be maintained. 1. 'Urinalysis for phenol given to employees having acute exposure to benzene. 5. The BFG OHP on benzene (5.11) does require that urinalysis for phenol be given to employees having brief, high exposures to benzene. not 6. (a) do respirator exam given to Pi and maintenance operator, (b) Compound area - mill, Henschel ieel and weigh areas contain pul monary hazards. 6. (a) Per BFG OHP 1.17, use of respira tors: Any employee whose job requires him to routinely wear a respirator must be provided an examination to determine if he will be handicapped by such respirator wearing, (b) Total particulate samples collected on Henschel operator showed a value of 8.7 mg/M3 (see attachment). BFG exposure standard is 10.0 mg/M^. Since this sample result is below the BFG exposure standard for total particulate, no recom mendation for engineering controls is being offered. However, the value is over one-half the exposure standard, high enough to declare the area a pulmonary hazard area requiring that employees wear a dust respirator such as 3M8710 or 3M9900. Employees assigned to work in these areas must receive a medical examination per JJFG OIIP 5.06. NGC 01267 S()OV0U2 Henry IH Survey-1982 Findings 7. Pclychemical area issues monthly meeting minutes. The Environmental Health Dept, is on distribution list. Plant issues monthly Environ mental report; Environmental Health Dcot. is not on distribution. 8. No formal reply to 1981 IH survey report. Recommendations Date of Comp. 7. Henry should consolidate their polymer chemical environmental meeting minutes with the plant's environmental report and include the Environmental Health Dept, in the monthly distribution. 8. Dug to an oversight on the part of the Henry plant and my lack of follow-up, the plant failed to reply on a quarterly basis to the 1981 IH survey. Quarterly reports on actions taken to address recom mendations contained in this report are required. 5. Responsibility NGC 01268 hoot-oosz Henry IH Survey-1982 6. Discussion The attached table contains the results of personnel monitoring conducted at Henry for noise and total particulate. Noise results on a time weighted average for an 8-hour shift show exposures to be 34 to 77%. A reading of above 100% would be a violation of OSHA law and above 50% requires implementation of the hearing conservation program. Total particulates were collected in the compound operation. The Henschel operator's exposure of 8.68 mg/M^ TWA for 8-hours is below the BFG standard of 10 mg/M^, but above 5 mg/M^ action level. Due to this high result, the compound Henschel floor is to be considered a potential respiratory hazard area with appropriate physical examinations and respirator wearing required. TSB q. o o ^GC 01269 Employee/SSg TABLE I. PERSONNEL MONITORING - NOISE Henry - June 1982______________ Job/Area Sample Time (min.) Recovery Oper. - PVC 445 Value 8-Hr. TWA % of Standard 42% Upstairs recovery Oper. PVC 350 41 Pearl Charge Oper,. PVC 347 34 Dispersion bagger PVC 347 44 Venturi Oper. PVC 342 77 TABLE II. TOTAL PARTICULATE MONITORING Compound weighman 345 Henschel operator 345 TLV (mq/M^) 0.6 8.68 redacted 3 o NCC 01270 o TELECOPY TO: R. Graheck4'Hearty. 111* Plant From: T.S. Bialke, Akron, D/0020, 5-H Subject: Henry Chemical Plant Industrial Hygiene Survey This is to confirm the Henry plant industrial hygiene survey scheduled for the week of April 23-26. During my survey I will be interested in the following: 1. Henry plant industrial hygiene program requirements, 2. Henry industrial hygiene personnel monitoring codes interface with Corporate PMIS, 3. VCM exposure of PVC bagger, 4. Henry plant respirator fitting procedure implementation, 5. Worker exposures to VCM, benzene, OBTS, MBT, 6. Henry job health hazard inventory, 7. Review completion of actions to address previous survey recommendations. I look forward to meeting with you and your staff to discuss any industrial hygiene and/or occupational health concerns that you may have. v H.Waltemate/G.Lefebvre K.Willings, Henry T. S. Bialke c oe t O NCC 0127] L TO FROM SUBJECT R. V. Tebbutt JL J. Killings FIELD POINT OR DEPT & BLDG. NO Henry____________________ Fiao POINT OR DEPT. * BLDG. NO. --...ge.pyy_________________ 1983 INDUSTRIAL HYGIENE SUMMARY FOR THE PVC AREA f-EB 1 7 1984 DATE YOUR LETTER DATE THIS LETTER 2/lk/Sk The Environmental Group, with the aid of the Safety and Environmental Operator, conducts an extensive personnel monitoring program designed to document personnel exposure to chemical substances and physical agents in the work environment. Once exposure sources are identified through monitor ing or area surveys, then the proper engineering controls or other corrective action may be instituted to ensure that personnel exposure is maintained below permissible levels. The following is a summary of PVC Area Industrial Hygiene activities: I. II. III. IV. Vinyl Chloride Dust Noise 198b Goals I. Vinyl Chloride Monitoring for Vinyl Chloride exposure has been greatly reduced as compared to past years and only those personnel regularly working in the Poly Building, Dryer Building, and Tank Farm are being regularly monitored. The Vinyl Chloride OSHA permissible exposure limit (PEL) is: 1 ppm for 8 hour (TWA) 5 ppm for 15 min (TWA) Anyone working regularly in an area in excess of the Action Level (0.5 ppm for 8 hour (TWA)) will be monitored to determine if their exposure to Vinyl Chloride is in excess of the PEL. In 1983, l6U personnel monitoring samples for Vinyl Chloride were taken. They are broken, down to the following categories: 21 io 23 $ 56 ja 35 sampLes were > 1 ppm 38 samples were < I ppm, but .> 0.5 ppm 91 samples were < 0.5 ppm The job classes with exposures greater than the PE.L are the following: 600500 Job Code 009 0L0 Oil 012 015 016 -028 Name Building Pearl Charge Operator 731 Lo Sope Charge Operator Recovery Operator Dryer Operator 731 73i 732 HRC Poly Cleaner Dryer Building Bagger 731 732 Safety and Environmental Op!erutor 731 No. T*5' L -com 7 5 1 6 6 7 2 OfO-4956-E I 11BO LI' "0 IN U S A NGC 01272 By examining the job classes' exposures it shows that two of the highest exposure classes are in the Dryer Building. Most of these are attributed to the new Reduced Lo Sope Process. This area is being monitored and corrective action plans are already in motion. A study of this area is being prepared. II. Dust Exposure Dust Exposure monitoring in the FVC area has been limited to the Dryer Building and Compound Building. The limit for exposure to respirable (FVC) dust is 5 mg/m . The following lists the samples taken in 1983: Job Class No. of Samples Building Average Value 023 1 7*+l 1.66 012 5 732 0.76 016 6 732 0.72 From this and previous sampling, no dust exposure problems have been encountered. Sampling in I98U will be limited to areas that have had changes that may increase dust exposure. III. Noise E^xuosure In accordance with the BFGoodrich Occupational Health Policy for Noise, Section the Henry Plant has performed personnel monitoring to determine noise exposures throughout the facility. In the PVC area actual noise exposure is determined by the use of noise dosimeters to measure the person's actual noise exposure on a time-weighted basis. In addition to the personnel monitor ing, area surveys are taken and any area above 85 dBA is posted "Noise Hazardous". The areas that are posted in the PVC area are: 1. The Poly Building 2. The Dryer Building/Resin Reclaim 3. Sections of the Compound Building Hearing protection is required in those areas. The following outlines the personnel monitoring, results: f Total Samples Exposure > 50% (85 dBA ) Exposure <1 50 $ , i ____________NOISE___________ _____NOISE hU 30 lU \GC 01273 -^ -3- These results are in line with the area surveys taken and show the need for hearing protection. IV. 198U Goals A. A reduction in exposures and the identification of methods to reduce exposures to Vinyl Chloride. B. Implement the requirements as specified by the Illinois worker "Right-to-Know" law. C. Insure all tasks needing respirator protection are properly defined. D. Continue auditing all areas for compliance with Industrial Hygiene Requirements. K. J. Willing; KJWrksp cc: R. J. Grahek A. W. Otto/F. V. Zemanek M. E. Guyer/j. P. Griffin/R. D. Webber A. M. Matyger J. V. Nordmeyer D. L. Rys D. E. Giffin/W. J, Grudzinski/N. H. Louis R. A. Martin T. S. Bialke File L' NGC 01274 R.J. Grahek Henry T.S. Bialke Akron - D/0020, 5-H 5-30-84... Industrial Hygiene Survey During the period April 23-26, 1984, an industrial hygiene survey was conducted at the Henry plant. The plant has done a good job of implementing hearing con servation and respiratory protection programs. All previous survey recommen dations have been completed. Out of 82 industrial hygiene audit items, the Henry plant was found to have 75 satisfactory; seven items need attention. Recommendations are contained herein to review employee VCM monitoring data with consideration to reducing VCM physical examinations, to eliminate audiometric testing of polymer chemicals employees, and to reducing monitoring even further for acetonitrile, benzene and polymer chemicals dust. Recommendations are also offered to improve venti lation of resin reclaim press dryer, ventilate metal spray operations, and conduct semi-annual flow check of the compound weigh booth. I want to thank K. Willings and D. Friesz for their help during the survey. My thanks also to J. Griffin, M. f.uyer and R. Grahek for their enthusiastic support of the plant's industrial hygiene program. v cc t M. Guyer/K.Willings/D.Friesz G.Lefebvre/H.Walt ema t e N. Aquino/F.Krause/J.Hobey J.Stroope/K.Lee F.. B . Kat zenmeyer/H. W. Diet z , MD/G020 R. A.Guyton,MD/R. A. Kelley T. S. Bialke <T. 's--- O c*. o o NGC 01275 Henrv IH Survey; April 1984 1. Compliance with Previous Survey Reconunendations : 81-1. Respirator cleaning and storage has been improved; action complete. 81- 2. Job health hazards have been inventoried; action complete. 82- 1. Personnel monitoring for VCM dropped to OSHA standard requirements. Benzene and acetronitrile monitoring has been reduced. Routine monitoring for toluene and hydrogen sulfide has been discontinued. Action complete. 82-2. Respirable dust sampling requirement o^l.7 Lpm is being met. Invalid data has been deleted from monitoring record^. initiated. Action complete. Repeat monitoring has been 82-3. All noise hazardous areas are posted; action complete. 82-4. Draeger monitoring pumps are being properly maintained; action complete. 82-5. Urinalysis of employees for phenol who receive brief, high exposure to benzene has been discontinued; action complete. 82-6. All employees whose job requires them to wear a respirator are offered a respirator examination; action complete. 82-7. Monthly environmental health report has been discontinued; see current findings. 82-8. Formal replies to 1982 industrial hygiene survey were timely and complete; action complete. Industrial Hygiene Survey Recommendations: 1984 84-1. Arrange for the Henry plant's industrial hygiene coordinator to attend a course in inustrial hygiene. NIOSH, Natalsco and others offer such courses. Contact T.S. Bialke in Akron (ext. 4224) for details, 84-2. Issue a quarterly industrial hygiene report containing, as a minimum, the following: summary of personnel monitoring results, explanation of overexposures, personal protective devices worn and corrective actions taken to prevent further occurrences of overexposures. T. am forwarding examples of report formats to K. Willings. 84-3. Review past two years of VCM personnel monitoring data and compare the results with the VCM physical exam requirements contained in BFG OHP 5.02. The Knvironmenta 1 Health Department in Akron must be informed of deviations from these requirements. 84-4, Discontinue audiometric exams for polymer chemical employees as noise exposures are not above 50%. 84-5. Ensure that the plant physician is noting in employees' medical record that 1 ha employee has been medically approved to wear a respirator. Lf there are anv restriction';, fir* nTm must be recorded in the employees' medical rooo rd s . oodohhz CV NGC 01276 Henry IH Survey; April 1984 2. IH Survey Recommendations: 1984 (con't) 84-6. Update MSDS book that is kept in the PVC compound office to ensure that all MSDS are available for all chemicals used in the compound operation. 84-7. Indicate on recipe card used by weighman which compound codes are toxic and need special handling. 84-8. Sample for asbestos by conducting personal monitoring on Henry plant employees each time they remove asbestos-containing insulation. See Section 9 of BFG OHP manual for procedure. 84-9. Reduce benzene personnel monitoring to once per month per exposed job class when running X70/Geltrol process. 84-10. Reduce acetonitrile monitoring to once per year per exposed employee. 84-11. Reduce polymer chemical dust monitoring to twice per year per exposed employee. 84-12. Obtain personnel samples for toxic dusts during weighing and Henschel loading in compound. Compounds to sample for are chromates, nickel and cadmium. Sample three times per exposed employee. 9 for procedure. See BFG OHP, Section 84-13. Conduct personnel monitoring for nickel and hexavalent chrome during metal spraying operation being conducted in maintenance shop. Obtain three samples per exposed employee. See BFG OHP, Section 9 for procedure. 84-14. Require that employees conducting metal spraying operation wear a high efficiency particulate respirator until lathe is ventilated and monitoring does not show the existence of a problem. I am forwarding to D, Friesz a copy of the American Welding Society "Recommended Safe Practices for Thermal Spraying". 84-15. Conduct semi-annual ventilation flow checks and/or maintenance on compound weigh booth. Ventilation rates may need to be improved if personal moni toring recommended (see 84-12) indicates that significant exposures exist. 84-16. Modify plans to ventilate resin reclaim press dryer by providing for draft curtains on top and sides from the wall to the back side of the press. Such a "modified enclosure" would ensure that air exhausted from the press dryer area would be drawn through the press and out of the building. 84-17. Until resin reclaim press is ventilated, reduce bagger's exposure through use of respirators or improved work practices. 84-18. Require that employees engaged in blend tank cleaning wear an airline respirator (Sample //3, Appendix I). o C: ' O CO MC.C.(U 277 J Henry IH Survey; April 1984 3. Industrial Hygiene Audit Checklist Attachment I is the completed checklist for the 1984 Henry plant IH survey. The checklist is a guide that is used during the survey to ensure all areas of a plant's industrial hygiene program are addressed. The checklist is based on the BFG Chemical Group industrial hygiene program standard IH-101. Overall, the Henry IH program is satisfactory with 75 satisfactory areas (including the 24 satisfactory items from the hearing conservation checklist) and seven areas that need attention. In the first part of this report I detailed my recommendations to address these seven areas. In the following discussion I will elaborate on the recommendations that are not self-explanatory. Discussion: The administration of the Henry plant's IH program is functioning smopthly, but needs enhancement. The plant IH coordinator has developed skills through work experience, but has not attended a training course in Industrial hygiene. There is a vast amount of fundamental knowledge of toxicology, engineering, ergonomics and chemistry which the science of industrial hygiene requires of the practitioner that can only be obtained through formal training. Courses are offered by NIOSH, Natalsco and others in IH fundamentals and sampling procedures. The monthly environmental report issued by Henry plant was eliminated in December 1983. With the elimination of this report, the plant has no mechanism for in forming Chemical Group management or Environmental Health Department of employee exposure problems or control successes. A periodic report of industrial hygiene efforts is a valuable tool for getting the attention of upper management and keeping them attuned to Henry's unique industrial hygiene problems. The Henry plant industrial hygiene coordinators do an excellent job of a year-end summary of plant IH activities. The coordinators have also diligent in establishing goals for the following year. issuing been very One item identified under OVA as a possible cost savings was to eliminate the physical exams of employees that the plant is not required by law or BFG policy to examine. To help Henry achieve that goal, the plant nurse, along with the IH coordinator, must review the past two years of VCM personnel monitoring data and determine the jobs that expose workers to VCM above 0.5 ppm, the OSHA cut-off for the vinyl chloride physical exam requirement. People working on these jobs must, by law, be provided examinations. BFG OHP 5.02 also requires that employees who were exposed in the past (prior to 1967) on a routine basis to VCM above 0.5 ppm be provided a VCM physical exam regardless of their current VCM exposure. The Henry plant has identified all asbestos sources and implemented a removal and disposal procedure. Monitoring for personnel exposure to asbestos during insula tion removal was conducted four years ago. As a result of the mounting concern with asbestos exposure, it is in the best interests of the plant to document employee exposures to asbestos fibers each time asbestos is handled. o o o Henry has reduced the number of personnel monitoring samples collected for benzene, VCM, acetonitrile, PVC dust and oolymer chemical dusts. Further reductions are. still possible. 1 hove made recommendations to reduce monitoring frequency tor some substances. Reductions are possible that will save time and money, but stil 1 ensure that employee health is being protected. ''QC0127S Henry IH Survey; April 1984 Discussion (con't) 4. Thermal spraying or spray metalizing is conducted on an unventilated lathe in the machine shop. Depending on the type of metal being sprayed, workers can be exposed to the fumes of nickel, chromium, tin and zinc. Personnel monitoring on workers involved with spray metalizing on an unventilated lathe at the now closed Indepen dence technical center showed exposures to nickel to be above the allowable limit of 1.0 mg/M-^. Both nickel and chrome compounds are carcinogenic. As a result of personnel monitoring conducted by the plant, the resin reclaim bagger has been shown to be overexposed to VCM. I collected two personnel monitoring samples on the resin reclaim bagger during this survey; one was above 1.0 ppm, the other below 0.5 ppm (Appendix I, sample numbers 1 and 2). The VCM source causing the reclaim bagger's overexposure is thought to be the resin reclaim press on the second floor. Plans to ventilate the press, with modifications, should reduce the bagger's VCM exposure. Until engineering controls are implemented and monitoring shows that exposures are below 1 ppm, the resin reclaim bagger's exposure must be reduced through use of respirators and work practicef/administrative controls (OSKA VCM standard 1910.1017 (f) 5 (g). Samples 3 and 4 in Appendix I were collected on the poly cleaner job class in the PVC building. Both sample results were in excess of the standard. An airline respirator was worn by one employee (//4) during cleaning of two polymerization reactors. The other sample (#3), the employee indicated he did not wear a respi rator during cleaning of a blend tank. Respirator usage must be reviewed. The PVC bagger's result of 0.98 mg/M^ (#5, Appendix I) is low and demonstrates adequate control of PVC dust exposures. Samples collected in the polymer chemicals bagging area have not yet been analyzed. As soon as I receive the results I will forward them to you. Feedback: The following comments were made during the feedback session: 1. We need BFG employee exposure standards for 0BTS, MBTS, Superflex and Vanlube. 2. BFG needs an expert ventilation and noise control engineer. TSB 01 ;j0090 ^ ' NGC 01279 No. Date 1. 4/24 2 . 4/25 3. 4/24 4. 4/25 Name/SSft APPENDIX I. PERSONNEL MONITORING RESULTS Henry - April 1984 Job Sampling Time (min) Respirator Helper, bagging reclaimed resin 422 430 No No poly cleaner (cleaned blend tank) 385 No poly cleaner (cleaned 2 polys) 465 airline half-mask VCM (ppm)* 1.5 0.4 5.1 2.3 5. 4/25 6. 4/24 PVC bagger Compound operator 387 445 Total Dust** (mg/M3) No 0.98 No 4.93 *VCM samples collected on standard size charcoal tubes with MSA C210 pumps operating at 22-24 cc/rainute followed by G.C. analysis by Brecksville Environmental. Laboratory. ** Total dust samples collected on 5.0 1 PVC 3^ mm filters using duPont P-2500 pumps operating at 1.5 Lpm with gravimetric analysis. redacted c; & i o NGC MFdoodrich INTER-ORGANIZATION CORRESPONDENCE 1 ro m f r.uyp.r. FROM Bj.ana G. Friesz SUBJECT FIELD POINT OR DEPT & BLDG NO Henry FIELD POINT OR DEPT & BLDG NO Henry INDUSTRIAL HYGIENE UPDATE FOR THE FIRST HALF OF 1984 JUL 13 1984 DATE YOUR LETTER ; DATE THIS LETTER JuX%. 1984 Henry Plant personnel monitoring results for the first sx'"roonths of 1984 are summarized as follows: No. of Personnel Average Personnel Building Monitored _______Exposure I. NOISE (BFG Permissible Exposure = 50%) Poly Building (731) 11 66.7 % Dryer Building (732) 23 59.5 % Polymer Chemicals (712) 35 23.2 % MBT-C Building (711) 5 19-9 % 3114 Building (722) 4 20.8 % Boiler House (719) 1 31.7 % Weld Shop (723) 5 49.47 % * 'k Area monitoring in the weld shop indicates that personnel are receiving noise exposure while working in other high noise buildings and not in the Weld Shop itself. II. DUST/TOTAL (Permissible Exposure Limit = 10 rag/m3) Polymer Chemicals (712) Compounding (714) (025) Weighman (023) Henschel Operator 22. 4 3 DUST/RESPIRABLE (Permissible Exposure Limit = 5 mg/m3) 2.18 mg/ra3 0.73 mg/m3 2.11 mg/m3 Dryer Building (732) There were no single exposures limits. 6 exceeding the total or 1.25 mg/m3 respirable exposure III. BENZENE (Permissible Exposure Limit = 1) Po1yme r Chemicals X-70 Operator 0BTS Ope rator PC Ma intenanc.e (712) 50(total) 10 7 2 0.44 ppm 1.00 ppm 0.51 ppm 0.72 ppm All other job over 8 hours. PEL) . c lassifleations monitored were exposed les s than 0.5 ppm Benzene There were no single exposures exceeding 10 ppm (0SHA current ro o -\ o IV. ACETONITRILE (Permissible Exposure Limit = 40 ppm) 3114 Building (72?) 32 There were r.o single exposures exceeding 40 ppm. 7.6 ppm v- \ l' / /. / // V. VINYL ClIJ.ORnJjE ( Fv r m i'-. s 1 b : Exposin'" Limit - 1 ppm) PVO (i'olv and Drver Building) SO 0.76 ppm NCC 01281 2 Fifty-four percent of the Vcl personnel monitoring results were less than .5 ppm, 23.7% were greater than 1 ppm. Nearly one-half of the exposures greater than 3 ppm were from monitoring resin reclaim baggers. However, there may be an interference in the area which appears as vinyl chloride during analysis. Investigation of this problem is continuing. DGF:rdm Distribution: R.J. Grahek W ,W . Bispeck R.V. Tebbutt K. J . Willings T.S. BlaIke File Diana Friesz cn o j. o yGC 01282 On January 19-20, Cleveland Individuals - E. W. Harrington, W. E. Brodine, H. . Waltemate and T. R. Linak - audited the Henry plant. From this audit, T. R. Linak generated a list of projects which the plant was to pursue. This letter attempts to answer the progress on each item. I. Resolve concern that inclusion of recovery vent in common stack may ap proach explosive limit (Brodiue - Bixby), Action: A report was issued by Calsing which did not answer the total question concerning explosive potential. Based on THA monitoring, the plant determined that explosive limits in fact probably do occur. Steps to humidify and to control emissions with the aid of the T1IA unit are presently being pursued.. if fire escape near stripping columns can be used as a safe haven Action: Six hour sampling is presently being conducted to determine, the actual vinyl chloride concentrations. This monitoring will be concluded March 31 3. Resolve problem with safe havens by April 1, 1976 (Giffin) ., Action: The D.J, has been estimated (S5,000) to provide positive pressure in the north stairwell of the Poly Building. The recovery vents have been tied into the common stack to insure that first floor office area is safe. And the duct work has been fabricated and will soon installed to extend the third floor control room air intake. Confirm safety of air line masks in high VCM levels found in Paste polys (Giflin). Action: Activity has not been strong. Recently the plant received a special mask so that the monitoring can be done, K. D. Konter is setting up to do dual short term monitoring. Reduce breathing air header pressure and install individual regulators at stations (Giffin - Ehnle - Waltemate) .. Action: Present plans are underway to install a separate breathing header system throughout the Building, Each main header will be regu lated. However, individual stations will not. be held within the next, two to three in-mask sampling (Giffin): ?- Action: None. Presently, the alarm is at 5 ppm and will be set down to 1 ppm on March 15- 1. Exchange meeting minutes end pertinent data with other four plants (Giffin). Action: Each plant was sent the OSHA Review Manual and current reports are being shared. 8. Make recommendations regarding breathing air humidification (Giffin). Action: No humidification being planned until new breathing air system is installed. Based on future experience with new system, recom mendations will be pursued. 9. Go ahead with breathing-instrument air system design as agreed with W. E. Brodine (LaCosse). Action: E.A. has been submitted for approval. 10. Provide H. Waltemate with VCL Floor Procedure (Mussclman). Action: Complete. 11. Investigate and recommend system for continuous VCM monitoring at Tank Farm (Ciffin). Action: Plan to use TRA unit that will be freed up when Bendix 6000 chromatograph is installed to monitor Poly Building. 1.2. Furnish Cleveland Manufacturing with ACSP versus Lupersol 223 clean poly reaction time data (Prather). Action: Complete. .3 Check reason for delay in delumper installation and give to W. E, Brodine (Kemp), Actiony Contract has been, issued and work is in progress. 14, Check Delumper needs for G-90 job (Goode - Harrington). Action: G-90 project has been placed on Hold.. NGC oUfM 15, Change steam entry point to stripping columns by March 1 (Plant) Action : Other priorities have delayed this project, 16, Install permanent ventilation at VCM strai.ners and recovery pumps (Giffin). Action; Special contractor has .installed duct werk to all needed emission sources (blend tank catch strainers and homogenizers). Special ex hausting of recovery pumps has been postponed pending installation 17. Try double seals on one recovery compressor (Kemp). Action: Double seals have been received Cor one unit and work to install seals has begun, 18. Provide Cleveland Manufacturing with data regarding AVCM exposure problem associated ivith cleaning of Lo-Sope resin strainers (Edwards). Action: Complete. 19. Pipe VCM compressor relief valves to east side of Poly Building; however, find more permanent solution to pressure, surges on recovery pumps (Goode). Action: Relief valve project has been completed. Changes in the Recovery system are being made to prevent such emissions. 20. In Minutes of Ambient Task Force meeting of January 9, 1976, set target dates for projects 12 and 13 (Plant) . Action: Complete. Provide rupture disc assemblies on stripping columns with Gajdos flag de vice (LaCosse). Actio_n: At present no work has been done. Present Leak detection program will be adjusted to Identify and correct fugitive emission sources (Giffin), Action: None. Plant initiated histogram report. Therefore such identi fications, etc,, has been in use continually. 23, Henry Production-Engineerin g-Enviroumenfal representatives will visit the Avon Lake and Pedricktown plants for information exchange (Linak), Ac tion: Complete. R. K. LaCosse and D. F,.. G.iffin visited both plants. 24 v Fire-Safe Teflon 0-Rings and plug valve liners will be tried to reduce valve leakage (Plant.) . Action: Plant is presently pursuing the installation of butterfly valve for vinyl chloride applications P- Hopefully, the above will provid an up-date on Lhe projects outlined during the Audit. b"' / 1 DEG;vek E. W. Hat' r inglon T. R.. Li nak w. E. 3rodine H. Wa 1 tenia te L. V. Goode C. E. Kemp R I,. Eimie ft. A, Edwards R, K. LaCosse K, E. Muospl3i. D. E. Giffin G f ` {} f 285 TO: P. Donataccio FROM: D. G. Friesz 3/17/39 1988 INDUSTRIAL HYGIENE SUMMARY-HENRY PLANT During 1988, Henry Plant personnel were monitored for exposure to noise, vinyl chloride, toluene, acetonitrile, formaldehyde, heavy metals, dust (total FVC and total unspecified, and silica . The following exposure summaries reflect the results of this monitoring. I. Noise (C6HA Permissible Exposure Limit - 100% dose/90 decibels) (EFG Permissible Exposure Limit = 50% dose/85 decibels) IXiPont Mark I noise dosimeters were used to monitor 82 employees in different job classifications for noise exposure. The noise dosimeter is worn by the employee to measure his total exposure to noise over the work shift. All continuous, intermittent and impulsive sound levels are integrated during the monitoring period to provide the accumulative noise exposure in percent dose. Fifty-tro (63%) of the monitored employees exceeded the BFGoodrich exposure limit of 50% dose. Only fourteen (17%) exceeded the OSHA exposure limit of 100% dose. AREA *Fbly Bldg JOB or ASS NO. OF MONITORINGS EXPOSURE AVERAGE (%) NO. >50% DC6E WITHOUT HEARING PROTECTION HRC Poly Cleaner Blending Resin Operator Ebly Bldg Foreman Pearl Charge Operator Paste/LoSope Operator Valve Cleaner Recovery Operator 4 1 4 12 8 2 7 100.98 68.40 60.42 55. 06 54.14 47.85 44.79 1 0 1 1 0 0 0 *Dryer Bldg Dryer Operator PVC Bagger Dryer Foreman Silo Operator 10 114.58 0 2 110. 40 1 4 31.41 0 2 30.78 0 *Corqpound Bldg Relief Operator Mill Operator Henschel Operator Corrp. Packager Silo Operator 3 115.24 0 5 102.05 0 3 82.24 0 3 34.92 0 2 30.78 0 HEARING PROTECTION COMPLIANCE FOR AREA 86% 91% 100% VGC-' 012H6 NOISE EXPOSURE BY AREA (Continued) AURA JOB CLASS NO. OF EXPOSURE MONITORINGS AVERAS(%^ NO. >50% DOSE WITHOUT HEARING IBOIBgriQN HEARING PROTECTION COMPLIANCE FOR AREA Utilities Coal Boiler Operator Gas Boiler Operator 2 2 54.64 54.40 0 0 100% Polymer Chemicals (712) PC Bagger OBIS Operator Stalite/VanLube Operator 1 3 1 62.60 48.52 19.08 Indicates areas that are currently posted as "High Noise" and hearing protection required. Only the mill and henschel areas are affected in Coirpounding. II. DOST (Total Dust Exposure Limit 10 mg/U* Operators in the Confounding Building, Dryer Building, PC 712, Accelerator Expansion Building 725, and 3114 Building were monitored for total dust (unspecified or FVC). Most of these individuals were tagging finished product, but some of them were process operators. There were no individual dust exposures exceeding the specified limits. An K3A Flow-Lite sampling pump (set at 2 lpm flow) equipped with a PVC-5 filter inside of a three-piece cassette was used as the sampling device. TOTAL DOST EXPOSURES Type Job Clnfffi No. of Average Personnel Monitored Exposure PVC FVC Unspecified PVC Unspecified Unspecified Unspecified Dryer Operator (732) PVC Bagger (732) Henschel Operator (741) Contract Employees (732) PC Bagger (712,722,725) Mill Operator (741) OBTS Operator (712) 4 3 2 2 1 2 2 1.06 mgA& 0.74 mgyfap 0.69 mg/m3 0.57 mg/ri* 0.46 mg/fo 0.38 mg/ra 0,24 rag/raP III. CRYSTALLINE FREE SILICA (Respirable Fraction Exposure Limit = 0. 1 rng/toi3) Analysis of the coal boiler fly ash disclosed a crystalline free silica content of 28% in the combustion chamber fly ash. Because long-term exposure to crystalline silica can cause a chronic fibrogerdc lung disease known as silicosis, several boiler house operators were spot checked for silica exposure while loading fly ash from the silo to the disposal trucks. A monitoring punp (drawing air at 1.7 1pm flow) was set up to capture only the respirable fraction of the dust vising a cyclone collector and a PVC-5 filter. The filters were then laboratory analyzed for silica content. The results (as 10-hour TWA's) were 0.04 ard 0.16 mg/te3. XCC 01287 Since one of -the saiqples exceeded the permissible exposure limit, a sign warning of silica exposure has been posted at the entrance to the silo unloading area. Boiler House personnel have routinely used the 3M - 8710 dust mask for protection from fly ash dust. This mask is also rated for protection against silica at the exposure level found and will continue to be worn during fly ash exposure. IV. TOLUENE (Permissible Exposure Lindt = lOOppro) During 1988, personnel monitoring for Toluens exposure was done in the Polymer Chemicals Bldg. 712, the MBT-Crude Bldg. , the Laboratory, and at Waste Treatment. The monitoring results continue to show that there is little Toluene exposure. Spot check monitoring will be done on a monthly basis for a representative operator from the X-70/Geltrol processes, and quarterly for a representative operator from each other job classification that may be subject to Toluene exposure. AREA MBT-CRUDE Polymer Chemicals (712) PC Laboratory Wastewater Treatment PC Maintenance (in 712) TOLUENE EXPOSURE NO. OF tCNITORIflGS AVERAGE iarccMia x EXPOSURE (811 2 1. 00 8 1.63 1 1.00 5 1. 00 1 1. 00 Several Toluene monitorings were also done as area saiqples in the sludge dewatering building at wastewater treatment to check for off-gasing from the sludge. The average exposure detected for the area was 5.20 ppm. V. ACETONITRILE (Permissible Exposure Limit = 40 ppm) For 1988, the acetonitrile exposure average in. the 3114 Building (722) was 9.4 ppm. A quarterly spot-check monitoring is done of a representative operator in the area. Additional monitoring will be done whenever there is a process change or unusual situation that could cause acetonitrile exposure. VI. METHYLENE CHLORIDE (Permissible exposure limit = 50 ppm) The American Conference of Government Industrial Hygienists (ACGIH) has lowered the permissible exposure limit for Methylene Chloride from 100 ppm to 50 ppm. A quarterly spot-check saiqple is done in the Accelerator Expansion Building for Methylene Chloride exposure. The 1988 monitoring results show the average exposure to operators in the 725 building to be 1.55 ppm. Mcnitoring will continue at the spot-check frequency unless problems occur. VII. HEAVY METALS (Permissible Exposure Limits: ) Cadmium = 0, 5 mg/m? Chromium = (Hexavalent = 0.05 rag/ra?) (Trivalent = 0.5 mg/m?) Copper =0.2 rag/m3 Lead = 0. 05 rag/m? Nickel = 1 rag/ro? VGc 01288 Personnel in the Weld Shop, Maintenance Shop, and the Laboratory were monitored for exposure to heavy metals. A personnel monitoring purqp ( 2 1pm flow rate) with an 0.8 micron, mixed-cellulose ester filter in a 3-pieoe cassette was used, samples were sent to an outside laboratory for analysis. There were no exposures exceeding permissible exposure limits. HEAVY METAL MONITORING AVERAGE EXPOSURE (nw/W) JOB CLASS Service Shop Welder CAEMIUM 0.00016 CHROMIUM 0.00032 POPPER 0.017 T.RAT) 0. 00013 NICKEL <0.01 Malnt- Shop (Lathe Operator) 0.00051 -- -- 0.15 Lab Worker (Making up Premix) 0.00026 _ VIII. FORMALISHYIE (Permissible Exposure Limit = lppm) The 0SHA has established a new permissible exposure limit for formaldehyde which is set at 1 ppm. Because of formaldehyde off-gasing from the paraformaldehyde used to manufacture 3114, eleven representative monitorings were done in the 722 building. The average formaldehyde exposure to 3114 process operators is 0.13 ppm. Warehouse operators in building 712 were also monitored because of the paraformaldehyde skids that are stored in the area. This group's average exposure is 0. 05 ppm. Formaldehyde monitoring as area samples in the warehouse gave an exposure average of 0.24 ppm. The only area that is currently posted with the OSHA warning sign for formaldehyde (required for area above 1 ppm) is the paraformaldehyde storage room on the 2nd floor of building 722. DC VINYL CHLORUE (Permissible Exposure Limit = 1 pfan) All operators in the Poly and Dryer Building as wall as the FVC Tank Farm are monitored for vinyl chloride exposure at least once per year. The schedule of monitoring then follows the OSHA VC1 standard which requires monthly monitoring for any exposure greater than 1.0 ppm until two consecutive monitorings are less than 0.5 ppm. The employee need not be monitored again during the year if his annual monitoring result or the two consecutive monitorings are below 0.5 ppm. All VC1 monitoring samples were collected on Reiszner gas badges. y 1 n 1 i_i uniAjn 11 >Ci iJJMXii/rvxrnj i ro i v aim urver dlu.j-uingj, Year 1986 1987 TS89L IW5 No- of People Monitored 315 248 314 1.79 1.06 1.15 L % Greater Than 1 pop 40 21 27 Tton.,.0.5 ppm 30 58 48 '"^GC 1)1289 RESPIRATOR COMPLIANCE fFOT.Y BHTLDINm Year Ho. Of Exposures Greater than 1 doto No. of Exposures Greater than 1 w/o Resoi rator Respirator Comol ianne 1986 1987 1988 131 53 72 49 63% 15 72% 24 67% Tbs job class breakdown is as follows for Fbly Building employees exposed to greater than 1 ppn> VCL without the use of a respirator. JQB GLASS NO. OP EXPOSURE Lo Sope Charge Operator Recovery Operator Pearl Charge Poly Bldg. Foreman 11 09 03 01 There were 13 vinyl chloride exposures in the Dryer Building during 1988 that were greater than 1 ppm (since the last exposure on 11/09/88, there have been no new non-compliance exposures in this area). The job class breakdown is as follows: JOB CLASS HO. OF EXPOSURES Dryer Operator Bagger Dryer Foreman 3.1 ppm 1.7 ppm 1.2 pptn 09 * 03 01 *Three of these employees had entered the Roly Building during their work shift. Since several of the Dryer Operators who were exposed to VCL above 1 ppm had opened and flushed out BT 9 and/or 10 during the monitoring period, airline hookups have been installed on the 2nd floor near the manheads of these tanks. Two short-term VCL exposure samples that were taken during this task (with BT exhaust in operation) showed only 0.67 ppm and 0.53 pjpta. However, prior exposure checks using an OVA gave readings exceeding 1000 pptn at the open manheads when the BT exhaust was off. If BT 9/10 exhaust is inoperable, opening these tanks should be a respirator require task. For the year 1988, the overall Dryer Building VCL exposure average out of 93 samples was 0.51 ppm. During 1987, 74 samples gave an exposure average of 0.35 ppm. ,\Gc <>I29() VINYL CHLORIDE EXPOSURE BY JOB GLASSIFICATION JQB CLASS Poly Cleaner PVC Tank Farm Operator HRC Fbly Cleaner Recovery Operator Pearl Charge Operator P&st/LoSope Charge Dryer Operator Poly Bldg. Foreman Valve Cleaner PVC Bagger PVC Contract Employees (Baggers) Blending Charge Operator Silo Operator Dryer Bldg. Foreman Catalyst Make-Up PVC S&E Operator MONITORINGS 11 04 20 41 57 37 46 12 05 38 20 01 12 10 02 02 NO. Q AVERAGE (FFtL) 4.15 1.81 1.42 1. 40 1. 12 0.99 0.72 0.71 0.53 0.51 0. 44 0. 43 0. 33 0.28 0.27 0. 12 X. EMPLOYEE TRAINING As required by the QSHA Hazard Communication Standard (HAZCOM), training is given to employees who may be exposed to hazardous chemicals as new-hires before they start work in the plant, when they transfer to a different work area, when a new chemical hazard is introduced into the Plant, and then on an annual basis as a refresher coarse. During 1988, 306 Henry Plant Employees were given HAZCOM training. Two employees (PC & Maint.) missed the annual training and could not be scheduled into a makeup session. Hearing conservation training is given annually to all employees who work in areas where the noise level exceed 85 decibels. There were 158 employees trained during 1988. No employees missed the scheduled training sessions. XI. CONCLUSION The roost serious industrial hygiene problems in the plant continue to be noise and vinyl chloride exposures greater than 1 ppm without respirator protection, particularly in the Dryer Building which is not a regulated area. In both the Boly and Dryer Buildings these exposures seem to predominate in certain Job classifications. Although many of the operators list "no known VCL exposure" for the monitoring period, I think that we need to look closer at the individual tasks that they perform during the work day. Some of these tasks may already be "respirator required". In this case employee review training for respirator use requirements may be beneficial. ln/E259 Diana Friesz iiFGoodrich INTER-ORGANIZATION CORRESPONDENCE TO M. E. Guver FROM -- Plana Friesz_________ SUBJECT FIB.D POINT OR DEPT. & BlDG NO FIELD POINT OR DEPT. & BLDG. NO INDUSTRIAL HYGIENE UPDATE FOR THE FIRST HALF OF 1988 DATE YOUR LETTER DATE THIS UTTER 8/4/88 Henry Plant personnel monitoring results for the first six months of 1988 are summarized as follows: I. NOISE (BFG Permissible Exposure Limit = 50% dose) (C6HA Permissible Exposure Limit = 100% dose) Job Classification No. of Samples Average % Dose Noise Exposure Mill Operator Dryer Operator HRC Poly Cleaner FVC Bagger Poly Building Foreman Faste/LoSope Charge Operator Pearl Charge Operator OBTS Operator - 712 Henschel Operator Valve Cleaner (5536) Recovery Operator Dryer Building Foreman Compound Packager Silo Operator Stalite/VanLube Operator 3 *4 3 1 4 8 11 2 1 2 7 4 2 1 1 111.08 105.6 86.04 69.00 60.42 55.14 53.00 55.98 48.36 47.85 44.79 31.41 30.42 30.36 19.08 TOTAL SAMPLES 54 Of the 54 noise exposure samples taken, 25 (46%) exceeded 50% dose and 3 (6%) exceeded 100% dose. Three of tbs greater than 50% dose sanples occurred without the use of hearing protection. This puts hearing protection compliance at 88% for those areas where it is required. There were no exposures exceeding 115 decibels which is the limit specified by C6HA that should not be exceeded regardless of the exposure duration. II. EU5T/TOTAL (Permissible Exposure Limit = 10 rcg/ra3) Job Classification No. of Samples PC Bagger OBTS Operator 1 2 Average Exposure 0. 46 rog/m3 0.23 rag/ro3 BFG'495-E iM D Pnolirvfl Co , Herr>, in 5JSJ? ,N|GC 01292 2- - III. TOLUENE (Permissible Exposure Limit = 100 ppm) Job Classification No. of Samples MET Crude Operator X-70 Operator Geltrol Operator PC Maintenance Wastewater Treatment Operator 1 2 1 1 4 Average < 1 F < 1 ppm < 1 PPO <1 pm <1 Mm IV. ACETONITFmS (Permissible Exposure Limit = 40 ppm) Operators in the 3114 process building were spot checked for Acetonitrile exposure. The average exposure was 9.4 ppm. V. METHYLENE CHLORIDE (BPS Exposure Limit = 50 ppra) Operators in the 725 A/E building are spot checked for methylene chloride exposure. The average exposure was 1.55 ppm VI. FORMALDEHYDE (CSHA Permissible Exposure Limit = 1 pe) 06HA has issued a new standard for formaldehyde which lowers the permissible exposure limit to 1 ppm and requires initial monitoring in areas where formaldehyde may be present. In order to meet these requirements, representative operators were monitored in the 3114 process building and in the PC Warehouse. There were no exposures in either area that exceeded 1 ppm. The maxinum exposure was 0.18 p**n received by a 3114 process operator. Remonitoring will be done periodically in order to ensure that the exposure level has not changed. Job Classification No. of Average Exposure 3114 Operator PC Warehouseman 5 0. 09 pgm 2 0. 05 ppm VII. HEAVY METALS (Permissible Exposure Limits; Copperfume - 0.2 Eg/m? Cadmiun - 0. 05 ng/ra3 Chromium (Hexavalent) - 0.05 mg/to? (Trivalent) - 0.05 mg/nP Lead (Inorganic) - 0.03 mgAt? Nickel -1.0 ng/rtf> Maintenance personnel in the service shop area were monitored for heavy metal exposure as they were performing routine activities including welding, grinding, and cutting, and spray painting. None of the individual exposures exceeded the permissible exposure limits. .N'GC 01293 -3- Heavy total Copper Chromium Lead (inorganic) Cadmium Nickel No. of Personnel Monitored 5 5 1 4 5 Average RXTXXHJTft 0. 017 rrg/ro3 0. 003 rog/ra3 <0.001 mg/m3 <0.001 mg/ro3 <0.01 mg/m3 VIII. VINYL CHLORIDE (Permissible Exposure Limit = 1 pe*d) Job nation No. of Samples Average Poly Cleaner Pearl Charge Operator FM2 Bagger Recovery Operator Paste/LoSope Operator HRC Poly Cleaner Dryer Operator Silo Operator Valve Cleaner Catalyst Make-up Dryer Building Foreman Poly Building Foreman Environmental Operator Wastewater Treatment Operator 3 10 7 8 5 2 12 4 1 1 1 3 1 3 3.47 1.12 1.01* 0.96 0.89 0.88 0.74 0.48 0.46 0.41 0.34 0.25 0.12 0.09 TOTAL 61 Exposure of FVC baggers to vinyl chloride is of concern because their wsrk area is not "regulated" for VCL. Of the seven PVC baggers monitored this year, two were exposed above 1 ppm and three were greater than 0.90 ppm. There were also two dryer operators who were exposed to VCL above 1 ppm. All of these exposures occurred without the use of a respirator. Of the sixty-one personnel monitorings for VCL collected during the first six months of 1988 , 38 (62%) wsre between 0.5 ppm and 1 ppm, and 13 (21%) exceeded 1 ppm. In the Poly Building which is a VCL regulated area, nine samples exceeded 1 ppm. Five of these occurred without the use of a respirator. IX. SILICA (Permissible Exposure Limit = 0.1 mg/m?) Two coal boiler operators were monitored for respirable dust exposure. The filters from these samples ware then sent to an outside laboratory to determine crystalline free silica content. One sample was analyzed at 0.04 mg/raP free silica and the second at 0.17 mg/m1 (which exceeds the exposure limit). Disposable 3M-8710 dust masks ware worn by the utility operators during exposure to flyash dust. Additional monitoring will be done when the coal boiler starts up following the maintenance shutdown. ^GC 01294 -4- X. CONCLUSIONS Exposure to noise and vinyl chloride, particularly VCL in the Dryer Building, are the main areas of industrial hygiene concern at the Henry Plant. Compliance with hearing protection requirements for employees working in posted areas should be 100%. There continue to be some instances where hearing protection is not being worn. Most of the high VCL exposures in the Dryer Building still appear to be traceable to the resin reclaim process. All four of the greater than 1 ppm exposures occurred on days then B grade material was run in resin reclaim. Date Operator Job Exposure R/5 Status *2/24 Bagged LoSope on #1 and #2 Spray 1.0 ppm Running 171 (B) 3/2 4/22 6/10 Bagged 178 Worked In UF Bldg, and Spray #2 R/5 Operator, Unplugged head tank four times 1.7 ppm 1.9 ppm 1.6 ppm Running 178 (B) s*/ *3 Running 171 (B) wixo eu&Kua m'^rrulX- ***! Running 173 (B) Another Dryer Building Bagger had an exposure of 0.91 pew on this day. The other two higher VCL exposures in the Dryer Building (0.95 ppm and 0.99 ppm) occurred when B grade was running in resin reclaim on 3/1/88. This was also the time that the resin reclaim dryer oppressor was down and pressed resin was being stored in gaylord boxes in the dryer building warehouse. OVA checks around these boxes several weeks later still indicated higher VCL levels which may have contributed to employee exposure. In the Poly Building, some of the greater than 1 ppm VCL exposures without a respirator are traceable to the employee performing a task already identified as 'respirator required" without wearing the proper protective equipment. These situations are handled by passing the information along to Roly Building management who then discuss the problem with the employee. Since the number of building lights continues to be low, the source of VCL for the remaining exposures is unidentified. rdl/E177 REDACTED Diana G. Friesz 01295 cc: Bi J, GiuHOll ' P. Donataccio K.J. Hillings Tfl Hullin (01.u uluuii) V. D. Marquis R. C. Linnerean M. H. Reynolds M. A. Ackerman J.F. Griffin D. L. Rys D.K. Giffin R.D. Webber W. J. Grudzinski riarty jr cjt&o/xfro NGC 01296