Document GGdy1gX1xkXeZw3JKvDzMQ3n

;. 1' '; r\ R 8 IOE COPPOPA i'lON ( tr::.'i 1 i,,u 1 s A* i 1 us'" L : ** 2 70 Park Avenue .'.ew fork, ;,cw York 10Ul7 To: (See Attached Distribution List) Date: August 9, 1974 From: Dr. A. B. Steele Subject: Vinyl Resin Operations Flash Report Vinyl Chloride Monomer Proposed Permanent Standard on VCM Emissions Not Achievable Through Known Technology The OSHA Act requires the Secretary of Labor to adopt feasible standards which are generally understood to represent technologically achievable condi tions. In proposing the standard of a non-detectable exposure level with re gard to vinyl chloride, the Secretary has not taken into consideration the over whelming engineering and technological data which decisively establishes that the proposed exposure levels are not attainable through engineering controls and work practice methods; the standard simply cannot be implemented by such means. During the past two months, the Operations group has reviewed the most advanced engineering technologies and systems design presently known. It is our judgement that it is technologically impossible to meet the non-detectable exposure level required by the proposed standard through engineering and tech nological means regardless of the amount of capital expenditure that might be made to improve and renew existing plants. This judgement leads to the con clusion that Carbide would have no alternative but to cease all polyvinyl chlo ride manufacturing operations if the proposed standard is adopted. After analyzing the many complex engineering factors involved, we con clude also that it is presently impossible to predict whether any exposure Level below 50 ppm can be reached until additional equipment has been installed and the designed changes accomplished. This conclusion has been communicated to Foster D. Snell under contract to OSHA to determine technical feasibility of the proposed standard. 1,400,000 pounds of vinyl chloride monomer was purchased from Rcfcintech, Inc. to provide material owed Conoco for shipment in late August and early Sep tember as replacement for the Conoco lifting of a like amount of VCM to Brazil during July. inventory at South Charleston is 1,435 M pounds. Susnensior./Non-Solvent Resins Suspension/Non-Solvent production is running at a 14.3 million pound monthly rate, Approximalely two days of outage have been experienced so far this month in the suspension operation due primarily to VCM shortages but six teen hours was due to a brine header failure. The plan for the month, including the various agreements for ohtaining additional nonomcr will permit the produc tion of approximate ly 14,100 M pounds of resit, in 1'IC 282. UCC 095286 *2- Dispersion Resins tem. Production was 80% of plan due to mechanical failures on the drying sys The new catalyst unit is 99% complete, and operating procedures are being written. The Plant inspection for three days by OSHA proceeded smoothly. ABS :ml A, B. Steele UCC 095287 DISTRIBUTION LIST -- WEEKLY FIASH REPORT -- VINYL OPERATIONS TO: Mr. E. Bell Mr. G. P. Bigelow Mr. P. E. Bouffard Mr. L. D. Burnett Mr. J. L. Carvajal Mr. D. Engle Mr. E.F. Cox Mr. R.G. Davis Mr. M.E. Eisenhour Mr. C.R. Field Mr. R.L. Frantz Mr. J.E. Giffin Mr. R.J. Hanna Mr. J.M. Herbert Dr. M.H, Jellinek r. W.R. Manning Mr. S. A. Mortimer Mr. J. Nesmith Mr, G.J. Norberg Mr. G.T. Scott Mr. G.C. Shipaton Dr. A.B. Steele Mr. G.F. Tacquard Mr. R.N. Wheeler Or. V.Z. Williams 312 33 28 28 514 515 312 312 515 28 515 514 511 28 32 511 28 33 28 28 28 28 515 514 28 Bound Brook (Bldg. 72) New York Office New York Office New York Office South Charleston (Plant) Texas City Bound Brook (Bldg. 200) Bound Brook (Bldg. 72) Texas City New York Office Texas City South Charleston (Plant) South Charleston (Tech Center) New York Office New York Office South Charleston (Tech Center) New York Office New York Office New York Office New York Office New York Office New York Office Texas City South Charleston (Plant) New York Office Ucc 095288