Document GMBOkExMjByLwdEXKyGdRZLx

0o Statement n,< by rt~~3l. r11 t-- The Goodyear Tire fit Rubber Company ,, *-tx> , For the following reasons, The Goodyear Tire fit Rubber Company is submitting in writing its statement on the proposed standard for occupational exposure to vinyl chloride, and is foregoing its allotted time for oral testimony at the Department of Labor hearing; + 'm ' 1* The company, prior to this statement, had three of5its people testify at the hearing. Paul Beebe, Jr., development manager, films and flooring division, gave testimony as part of the SPI portion, William R. Miller, manager, corporate safety, and Dr, C.W, Wadelin, section head, analytical services, offered testimony during the RMA segment. 2, Medical reports at Goodyear operations already have.been covered by Dr. Selikoff's group, 3. Bulk of material in this statement of most va^ue is contaiped in. appendices and tables, 4... Submitting written testimony will not burden the record, and is done with the intent of expediting the hearing. After reading the statement that follows, if members of the Labor Department hearing committee have questions that they feel call ,for oral answers, Goodyear personnel certainly will be available to offer any additional clarification required,. Vv t ' Goodyear is a multinational company with annual sales of approximately $5 billion. The company* s major activities are in tires, industrial rubber products, automotive and aircraft wheels and brakes and numerous other related products. ' ***' In our chemical operations we produce various synthetic rubbers, rubber latex, polyester resin and rubber chemicals in addition to * PVC resin. We estimate that Goodyear will sell more than $100 million worth of PVC and fabricated PVC products during 1974 -- about 2 per cent of total annual sales. 100234 (more) \ C) 2- Nearly 20 per cent of the resin we make is used by other divisions of the company. Approximately 2,000 Goodyear employes are engaged in the manufacture of PVC resin or in making products *1 which use it. The remaining 80 per cent is sold to 300 customers, many of whom operate small businesses. t Should it become necessary for Goodyear to discontinue PVC resin production, 2,000 jobs within the company would be eliminated. And many times that number by our customers. , Goodyear operates two PVC resin producing plants, one at * 7 Niagara Falls, N.Y., and another at Plaquemine, La. Until 1966' s we produced vinyl "chloride monomer at Niagara Falls by "the acetylene^iydrochloric acid process. We now purchase VCM` from suppliers using the more modem ethylene-chlorine process. During the question period following Dr. Selikoff's testim ny, there arose a question concerning chlorine in the atmosphere* We did u'se HC1 in the production of VCM until 1967. "The monomer process did involve venting detectable quantities of HC1..- There is also el disceraable background of Cl or HC1 in the HF 'area. We have no evidence to indicate that chlorine is a factor in employe health problems, but its presence during the early periods cannot be. ignored. The Niagara Falls plant was built in 1946 with an initial annual capacity of 1,400 long tons. Present capacity is 50,000 long * tons. Several different types of homo polymer resins are manufactured in the plant by the emulsion and the suspension processes. '* 100235 (more) We have produced PVC compounds at Niagara Falls since 1971., Rubber chemicals also are produced in an area separated rom the PVC plant. Functions such' as maintenance, utilities, laboratory ,i and administrative are common to all manufacturing operations. Total employment at Niagara Falls is 465 persons, 345 of`them engaged exclusively or predominantly with PVC production* The Plaquemine plant started in 1969 with a capacity of* " 20.000 long tons a year, and soon will be producing more than 100.000 long tons annually. VCM is brought into the plant by V pipeline on a continuous basis eliminating tank car unloading and necessitating only small storage of the monomer. Plaquemine uses * a- bulk polymerization process licensed to Goodyear by Rhone-Progil 4 of France, a two-step batch process in which no water pha,se is involved, eliminating drying of the finished product. When we learned last January of a possible connection between vinyl chloride monomer and angiosarcoma we began a program of. physical Examinations of employes at Niagara Falls and Plaquemine and a review of the medical records of past employes. Screening tests for liver function among Plaquemine employes has revealed no abnormalities and a heightened medical surveillance program is continuing, .Because the reactors at Plaquemine are in ai} open structure, and the process and equipment are new, we believe that past levels of employe exposure to VCM has been low. Although the Instruments used to monitor VCM prior to March m* were not sensitive to lower levels of VCM, the measurements did indicate that worker exposure was well within 200 ppm TWA level. Recent surveys of all operators on an 8-hour TWA basis shows'a mean of 7 ppm with a range of 1 to 28 ppm. 100236 (more) -4- During the some period spot checks showed a range of 0 to 159 ppm with an average of 13 ppm. The reactor building currently in operation is an open structure. The 8 hour TWA mean for all operators working in this building is 8 ppm with a range of 1.4 to 28 ppm over a 2/f-day period. While there is some difference in job.-to-job TWA levels, the major difference is in day-to-day variations on a given job. The data summary is given in Appendix 1 which is .attached to this testimony. Being an open structure means that very little improvement in % exposure levels can be accomplished by forced ventilation. Rather, any reduction in the level of VCM in the reactor building must .be ** accomplished by reducing emissions. A recent survey which is summarized in Appendix II of this testimony shows that of the total 3.3% loss of VCM in the process, 1.6% is in fugitive emissions i the remainder being vent losses. *In order to meet the 1976 target 10 ppm max.,\ a TWA mgjm of 5 ppm or less will be required. To meet this level will require capturing'virtually all of the vent losses and also a substantial reduction in the 1.6% fugitive loss. While projects to accomplish these goals are being pursued vigorously, not all technology is now in sight. All Niagara Falls employes have been given thorough medical examinations by a medical team from New York City's Mt. Sinai Hospital and locdl physicians. The results have been reported by - Dr. Selikoff and Dr. Nicholson in their testimonies. While there were some indications of abnormal liver functions there were, no indications of tumor development among active employes. An ongoing medical program has been established, 10023*7 Q -5 An extensive review of the medical records of deceased Niagara Falls employes was undertaken earlier this year and revealed three deaths attributed to angiosarcoma. These deaths were disclosed publicly and reported to N10SH as they became known to us: One on March 1 and the other two on March 22. They involved: *The 1968 death of a 59-year-old man who .worked 12 years in the plant's original (1946) reactor area, three years in the new reactor area (added in 1957) and two years in resin finishing. j *The 1961 death of a 41-year-old man who worked for 10 ..years in the original (1946) monomer production and reactor buildings 'and another four years in other plant areas where VCM concentration was lower. - * -pP *The 1970 death of a 60-year-old man employed 23 years as a tV* supervisor in the original (1946) reactor and monomer area, nine . * ** of which he also spent, supervising the new monomer and reactor facility. We estimate that he spent two-thirds of his time in the older fanility> With confirmation of these deaths, we began a study at Niagara * Falls aimed at determination of the VCM levels in the areas where these men worked and during the years when they worked there. Our best estimates -- based on available statistical data plus extensive interviews - of 24 long-time Niagara Falls employes -- indicate that the time weighted average exposure for the years that the three deceased men were employed was approximately 500 ppm in the original (1946) monomer and reactor areas, approximately 150 ppm in the newer (1957) monomer and reactor areas and less than 20 ppm in th resin finishing area. (more) 100238 o -6- Using these figures weighted for the amount of time that ' each of these men spent in the various areas we estimate their average exposure to be: Employe no, 1 - 380 ppm TWA for 17 years A Employe no, 2 - 360 ppm TWA for 14 years Employe no, 3 - 450 ppm TWA for 23 years pp W ' In arriving at these, estimates of exposure, 'we used a threshold odor level of 450 ppm. Because recent information ^indicates an odor threshold considerably frigher than 450 ppm ih areas where VCM is present, our estimates may be quite conservative. Since April we have been engaged at Niagara Falls: in extensive */> monitoring -- both on an area basis and on an individual ^worker basis. By correcting emissions and improving ventilation and work practices, we have drastically reduced the level of VCM*. * Since the issuance of the temporary 0SHA standard on April. 5, 1974, *we generally have been able to stay within the 50 ppm ceiling, although surges have necessitated the use of ^' masks for short periods. Trouble spots such as leaking compressor seals and valves have been pinpointed and corrected. Work practices have been thoroughly reviewed and those procedures that permitted VCM to be vented to the atmoshpere were changed to minimize worker exposure. Substantial improvements in the plant ventilation systems have been made to remove VCM from the work area. (more) 10023S o -7- Current samplings using gas chromatography in both of the* plant reactor buildings now show a time weighted average mean f 9 ppm of* VCM. The range of the samples -- excluding periods when masks were worn -- was l to 45 ppm. Based on these data]; we conclude that the exposure during the working' life of the three employes who were found to have angiosarcoma was at least 40 times greater than it would be under the emergency standard of a 50 ppm ceiling, I emphasize that I am talking about a PVC producing plant.' 1\ Theoretically it would be possible to approach a 50 ppm time weighted average while staying within a 50 ppm ceiling. Such * would be possible if the release of VCM were consistent and the ventilation constant. The nature of the PVC reactor operations, . together with the fugitive nature of VCM, causes peaks and valleys in the exposure curve. Occasional short term surges also must be expected. In bur opinion a 50 ppm ceiling in a closed reactor building can be equated to a mean TWA of 10 ppm with the range Of TWA samples covering from just detectable to 25 ppm -- depending upon the assignment of the employe and the number of fugitive emissions in his area. While there are no data which support a position of a "safe" level of exposure to VCM from the standpoint of worker health, we believe there is conclusive evidence that the level of exposure has been reduced -- at least in our Niagara Falls plant -- to a level that is so small by comparison with previous levels as to make worker exposure within acceptable limits. (more) 100240 \ t G -8- Putting it another way: Under today's conditions and within the emergency standard, 600 years would be required for a worker to reach the same total exposure to VCM as was experienced by the three angiosarcoma victims at Niagara Falls, I hasten to add that I am fully aware of the hazards, of any conclusions until we know more about the effects of VCM, I do hope that this discussion will put the incidence of angiosarcoma 'among Niagara Falls workers in proper perspective, that is: The exposure of workers developing angiosarcoma in Niagara Falls was conservatively estimated to be in,the vicinity of 400 ppm TWA as compared to 9 ppm TWA when operating under today's* emergency standard. Appendix 3. contains monitoring data, a summary of measurement methods used, *.. and the, procedure for estimating exposure levels. In. the last few months we have learned a great deal about the sources of VCM in our Niagara Falls and Plaquemine operating areas and much, has been done to eliminate as many of these as possible. We plan to lower exposure levels still further using every available scientific and engineering technique. ^However, technology needed to reach the proposed "no detectable" jy level is not now available to us. And we question that it can be developed for existing plants. The proposed regulation permits use of breathing equipment only in the case of emergencies. Even if this restriction were lifted, continuous use of breathing equipment which would be required under the "no*detectable" level proposal cannot be ' considered practical. Continuous use of any type of respirator -- particularly full-face, self-contained types would; seriously impair a worker's' ability to do his job and would pose unacceptable risks and worker discomfort. r____ \ oo -9- For these reasons, we see no alternative but to discontinue the operation of our two PVC plants if the "no detectable" standard were imposed. We are not convinced that medical evidence available today warrants such stringent restrictions, but we do believe that the risk -- if any -- that would be involved in setting a reasonable standard permitting continued operation of PVC producing plants would be so small as to be acceptable* We endorse the SPI recommendation of a graduated standard which would establish a ceiling ofP40 ppm and a TWA of 25 ppm for the first year, a reduction to a*^5 ppm ceiling the second year and a 25 ppm ceilingwith a TWA limit of 10 ppm the third year* * *. These limits will involve technology not available today, but we are confident it can be developed. .`V The attached Appendix 4 lists the engineering projects that, have been undertaken to reduce VCM in the work areas. They will elimin*ate -the necessity to enter reactors for clea*ning, reduce residual VCM in resin, recover VCM stripped from resin and improve monitoring procedures. Also listed are a number of engineering considerations now under evaluation. These programs axe aimed at achieving the recommended target levels. To meet a "no detectable" level within the plants, if possible, would require engineering * approaches beyond those listed. We are spending more than $1 million on these improved production safeguards. Considerable additional expenditures will fund our medical surveillance programs. (more) 100 -10- There are other areas in the proposed standard such as the; concept of regulated areas, monitoring provisions, the use of impervious clothing, product marking and notification requirements that will per se be changed if a reasonable exposure level is adopted. Specifically, the requirements that regulated areas be established where vinyl chloride monomer is present are far too restrictive. Because of its fugitive nature, the amount of VCM that can be transported from one area to another by dust on ; I clothing is so small as to be negligible. The purpose of limiting the number of people authorized to enter an area where VCM is * j present* in larger quantities -- such as a reactor area -- should be to limit exposure in case of an accidental releases This can be accomplished by designating such areas as restricted areas in which only persons who have duties in the area are permitted. Previous testimony has pointed up that VCM contained in resin dust on clothing will dissipate to below detectable levels in minutes. Thus, the decontamination procedure specified for ' regulated areas is redundant. The monitoring requirements in the proposed regulation call for a procedure that would assure any exposure for an employe be determined at a 95 per cent confidence level. This requirement is ambiguous. A more precise statement of goals taking into account the limitations of sequential monitoring is needed. (more) 100243 -11 The .required use of impervious clothing should be limited to very high VCM levels or to operations of short duration where there is a potential of' high levels of VCM. This type of clothing cannot be used for prolonged periods, particularly in hot climates, without extreme discomfort. Heat prostration and limitation of movement imposed by impervious clothing would create additional hazards. - We endorse the SPI position on product marking. Our experience in the use of PVC resin in films and flooring -- covered *' in earlier testimony -- leads us to conclude that exposure to VCM from the use of PVC* resin is negligible if simple precautions in unloading, storing, and mixing are taken. The reporting requirements are ambiguous. Reporting should * `4 9* follow the NIOSH March 11, 1974, definition of an emergency. Since employes have access to exposure measurements, the necessity to report in writing each incident of exposure is excessive. A number of improvements have been made in recent weeks in lowering he VCM content of PVC resin. Appendix 5 shows data at previous versus current levels of residual monomer in the various types of resins* The drive to lower VCM content of resin started about 2 years ago when it was discovered that concentrations in V the explosive range could accumulate inside of processing equipment if the residual VCM was very high. Thus the levels in early 1974 reflect a reduction from previous years. (more) 100244 -12- Our data shows that we have been able to lower the VCM level in the general purpose suspension and bulk types from a level of over 800 ppm to under 200 ppm. Modifying resins were lowered from over 1100 ppm to 320 ppm. Flastisol resins of the types ye made have been low consistently with the current level averaging 4 ppm. It should be noted-that we do not produce copolymer resins, some of which we understand cause difficulty in removing VCM, We are safely under the recommended 0.1% max at the present time and believe that we can reach a level of 0,01 max by the * t'arget. date, if not sooner. It is our intent to continue to push programs designed to obtain that goal at the earliest possible date, Wei strongly urge that 0SHA reconsider its position as Vk presented in the proposed standard by taking into account the serious impact that the elimination of the PVC industry would have on the nation's economy. We are firmly convinced that reasonable standalrds and working rules can be developed that w* ill permit the continuation of a safe and viable PVC industry. We appreciate this opportunity to express our views. Thank you. -0- rr 100245 o APPENDIX I Distribution of Vinyl Chloride Concentration Data Plaquemine, La. *< In the attached tables are summarized (L) the data for levels of vinyl chloride in plant air at Flaquemine measured over the period of May 1 to June 26, 1974, and (2) eight-jiour TWA values for air samples taken from the breathing zone of Plaquemine. employes during the period of May 15 to June 11, 1974, Plant air ** - "data were determined from "grab" samples directly injected into the Hewlett-Packard Model 7620 Gas Chromatograph. Personnel monitoring samples were taken at the rate of 1.9 liters per minute \ and absorbed on 16 grams of 20 x 50 mesh Nuchar activated carbon, then desorbed in carbon disulfide prior to injection into the chromatograph. *Eliminated from the plant air data were thos\e samples taken at work stations during periods where employes routinely wear air-line respirators -- during catalyst addition and reactor cleaning. 100246* o Table I -- Vinyl Chloride Levels in Plaqueraine Areas (non-respirator areas -- grab samples) May 1 -- June 26, 1974 Location -- Operation Viftvl Chloride -- PPm Median Low High Day Tank Area Compressor IK-1 ,, Compressor 2K-1 VP Seal Discharge Blowgr Discharge Popo .Sampling 109/209 Blind Warehouse (a) Laboratory (b)- (b) * " . (b) Office (b) Pumping VC De-gas De-gas De-gas During Cleaning Before Discharge Changing Blind Aisle Workbench Office CompositinVg Samples Center of Area 3.4 0.0 71.6 7.0 0.0 136. 3.0 0.6 31.4 8.4 0.3 159. 7.0 0*9 34.0 4.5 . 0.0' 46.5 9.3 0.4 137. * 5.2 0.0 7.7 4.0 Not Applicable \ 1.7 < 6.4 it 2.1 (t it (a) Four samples only (b) One sample only 100247 Table II -- Distribution of Data -- Plaquemine VC Levels ' 110 Grab Samples Hay 1 to June 26, 1974 Minimum Value Maximum Value 0.0 ppm 159 <- pipm 10% of samples showed VC levels of 0.5 ppm or les 20% II II ii IV II i 1.1 II If <1 30% V| If ii IV ii 1.7 IV If ff 40% l| It ii II ii 2.9 II IV If *50% 1 60% II 9> II ii II If > 4.0 II If # ii II I ii 6.4 If IV ii*>' 70% II II VI II If ii 9.7 II If ao%` II If IV II If ii 14.9 11 II it 90% II 95% t . 1# IV If If ii 26.2 II II n II II II 39.7 II4 ft ii II II II II II i 71 C II II i Similarly: 3.64% showed VC levels greater than. 50 ppm 4.55% II 9V II II II 40 11.8% 1 IV II If II 25 i 30.0% II IV If II 10 i 42.7% If If 11 If II 5 ii 81.8% II If II VI II 1 t 100348 Table III -- Distribution of 8-HR TWA Levels Flaquemine Employes -- 45 Samples May 15 - June 11, 1974 Median 4,9 ppm Range <0,1 -- 27.9 ppm ' *! 10% of employes had TWA values of 1,2 ppm or less 20% tf H ft tf tt If 1.5 ft it i 30% If >t tf tf ff 2.3 ff ti. ii 40% ff . ft *50% If U ft M ft ff tf ` tf ff 3.2 tf tt 4.9 ft <t it it *i#t 60% ff ft ft ft tt ff 5.9 tv it .1 ` 70% ff tf ff tf tt If 7.8 It it II 80% ft If if Vf ff 10.2 ft it IV 90%. ff ft ft ff If ff 14.0 ff it ft 95% ft ff tf tf tf It 21.1 t ** it tt ^97.5% It j ff ft ff tf 27.9 tt ii ft *v ^ Similarly: None had. TWA values greater than 50 ppm 2.2% ft ff ff If ft 25 H 22.2% ft tf ft If If 10 it 44.5%`- ft tf If IV ff 5 ii 91.1% ff ff tf tf ft 1 I *r 100249- Table IV --. -Distribution of Plaquemine TWA Values by Job Classification Job Classification *Reactor Cleaner *Poly Area Operator *0utside Operator Finish, Bldg. Operator Loading-Rack Operator Control Room Operator A* " Supervisor Tech, Supt. (in plant) TOTAL Number of Values Vinyl Chloride -- ppm as TWA Median Low High 21 6.3 1.4 ' 27.9 4 11.4- 4.2 23.7 4 3.4 1.9 14.3 5 .. 1.6 0.4 ' .'3.2 4 . 3.6 1.2 9.6 4 0.9 $.1 6.0 2 3.7 2-3 4.9 ' _1 6.9 Not Applicable 45 4.9 < 0.1 27.9 *TWA mean for reactor building 8,5 ppm -- range 1,4 to 27*9 ppm* 100250 APPENDIX 2 o Plaquemine *l t Fugitive Loss Estimations * 1. Production of PVC 8.637.000 #/rao " 12,000 tf/hr prime PVC 2. VC used (efficiency over several months) 104*8 #VC/100# PVC 12.000 #/hr PVC x 1.048 - 12,576 #/hr VC * -' Total VC losses 576 #/hr * . ** 3. Na'sh Pump Losses V Estimate From Batch Weight Loss fccperience - 200 #/BA Average Loss 180#/hr (1 BA every 1 hour & 15'mins) i 4. Day Tank Vent Losses - 20% VC in inert gas vent '' Approximately - 22 #/hr > 5. VC lost in Nash Pump Seal Water 18.000 #/hr water at 195 ppm (solubility) 3.5 #/hr VC 6. VC Lost between Popo and Railcars 400 ppm out of Popo 200 ppm into railcar 200 ppm = .003; 0.003 x 12,000 #/hr 2.2 #/hr - 7. Emergency Vents ------- - VC and PVC Approximately 9,000 #/mo from exp. data * 12.5 #/hr - 100251 * o 8. By-products.(cleanings, etc) Jan, l, 1974 to June 1, 1974 ---------- 501,000 100,200 #/mo = 140 ,#/hr 9. Scrap to Dump............................ 36,000# in 5 mo. 10 #/hr 10, Fugitive Losses 576#/hr total no shipped as prime ;PVC -- loU Nash pump 335 - 22 375 day tank vent 3.5 Nash Pump Seal Water 37^3 r 2.4 From Popo to Railcar 35S7T - 12.5 Avg From Emergency Vents 1353 -140 #/hr by-products (solid) 1T575 - 10 . #/hr Scrap to Dump (solid) 30575 - 8.5 Dust Loss (solid) mrr Fugitive Loss * 100252  APPENDIX 3 o VINYL CHLORIDE LEVELS AT NIAGARA FALLS PLANT FROM 1946 to 1974 During the early years of VCM and PVC production at Niagara Falls the major safety consideration was the possibility of fire, and explosion anaesthetic effects* Work practices and ventilation \ were designed primarily to meet this threat. Where instrumentation was used to measure VCM levels, this equipment was of the "explosion meter" type. Thus there is no finite data to establish the exposure of these early employes to VCM. Table I shows the chronology of portable detectors used to monitor for VCM. The sensitivity.of the various instruments ia also shown. During the period of 1946-1967 when the MSA 0 /> Explosimeter was used to monitor for maintenance or vessel entry ** permits, a "blip" (probably less than 720 ppm) was cause for further ventilation before a permit was issued. '' TABLE I VCM TEST METERS 1946-1967 i968-1971 1972-1973 1974 MSA Explosimeter Lowest reading on scale, 2% of LEL, or 720 ppm not accurate at this level. . Davis Vapo/tester Lowest reading on a X10 scale was 0.2% of LEL or 72 ppm - not accurate at this level. Johnson & Williams SS PK Tester Scale reads 26 ppm per division but not accurate below 50 ppm. Zero drift often in excess of 50 ppm. Century OVA #98 Portable FID Testers Not specific for VCM, Reads down to 1 ppm. We calibrate with certified gas at 50 and at 5 ppm. > o -2- o In order to approximate the levels which existed during the past years an interview procedure was used, during which 24 workers, selected on the basis of long service (15 to 28 years), long j, operating building exposure (13 to 27-% years), indicated their work practices, per cent of work assignments in each area, and their detection of air-borne VCM by smell, dizziness, or, in one case, unconsciousness. While realizing that this procedure may lead to estimates correct perhaps only to an order of magnitude, we believe that the results of the survey present a marked contrast with the conditions of VC exposure encountered at the plant today, ', at the same time verifying the belief held by many that the angiosarcoma cases`detected to date resulted from what we now --* * recognize as gross, prolonged exposures to vinyl chloride. VT The data in the attached table indicate the probable TWA values for men working in the buildings designated during the time span indicated. *T*he three cases of angiosarcoma discovered to date occurred in men who had prolonged work assignments in Buildings C-l and E-l, areas- of/the highest exposure. Work practices which increased potential exposure to VCM in the early years of plant operation were revealed by the following interview responses: 1. Most men ate food in every building during their employment period, 2. None ever used a respiratory device during the performance of their normal duties. 100254 3. While all showered at the end of each shift, none ever took a shower as a result of VCM contact with their clothing. (more) o 3- Cj Reactor cleaning, too, enhanced VCM exposure. Responses showed that all men who had cleaned reactors smelled VCM at some time during this procedure, and half of these became diz2y a few times during their service while cleaning reactors, indicating temporary levels above 1000 ppm. The use of air movers reduced this concentration, as shown by measurements taken with a Davis . Vapo^#fcester in 1967-68 which indicated maximum levels of 350 ppm typically. TABLE 2 Vinyl Chloride Levels in Operating Buildings Time Span, 4 " 1946-1972 TWA 1973 Number of Readings TWA (ppm) Maximum reading (ppm) Jan, 1974 Number of Readings TWA (ppm) April 8, 1974 to May 21, 1974 Maximum Reading (ppm) Number of Readings* TWA (ppm) Maximum Reading (ppm) C-l 500 77 50 2800 9 64 300 306 8 246 C-2 E-l E-2 140 500 150 73 - 585- 597 5 50 25 200 3000 2800 9 63 ''80 8 25 17 60 504 168 131 935 1068 476 35 43 34 >-l F-3 20 222 73 125 5 2460 200 27 8 93 44 840 300 528 328 10 8 50 65 K. m 85 175 2240 9 17 100 132 7 46 ^Exclusive of Reactor Cleaning. Work Functions: C-l -- T"ank Car Unlonading, VC pumr*ping, VCitM prodMuction unittil 196H7 E-l - Polymerization, Monomer Recovery E-2 - " "" F-l - Filter, Apron driers F-3 - Filter, Rotary drier K - Filter, Spray drier : 100255 o Comments on Tables 3 to 6 The data in the attached tables represent (1) total hydrocarbon levels in plant air, expressed as parts per million vinyl chloride, over the period April 8 to June 27, 1974, and (2) results of personnel monitoring surveys, including both ten-minute and eight-hour TWA values for vinyl chloride measured in the period April 17 to June 28, 1974. Total hydrocarbon values were measured as "instantaneous*'.' samples using a Century OVA meter. The data presented do not cover excursions, but represent normal conditions. : Personnel monitoring data were obtained in samples of air obtained from the breathing zone of employes during their normal assignments. Samples taken in 250 ml glass tubes were injected directly into a gas chromatograph, either at Niagara Falls or, in our Akron laboratories. Samples absorbed on carbdn were desorbed in carbon disulfide prior to injection into the chromatograph. 100256 o Table 3 -- Area Sampling Results -- Niagara Falls, N.Y. April 8 - June 27, 1974 (Century OVA Meter) Building Readings Time Period - 1974 Upwind E-l E-2 F-l . C-l C-2 K F-3 Reading Average of All Readings DDtn Vinvl Chloride) 4/8-4/17 4/27-5/7 5/17-5/25 6/5-6/13 6/14-6/27 4.9 6.2 4.8 - 3.7 3.8 14.7 12.6 11.7 11.4 9.3 9.2 7.0 7.9 7.6 7.7 - 38,9 9.1 14.2 14.7 *- 10.1 10.6 14.2- 12.8 - 6.7 7.9 10.3 10.9 8.2 5.5 5.7 6.2 10.5 9.2 5.5 6.0 7.3 7.0 4/8-6/27 4.8 10.5 9.7 13.1 7.2 Number of Readings 240 1678 1229 398 310 '1 . * Maximum. Readine Recorded (as DDtn Vinvl Chloride) 7.9 10.5 11.6 153 154 215 4/8-4/17 " 4/27-5/7 5/17-5/25 6/5-6/13 6/14-6/27 7 45 32 - 500 30 45 42 13 28 40 - 24 40 49 33 18 35 40 - 21 22 27 45 6 20 35 40 io` 10 16 55 5 27 45 35 12 11 50 20 4/8-6/27 % 18 50 45 275 500 40 50 55 100257 Note: These data do not cover excursions, but represent routine conditions, "  Vinyl Chloride Levels Inside Niagara Falls Reactdrs April 8 -- June 27, 1974 Century OVA Readings as ppm Vinyl Chloride Time Period - 1974 Average* Maximum* Mimimum* ' E-l E-2 E-l E-2 E-l: E-2 4/8-4/17 4/18-4/26 4/27-5/7 5/8-5/16 5/17-5/25. 5/26r6/4 6/5-6/13 6/14-6/27 33.0 27.5 29.8 34,2 25.9 20.8 21.8 20.3 27.1 -- 33.1 m 29.8 -- 31.0 29.7 115 40 ' 48 45 46 45 41 40 35 ** m 46 -- 45 mm 60 48 15 14 15 -6 15 10 m m 7 10 '7 -- 4 1*5 5 10 4/8-6/27 26.5 30.6 115 60 4 10 * A total of 193 readings were taken in E-l reactors; 98 readings in E-2 reactors. 100258 .. rt Table .5 -- Personnel Monitoring Data -- Niagara Falls, N.Y.-. April t-j ii June 28 , 1974 Description of Value Number of Samples Minimum Value -- ppm Maximum Value -- ppm 250 ml Glass 94 0.1 160 10 min All ShortCarbon Term Samples 74- 168 Nil Nil " 55* 160 8-HR TWA 31 c 0.04 100 VCM (ppm) -- 10% of samples 20 " n . * j* *m 30 ; 40 " 50 " 60 " 70 " 80 ' * 90 " 95 " 97.5 " II it IV it >i it it it Percentage of values above 50 ppm '*V 1} It It 99 40 ff ff M II 17 25 ft If n If 10 ft If IV f ff 5 ft I If u If 1 ff 0.6 1 2 2 3 5 7 12 ` 22 42 60 *1 <1 1 2 3 3.8 6 9 12 25 44 4.3 1.4 6.4 2.7 9.6 4.1 20.2 16.2 39.4 31.6 73.4 66.2 1 1 1*8 2 3 5 6 * 10 15 37 55 3.0 4.8 7.1 18.5 35.7 70.2 3 4 5 8. 12 14 16 20 24 28 100 6.5 6.5 9.7 51.7 67.8 93.7 100253  Table 6 -- Distribution of Personnel Monitoring Data By Job Function and/or Area *C|I 5 Work Area or Function Reactor Cleaning Transfer iwactor Area Pump Room Control Room E-Bldg. Supervisor Bagger P&S Dryer Break Room Locker Room Lunch Room Main Office Warehouse We lex Laboratory Maintenance Shop sM.ft Monitor Ten Minute-Glass & Carbon Tubes Total No. No. Vinvl Chloride Samples -^40 ppm >25 ppm Ave Max HMIn ppm ppm ppm 20 6 9 33.1 160 2 23 2 8.3 75 1 23 0 0 5.0 22 1 12 0 0 5.8 9 < 1 11 0 0 6.0 12 2 "" ---- * 13 0 0 4.9 13 1 9 1 1 14.6 60 3 7 0 0 1.2 2 < 1 7 0 0 1.3 2 0.4 6 0 0 1.8 7 Nil 7 0 0 1.7 5 Nil 7 0 0 2.0 5 < 1 10 0 0 - 1.3 10 <0.1 6 0 0 0.6 1 Nil 7 0 0 0.6 2 0.1 -- -- "*m 1 f: 8-HR TWA Total 1 Samples ) /6 \3 )5 1 I2 v3 i (2 \3 No. No. Vinvl Chi 5 25 ppm >10 ppm Ave Max ppm ppm 0 0 0 5 15.7 1 7.7 2 10.0 22 12 24 0 0 5.0 1 1 18.0 28 1 1 22.0 51 0 0 4.5 6 0 3 17.3 24 Hr Mi PI 1 tm -- ' -- tm m mw mm * _ 1 ;2 __ w mm mm 0 0 * 0.04 0 0 2.1 3.6 0. __ I tm -- ---- -- - 3 1 3 44.0 100 1 t * \ 4 1 APPENDIX 4 Engineering Considerations Conformance to new VCM exposure criteria ultimately depends on finding engineering solutions to the loss of VCM into the plant surroundings. The following Sections A and B list engineering projects in-progress or recently completed, which were done to minimize the loss of VCM to the atmosphere. Section C lists items for future consideration and development. Section D is a brief statement; on preventative maintenance. Section A, Goodyear Niagara Falls FVC Plant 1, Solvent Cleaning System for PVC Reactors In the past, personnel have entered reactors t Clean them by removing left-over quantities of * PVC resin adhering to reactor walls and heat transfer surfaces. The new system allows reactors to be cleaned by -apraying solvent into the reactors to dissolve remaining FVC resin. No entry into the reactor is necessary. Project completion ............................... ,, mid-1975 Project cost . , . . ................................ $300,000 2, Improved Ventilation in Reactor Buildings Involved installation of twelve new fans with a capacity of 12,000 CFM each. These fans are to be used for emergency ventilation when the monitoring system indicates an excessive VCM level in the work area. Project status........................... .... . . . . complete Project cost ........................................... ... $18,000 3, VCM Detection Installation of four VCM Detectors. Project status . ................................................... complete Project c st............................................................$12,000 100261 2 Section A. (con't) 4. Central Vacuum Cleaning System Eliminate.accumulation of PVC dust in the drying areas. Project completion . ......................................Sept., 1974 Project cost .. ........................... . $21,000 5. Exhaust System Remove VCM fumes from nine storage tanks (10,000 gallons each). rH Project completion ........... Sept., 1974 Project cost.......................................... $5,400 6. Hewlett-Packard Chromatograph Measurement of VCM concentration in various working areas. * #. " Project status ........................... . complete Project cost .., .'$9,000 7. Reactor Ventilation ** ** Provide a permanent ventilation system (ducts) t remove VCM fumes from reactors before and during - manual cleaning and repair reactors. Project completion .................. .. 3rd quarter, 1974 ' Project cost *.... ................ ... $6,000 8. Compressor Replacement An older design compressor is being replaced with a new specially sealed compressor, c.cnh*'*- V Project completion ....................................... Dec., 1974 Project cost ............................ ...... $5,000 9. Sifter Ventilations Remove VCM fumes given off at "wet sifters" in the reactor buildings. Project status Project cost . complete : ?U,i<b0Z62 Section A, (con't) 10. Continuous Monitoring Chromatograph and sample collection system is being installed to continuously monitor sixteen critical plant locations for VCM. Project completion....................................Jan., 1975 Project cost .................................................. $50,000 Section B Goodyear Plaouemine PVC Plant 1. New Compressor M *6 A new booster compressor`will be installed to service the two older process areas to provide lower pressure evacuation of reactors. This will reduce the amount of VCM released to the atmosphere and permit recovery of VCM '-in the recovery area. Also, better evacuation of reactors . after each batch will reduce residual VCM in the PVC. Project completion .................... ...... June, 1975 Project cost.................................................. $83,000 2. Cleaning System for PVC Reactors A water cleaning system will eliminate the need for operators to enter reactors for manual cleaning in a new facility now under construction. Project completion ........... late, 1974 Estimated cost ....... .................... $200,000 3. Condenser Modifications in Recovery Area Increase efficiency of VCM recovery. Project status ....................................... complete Project cost ...................................................$15,000 4 Improved Piping in Transfer/Blender System Lower residual VCM content of PVC prior to shipment Project status Project cost . complete $16,000 100263 GO 4- Section B. (con't) 5. Compressor Re-arrangement In the new plant now under construction, evacuation compressors were re-piped to permit series operation, thus allowing very low pressure evacuation of reactors. Improved reactor evacuation at end of each batch will remove residual VCM from the PVC. Project status ...........................................complete Project cost .................... $10,000 6. Continuous Monitoring A chromatograph and sample collection system are being installed to continuously monitor ten critical plant locations for VCM. Project completion ................ ...... Jan., 1973 Project cost $30,000 Section C. Future Engineering Considerations New ideas which have yet to be fully evaluated are presented in this section. It is not possible at this time to supply cost estimates as each item will require thorough engineering design before its total capital and operating cost can be defined. 1. Vent Incineration t All process and emergency vents could be.tied into " a common header, system. At the point of vapor release to the atmosphere, an incinerating flame (2,000F) would be used to convert any VCM to C02, H20 and HC1. Exhaust gases would be water scrubbed to recover the HC1. All normal process and emergency vents except reactor emergency vents would be tied into such a system. 2. Dryer Line Modifications In plants producing PVC using the emulsion or ..suspension processes, VCM is lost to the atmosphere during the drying of the PVC. Presently, rotary ''* kiln dryers or apron dryers are used and residual VCM is lost to the hot air which passes over the PVC being dried. Possible methods to eliminate VCM release in the plant surroundings are: 100264 oO (con't) -5- 2. Dryer Line Modifications (con't) a. Pre-treat the resin before drying to remove VCM from the wet resin. b. Replace open dryers with enclosed fluidized bed dryers and provide total recycle of dryer gases. c. Install high stacks to disperse trace VCH in the atmosphere (subject to EPA air pollution limitations). 3. Closed Loop or Dense Phase Conveying PVC resin is transported by air conveying. Air \sc> used is often on a "once through" basis with filters to remove powder'-before the air is exhausted to the atmosphere. Some residual VCM is released from the polymer during conveying and this VCM exhausts to the atmosphere with the air. it would be possible to use a closed-loop air conveying system or a dense phase air conveying system to minimize the amount of air vented in the plant surroundings. 4. Vacuum Release of VCM from PVC Storage tanks for dried PVC could be designed for full vacuum operation. Each tank full of PVC - could be fully evacuated and left to stand for a period of time to remove entrapped VCM. Substantial capital expenditure would be needed to provide tankage and evacuation system in a way which does not reduce plant production capacity. 5. Resin Vapor Stripping Restrictions on the residual VCM content of PVC resin may require steam (or other vapor) stripping of resins before drying. Stripping gas containing released VCM will have to be condensed and the VCM recaptured to prevent its release to the atmosphere in the immediate plant surroundings. 6. .Direct Contact Refrigerated Brine Condenser Achieve lower temperature refrigeration of vents from VCM recovery areas. 100265 *6Section C. (con't) 7, Secondary Filters Install secondary filters on all dust collectors to eliminate trace PVC dust discharge* 8. Reactor Cleaning at the Plaquemine PVC Plant Methods for cleaning the older two process areas of the Plaquemine Plant are being studied* . These can include either water cleaning or solvent cleaning. 9* Breathing Air Supply During emergency or failure situations when the VCM in the plant surroundings exceeds the limits, some method of protecting workers with an auxiliary breathing apparatus will*be needed. This technology is poorly defined and will need careful study to develop safe systems, 10. Change in coag system Section D* Preventative Maintenance Programs Equipment installed to prevent VCM loss to the atmosphere will be effective only if the plants carry-out sound presentative maintenance programs* New equipment such as valves, instruments, seals, gasket materials, etc., may have to be developed to achieve very low emission levels. Some of the technology developed in the various AEC programs may prove useful to the VCM/PVC industry. W- \ 100266 o APPENDIX 5 VCM Residual in PVC Resin 2m - Prior Level ppm (Jan-Mav) Avg Range Current Level ppm (June) Avg Range Bulk (pipe) Bulk (film) Suspension (General Purpose) Modifying Resin Plastisol 841 726 88.0 1137 <r 30 30-3050 10-2450 , 500-900 450-1850 134 9-782 56 12-150' 230 1-800 . 322 24-640 4 *1-12 * j t 4 * - 10026*7 'iJtrli ? PERATOR MOV 100268 S~\ A(C\Pi \^y,< g v3/ Vs.-/ o | irr tXMACTOH i Oir*3 A A l! W V_/ "Ezb! iit I REACTOn I f REACTan J :: z uoCTtw <)<) ,, <)() O' !i 1' ol O (3) (3) -- W*> /Oj wsmrr ATS ,(r) & | MfACTOM ^Rt AHOR^ |REACTOM -K: 46. Jt 5L SL I REACTOR 1 I REACTOR I I REACTOR I -J!Lr-' W Kj... TRIPS - CONTROL ROOM TO REACTORS - 60 PER SHIFT O MIXING AREA - 6 PER SHIFT O WEIGHT TANK - 6 PER SHIFT RECEIVER - 6 PER SHIFT O MON. MIX TANK - 6 PER SHIFT TOTAL DISTANCE PER OPERATOR PER SHIFT 4-6 MILES ,