Document JJXKj6KNGn3kbeX6kZg864RmK
DIAMOND SHAMROCK PLASTICS CORPORATION Delaware City Plant
TO; J. R. Semancik*
FROM;
R. A. Barrish*
SUBJECT: Delaware City Health and Environmental Report - September 1981
CC: Dr. R. McBurney
Messrs. E. Baier*
J. A. Bailey
D. C. Bobish/J. E. Pyle/C. W. Greenberg/S. A. Kuhls
B. Christensen
C. A. Burkins/P. L. Bowman
R. F. Cronin/W. D. Peeples
D. L. Lull
R. E. Nagy
S. W. Schaefer
File No. El*
(* with attachments)
I. Health
A. General
On September 29th the OSHA inspector conducted the closing conference for the 1981 inspection. With respect to VCM standard, we are the state of the art. Exposure levels are as low or lower than other PVC producers. All engineering and administrative controls, medical surveillance, respiratory protection, and recordkeeping are good. There will be no citation for VCM exposure. From the 1978 citation all items but lead exposure have been abated.
Apparent violations from the 1981 inspection are ipaBequate confined space program (reactor rescue), eye and body weaker in reclaim area, and five alleged violations of the lead standard. None of the viola tions are considered willful. Because the lead standard has changed since 1978, the lead exposure violation will not be considered a repeat. The formal citation is expected in October.
B. VCM
1. Personnel Exposure
a. A total of 16 TWA samples were analyzed during September. A copy of the results is attached. (Exhibit I)
VCM Range (ppm)
<1 1-5 5-10 >10
Number of TWA
13 3 0 0
Number of Masks Worn
8 3 0 0
OCC 11455
Delaware City Health and Environmental Report - September 1981
Page Two
1. Personnel Exposure (cont'd)
b. There were no ceiling samples taken during September.
c. Personnel exposure by area is summarized below and in Exhibit II.
Month
Sept., 1981 Aug., 1981 July, 1981 June, 1981 May, 1981 April, 1981 March, 1981 Feb., 1981 Jan., 1981 Dec., 1980 Nov., 1980 Oct., 1980 Sept., 1980
Area Surveys
Poly Area VCM (ppm)
Bio Plant Avg. VCM (ppm)
0.44 0.31 0.35 0.83 1.35 1.57 2.37 1.30 3.47 1.36 2.82 3.71 1.30
2.06 0.10 0.10 0.10 0.10 0.44 0.27 0.10 0.18 0.10 0.10 0.10 0.10
Reclaim
Incineratic
& Unloading
Avg.
Avg. VCM (ppm) VCM (ppm)
0.58 0.48 0.14 0.47 0.12 0.42 0.44 0.93 1.07 0.22 0.31 1.24 0.36
0.13 0.14 0.10 0.13 0.11 0.20 0.26 0.12 0.21 0.10 0.1 1.18 0.1
The ARCAS area averages and area TWA readings for the control rooms are summarized in Exhibit III.
C. Dust
There was no dust sampling during September. Sampling will resume in October.
D. Noise
There were no noise surveys during September. The new noise dosimeters still have not been received. The Compound Plant will be surveyed when they arrive.
E. Lead
There was no lead sampling during September. There was a thorough cleaning of the Compound Plant during a two week outage in preparation for a lead run in mid-October. The respiratory program has been upgraded with the addition of the 3M 9910 masks and the associated respiratory training program.
OCC 11456
Delaware City Health and Environmental Report - September 1981
Page Three
II. Environmental
A. Air
The six month report was sent to EPA on September 15.
There still has been no action by the Federal EPA concerning our response on safety valve releases.
On September 21, the State inspected five emission sources for permit renewal; four purge stacks APC-79/138, 139, 140, 141, and the incinerator and scrubber lines APC-79/280. The permits expire on October 21, 1981. All will be renewed with no problem. A request for a modified permit on the bulk lead system was also ruled on favorably.
The monthly VCM data is summarized below:
1. Incinerators
0.32 ppm
2. Stripping
a. Latex
Number of batches stripped Average value (ppm) Batches out of compliance Excursions (24 hr. average)
September
209 1,049
20 0
b. Suspension
Slurry average (ppm) Excursions (24 hr. average)
11 0
c. Wastewater
Monthly average (ppm) Excursions (24 hr. average)
2.3 1
3. Reactor Openings
a. Suspension
Number of charges
1 ,099
Number of openings
1 ,099
Reactors sampled
21
Samples exceeding compliance
limit
1
Year-to-Date 2,345 992 292 10
28 3
2.7 9
12,217 12,217
210 23
OCC 11457
Delaware City Health and Environmental Report - September 1981
Page Four
3. Reactor Openings (cont'd)
b. Paste
September
Number of charges
205
Number of openings
52
Reactors sampled
4
Samples exceeding compliance
limit
0
Year-to-Date 2,317 695 45
5
4. Leak Detection
Leaks detected Leaks repaired
95 1,100 115 928
5. EPAReportable Releases
13
There was an EPA reportable PSV release on September 12. Overcharging water to a reactor due to a faulty valve resulted in a discharge of 135 pounds.
A State reportable release occurred on September 29. VCM was charged to a reactor with the air vac open. This resulted in an emission of 200-300 pounds.
6. Total VCM Emissions
a. Suspension Stripping Permitted pounds Actual pounds Over/(under) pounds
September 2,612
75 (2,537)
Year-to-Date 28,640 2,080 (26,613)
b. Paste Stripping Permitted pounds Actual pounds Over/(under) pounds
2,262 1,186 (1,076)
26,969 13,350 (13,620)
C. Reactor openings Permitted pounds Actual pounds Over/(under) pounds
153 32
(121)
1,699 1,140
(560)
d. Relief Valve Discharges Actual pounds
1 2,355
OCC 11458
Delaware City Health and Environmental Report - September 1981
Page Five
B. Solid Waste
1. Monitoring of the on-site PVC landfill continues. Air readings continue to be below 0.10 ppm. Well water samples are being taken monthly.
2. The EPA and FBI are investigating the activities of several waste haulers during the period 1976-1979. One of the haulers. Inland Pumping and Dredging, hauled and disposed of our waste during this period. All invoices and manifests that were available for this period of time were assembled and sent to our Corporate Legal Department.
Ill. Safety
Reactor Rescue Procedure Modifications
A new block and tackle assembly was tested. It was determined that wristlets are the fastest and most successful technique in carrying out the rescue. A kit consisting of an air hose and full face mask, safety wristlets, a neck brace and oxygen supply should be available.
Another test will be conducted after a block and tackle with a top swivel
joint is received.
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R. A. Barrish
jds Attachments
OCC 11459