Document JrkmM57VJ12q5p0r6nwj2mjY2

(conoco) Interoffice Communication To : Distribution jj o M From J. V, Uptain ot : November 30, 1976 Subject ; Vinyl Chloride Safety Association (VCSA) Trip Report, November 18 5 19, 1976 The V( SA meeting was held in Denver, Colorado, A total of 73 people , representing 24 U. S, Companies and nine foreign companies were in attendance- Conoco Chemicals was represented by R. A. Fronreich, E. C. Gremillion, and J. V. Uptain. In suimary, the meeting was informative, with good exchange of infor- matioi between companies. The meeting dealt with OSHA and EPA compliance, trans] ortation problems, industrial hygiene, the safe use of large reactors, job safety analysis, motivation, training, and balancing productivity versui safety. Following is a brief summary of the highlights of the meeting. I. V(M TRANSPORTATION PROBLEMS - Speaker: Jim Ferrell, Pantasote Aj All companies handling hazardous materials should get the pamphlet "Hazardous Materials-Emergency Action Guide, 1976", by the U. S, Department of Transportation. Emergency Response systems were discussed. Dow has a system whereby Dow telephone number is printed on each rail car and a response team is on standby, DOT is expected to establish very stringent regulations on VCM within IS months. Unloading problems were discussed. PPG purges with N2 and has had no problems. Pantasote does same at a barge facility but has been unable to reduce total emission to less than one gallon, Goodyear uses Corken compressors to evacuate lines and is working on a system of mechanical seals. Pantasote has been cited by OSHA at a barge facility for not keeping area logs. They have fixed regulated area signs, but don't consider the facility a regulated area except when a barge , is present, because of low VCM levels, OSHA takes the view that the facility should be regulated at all times, Situation complicated by Coast Guard's attitude that barge is under their jurisdiction at all times, 1 The problem of VCM rail car security was discussed. Several companies are trying to lease outside trackage on a long-term basis and fence it in SAL 0001029?i YCSA Trip Report November 30, 1976 page 2 Mo st agreed that in-plant VCM storage is more secure Se veral companies are considering cable-type seals, be cause of vandalism experienced with present "car 5eals". One company cited for failure to have a 24 he ur patrol on cars on trackage outside the plant. II. MUTUAL RESPONSE TO TRANSPORTATION ACCIDENTS - Speakers: Thomas Moore, Tenneco Bob Wilson, Stauffer The pirpose and methodology of CHEMTREC was reviewed by Bob Wilson. He emphasized that by calling CHEMTREC at (800] 424-9300, anyone can find (ut immediately the basics of coping with particular hazardous chemical emergencies. A current proposal is that when alerted to a given emergency, CHEMTfEC would make every effort to contact the shipper and advise them of the nearest emergency response team. If un able 1o contact the shipper, they would contact "someone else who ii nearest". The prime responsibility for responding to the emergency is the shipper's. The Association of American Railr<ads has threatened to apply pressure for DOT regulation to force the issue if the proposal is hot adopted. Penta: ote's posrtion(also expressed by Tenneco) is that they will act st rictly in an advisory capacity. They further believe that only people who can qualify as "experts" in court should be sent to emergency scene: to give advice. The discussion continued along the lines of. legal responsibility. The Compressed Gas Association is developing an emergency kit for cpver:.ng VCM railcar domes. The iv:w "Flammable Gas" placard for railcars and trucks was reviewed. Regulations will require use of this placard as of July 1, 1977, although conversion nay be made ahead of that date. DOT l; expected to announce (within 2 weeks) a stringent regulation on th i design of railcars for compressed gas service. Included will >e requirements for head shields and a thermal insulation jacket Stauffer believes the conversion will require $10,000 per car and reduce car capacity. When isked, three companies stated they have "formal" programs for trainiLng outside agencies, such as city fire departments, in handling VCM p roblems. III. SPECIAL PROBLEMS WITH LARGE REACTORS - Speaker: Norman Fahnoe, Diamond Shamroc) Diamoid Shamrock's basic approach to large reactor safety is the same as wi th small reactors. They utilize: A. J 5b Safety Analysis - On most serious tasks. They have ''over 300" JpA's that "are kept up to date". SAL 000102972 VCSA Tiip Report November 30, 1976 P.age 3 B. Lockout procedures. - - -;-r; C. Deluge and Fire Systems - Deluge trips @ 20% of LEL, alarms 6 50%. -- ~ ------ " D. Standby electric generators - Fourteen companies have standby electrical for agitation. ------- :;.r E. Redundant rupture disc/relief valve systems, F. -A "Quick Kill" system- Agent is-charged to reactor in:five (5) seconds or less. Can be activated-remotely,--------------- --=-- G. Direct line telephones for use during reactor entry (accomplished .every 3 batches), " r r:vs* srf-rr - H; Life lines and harnesses'-"used during'vessel entry. T. Double blocks and bleeds. 'in-'Manway standbys 30+- companie'srtise iv. a TALYST HANDLING-- ^Speaker:Schaafj-B. -Fi Goodrich jor points of- interest weTe'rr~ -; i:. -c*ur; e.*- co-eracr?! "B.- F. Goodrich uses a "Catalyst Committee*!, similar to that set up by NFPA. They have set' up a~~hazard classification system similar to Factory Mutual's. .' "They now use horizonal freezers and-handling incidents have been reduced as a result.- .. jD. No companies reported havirig-:any storage -failures'during--the: V. -i TOSTRIAL HYGIENE - Speaker:" J.: D. ^Tbrry, OSHA: Fr. Torry reviewed the history of OSHA, the VCM regulation, the lole of NIOSH, current trendsin OSHA thinking,"-and new regulations, 'jome points of interest were: "~ - /. Standards relating to carcinogens or suspected carcinogens ..require concentrations to be "as low as possible".. . - . "Hr For the most part, "ceiling" valueS"-which'are-Tnot"to:be':-; san.^ ' exceeded at any time, are measured over IS minute periods, 'll. '.The*purpose of the "Action'Level'-'*is to^alertTyou to-a problem:: is' deVeloptttg"*;'' --- SAL 000102973 "VCSA T ip Report Novembt r 30, 1976 'Fage 4 D, The proposed noise standard will require audiometric testing above 85 DB, ___ e. OSHA expects employees to keep records of all exposure measurements F. The two methods of exposure monitoring are calculation and actual measurement. , G. Regulation expected during 1977 include those on toluene, benzene, cotton dust, trichlorethylene, chloroform, carbon monoxide, noise ahd_1,carcinqgens"~'(NIOSH thinks there are about 100 suspected carcinogens), ''Guidelines" are. expected for lead, jnercury, and crystalline silica,__ H ^OSHA's position on beards isj 1; "OSHA can't require a man to shave his beard. If you transfer or terainate a man because he refuses . to trriimm_po;r remove his beard, OSHA will uphold your decision. Ultimately all citations willjbe reviewed by one OSHA group `^^o^eliMihate disparity' between-"regions. Ifflr an'employee violates an established'employer rule, OSHA will hold_the employer responsible, VI. E >A REGULATION - Speaker: Bill Madden, Firestone Madden reviewed the current status of the regulation. In d>ingso, several points worth noting were made: -D B If a company has any alternate procedure it wishes to use, it should apply for the alternate and submit a waiver request. "EPA^cannot terminate a waiver^. There appears to be differences in- EPA regional approaches to the. regulation, - Except for handling waiver requests, states can take over, .They can be ,as_ strict or more strict as EPA, but never less so. XT' "EPA enforcement people have purportedly made the following statements: 1.' Enforcement guides will be coming out after the 90 day period. U 2^^Equivalent .'methods Vill. j>ot. J5e approved if the other methodology '"""will result in quicker compliance. i:. SA|. 000102774 YCSA T *ip Report Novemb ;r 30, 1976 Page 5 3, All plants will be inspected within a year. At least f 24 hours notice will be given. 4, An "Excess Emission" is anything over 10 ppra. "It must be reported to EPA", *-- ~ -------------------------- ----------- 5, Enforcement action is likely if a plant*reports that it is in compliance, but EPA testing shows otherwise. 6, EPA will determine if error was avoidable. VII, OSHA - Speaker: Joe Degenfeldef, Borden' z A. Variances - No company reported having received positive action on variance requests. B, Inspections - 1. 12 companies received-OSHA- inspections--since April 1, 1976. 2. 2 companies received 2 or more. 3. 16 companies had none.- - ' ~r_.- C Caimister- Windocators - There is evidence that OSHA won*t cite for the lack of windocaters, although the deadline was not extended beyond October 31,_L976._____- _ -- " ilj :r- D Cases Related to Regional Differences T. Ethyl reported a case in which an OSHA inspector turned off a personnel monitor while an employee wore a -- - respirator. ----- -=-' ----- r- *2zr'_Twcr Cases (one of-them reported7 by-TermecoY'-of OSHA z -- --inspector turning off personnel'monitor when employees left regulated areas. -3. -One citation was mentioned hecause^an employee "toiiched - reactor residue without wearing gloves, - one -case , OSHA-admitted'sapling errxufwhefFcbn^-3"- ' fronted with company samples made at the same time which contradicted the OSHA results. VIII, :0B SAFETY ANALYSIS - Speaker: H.: Loyd, Georgia Pacific lr. Loyd reviewed job safety analysts as* practiced at CTeorgia lacific. They like the system and advise working on critical hazards first. Ten other companies reported that they too use SA. - - - -7- ' 7 - IX. . OB SAFETY, MOTIVATION AND TRAINING 7-? -SpeakerTonf ZTeHns'kavHooker Mr. Zielinski reviewed their efforts in upgrading their motivation ;tnd training as a result of 2nd., degree burns to two people caused >y decomposition of catalyst. One aspect of their efforts was 1 series of employee interviews conducted by a "human resources :ompany". The results of that survey indicated that employees wanted: , SAL 000102975 SAL 000102976 a 5 Vi . 1 . ^4) A .i . :vi 3 r -i H'i * -'V:| ?-!