Document KRgyZ8XEEq0B4Dzzg5wdQ5x4o

Interoffice AVeiuoraiH^m Mr. R. C. Reitz FROM (Name n<l Location) C. J. Duey GEN 55 (REV.6 OATE June 22, 1976 REFERENCE NO. CJD-200-76 Subject: Hld-Year OSHA Review - Air Contaminants in Work Place Major emphasis has been put on measuring employee exposure to methanol vapors in the Nylon Salt Unit. Jill Luppes is making a weekly measurement of the outside B Operators' exposure. All results obtained to date are shown in Table I. Recent samples show less exposure. This is partly a re sult of operator awareness (move back when odor is noted) and better house keeping (discharge chutes covered and on tight). We may still have high exposures during unusual conditions (startup, shutdown, strike washouts, etc.). Only one sample has been taken on a Mechanic working on a salt centri fuge. The exposure was very high at 2380 ppm. This measurement will be repeated at the first opportunity; an air blower will be used to provide ven tilation for the Mechanic. Hopefully, this will greatly reduce the exposure. A rough draft (CJD-197-76) of the Bay City method for measuring methanol vapors was sent to B. J. Bland to share with the other Chemical Company loca tions . Hexamethyleneimine (HME) is loaded hot into tank cars or trucks. HMI vapors escape from the hatch during the loading. Air near the hatch opening contained 700 ppm HMI. Air near the breathing zone of the loader contained 80 to 100 ppm HMI. OSHA has not set a TLV for HMI, but 100 ppm is surely too high. Mr. D. L. Schuetz has recommended a heat exchanger to cool the HMI before loading (DLS-25). This will reduce the HMI vapors to about 10 ppm in the breath ing zone. Several amines have TLV's at or near 10 ppm and this may be adequate. A sample of HMI has been sent to an outside laboratory for mutagenacity testing. The results of this test will be used to decide if additional testing is necessary. Inhalation studies required to establish a TLV would cost about $18M. A meeting was held at Bay City on May 27th to prepare a plan for measuring all possible r contaminants in the work place by July, 1977. Most of the plan is reported in CJD-198-76. A plan for Maintenance and Laboratory employees will be developed at a later meeting to be held in July. ic CJD-200-76 -2- cc: Messrs. P. E. Hime D. H.Miller J. N. Gann J. L. White J. I.Luppes J. M. Ramey - NYO B. J. Bland - CCCTC Central Files - " File: 71 June 22, 1976 004895 Table I EMPLOYEE EXPOSURE TO METHANOL VAPORS Date 10-29-75 11-5-75 12-4-75 2-20-76 2-24-76 3-2-76 4-22-76 4-30-76 5-10-76 5-17-76 5-20-76 5-26-76 6-3-76 6-10-76 Employee Bennie ICainer Joe Cox Craig Eversole Kenneth Tyler Craig Eversole John Marek Dan Barosh David Carrol Kenneth Tyler Thomas Orsak (Maintenance) Craig Eversole John Marek Robert Gatica Kenneth Tyler Total Sample Time, Minutes______________ 369 425 427 325 355 386 347 293 302 107 242 290 315 360 ppm MeOH, TWA 91 26 93 398 725 76 81 345 476 2380 26 29 16 14 004896 /erofficc Aicinoraiidtiriim/ j (Name and Location) Mr. J. N. Gann FROM (Name and Location) C. J. Duev GEN 55 (REV.6/7 OATS June 8, 1076________ REFERENCE NO. CJD-1Q8-76 Meeting on Air Contaminants in the Work Place On May 27, 1976 a meeting was held to develop a plan for measuring all airborne contaminants in the work place. Those present for all the meeting were J. M. Ramey, C. H. Laubly, B. J. Bland, R. C. Reitz, J. N. Gann, and C. J. Duey. Those present for specific areas were J. P. Pirtle, E. E. Abels, J. I. Luppes, J. G. Forister, F. B. Ideus, C. C. Riggs, C. J. Brugger, S. C. Dalton, J. C. Susil, and C. D. Bartine. Mr. Ramey explained that the company objective is to measure employee exposure to all airborne contaminants. The measurements should include the following employee samples: 1. The Operator with the greatest exposure. 2. A Mechanic during turnaround or other maintenance. 3. An Operator during upset conditions. These measurements are to be completed by July 1, 1977- The accomplishment of this objective will cost considerably more than previously estimated for a SOCMA questionaire (CJD-190-76). The SOCMA survey excluded certain chemicals (methanol and ammonia) and also excluded ail chemicals which have no established TLV. The SOCMA. survey was based on OSHA requirements. OSHA allows calculations to be made to determine if there is any likelyhood of employee exposure. OSHA also allows the use of spot samples taken at the source of contamination to prove an acceptable exposure. Calculations and spot samples are much cheaper than 8 hour TWA employee measurements. A list of chemicals used at the Bay City plant is attached. The chemicals are listed for each Unit. A priority for measuring each chemical is given. A one priority was given to chemicals that are more likely contaminants or that are especially hazardous. (Several of the one priorities have already been measured). A two priority was given to chemicals that are less toxic or less likely contaminants. A three priority was given to chemicals with low toxicity or very little chance for exposure. Comments are included' listing the analytical technique if known or who will be responsible for providing the analytical method. The attached list does not include all air contaminants to be measured on Maintenance employees. Also the Laboratory and Traffic (Loading) were not discussed for lack of time. A plan for these employees will be developed at a later meeting. -- Uniterms: Air Pollution, Contaminants, OSHA 004897 CJD-198-76 Page 2 Dr. Bland pointed out a potential problem area. The sodium nitrite inhibitor that is added to the monoethanol amine solution in the Hydrogen Units could possibly react to form nitrosamines. Nitrosamines are known carcinogens. Since this inhibitor system is not unique to the Bay City Plant, I recommend that Dr. Bland coordinate any inventigation into the safety of this system. A need for TLV's on HMI and other amines was briefly discussed. No decision on HMI will be made until we get the results of a mutagenacity study. An inhalation study will cost about $18 M. CJD/dea cc: Mr. P. E. Hime Mr. D. H. Miller Mr. K. A. Dunn Mr. L. E. Hackfeld Mr. C. J. Brugger Mr. J. P. Pirtle Mr. R. C. Reitz Mr. C. D. Bartine Mr. H. C. Thiele Mr. E. E. Abels Mr. S. C. Dalton Mr. J. G. ForisterMr. F. B. Ideus Mr. C. C. Riggs Mr. J. C. Susil Ms. J. I. Luppes Dr. B. J. Bland - CCCTC Mr. C. H. Laubly - NYO Mr. J. M. Ramey - NYO Mr. J. W. Dunn - CLP Mr. W. H. Meyer - Bishop Mr. W. H. Tuke - Pampa Mr. W. T. McNair - CCCTC File: 71 Technical Objective: VII. A. c 004898 CJD-196-76 Priority 3 3 2 1 1 Page 3 ATTACHMENT of Chemicals to be Measured as Possible Air Contaminants in the Work Place NYLON SALT UNIT Chemical HMDA Adipic Acid Nylon Salt Methanol Lubricating Oil Mist Comments Document no exposure Document no exposure Dust Sample Continue Weekly Sample Method from CCCTC ADIPIC ACID UNIT 3 Cyclohexanone NIOSH Method 3 Cyclohexanol NIOSH Method 2 Nitric Acid 1 nhuvo3 Dust Sample 2 Adipic Acid Dust Sample 2 NO 2 no2 3 Mono Basic Acids l Sodium Dichromate (No sample if we switch to solution). l Lubricating Oil Method from CCCTC Mist 004899 CJD-198-76 Priority 1 1 1 3 3 3 3 3 3 3 1 Page U CHOX - CYCLOHEXANONE UNIT Chemical Cyclohexane Cyclohexanone Cyclohexanol COP Acids Recycle Diol Ester Lean Oil Chrome Naphthenate CO Sodium Hydroxide Lubricating Oil Mists Comments Completed (CJD-170-75) Completed (CJD-170-75) Completed (CJD-170-75) Total Carbon (Method frc Total Carbon Total Carbon Total Carbon Prove there is no +6 in Document no exposure Method from CCCTC HNO,, UNIT 1 Ammonia NIOSH Method 1 NO 1 NO 2 1 HNO3 2 Platinum Dust sample when there 004900 CJD-198-76 Priority 3 1 1 3 3 3 3 1 Page 5 HDO UNIT Chemical Ester Copper Chromite Filter Aid Hexanediol Recycle Diol T-70 Overhead T-60 Residue Lubricating Oil Mists Comments Total Carbon (Method from CCCTC) Dust sample Dust sample Total Carbon Total Carbon Total Carbon Total Carbon Method from CCCTC AMMONOLYSIS UNIT 1 Ammonia NIOSH Method 3 Hexanediol Total Carbon 1 HMDA Need CCCTC Anal. Dev. help 1 HMI Need CCCTC Anal. Dev. help 3 Raney nickel Dust sample before catalyst activation 3 T-74 OH (1,4 DACH) Total Carbon 2 T-67 OH (Amylamine, Need CCCTC Anal. Dev. help piperidine,hexylamine) 3 T-68 Res- Total Carbon 3 T-72 SS Total Carbon 3 T-72 RES. Total Carbon 004901 1 Cyclohexanol NIOSH Method 1 Cyclohexanone NIOSH Method CJD-198-76 Priority 1 2 Page 6 AMMONOLYSIS UNIT (cont'd) Chemical Lubricating Oil Mist Baroid S-35 or H-35 Comments Method from CCCTC VINYL ACETATE, SO, WACKER 1 Ethylene 1 Acetic Acid 2 HQ Method from CCCTC 2 PBQ Method from CCCTC 1 Vinyl Acetate 2 Ethyl Acetate 1 Acetaldehyde Method from Bishop 1 Manganese Acetate Dust sample CO t 1 Hydrochloric Acid' Sample after Process improvements 1 Chloroaldehyde Method from Laubly 2 Methyl Chloride 2 Ethyl Chloride 1 Raney Nickel Dust sample during iso BuOH run. 1 Lubricating Oil Method from CCCTC Mist 004902 CJD-198-76 Page 7 UTILITIES Priority Chemical Dowtherm 1 Biphenyl-Biphenyl ether mixture Hydrogen .I Monoethanolamine 3 NaNO 2 3 BaO 3 Na MoO^H^O and Water Treatment and .Steam Comments Sample when upset Dust sample No exposure - solution from Lab. Dust sample 3 h2sc>4 3 NaOH 2 Lime 2 NagSO^ 2 NaN03 1 Morpholine 1 Cyclohexylamine 1 Chlorine Cooling Towers 1 Chlorine 3 Cr 408 3 Cr 403 3 AF 521 3 AF 502 Effluent 1 Ammonia NIOSH Method Dust sample Dust sample Dust sample Document no exposure Document no exposure Vendors to supply Composition Data Vendors to supply Composition Data Vendors to supply Composition Data Vendors to supply Composition Data NIOSH Method 004903 CJD-198-76 Priority 1 3 3 3 UTILITIES (cont'd) Chemical FeSO^'THgO NaOH H SOi. 24 HNO 3 Comments Dust sample Page 8 004904