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VRD 0002013620
Firm or Organization Visited
Air Products, Inc. Valley Forge, Pennsylvania Allied Chemicals, Inc. Corporate H.Q. Morristown, New Jersey American Chemical Co. Long Beach, California Conoco . Corporate H. Q. Saddlebrook, New Jersey . Oklahoma City, Oklahoma Diamond Shamrock . Corporate H.Q. Cleveland. Ohio . Delaware City. Delaware . Deer Park, Texas Dow Chemicals, Inc. , Oyster Creek, Louisiana . Freeport, Texas Ethyl Corporation Baron Rouge, Louisiana Firestone Tire & Rubber Co. Akron, Ohio General Tire & Rubber Co. Ashtabula, Ohio
EXHIBIT II-XI) USDOL/OSHA VINYL CHLORIDE/POLYVINYL CHLORIDE PRODUCERS VISITED AND INTERVIEWED BY PHONE BY SNELL STAFF FOR DATA COLLECTION Purpose of Visit Technical and engineering data collection on PVC
Technical and engineering data collection on VCM
Plant visit on VCM and PVC
Technical and engineering data collection Plant visit on PVC Technical and engineering data collection on PVC Plant visit Plant visit
Plant visit on VCM Plant visit on VCM
Plant visit on VCM Phone interview on PVC
Plant visit on PVC
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VRD 0002013621
Firm or Organization Visited
B. F. Goodrich Co. . Corporate H. Q. Cleveland, Ohio . Calvert City. Kentucky . Long Beach, California . Louisville, Kentucky . Pedricktown, New Jersey
Goodyear Tire & Rubber Co. Niagara Falls, New York Great American Chemical Co, Fitchburg, Massachusetts Hooker Chemical Corp. Florence, New Jersey Monsanto Springfield, Massachusetts v National Starch & Chemical Co. Corporate H.Q, Plainfield, New Jersey Olin- Thompson Plastics Assonet, Massachusetts Pantasote Passaic. New Jersey
Robintech. Inc, Painesville, Ohio Shell Oil Co. . Corporate H, Q. Houston, Texas . Deer Park, Texas
Stauffer Chemicals Delaware City, Del.
Tenneco Burlington, New Jersey
Purpose of Visit
EXHIBIT 11-1(2) USDOL/OSHA
Technical and engineering`data collection Plant visit on VCM Plant visit on PVC Plant visit on PVC Plant visit on PVC Plant visit on PVC
Plant visit on PVC
Plant visit on PVC
Phone interview on PVC
Technical and engineering data collection on PVC
Plant visit on PVC
Plant visit on PVC
Plant visit on PVC
Technical and engineering data collection on VCM Plant visit on VCM Plant visit on PVC
Plant visit on PVC
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VRD 0002013623
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I. Government Agencies
U, S. Department of Labor Washington, D. C.
National Institute for Occupational Safety and Health Cincinnati, QMo Environmental Protection Agency Washington, D. C. and Research Triangle Park, N.C.
U. S, Department of Commerce Washington, D. C.
II. Industry Organizations
Manufacturing Chemists Association New York, New York Organizational Resources Council, Inc. Washington, D.C. Society of the Plastics Industry New York, New York
III. Equipment Manufacturers, Medical Laboratories, Industrial Consultants^ Etc, The Pfaudler Co, - Div. Sybrou Corp. Rochester, New York Diagnostic Sciences. Inc, - Ivan K. Smith Morris Plains, New Jersey Tec-Air, Inc. - David Metal East Northport, New York Human Motivation Resources - Joel D. Schaffer Morris Plains, New Jersey
Source.- Snell
EXHIBIT II-2 USDOL/OSHA GOVERNMENT AGENCIES, INDUSTRY ORGANIZATIONS, AND .EQUIPMENT MANUFACTURERS VISITED BY SNELL STAFF FOR DATA COLLECTION
General data collection and attend hearings
Discussion on medical, monitoring, and protective equipment General data collection
Industry marketing data collection
Discussions on technical feasibility and marketing data General discussion Discussions on technical feasibility
Discussions on polymerlzers and other technical questions (sole U. S. suppliers of glass lined equipment) Medical surveillance data collection Protective equipment data collection Safety program data collection
VRD 0002013624
I. Monitoring Equipment Manufacturers
AID West Chester, Pennsylvania Bacharach Instrument Co. Pittsburgh, Pennsylvania Bechmann Instrument Fullerton, California Bendix Corporation Environmental Science Division Baltimore, Maryland Byron Instruments, Inc. Raleigh, N.C. Carle Instruments Fullerton, California Century Systems Corp. Arkansas City, Kansas
II. Respiratory Equipment Manufacturers
Bausch &, Lomb Rochester, New York
Mine Safery Appliances Pittsburgh, Pennsylvania
Minnesota Mining & Manufacturing, Inc. Minneapolis, Minnesota
Scott Aviatian South Haven. Michigan
Vi.
EXHIBIT II-3 (1) USDOL/OSHA FIRMS CONTACTED DURING THE SNELL TELEPHONE SURVEY OF EQUIPMENT MANUFACTURERS
Hewlett-Packard Co. Avondale, Pennsylvania
Microchemical Specialties Co, Berkeley, California Perkin- Elmer Norwalk, Connecticut
Anatole J. Sipin Co, 386 Park Avenue, S. New York, New York Varian Association Palo Alto, California
Wilks Scientific Norwalk. Connecticut
i
Survive-Air Santa Ana, California
Welsh Scientific, Inc. Providence, Rhode Island
Willson Products Pennsylvania
VRD 0062013625
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III. Protective Clothing Manufacturers
Arrow Disposables, Inc. Cincinnati, Ohio
E. I, Dupont de Nemours Wilmington. Delaware Durafab Cleburne. Texas
* IV. Processing Equipment^Manufacturers
i Crawford and Russel. Inc. < (Design Engineers)
Stamford, Connecticut
Dresser Industries 4* (Compressors and Vacuum Pumps)
Connersvillc. Indiana
Durion Company, Inc. (Valves and Pumps) New York, New York
Fluid Handling System (Viking Pumps) Secaucus, New Jersey
Source: Snell
EXHIBIT n-3 (2) USDOL/OSHA
Edjnont-Wilson Coshocton, Ohio
Mars, Inc. Ashville, North Carolina
Uniroyal, Inc. New York, New York
GAF (Cleaning Systems) New York, New York
Nash Engineering Co. (Compressors and Vacuum Pumps) Norwalk, Connecticut
Process Pumps, Inc. (Pumps) Kenilworth, New Jersey
Stauffer Inc. (Cleaning Systems) Westport, Connecticut
VRD 0002013626
Broad Job Classification
Production^ Maintenance^ Laboratory Management and Support^
Total
EXHIBIT in - 3 XJSDOL/OSHA
,
\
VINYL CHLORIDE PRODUCTION WORKERS - 1974
Approximate 1974 Number of Workers
* 410 250 60 220
940
Percent of Total
44<fr .27
6 23
100<7e
s
kTteS:
(I) Includes line supervisors, such as foremen (2) Includes plant managers, engineering staff, clerical, etc.
,
Source:
Snell survey of industry covering approximately
of 1974-1975 nameplate capacity
VRD 0002013627
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IIIB. POLYVINYL CHLORIDE PRODUCTION
This section defines the structure of the polyvinyl chloride (PVC) manufacturing industry. The exhibits supporting this discussion appear sequentially after the text of this section.
1. 21 COMPANIES OPERATE 36 MAJOR PLANTS
A profile of PVC producers in terms of plant locations, nameplate capacities, and probable polymerizer (reactor) sizes is summarized in Exhibit III-4. Exhibits III--5 and III--6 provide interpretation of these data.
The total 1974 nameplate capacity of the industry is approximately 5.4 billion pounds per year, with over 1.9 billion pounds of new capacity scheduled over the next two years.
As shown in Exhibit III--5, no single company dominates PVC production. Goodrich, the largest single producer with five plants, produces approximately 20%of the nation's PVC. The next five largest producers, with a total of nine plants, each produce between 6% and 9% of total production. These producers are Firestone, Conoco, Union Carbide, Borden and Diamond Shamrock. Each of the next thirteen producers, with a total of twenty plants, shares from 1% to less than 5% of total production.
The remaining two companies, with a total of two plants, each shares less than 1% of total PVC production.
IU-5
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VRD 0002013628
PVC is produced in sixteen states, as shown in Exhibit III--6. Production is close to raw material supply (VCM) or near resin market centers'.
Over 50% of PVC resin capacity is concentrated in five states - Ohio, New Jersey, Texas, Massachusetts and California. Within these five states are located eighteen producing plants. Only ten plants are located in warm climates where open structures are possible; the remaining twenty-six plants are sited in states having moderate to cold temperatures.
A majority of the operating plants are older than ten years, as estimated in Exhibit HI-7. About 58% of the plants are older than ten years.
Only 8% of operating plants are less than five years old, with the newest plant starting operation in 1971. Two new plants are scheduled to come on stream in late 1974, and several others are planned for later construction, seen from Exhibit in-4. Historically, PVC production has been a batch operation and manufacturing was conducted in relatively small reactors to maintain product flexibility, quality, and most important, these reactors were not available in large qapacities.
As shown in Exhibit III--4, reactor sizes are almost equally divided between those plants using reactors less than 2,500 gal. capacity, and those between 2,500 gal. and less than 7,500 gal. Only nine plants use polymerizers equal to or larger than 7,500 gal.
III-6
7
VRD 0002813629
According to recent technological developments, the trend is toward larger reactors in new plants. An industry-wide summary of PVG homopolymer production as a function of reactor size in 1972 vs. 1975 is summarized in Exhibit III-8.
Approximately 85% of the homopolymer produced in 1972 was made in reactors with 7,500 gallons or smaller capacity. By 1975, it is expected that the smaller reactors will account for less than 60% of total production. Bulk polymerization capacity is expected to almost double. The use of small reactors is expected to continue in the long run, but only for production of specialty resins. The four methods used for polymerizing PVC include suspension, emulsion, bulk, and solution polymerization, with suspension polymerization being used at a majority of plants as shown in Exhibit III-9. Suspension resin production is reported in 33 plants, accounting for 78% of 1973 output. Emulsion resin production is reported in 17 plants, accounting for 13% of 1973 output. Four plants produce bulk resins, while 2 plants produce solution resins, accounting for 9% of 1973 output.
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VRD 0002013630
2. THE PVC MANUFACTURING INDUSTRY HAS APPROXIMATELY 5,000 PLANT EMPLOYEES
. Based on an essentially total survey of PVC producers by Snell, estimates were developed of the 1974 number of production and related personnel in the industry, as shown in Exhibit III--10.
The approximately 3,100 workers identified with suspension processes represent 62% of industry employment, while emulsion process workers represent 26%; bulk and solution process workers represent 12%.
55% of PVC plant employment is represented by production workers, while 24% by maintenance personnel; these approximately 3,900 workers have the highest likelihood of VCM exposure.
. The Snell survey identified 4,965 plant employees. A confidential study by industry sources independent of Snell, presented in Exhibit B-l, identified 5,045 workers.
* * * * *
This section defined the structure of the PVC manufacturing sector. The section that follows defines key PVC markets.
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EXHIBIT III - 4(1)
USDOL'/OSHA
PROFILE OF POLYVINYL CHLORIDE PRODUCERS
1 I Producer
Location
Approximate 1974 Nameplate Capacity
(million lbs.)
Planned^ Million Lbs.
Per Year
Additions^2, ^
Starting Date
Probable Polymerize/2^
Size Range (gallons) > 2,500 2.500 - <7,500 >7,500
Air Products
Calvert City. Ky. Pensacola. Fla.
1
American Chemical
Long Beach, Cal.
8<r ' 160<2)
200-300
planned
X X
XX
X
1 Atlantic Tubing
50 2nd qtr. 1974
i\ Borden
niiopolis, ni.
(2) 125
200 late 1974
X
Leominster, Mass.
190f2)
XX
Springfield, Mass..
70(1,2)
<X
Certain-Teed
Lake Charles, La. .
300 late 1974
n. a.
Conoco
Aberdeen, Miss. Oklahoma City, Okla.
215l
J50 4th qtr. 1974
XX
X X
Diamond Shamrock
Deer Park, Tex.
(2) 250
200 late 1974
Delaware City, Del.
100*1,2*
5
Ethyl
Baton Rouge. La.
180(1)
unspecified
under way
XX XX
X
Firestone
Pottstown, Pa. Penyville, Md.
190f2) 315(2)
|50 planned by mid X 1975
X X
General Tire & Rubber
Ashtabula, Ohio
125(1}
XX
V
VRD 0002013632
EXHIBIT III - 4(2) USDOL/OSHA
PROFILE OF POLYVINYL CHLORIDE PRODUCERS
Producer
Location
Approximate 1914 Nameplate Capacity
(million lbs.)
Planned^
Million Lbs. Per Year
Additions^2, ^
Starting Date
Georgia-Pacific
Plaquemine, La.
B, F. Goodrich
Avon Lake. Ohio Henry, 111. Long Beach, Calif. Louisville, Ky. Pedricktown, N. J.
Goodyear \
Niagara Falls, N. Y. Plaquemine, La.
Great American Chemical Fitchburg, Mass.
Hooker Chemical
Burlington, N. J. Hicksville, N. Y.
Keysor-Century
Saugus, Cal.
National Starch
Meredosia, 111.
315 235 190*^ 1S0(2) 160<2)
,1a00a(1.2)
ioo(1)
(2) 70
ISO*1'2) 15(1.2)
35(1>
f4)
10
220 4th qtr. 1974
100 3rd qtr. 1974 i expansion > held in ( abeyance
Olin
Assonet, Mass.
150C1*2)
Pantasote
Passaic, N. J. Point Pleasant, W. Va
60 O'*) 95(2'5)
Probable Polymerizer(2)' Size Range (gallons)
> 2,500 2.500 - <7.500 >7,500
n. a.
XX xX XX XX XX
X X
X
X
X X
X XX X XX
1 VRD 8082813633
:i
EXHIBIT m - 4(3)
i
USDOL/OSHA
'j
At Producer Robintech Stauffer
Tenneco
*
1 Union Carbide
Uniroyal
PROFILE OF POLYVINYL CHLORIDE PRODUCERS
Location Painesville, Ohio Delaware City, Del.
Approximate 1974 Nameplate Capacity
(million lbs.)
250<*1'2>3
160<2)
Burlington, N. J. Flemington, N.J, Pasadena, Tex.
S. Charleston, W. Va. Texas City, Tex.
Painesville, Ohio
150<2> 85(2)
160(1> 240(1*
120t2>
Planned ^ ^ Million Lbs.
Per Year 220 10 55
300
Total Nameplate Capacity 5.435 ;
Planned or 1,955+ Anticipated New Capacity
Additions^2, ^ Starting ' Date
4th qtr. 1974 3rd qtr. 1975 3rd qtr, 1976
4th qtr. 1974
Probable Polymerized2^ _______ Size Range (gallons) > 2,500 2,500 -<7,500 >7,500
x
xx
xx XX
N.A.
x X*
x
XX
22 27
9
Notes:
(4) Operates a pilot plant at Plainfield, N. J. with an estimated capacity of 0.2 million pounds (5) Jointly owned by Pantasote and General Tire & Rubber, and operated by Pantasote
Sources;
(1) Chemical Marketing Reporter, May 20, 1974
(2) Industry interviews
(3) Modem Plastics, May 1974
4
N.A. - not available
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VRD 0002013634
EXHIBIT HI - 5
' USDOL/OSHA
COMPANY CAPACITY AS PERCENT OF TOTAL POLYVINYL CHLORIDE PRODUCTION CAPACITY
Company
B. F. Goodrich Firestone Conoco Union Carbide Borden Diamond Shamrock Robintech Tenneco Air Products Goodyear Hooker Ethyl Stauffer American Chemical Pantasote Olin General Tire Uniroyal Great American Key so r-Century National Starch Total
Company Nameplate Capacity (million lbs.)
1080 505 465 400 3B5 350 250 235 205 200 195 180 160 160 155 150 125 120 70 35 10
5,435
Note:
(1) Does not add to 100% because of rounding errors
Source-
Exhibit III - 4 and Snell estimates
Share of Total Capacity at mid 1974 (percent)
19.9 9.3 8.6 7.4 7.1 6.4 4/6 4.3 3.8 3.7' 3.6 1 3.3 2.9 2.9 2.9 2.8 2.3 2.2 1.3 0.6 0.2
lOO.l^
Accumulated Percent
19.9 29.2 37.8 45.2 52.3 58.7 63.3 67.6 71.4 75.1 78.7 82.0 84.9 87,8 90,7 93.5 95.8 98.0 99.3 99.9 100, l*1*
VRD 0002013635
State
Ohiofl) New Jersey ^ TexasC2)
Massachusetts ^ California Illinois ^ Maryland ^
Kentucky Louisiana v Delaware ^
West Virginia '
Mississippi^
Oklahoma ^ Pennsylvania ^ New York ^ Florida*2^
Number jof Plants
4 5 2 4 3 3
1
2 2 2 2
1 1 1
2 1
TOTAL
Notes: (1) Sited in moderate to cold climate
(2) Sited in warm climate
36
26 10 36
Source-
Exhibit III -4 and Snell estimates
EXHIBIT III - 6
USDOL/OSHA
GEOGRAPHIC DISTRIBUTION OF
polyvinyl chloride plants
Production Capacity (million lbs.)
810 635 490 480 385 370 315 305 280 260 255 250 215 190 115 80
5. 435
'3.735
1,700 5,435
Share of Total Capacity (percent)
14.9 11.7
9.0 8.8 7.1 6.8 5.8 5.6 5.2 ' 4.8 4.7 4.6 4.0 3.5 2.1 1.5
100.1%(3)
68.7
31,4
100. I#3)
Accumulated Percent
14.9 26.6 35.6 44.4 51.5 58.3 64.1 69.7 74.9 79.7 84.4 89.0 93,0 96.5
98'6(3) 100. V }
[*
VRD 0002013636
Producer Air Products . American Chemical Borden Conoco Diamond Shamrock Ethyl Firestone General Tire Goodrich Chemical
Location
Calvert City, *Ky. Pensacola, Fla,
Long Beach, Calif,
Leominster, Mass. Hliopolis, HI, Springfield, Mass.
Aberdeen, Miss. Oklahoma City, Okla,
Deer Park, Tex, Delaware City, Del.
Baton Rouge, La.
Pottstown, Pa. Perryville, Md.
Ashtabula, Ohio
Avon Lake, Ohio Henry, 111. Long Beach, Calif. Louisville, Ky. Pedricktown, N, J.
EXHIBIT III - 7(1) ' USDOL/OSHA
U. S. POLYVINYL CHLORIDE PLANT AGE
Plant Age As Approximately Indicated By Startup Date^ (years)
0- 5
6 - 10 11 - 15 16 - 20 21 - 25 over 26
x
X
X
X X
VRD 0002013637
Producer Goodyear Great American Hooker Keysor-Century s National Starch Olin Pantasote Robintech Stauffer Tenneco
Location
Niagara Falls, N.' Y. Plaquemine, La,
Fitchburg, Mass,
Hicksville. N. Y. Burlington, N. 1.
Saugus, Calif.
Meredosia, 111.
Assonet, Mass.
Passaic, N. J. Point Pleasant, W. Va.
Painesville, Ohio
Delaware City, Del,
Flemington. N. /, Burlington, N. J.
EXHIBIT HI - 7(2) USDOL/OSHA
U.S. POLYVINYL CHLORIDE PLANT AGE
Plant Age As Approximately Indicated By Startup Date^ (years) 0 - 5 6 - 10 11 - 15 16 - 20 21 - 25 over 26
X
x
X X
X
x(2)
X X
X
X X X
X
VRD 0002013638
Producer Union Carbide
Uniroya! Total
Location
S. Charleston, W. Va. Texas City, Tex.
Painesville. Ohio
EXHIBIT III - 7(3) USDOL)(OSHA
U. S. POLYVINYL CHLORIDE PLANT AGE
Plant Age As Approximately Indicated By Startup Date^ (years) 0-5 6-10 11 - 15 16 - 20 21 - 25 over 26
X X
X
3 12
6
8
4
3
Notes: Source:
(1) Or when plane underwent drastic rebuilding (2) Joint plant with General Tire & Rubber and operated by Pantasote
Snell industry interviews
VRD 0002013639
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Broad Job Classification
Production Maintenance Laboratory Management and Support
Total
Percent of Approximate 1974 Capacity Covered by Snell Survey
EXHIBIT III - 10 USDOL/OSHA
POLYVINYL CHLORIDE PRODUCTION WORKERS - 1974
Suspension
1.-660 680 225 530
3,095
Emulsion
690 410
80 120
1,300
Workers By Process Type
Bulk
Solution
Total
190 35
( ns
260
185 ( 125 t--
310
2,725 ~ 1,190
335 -- 715
4,965
Percent of Total
55% 24
7 14
100%
92 77 100 100
Hotes: Sources:
(1) Includes line supervisory, such as foremen (2) Includes plant managers, engineering stiff, clerical, etc.
Snell survey of industry
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VRD 0002013640
Resin Homopolymer Resins, $/lb. Copolymer Resins, $/lb. Dispersion Resins, $/lb.
EXHIBIT III - 12 USDOL/OSHA
POLYVINYL CHLORIDE OUTPUT AND PRICE FORECASTS
1970*1* 0.10 0.12 0.19
1972*1* 0.10 - 0.11
0.13 0,19
July 1974*2*2 0.21 - 0.23 0.23 - 6.25 0.31-0.35
1978-1980('1') 0.22 - 0.25 0.24 - 0.28 0.32 - 0.38
Total PVC Production,*'** Million Lbs, PVC Capacity*3* Million Lbs. /Year VCM Capacity*?* Million Lbs. /Year
~ 4,700 ~ 5,000 ^ 6,200
6,300 - 6,800 6,120 - 7,120
~ 7,500
Note: Sources:
1978-1980 values do not Include any impact of OSHA regulations, and price projection* are Judged by Snell to be on the low side. (1) Disch, G. E., Plastics--Raw Materials to End Markets and Coatings--New Technology and Markets,
American Chemical Society,, Brooklyn, 1974, p. 7
(2) Chemical Marketing Reporter, July 22, 1974
(3) Hydrocarbon Processing, May 1974, p. 83
VRD 0002013641
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Resin Type
Typical Average Mid-1974 Residual VCM Levels' (ppm)
Suspension Pipe Grade General Purpose Copolymer Overall
150 yfS
500 1000 - 7000
500
Dispersion Latex Other Overall
400 25
~10
Bulk
High Porosity Overall
25 ~20
Solution Overall
<1.5
EXHIBIT in - 17
USDOL/OSHA
MAJOR RESIN TYPES AND THEIR TYPICAL FREE MONOMER LEVELS RELATED TO FABRICATION CATEGORY
.
Calendering
Coating
Extrusion
Molding
Paste
1,255 550 215 840 185 290 90
All Other
1973 Total
1,255 1,790 160 540
200 240 *155
200 395
70 205
275
70 65 135 910 485 2,300 515 155 225 4,590
Note; (1) Sources:
Individual data points around the averages can vary by a factor of three or more. Before steps were taken to comply with the Emergency Temporary Standard these averages were significantly higher. Improved stripping Is believed to have been achieved using state-of-the-art technology and operating procedures Snell estimates and Exhibits in-14 and HI-16 based on industry interviews
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EXH IBIT IV - 4(1)
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VRD 0002013643
EXHIBIT IV - 4(2)
USDOL/OSHA
ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974
Unit Production Costs For A 500 Million Lb. Ethylene Oxychlorination Plant of 1974 _________ Construction With Total Fixed Capital of $20.4 Million (#/lb.)
Profitability
Net selling price (FOB plant)
7.41
Cost of manufacture
(6.13)
Selling, general and administrative expenses
' --(0.30)
Pretax profit
0,98
Pretax return on total investment 1.2 plant investment) 20*70
\
Sources:
(1) Snell estimates based on Brownstein, A. M., U. S. Petrochemicals, Tulsa, Oklahoma, The Petroleum Publishing Co., 1971, p. 25
(2) Snell estimates based on mld-1974 Chemical Marketing Reporter posted prices
EXHIBIT IV- 5 (1)
USDOL/OSKA
EXAMPLE OF A STANDARD OPERATING PROCEDURE FOR . MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS
SAFETY PROCEDURE
Subject:
BLEED-DOWN OF VINYL CHLORIDE CONTAINING EQUIPMENT
Problem:
At present, pumps, sections of piping, and some equipment is partially or otherwise bled down to atmosphere. .This exposes personnel to vinyl
vapors if care is not taken.
Situation: Obviously, there are numerous situations that occur in the plant, where exposure to vinyl vapors is possible when preparing equipment for repair or entry. Most equipment is either already tied into the vent recovery system for bleed-down, or can be, with limited temporary piping. Almost all bleed-downs can be done through the vent recovery system and all personnel exposures to vinyl vapors must be eliminated. Elimination of exposure to the vapors should extend to any final low pressure bleed-down of equipment that has already been relieved through the vent recovery system. Also, preventative measures should be taken when opening equipment with stagnated vapors in it. In these two cases, proper respirators should be used to prevent exposures due to change of wind direction or otherwise.
Solution:
1. All seal repair work done on vinyl furnace pumps should utilize the vent recovery system for the primary bleed-down. Any small final bleeddown should involve personal respirator protection. In some cases, It may be necessary to use a full face mask, rather than a mouth-bite respirator.
2. Temporary piping to the vent recovery system should be run when necessary to vent an isolated piece of equipment, or run of piping,
3. When breaking into a vessel or piping system containing vinyl that has been depressured, use a respirator. (Hose-Line Mask). In the case of breaking vinyl containing system, the use of respirators should parallel the policy of using monogoggles.
VRD 0902013645
EXHIBIT IV- 5 (2) USDOL/OSHA EXAMPLES OF A STANDARD OPERATING PROCEDURE FOR . MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS
4. All vessels will be purged to D-234 vent recovery system before opening. Considerable exposure to vinyl vapors Is possible working around these openings due to trapped liquid vaporization inside the vessel. Therefore, fresh air-supplied masks should be used around such openings for exposures of any length.
5. When breaking into vinyl containing equipment, the immediate supervisor of that area should advise the type of respiratory equipment to be used, and issue a safe work permit in some cases.
o
Source: Dow Chemical Corporation
\
VRD 9002013646
Method Major ventilation project Minor ventilation
Venting of temporary tank car connection lines
Installation of new gauging systems on tank car fleer Replacement or reconditioning of reactors (polys) Installation of solvent cleaning of reactors Installation of automatic water cleaning of reactors Additional stripping not requiring new steam generating facilities Additional stripping requiring new steam generating facilities Replacement of strainers
EXHIBIT IV - 12(1)
USDOL/OSHA
TYPICAL TIME REQUIREMENTS FOR IMPLEMENTING VARIOUS ENGINEERING CONTROL METHODS
Rationale
Increase rate of air changes in closed buildings
Install spot ventilation on a piece of equipment: pump, strainer, etc.
Decrease release of VCM trapped between tank car valve, using vacuum and/or nitrogen flush
Eliminate the continuous emission of VCM which occurs with the dip tube system
Reduce leakages at manholes, seals, etc. Reduce need to clean manually
1
(Alternative to solvent cleaning)
Reduce VCM emissions downstream from the poly merization step
Reduce VCM emissions downstream from the poly merization step
Eliminate open strainers and/or substitute closed self cleaning units
>
Time to Complete 18 months
1/2-2 months
1-2 months
12 - 24 months
18 -24 months 30 months 24 months 18 months
36 months
3-8 months
319
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VRD 8002013648
V. FINDINGS AND CONCLUSIONS
This chapter of the preliminary report presents the findings and conclusions drawn from the detailed data appearing in Chapters 11 and III, dealing with industry structure and technology respectively, as well as from the appendices.
Information is presented in individual sections topically addressing each of the key regulatory consid erations of primary concern to the study. See Exhibit II--1. Secondary considerations are discussed in a genera] category. Then, an overview is provided in a preliminary economic impact assessment. Sections follow as shown
. VA - Preliminary Economic Impact Assessment, Including Timing of Engineered VCM Controls
VB - Personal Protective Equipment VC - Monitoring Equipment VD - Medical Surveillance Costs Each of these sections will indicate the analysis, refinements, or new information to he developed during the remaining three weeks of the study between this preliminary report and the draft final report.
V-l
V
VRD 0002013649
VA. PRELIMINARY ECONOMIC IMPACT ASSESSMENT
This section presents the preliminary estimated economic impact of various regulatory standards on the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) industries. For this study, economic impact is defined only as the direct cost impact on the VCM and PVC industries resulting from compliance with proposed OSHA levels of VCM exposure. Economic impacts in other sectors were not included in the scope of work. The timing required to achieve engineered controls of VCM at various compliance levels is also discussed.
1. THE METHODOLOGY FOR ASSESSING THE ECONOMIC IMPACT IS BASED QN SNELL AUDITS OF INDUSTRY ASSESSMENTS OF REQUIRED ENGINEERING, PERSONAL PROTECTIVE AND MONITORING EQUIPMENT
Information for assessing the economic impact under various VCM regulatory levels was collected through an industry survey conducted by Snell.
The cost estimates are developed for various compliance levels,
plant-by-plant costs reported by industry for various VCM exposure levels provided the data base
individual plant information was aggregated to provide the estimated economic impact per pound of VCM or PVC produced for the industry.
Cost estimates of specified equipment were checked by Snell for order of magnitude validity.
monitoring and personal protective equipment information were compared with equipment supplier quotations specific items such as compressors, pumps, etc. were validated with supplier quotations
V-2
VRD 0002913650
in addition, process designers were contacted
selected extraneous industry claimed improvements, such as water treatment systems, were not included in the cost summary
2. THE ESTIMATED ECONOMIC IMPACT OF STANDARDS ON THE VINYL CHLORIDE MONOMER INDUSTRY
RANGES FROM 0.073* PER POUND TO MEET A 50 PPM CEILING VCM LEVEL TO 0.42$ PER FOUND TO MEET A LESS THAN 10 PPM CEILING VCM LEVEL AND i TO 5 PPM TWA AND SUSTAIN 1974 CAPACITY
Snell assessed industry costs of reducing VCM levels in VCM plants were separated into five categories which include:
engineering costs, including:
ventilation vapor recovery stripping loading for shipping other (pumps, piping, etc.)
'
personal protective equipment costs, including:
.. shower and eating facilities breathing equipment (respirators, air lines and bottled air) clothing (uniforms and protective clothing)
monitoring costs, including:
personal monitoring equipment .. area and leak monitoring equipment . . medical testing
recordkeeping
V-3
VRD 0002013651
sl productivity loss the cost of keeping at the levels unimpacted by OSHA capacity otherwise derated as a result of regulation the cost includes equipment, personnel, etc.
expensed items these include consultant costs, management time, etc.
t
,1 out-of-pocket expenses of 0.01$/lb are not included in the cost summaries
*>
i Summarized estimates of VCM industry cost impacts and timing to meet selected VCM compliance levels follow in Exhibits V-l through V-5. Exhibit V-l presents the case of the 50 ppm VCM ceiling Exhibit V-2 presents the case of the 25 ppm ceiling
i
'I Exhibit V-3 presents the case of the 15 ppm ceiling and 5 to 10 ppm TWA (time weighted average) Exhibit -V-4 presents the ca.se of the 10 ppm ceiling and 1 to 5 ppm TWA Exhibit V-5 presents the industry claimed time requirements for compliance
Exhibit V-6, following Exhibit V-5, serves as a summary discussion of findings. 1
V-4
3
VRD 0002013652
k
i
EXHIBIT V-l
USDOl/OSHA
Snell assessment of VCM level potentially achieved*
Total piano In sample: Processes represented*2)*
9 O STO. DO, DC^ C
Location of plants In sample*2)* 8W, 1C
ESTIMATED INDUSTRY COSTS OF ACHIEVING A 50 PPM VCM CEILING LEVEL IN VCM PLANTS AS CLAIMS) BY INDUSTRY AND ASSESSED BY SNELL
Capacity in Sample - Millions lbs. per year (Percent 1974 U. S. nameplate capacity):
Percent Industry claimed capacity from sample subject to shutdown at a
50 ppm celling VCM level:
0%
Snell estimate of percent capacity from sample subject to shutdown at a
50 ppm ceiling VCM level:
0%
5,125(77%)
Direct Costs
Capital (S/1.000 lb.)*
Annual (S/1.000 lb.)
ffercent of Total Annual Cost
L Engineering Gosts*4)
$1.14
$0.41(5)
56%
n. Personal Equipment Costs*2)
0.05
0.03(1)
4
m. Monitoring
O.ll*2)
0.19a 8.8)
26
Total Direct Costs**0)
$1.30
$0.63
86%
Productivity Loss
S0.18
$olio
14%
Total Costs
$1.48
$0.73
100%
Note* (1) sngii estimate of VCM levels achieved In plants incorporating the level of control effort represented in die Exhibit.
`
Monitoring data Is detailed In Appendix B.
(2) O = Oxychlorination, STO - Stauffer Oxychlorination, DO = Dow Oxycholorinadon, DC = Direct Chlorination, G = Goodrich Oxychlorlnadon.
(9} W = Sited In warm climate, C = Sited in cold climate. (4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.)
(5) Includes capital amortized @ 12% - 10 yij. and O&M charges, (6) Includes breathing equipment and clodilng.
(7) Includes capital amortized @ 12% - 5 yrs, and O&.M charges.
(S) Includes area and personal monitoring equipment.
'
(9) Includes medical and recordkeeping costs.
(10) Productivity loss Is the industry average cost of additional capacity, personnel, etc. to maintain Industry capacity levels ununpacted by OSHA regulations.
Source: Industry Interviews and Snell estimates.
*
VRD 0002013653
EXHIBIT V-2
USDOI/OSHA
Snell assessment of VCM level potentially achieved!1)
Total plana In sample;
9
ftocessea represented!^): O, STO, DO, DC, G
Location of plana In sample^3); 8W, 1C
ESTIMATED INDUSTRY COSTS IN ACHIEVING A 25 PPM VCM CHUNG LEVEL IN VCM PLANTS AS CLAIMH3 BY INDUSTRY AND ASSESSED BY SNELL
Capacltyln Sample - Millions lbs. per year (Percent 1974 U.S, nameplate capacity):
Percent Industry claimed capacity from sample subject to shutdown at a
25 ppm celling VCM level:
0ft
srull estimate of percent capacity from sample subject to shutdown at a
25 ppm celling VCM levels
0ft
5,125 (77%)
Direct Costs L Engineering Costs*4) IL Personal Equipment Costal 8) hl Monitoring
Total Direct Costs! 1) Productivity Loss Total Costs
Capital (3/1.000 lb.)
Annual (3/1.000 lb.)
$2.13
$0.7ltS>
0.07 0.17(8)
0.04(9) 0.25(7. B,S)
$2,37
$1.00
$0.36
30.21
$2.73
$1.21
feicent of Total Annual Cost. 59* 3 21 83* 17ft 100*
(i) Snell estimate of VCM levels achievable In plants Incorporating the level of control effort represented iri die Exhibit. Monitoring data Is detailed In Appendix B.
(2) O = Oxychlorination, STO * Stauffer Oxychlorlnation, DO = Dow Oxychltrlnatloo, DC = Direct Chlorination, G Goodrich Oxychlorination. (3) W = Sited in warm climate, C = Sited In cold climate. (4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.). (5) Includes capital amortized @ 12* - 10 yrs. and O&M charges. (6) Includes breathing equipment and clothing. (7) Includes capital amortized 12ft - 5 yrs. and O&M charges. (3) Includes area and personal monitoring equipment. (3) Includes medical and recordkeeping costs. (10) Productivity loss is the Industry average cost of additional capacity, personnel, etc. to maintain Industry capacity levels
unimpacted by OSHA regulations. Source? Industry Interviews and Snell estimates.
I
EXHIBIT V-9
USDOL/OSHA
Snell assessment of VCM level potentially acblevedC*) Total plants In samples; 9 ftocesses represented^; O, STO, DO, DC, G Location of plants in sampled; 8W, 1C
ESTIMATED INDUSTRY COSTS OF ACHIEVING A IS PPM VCM CEILING AND 5-10 PPM TWA LEVELS IN VCM PLANTS AS CLAIMED
BY INDUSTRY AND ASSESSED BY SNELL
Capacity In Sample-Millions lbs. per year ( Percent 1974 U. S. nameplate capacity):
Percent Industry claimed capacity from sample subject to shutdown at a
10 ppm ceiling and 5-10 ppm TWA VCM level:
Oft
Snell estimate of percent capacity from sample subject to shutdown at a
10 ppm ceiling and 5*10 ppm TWA VCM level;
05*
5,125 (77%)
Direct Costs
Capital f*/l. 000 lb.)
Animal (S/1.000 Ib.>
Percent of Total Annual Cost
L Engineering CostsH) IL `Personal Equipment Costs(^) UL Monitoring
Total Direct Costs Productivity Loss*
$3.59
0.11 0.24(8)
S3.94
$0.64
$1.2^
0. osf^> 0.29(7, 8,9)
$1.53
$0.41
61% 4 15 79%
21%
Total Costs
$4.53
$1.99
100%
Notes: (1) Snell estimate of VCM levels achievable in plants Incorporating die level of control effort represented In die Exhibit. Monitoring
data is detailed In Appendix B.
(2) O = Oxychlorination, STO = Stauffer Oxychlorinatlon, DO = Dow Oxycbolotinatlon, DC = Direct chlorination, G = Goodrich Oxychlorination.
(3) W = Sited In warm climate, C = Sited in cold climate. (4) Includes ventilation, vapor recovery, snipping, loading and other (piping, general pumps, maintenance, etc.).
(5) Includes capital amortized g? 12% * 10 yrs. and CAM charges.
(6) Includes breathing equipment and clothing. (7) Includes capital amortized y 12% - 5 yrs. and O&M charges.
1
(3) Includes area and personal monitoring equipment. (9) Includes medical and recordkeeping costs.
(10) ftoducrivity loss is the industry average annual cost of additional capaciry, personnel, etc. to maintain capacity levels
uuinipacred by OSHA regulation*.
I
Source; Industry interviews and Snell estimates. '
i
VRD 0 00 2 01 3 6 5 J
EXHIBIT V-4
USDOL/OSHA
Snell assessment of VCM level potentially achieved^)
Total plants in sample: 5 Processes represented: 0, DO. STO Location of plants in sample: 5W
ESTIMATED INDUSTRY COSTS OF ACHIEVING A LESS THAN 10 PPM VCM CHUNG AND 1-5 TWA LEVELS IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL
Capacity of sample: Millions lbs. per year (percent 1974 U.S. nameplate capacity)
2,950 (44*)
Percent Industry claimed capacity from sample subject to shutdown at a 10 ppm
ceiling and 1-5 ppm TWA VCM level
. 42*
Snell estimate at percent capacity from sample subject to shutdown at a 10 ppm
ceiling and 1-5 ppm TWA VCM level
Capital
Annual
Direct Costs
(S/1.000 Lb.)
(SA.OOO lb.)
Percent of Total Annual Cost
1. Engineering Costs n. Personal Equipment Costs
*4.56 0,63
*2.1B<5> 0.24
- ' 51* 6
IU. Monitoring Total Direct Costs Productivity Loss^1^
0.24 *5.43
0.3lC,'8*9> k *2.73
$1.88
$1.51
7 64*
39*
Total Costs
$7.31
*4,24
100*
Notes; (lj Snell estimate of VCM levels achievable in plants incorporating die level of control effort represented in die Exhibit. Monitoring data is detailed in Appendix B.
(2) O = Oxychlorination. STO = Stauffer Oxycblorinadon. DO = DOW Oxychloxinadon, DG - Direct Chlorination, G = Goodrich Qxychlozlnation. (3) W = Sited in warm climate, C = Sited in cold climate. (4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.) (5) Includes capital amortized @ 12* - 10 yzs. and O&M charges. (6) Includes breathing equipment and clothing, (7) Includes capital amortized i 12* - 5 yts. and O&M charges. (8) Includes area and personal monitoring equipment, (9) Includes medical and recordkeeping costs. (10) Productivity loss is the industry average annual cost of additional capacity, personnel, etc. to maintain industry capacity levels unimpacted
by OSHA regulations. This is based on those plants that expected ability to meet the claimed levels shown In die Exhibit. Source: Industry Interviews and Snell estimates.
VRD 0002013656
EXHIBIT V - 5
USDOL/OSHA
U.S. INDUSTRY CLAIMED TIME TO REACH SELECTED VCM LEVELS IN VCM PLANTS THROUGH
ENGINEERED CONTROLS
VCM Standard
50 ppm ceiling
95 ppm ceiling
15 ppm ceiling fit 5-10 ppm TWA
:10 ppm ceiling fit 1-5 ppm TWA
Sample Total Number of Capacity
Plants (million lbs)
1TM________________ N \ 1975 Number of Percent'*' Number of Percent
Plants Capacity
Plants Capacity
9 5125
9 100%
End of Year 1976
Number of Percent Plants Capacity
1977
1978
Number of Percent . Number of Percent
Plants Capacity Plants Capacity
9 5125
1 5%
8 95%
9 5125 .
3
49% . * 5
46%
1
5%
5 2950
2 51% 3 49%
Notes: Source:
(I) Percent of sample 1974 capacity Industry interviews by Snell
2
C3 '
Source;
Exhibits V - 1 through V
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VRD 0002013658
3. THE ESTIMATED ECONOMIC IMPACT OF STANDARDS ON THE POLYVINYL CHLORIDE INDUSTRY RANGE FROM 0.72$ PER POUND TO MEET A 50 PPM VCM CEILING TO 2.73$ PER POUND TO MEET A 25 PPM VCM CEILING AND 10 TO 15 PPM TWA AND SUSTAIN 1974 CAPACITY
Snell assessed industry costs of reducing VCM levols in PVC plants were separated into five categories which include:
engineering costs, including:
VCM unloading ventilation reactor cleaning stripping and VCM recovery other (pumps, piping, etc.)
personal protective equipment costs, including:
showers and eating facilities
breathing equipment (respirators, air lines and botUed air)
clothing (uniforms and protective clothing)
t
monitoring costs, including:
personnel monitoring equipment area and leak monitoring equipment m-edical testing recordkeeping
productivity loss
the cost of keeping at the levels unimpacted by OSHA capacity otherwise derated as a result of regulation
the cost includes equipment, personnel, etc.
V-5
expensed items
.. these include consultant costs, management time, etc.
.. out-of-pocket expenses of 0.033$/lb are not included in the cost summaries
Summarized estimates of PVC industry cost impacts and timing to meet selected VCM concentration levels are presented in Exhibits V-7 through V-12 after page V-8.
Exhibit V-7 presents the case of the 50 ppm VCM ceiling
Exhibit V-8 presents the case of the 25 to 40 ppm ceiling and 15 to 25 ppm TWA
Exhibit V-9 presents the case of the 25 ppm ceiling and 10 to 15 ppm TWA
Exhibit V-10 presents the case of the "no detectable" VCM level based on data provided by the Firestone Tire and Rubber Company
Firestone was the only PVCproducer reporting the ability to meet a "no detectable" VCM standard primarily usihg engineering controls.
Exhibit V-10 presents the Firestone information for the two Firestone plants. These plants were not included in the indus try summaries since the Firestone recommended measures to meet the 50 ppm standard were not estimated to be complete for two years. In addition, the Firestone estimates were inconsistently high with estimates provided by the remainder of the industry at higher VCM levels, for example 50 ppm, and included environmental protection measures, such as incineration and water pollution control, not directly determining OSHA compliance at the higher levels.
VRD 008201366
.. Exhibit V-10 also presents the Firestone economic impact data as a weighted average over the Firestone capacity of 507 million lbs. per year.
Exhibit V-ll presents the PVC industry claimed time requirements for compliance.
Exhibit V-12, following Exhibit V-ll, serves as a summary discussion of findings.
4. INCREASINGLY STRICT VCM COMPLIANCE REQUIREMENTS ARE EXPECTED TO RESULT IN SIGNIFICANTLY GREATER PRICE ESCALATIONS FOR PVC THAN FOR VCM
Exhibit V-13, following Exhibit V-12, presents the estimated impact of selected VCM standards on VCM prices.
VCM prices are estimated to be reasonable through a 15 ppm ceiling and 5 to 10 ppm TWA since supplies are not expected to be affected.
. The B.OC/lb price at the less than 10 ppm VCM ceiling and 1 to 5 ppm TWA is viewed as being on the low side since the effect of the claimed 42% of industry capacity possibly lost as a result of this standard should cause additional price increases due to supply and demand factors.
Exhibit V-14, following Exhibit V-13, presents the estimated impact of selected VCM standards on PVC prices.
. PVC prices are estimated to be reasonable through a 25 ppm ceiling and 15 to 25 ppm TWA, since only 9% of supplies may be affected. That is, a 9% expected reduction in supply was claimed in the indus try sample.
V-7
VRD 0002013661
The 22.9$/lb through 30.5$/lb prices at less than a 25 ppm ceiling and less than a 10 to 15 ppm TWA are viewed as being on the low' side, since the effect of the claimed 31% to 100% of industry capacity possibly lost as a result of the lower standards should cause addi tional price increases due to supply and demand factors. This section presented economic impact details, The next section discusses personal protective equipment.
V-8
3
VRD 9002013662
EXHIBIT V-7 USDOL/OSHA
ESTIMATED INDUSTRY1 COSTS OF ACHIEVING A 50 PPM VCM CHUNG LEVEL
IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL Snell assessment of VCM level potentially achieved^: 25 ppm TV/A, 40 ppm Celling
Total piano in sample: 23
.
Processes representedP): S, E, B, SO Location of plants In sampled 5W, 18C
Age of plants in sample:
Range, Yean
0- S
6 - 10
11- 15
16 - 20
21 - 25 > 26
No. of Plants * 2
10 2
4
23
Capacity of sample - millions lbs. per year (percent 1974 U.S. nameplate capacity):
Percent industry claimed capacity from sample subject to shutdown at a 50 ppm ceiling VCM level
Snell estimate of percent capacity from sample subject to shutdown at a 50 ppm ceiling
Capital
Annual
Direct Costs
(5/1.000 Lb.)
(5/1.000 Lb.)
3,750 (8Cft) Oft
Negligible
Perfcent of Total Annual Cost
L Engineering Costs^
$1.69
0. 93<5)
13ft
u. Personal Equipment Costs^
0.16
0. 23(7)
3
HL Monitoring
\
Total Direct Costs
0. 70<8? 52.55
0.74^8-Q) $1.20
10 26ft
Productivity Loss^^
$9.77
$5.33
74ft
Total Costs
$12.32
$7.23
100ft
Notes; (1) Snell estimate of VCM levels achieved In plants Incorporating the level of control effort represented in the Exhibit. Monitoring data is detailed in Appendix B.
(2) S - Suspension, E = Emulsion, Dispersion, B = Bulk, SO Solution. (3) W = Sited in warm climate, C = Sited io cold climate (U.S. 26C, 10W), (4) Includes ventilation, loading, reactor cleaning, stripping and other (piping, general pumps, maintenance, etc.) (5) Includes capital amortized @ 12ft - 10 yts. and 04M charges. (6) Includes breathing equipment and clothing, (7) Includes capital amortized @ 12ft - 5 yrs, and O&M charges. (8) Includes area and personal monitoring equipment, (3) Includes medical and recordkeeping costs, (10) Productivity loss is the industry average annual cost of additional capacity, personnel etc. to maintain industry capacity levels
by OS HA regulations. Source: Industry interviews and Snell estimates.
i
VRD 0002013663
EXHIBIT V-8
usDbiyosiJA
Snell assessment of VCM level potentially achlevedd) Total plana In sample* 21 Processes represented^). S, E, B Location of plants In sample^)* SW, 16C
ESTIMATED INDUSTRY COST OF ACHIEVING A 25-40 PPM VCM CEILING AND 15-25 PPM TWA LEVEL IN JVC PLANTS AS CLAIMED
BY INDUSTRY AND ASSESSED BY SNELL
Age of plants In sample:
Range, yean
'0 -5
6 - 10 11 -15 16 - 20 21 25 >26
No. of Plants
2 10 1 4 2 2
Capacity in Sample - Millions lbs. per year (Percent 1974 U. S. nameplate capacity!*
Percent Industry claimed capacity from sample subject to shutdown at a
25-40 ppm ceiling and 15-25 ppm TWA VCM level;
9^
Capital
Annual
Direct Cosn
($/l.fl00 lb.)
(3/1,000 lb.)
3,400 (72ft) .
Percent of Total Annual Cost
L Engineering Costs^)
$7.93
$2.34(5)
IP*
\
II. Personal Equipment Cosat6)
l.oo o.eiO)
5
EL Monitoring
0,75(8)
0.8p(78* 9)
_6
Total Direct Cost
*9.66
$3_.7S
31$
Productivity Lossf))
16.08
8.48
69^
Total Costs
$25.74
$12.23
lOOfl
Notes* (1) Snell estimate of VCM levels achievable In piano incorporating the level of control effort represented In die Exhibit, Monitoring data is detailed in Appendix B.
(2) S = Suspension, E = Emulsion, Dispersion, B - Bulk, SO = Solution. (3) W = Sited in warm climate, C = Sited In cold climate (U. S. 26C, lt'W). (4) Includes ventilation, loading, reactor cleaning, stripping and other (piping, general pumps, maintenance, etc.). (5) Includes capital amortized ' 12Vl> - lu vrj. and O&M c! targes. (6) Includes breathing equipment and clodiing. '7) Includes capita! amortized-ff Ji^T- - 5 yrs. und O&M charges. (6l Includes area and personal monitoring equipment. (9) Includes medical and recordkeeping costs. (10) Productivity loss Is the industry average cost of additional capacity, personnel, etc. to maintain Industry capacity levels
unimpjcted bt OSilA regulations, excluding plants which reported Inability to meet the standard.
Source: Industry interviews and Snell estimates.
*
I VRD 0002013664
*
-
1-
Snell assessment of VCM level potentially achieved^1) i Total plants In sample: 16
Processes represented^: $, E, B Location of plants in sample^). 4W, 12C
V>
i EXHIBIT V-9 USDCL/OSHA
ESTIMATED INDUSTRY COST OF ACHIEVING A 25 PPM VCM AND 10-15 TWA PPM LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSQ) BY SNELL
Age of plants in sample:
Range, Years
0-5
6 - 10 11 - 15 16 - 20 ` 21 - 25 ^ 26
i
No. of Plants
1 71 3 2 2
Capacity in sample - millions lbs. per year (percent 1974 U. S. nameplate capacity):
2.600
Percent industry claimed capacity from sample subject to shutdown at a
25 ppm ceiling and. 10-15 ppm TWA VCM level:
31<Jb
Snell estimate of percent capacity from sample subject
< to shutdown at a 25 ppm ceiling and 10-15 ppm TWA VCM i level
Capital
Annual
Direct Costs
(S/1.000 Lb.V
($/1.000 Lh.)
Percent of Total Annual Cost
L Engineering Coscs^ 1L Personal Equipment Costs^ m. Monitoring
$28.79 1.02 0.
$10.00<5> 0. B2t'7> o. 87C7'8,9)
3Tft 3
___ 3_
Total Direct CostsW
$30,68
$11,69
43%
Productivity
$30.28
$15.58
57%
Total Costs
$60.96
100%
Notes; (1) Snell estimate of VCM levels achieved in plants incorporating the level of control effort represented In the Exhibit. Monitoring data is detailed in Appendix B.
(2) S = Suspension, - Emulsion, Dispersion. B = Bulk, SO = Solution. (3) W = Sited in warm climate, C - Sited in cold climate. (4) Includes ventilation, loading, reactor cleaning, stripping and other (piping,- general pumps, maintenance, etc.) (5) Includes capital amortized @ 12% - 10 yrs. (6) Includes breathing equipment and clothing. (7) Includes capital amortized @ 12% - 5 yrs. (8) Includes area and personal monitoring equipment (9) Includes medical and recordkeeping costs, (10) Productivity loss is the industry average annual cost of additional capacity, personnel, etc. to maintain industry capacity level, unimpacted
by OSHA regulations. Tliis is based on those plants that expected ability to meet the claimed level, shown in die Exhibit. Source; Industry interviews and Snell estimates.
_
m
V
*
C9
1-0
<ss
C yt
E X H IB IT V - 10(1)
c<=n> -o
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50 w to w
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2" 2
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mga H tO 3 CO O
OHO
H3
503 on 0 o
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50
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1
VRD 0002013666
EXHIBIT V - 10(2)
TJSDOL/OSHA
ESTIMATED COST FOR THE FIRESTONE TIRE AND RUBBER COMPANY TO ACHIEVE A
"NO DETECTABLE" VCM LEVEL* 2 3 4 5 6 7 8 9 10
Direct Costs
Capital
Pottstown, Pa.
Pcrryville, Md.
($/l,000 lb)
(S/1,000 lb)
(4) I, Engineering
$137.02
$47.06
(6) 11. Personal Equipment
8.22
0.55
>-* GJ
00
III. Monitoring
(8) 3, 74v J
Total Direct Costs J (10)
Productivity Loss
$148.98 . 136.32
$51.04 27.42
Total Costs
$285.30
$78.46
________ ______ Annual_________________
Pottstown, Pa.
Pcrryville, Md.
(5/1,000 lb)
(S/1,000 lb)
$59.37(5)
$24.82^5>
1.86<7) 3.51<7-8-9'
0.17^ (7,8,9)
0.59
__________ Two Plant Average
Capital
Annual
($/l,000 lb)
(S/1,000 lb)
$80,77
$37.77
3.42
0,80
2.30
1.57
$64.44 79.15
$25.58 16.15
1
$86.49 59.98
$40.14 38.26
$143,59
$41.73
$146.47
$78.40
Notes: .Source:
(1) Snell estimates of VCM levels achievable in plants Incorporating the level of control effort represented in the Exhibit
(2) S = suspension, E = emulsion, dispersion
(3) W = sited in warm climate; C = sited in cold climate
(4) Includes ventilation, loading, reactor cleaning, stripping and other (piping, general pumps, maintenance, etc,) (5) Includes capital amortized @> 12%- 10 years and O & M charges (6) Includes breathing equipment and clothing
(7) Includes capital amortized (5) 12% - 5 years and O &. M charges
(8) Includes area and personal monitoring equipment
1
(9) Includes medical and recordkeeping costs (10) Productivity loss is the industry average annual cost of additional capacity, personnel, etc. to maintain industry capacity levels
unimpacted by OSHA regulations Firestone presentation to 25 June 1974 OSHA hearing and Snell estimates
*
VRD 0002013667
EXHIBIT V - 11
USDOL/OSHA
U.S. INDUSTRY CLAIMED TIME TO REACH SELECTED VCM LEVELS IN PVC PLANTS THROUGH
ENGINEERED CONTROLS
VCM Standard
Sample Total_______ 1974' Number of Capacity Number of
Plants (million lbs) Plants
1975________ Percent^ Number of Percent
Capacity Plants
Capacity
End of Year 197619771978 Number of Percent Number of Percent Number of
Plants
Capacity Plants
Capacity Plants
Percent Capacity
50 ppm ceiling
23 3750 23 100ft
25 - 40 ppm ceiling & 15- 25 ppm TWA
21
3400
1
3ft(1)
7
3 9ft(1>
8
32ft(1)
5
26ft(1)
25 ppm ceiling & 10 - 15 ppm TWA 16 2600
m (1) (1)
5 3 6ft'" . 7 39ft 4 26ft
"No-detectable"
Claimed "Not feasible"
Note: Source;
(1) Percent of sample 1974 capacity Industry interviews by Snell
3 VRD 000 20 1 3 6 6 8
-4 ii
1 4 )
j
94
5 1V
i
VCM Level Claimed By
Industry
50 ppm ceiling
25 - 40 ppm ceiling with 15 - 25 TWA
25 ppm celling with 10 - 15 TWA
"No Dctccable"^
Direct Costs of Compliance
0.19
0,38
1.17 4,01
EXHIBIT V - 12
USDOL/OSHA
SUMMARY OF THE COST IMPACTS AND DELAYS TO COMPLIANCE EXPECTED BY PVC INDUSTRY
BY VCM TARGET LEVEL
Unit Costs, d/lb. Costs to Make Up For Loss of Productivity
0.53
Total Costs^ 0. 72 * 20ft
Compliance Period Required For
Engineered Controls
0 to 6 montlis
Percent of Industry "Endangered"^ * Based On Sample
(3) negligible
0.85
1.23 4 35ft
~ 2.5 years
9ft
1.56 3.83
2.73 - 50ft 7, 84 - 50ft
*'2,5 years ~'3 years
31ft 100ft
Notes? Source:
(1) The percentage ranges of total costs represent Snell'* estimates based on partial statistical analysis of data (2) Endangered = management wfll seriously consider plant shutdown (3) Temporary shutdowns for Installation of controls were reported. In addition., one plant (not in sample) accelerated a planned
shutdown by six, months resulting in a loss of 50 million lbs per year (4) Economic data based on average data shown in Exlubit V - 10 for the Firestone plants which were not included in the sample
for the reason explained in the text
Exhibits V - 7 through V - 11
VRD 0082013669
EXHIBIT V - 13
USDOL/OSHA
ESTIMATED VINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS
(1974 dollars)
Item Plant I nvestment^)
Unimpacted by OSHA fd/ib)
4.080
Cost of Manufacture
6.13
Selling, general and ad ministrative expenses
0.30
Pretax profit on total in vestment 20v>at 1.2 x plant investment)
0. 98
Net selling price (FOB plant) 7.410
50 ppm Ceiling (0/lb)
4.230 6.20
0,30
1.01
7,510
25 ppm Ceiling (0/lb)
4.350 6.25
0.30
1,04
7.590
15 ppm Ceiling 5-10 ppm TWA
(0/lb)
4.540
6.33
<10 ppm Ceilinj 1-5 ppm TWA*
(0/lb)
4.810
6.55
0.30
0.30
1.09 7.720
1.15 8.000
\
Notes.Source:
(1) Unit Production Costs for a 500 million lb.ethylene oxychlorinadon plant of 1974 construction with total fixed capital of $20.4 million unimpacted by OSHA costs include production loss replacement
(2) Includes two plants which estimated the ability to achieve a 1 ppm VCM ceiling and 1 ppm TWA, essentially "no detectable"
Exhibit IV - 4 for basic economics and Snell estimates for compliance levels based on Exhibits V - 1 through V - 4
I VRD 0002013670
j
EXHIBIT V - 14(1)
USDOL/OSHA
POLYVINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1974 dollars)
VCM Standard PVC Standard
( ( Unimpacted [ Dy OSHA
Designed plant capacity (millions lbs/year)
Plant investment ($ millions)
Production, (millions lbs/year @ 90^0 utilization)
Plant investment per unit of production (d/lb)
Cost of Manufacture Vinyl chloride monomer (1.06 lb x net selling price from Exhibit III -2 - 0.59d/lb trans port! added)
200 20
ISO 11.1 d/lb
8.5d
50 ppm Ceiling 50 ppm Ceiling
25 ppm Ceiling 25 - 40 ppm Ceiling 15 - 25 ppm
TWA
25 ppm 15 ppm Ceiling Ceiling 5-10 ppm TWA 25 ppm 25 ppm Ceiling Ceiling 10 - 15 ppm TWA 10 - 15 ppm
TWA '
<10 ppm Ceiling 1-5 ppm TWA 25 ppm Ceiling 10 - 15 ppm TWA
200 22,2
180
200 24.7
180
200 30.9
180
200 30.9
180
200
30.9
t
180
12.3 d/Ib
13,7 d/ib
17.2 d/lb
17.2 d/lb
17,2 d/lb
8.6*
8. T*
8.7*
8.8 *
9. Id
1 ppm Celling 1 ppm TWA
"no detectable"
200 46.3
180 25.7 d/ib
9. Id
4
VRD 0002013671
Item
VCM Standard PVC Standard
Unimpacted By OSHA
Cost of Manufacture (cont.)
Operating labor and supervision
0.4
Capital recovery ((2) 12% - 10 years) 2.0
All other costs (catalysts, utilities, maintenance, etc.)
3.5
Total cost of manufacture
14.4d
Profitability
Cost of manufacture
14.4*
Selling, general and administrative
1.5
Pretax profit (@ 20% x 1.2 plant investment)
2.7
Net Selling Price (FOB plant)
18.6d
EXHIBIT V - 14 (2)
USDOL/GSHA
POLYVINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1974 dollars)
50 ppm Ceiling 50 ppm Ceiling
25 ppm Ceiling 25 - 40 ppm Ceiling 10-15 ppm
TWA
25 ppm 15 ppm Ceiling Ceiling 5-10 ppm TWA 25 ppm 25 ppm Ceiling Ceiling 10 - 15 ppm TWA - 15 ppm
TWA
<10 ppm Ceiling 1-5 ppm TWA
23 ppm Ceiling 10-15 ppm TWA
1 ppm Ceiling
1 ppm TWA "no detectable*'^
< f 6.6
{ (
15.2 d
< j 7.1
(
,
f 8.6
L
17,3d
( | 8.6
( 17.4d
8.6
L_
17,7d
(13.7
L
22. 8 d
15.2# 1.5
2.9 19.6d
15,8d 1.5
3.3 20.6d
17.3d 1.5
4.1 22.9d
17.4d 1.5
4.1 23. 0d
17. 7d 1.5
4.1 23,3d
22.80 1.5
6.2 30.5d
L
VRD 0062013672
EXHIBIT V - 14(3)
USDOL/OSHA
POLYVINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1974 dollars)
Notes: Source:
(1) Grass roots plant, located on Gulf Coast, producing general purpose suspension resin (2) Based on Firestone data presented in Exhibit V - 10
Snell estimates based on industry Interviews and prices for VCM presented in Exhibit V - 13
\
VRD 000 2 0 1-3 6 73
VB. PERSONAL PROTECTIVE EQUIPMENT AND, HYGIENE RELATED FINDINGS AND CONCLUSIONS
Preliminary discussion follows. TWO OF THE FOUR TYPES OF RESPIRATORS LISTED UNDER THE PROPOSED PERMANENT STANDARD (PPS) ARE READILY AVAILABLE FROM AT LEAST ONE EQUIPMENT MANUFACTURER
As presented in Appendix Exhibit D-8, two of the types of OSHA listed respirators ore available from the manufacturer in approximately two to four weeks from the placement of the order . These types are:
pressure demand full-facepiece self-contained breathing apparatus (PD) combination pressure demand full-facepiece respirator and pressure demand self-contained breathing apparatus (CPD) . The two other types of breathing apparatus listed in the PPS are not currently produced. Interviews \yith manufacturers indicate that these devices are considered wasteful of compressed air. These types are: positive pressure full-facepiece self-contained breathing apparatus combination continuous flow respirators and a pressure demand self-contained breathing apparatus.
THE REQUIRED TYPES OF RESPIRATORS PURCHASED UNDER THE 50 PPM TEMPORARY STANDARD MAY BE USED UNDER LOW VCM CEILING CONCENTRATIONS
The purchase costs for types PD and CPD from Exhibit D-8 are $515 and $615, respectively
V-9
>
1 VRD 0002013674
5
I The operating and maintanance costs from Exhibit D-10 range between $500 to $1,000 i per man per year, with an average of data estimated at $900.
The cost of grade D or better breathable air is $15 per 310 SCF cylinders. With an air flow of 4 CFM, this amounts to a cost of $0.20/minute.
i 3. INDUSTRY AND THE EMPLOYEES PREFER HALF-MASK AIR LINES CANISTER OR CARTRIDGE TYPE RESPIRATORS OVER THOSE REQUIRED BY OSHA IN THE PPS
4 Industry and worker preferences and human factors are detailed in Exhibits D-l throughD-4.
Self-contained devices are heavy, bulky, and require highly trained individuals.
i
4
S
. Air line respirators are much lighter than self-contained, but they require a long hose for the air supply and a complicated air distribution system.
.4 . . Cartridge and canister types are the lightest and least expensive of the three, 1 but lifetime has not yet been fully established for atmospheres containing VCM.
Users of cartridge or canister type masks have no way of knowing when their air purifier is no longer effective. . Half-face mask types are more comfortable to wear than those with full-facepieces, however, they do not provide complete facial protection.
4. THE NUMBER OF COVERED WORKERS NEEDING RESPIRATORY PROTECTION INCREASES WITH A DECREASE IN PERMISSIBLE VCM CONCENTRATION LEVELS OR REQUIRE HIGHER RESPIRATORY
*! WEARING TIMES 1 The following table summarizes case studies of the percentage of workers needing respiratory pro
tection as a function of VCM permissible levels, climate of plant location, and plant type (VCM br PVC). Further data will be provided in the final report.
V RD 008201 367 5
i'w^
Plant Type . V_CM
PVC
Climate of Plant Location
Warm
Warm
Cold
Ceiling VCM Level ('ppm)
Percent Of Workers Needing Respiratory Protection
50 15-ffl 25 15 10 30 10 M
1 100
50 25 10 ppm TWA +25 ppm ceiling
1
50 25
1
11 100 100
NA
100 100 100
Source; Exhibit D-ll and Sr.ell Assessment
Percent Of Time Respiratory Protection Needed
GO% 50 75 50 100
1 3 25
NA
10. 25 100
Comments
With Engineering Controls With Engineering Controls Without Engineering Controls With Engineering Controls With Engineering Controls
With Engineering Controls With Engineering Controls With Engineering Controls
With Engineering Controls
Without Engineering Controls Without Engineering Controls Without Engineering Controls
5. MOST OF THE TYPES OF PROTECTIVE CLOTHING ARE AVAILABLE WITHIN FOUR WEEKS FROM ORDER PLACEMENT
Disposable clothing, hoods, shoe covers, gloves and overalls are available within one week from the manufacturers including one piece pressurized suits, as shown in Exhibit D-9.
Permanent (reusable) work clothing is also available within one month of order.
Full impervious pressurized suits however, have a procurement lead time of at least two months.
I
\
i
V-ll
v
VRD 0002013676
6. COSTS FOR PROTECTIVE CLOTHING VARY WITH TYPE, WITH A LOW OF $3.50 FOR DISPOSABLE CLOTHING TO A HIGH OF $178 FOR A PERMANENT, IMPERVIOUS FULL PRESSURIZED SUIT A full suit of disposable clothing including coveralls, hoods, shoe covering, and gloves costs approximately $3.50, Permanent work clothing costs in the neighborhood of $40.00 per worker for a full suit of clothing including coveralls, gloves and boots. A permanent impervious full pressurized work suit which can be worn with an air mask costs $178. Industry believes that routine use of these is not feasible on grounds of human factors, indicated in Exhibit D-5 and concluded from the Snell industry interviews. The cost of cleaning a suit of permanent work clothes is in the range of $1.00 to $1.50 per suit, per worker, per day.
The next section deals with monitoring equipment.
V-12
Sr
VRD 0002013677
VC . MONITORING EQUIPMENT, RELATED FINDINGS AND CONCLUSIONS
Preliminary discussion follows. 1. THE THREE MAJOR CLASSES OF VCM MONITORING DEVICES: PERSONAL, AREA, AND LEAK, ARE ALL
AVAILABLE TO THE VCM AND PVC PRODUCING INDUSTRIES Personal monitoring, which is the technique recommended to OSHA by NIOSH (see Exhibit E-3), is available to industry from the manufacturer within two months from time of order. The gas chromatograph needed for the analysis of their samples can be received from the manufacturer in two to three months time. Area monitoring systems of the automatic sequential or continuous type can be obtained for installation within six months from time of order. Installation could lake upwards of two months. Manual area monitoring systems comprising a gas chromatograph with a flame ionization detector (FID) and Mylar or Tedlar bags for sample collection can be obtained from the manufacturer within three months. These devices require . little or no set-up time. Leak detection devices such as portable gas chromatographs or infrared spectro photometers can be received from suppliers within two months.
V-13
THE COSTS OF MONITORING EQUIPMENT RANGE WIDELY DEPENDING ON TYPE, HOWEVER, MOST EQUIPMENT PURCHASED UNDER THE TEMPORARY 50 PPM STANDARD MAY BE USED AT LEVELS DOWN TO AND BELOIV ONE PPM VCM
Personnel monitoring equipment vary in cost from $300 for automated charcoal tube/pump system to $70 for colorimetric tube devices. For the automated system, a back-up gas chromatograph is required at a cost upwards of $7,000 including basic chromatograph, columns, recorder, and mechanical integrator as shown in Appendix Exhibit D-5.
Area monitoring systems of the sequential gas chromatograph type cost in the neighborhood of $12,000 per 10 point instrument system without installation. Those operating under the FID total hydrocarbon principle can be purchased for $8,000, again without installation charges.
Leak detection equipment, which are either of the portable gas chromatograph, total hydrocarbon-FID, and infrared types cost from $3,000 to $5,000. No installation is required for these devices.
EXPENDITURES FOR MONITORING EQUIPMENT FOR A TYPICAL VCM OR PVC PLANT AVERAGE $100,000 IN CAPITAL WITH ANNUAL OPERATING EXPENSES OF $80,000
Personal monitoring equipment of the colorimetric types do not require a chemist for back-up due to their instantaneous reading capability. The charcoal tube types, however, require a trained chemical technologist for analysis of samples due to the necessity of using a gas chromatograph. At least one chemist per plant is needed at an annual cost of $15,000 to $20,000.
VRD 0002013679
The cost of installation for automated sequential or continuous area monitoring systems is approximately $15,000 per 10 point unit with operating and maintenance costs of about $30,000 per year with an operator. A mini-computer can be interfaced with the system for alarming and recordkeeping for an additional $10,000 to $15,000 and 06M costs of $4,000 per year. Leak detection devices cost in the area of $2,000 to $3,000 for 06M including a part-time operator for each instrument.
4. THE INDUSTRY ASA WHOLE SHOWS NO PREFERENCE FOR PARTICULAR TYPES OF MONITORING EQUIPMENT, ALTHOUGH THE CONCEPT OF AREA MONITORING APPEARS WELL ACCEPTED The VCM and PVC producing industries employ a variety of different types of monitoring equipment in each classification. In personal monitoring, both the colorimetric and charcoal tube system are employed. However, the charcoal tube type are sensitive to lower VCM con centrations than colorimetric devices. . For area monitoring, both gas chromatographs (GC) and total hydrocarbon analyzers are used. gas chromatographs provide concentration values which are specific for vinyl chloride monomer total hydrocarbon analyzers, as their name suggests, are not specific for VCM but give the total hydrocarbon concentration in the sample air.
V-15
VRD 0002013680
5. AUTOMATIC SEQUENTIAL MONITORING SYSTEMS (ASMS) CAN SERVE AS A LONG TERM DATA COLLECTION SYSTEM FOR AN ENTIRE PLANT
The ASMS can analyze an air sample from a particular point in the plant in 1 to 3 minutes with potential for at least 10 point monitoring.
A sj'stem installed in the polymerization building can provide warning to work personnel in that area if VCM levels have gone above ceiling levels. Personal monitoring data can provide the statisitical basis for locating sampling points for the ASMS .
TWAs can be determined by the personnel monitors for critical areas
these values can provide a calibration for the ASMS and determine the points within an area where the greatest VCM exposures are most likely to occur .
The ASMS can be used to provide correlation with personnel monitoring data of actual worker exposure. In addition, it can be used to provide a permanent record of VCM levels, provide alarms in case of exceeding ceiling values, serve as a means to initially identify the general sources of VCM releases, and to monitor progress in complying with OSHA requirements .
6. THE AUTOMATIC SEQUENTIAL MONITORING SYSTEM CAN PROTECT WORKERS AND ALERT MAINTENANCE PERSONNEL WHEN EXCESSIVE VCM CONCENTRATIONS OCCUR VCM emissions can occur from two sources:
slowly developing minor continuous leakage, such as a worn pump seal
V-16
VRD 000291.36 8 1
serious leakage, such as resulting from an operating error (e.g. valve left fully or partially open) or a serious sudden leak (e.g. blown gasket, sight glass breakage, etc.) In both cases, the system can prove useful in alarming the potentially affected people. In the case of a minor leak however, (with localized effects) the sample point nearest the leak will register the localized concentration and alarm on the next sampling indicating localized concentration above the limit. Response to cither type of alarm can be standardized. These steps could include donning of personal protective equipment, investigation using leak detectors, isolating the point of VCM release and corrective maintenance.
* * * *' *
The next section deals with medical surveillance costs.
V-17
VRD 00020 1 3 6 8 2
VD. MEDICAL SURVEILLANCE COSTS, RELATED FINDINGS AND CONCLUSIONS
Preliminary discussion follows: 1. THE AVERAGE TIME REQUIRED PER EMPLOYEE FOR THE REQUIRED MEDICAL EXAMINATION
IS FOUR HOURS WHEN PERFORMED OUTSIDE THE PLANT From the information presented in the Appendix Exhibit F-2, the time allowance per employee is itemized as follows:
Travel to and from examination facility -- 2.5 hours Examination and laboratory tests - 1.5 hours Maximum time required - 4 hours or 1/2 working day 2. THE SNELL ESTIMATE FOR TOTAL EXAMINATION COST PER EMPLOYEE IS $160
I
The cost estimate developed by Snell is based primarily on the tests and examination procedures recommended to OSHA by NIOSH as detailed in Exhibit F-3. . The costs were estimated for examination and tests completed out side the plant for a manufacturing facility with 500 covered workers. The total cost for such a plant would be approximately $82,000/year.
V-18
I*1
VRD 0002013683
3. INDUSTRY ESTIMATES OF THEIR PRESENT MEDICAL SURVEILLANCE COSTS AVERAGE $140 PER WORKER PER YEAR It was assumed by Snell that the examinations performed by the reporting plants were based on
the NIOSH recommendations toOSHA. This will be confirmed prior to the submission of the final report.
** * **
The chapter that follows presents next steps in the study.
\
V-19
...
3*
VRD 0002H3684
VI. NEXT STEPS
This chapter will constitute the recommendations in the final report. For purposes of this preliminary report the work steps planned for the remaining study period are listed below:
. Refinement of economic information
based on further analysis of the exposure data in Appendix B, development of Snells estimate of achievable compliance levels of VCM compared to those claimed by the PVC industry
development of Snell's estimates of the fraction of the PVC industry "endangered" by various compliance levels .of VCM with judgments as to the effects of plant age, size, location and technology
analysis of the PVC economic data for case(s) between the "no detectable" level and 25 ppm (ceiling or TWA)
\A/ case study for a PVC plant representative of the industry with good
\ exposure data and assumed to be under a 10 or 15 ppm TWA com
pliance limit for VCM
"*
Expansion of PVC technical discussions
the 35,000 gal. reactor technology
polymerization cycles and reactor cleaning
monomer stripping
general ROD, such as carbon adsorption * * **
Appendices follow in a separate volume.
VI-1
' ~X
SP :'i
.'/