Document NNGmd2Z5BN25oYLLxLYbZRapE

RECEIVED MR i 1974 utiiAL DEPL INDUSTRIAL CHEMICALS DIVISION MEMORANDUM Q ft, TTmr February 28, To: Mr. P. B. Cornell Subject: VCM Monitoring Programs Subsequent to correspondence (January 28, 1974) from this office concerning the scope of near term VCM monitoring pro grams, a number of developments have occurred which impact on our further efforts in this area. These are: 1. In addition to the initial four (4) cases of angiosarcoma of the liver found among vinyl chloride workers at v B. F. Goodrich's Louisville^Ky. plant, two (2) additional cases have been dis cove red _at_^h^^^ite_^ A seventh case has also been found at Union Carbide's South Charles ton W. Va. facility. 2. Near term action by NIOSH in tandem with OSHA is projected to result in a ceiling value for vinyl chloride in the air of 50 P.P.M. Such a ceiling value will undoubtedly be defined as the maximum average concentration over any fifteen (15) - minute period. The foregoing is based upon attendance by Allied personnel at recent industry/government agency reviews of this matter and participation with MCA representatives now studying the problem. 3. Additionally, the EPA is expected to identify VCM as a hazardous pollutant within one to two months. This action would impose emission controls similar to those established for mercury, asbestos, and beryllium and would mandate abatements on all VCM facilities. This action would be in addition to and independent of any OSHA regulations treating vinyl chloride as a carcinogen. Basis developments to date and receipt of your more recent air sampling data, we have advised Marketing to urge discontinuance by Robintech of padding tank cars with nitrogen for unloading purposes (see 2/13/74 letter attached). ASI-PR 0003456 Mr- P. B. Cornell 2 February 28, 1974 In view of the foregoing, immediate location efforts should focus on: 1. Continued daily ambient air sampling of operating, storage and loading areas to identify background and potential excursion areas- Such data should be tabulated and for warded to MTO with the Monthly Environmental Report until further notice. 2- Our objective, (exclusive of pending NIOSIi/OSHA standards) should, as promptly as may be feasible, limit employee exposure to a maximum vinyl chloride concentration of 50 P.P.M. To provide further safeguards, those employees who may be exposed to excursions beyond this ceiling value should be provided with respirators equipped with organic vapor cartridges. Additionally plant areas which offer a high exposure potential (> 50 P.P.M.) should be identified and posted. Employees should be instructed to wear respir ators while in such operating areas and engaged in activities which may result in exposure to excursion concentrations. 3. Installation of the proposed vent recovery system to accomodate various VCM emission and purge streams should receive priority status with G.O. issuance expedited. 4. A universal industry-wide approach to sampling, analytical techniques, air monitoring programs and medical surveillance although under study by an MCA sub-committee will be slow to issue. Accordingly, our internal .efforts must be in tensified to develop "in house" procedures and expertise in these areas. ICD Environmental Services will monitor MCA sub-committee and co-producer progress in these areas and advise you of developments which may be of help to BRN technical personnel. As interim or more permanent standards are promulgated, we will keep you advised. In the meantime, please advise this office of monthly progress vs. the foregoing initial program. JMQ/sm cc: See Attached J. M. Quinn Director Environmental Services ASI-pr 0003457 cc: Messrs P. N. Shellenberger E. E. James R. S. Christian R. J. Geiger E. W. Callahan R. H. SanSS-/ W. S. Ferguson Dr. E. Dixon A. J. von Frank R. J. Nelepovitz J. M. DeVoe W. C. Koch R. E. Gribben A. J. Lichota Dr. E. F. Booth C. E. Sassano H. W. Founds 4Si~Pr 0345q Industrial Chemicals Marketing, DAB-2 Mr. A. J. Lichota VCM - flanJ HYGIENE N0N-C0NDEN5ABLES Industrial Chemicals Manufacturing, DAB-Q February 13, 1974 On February 8, 1974, I attended a meeting of the Vinyl Chloride Safety Association in Cleveland. This meeting was called to discuss the B, F. Goodrich report that four employee deaths at their Louisville, Kentucky PVC plant might be re lated to vinyl chloride exposure. A portion of the meeting was devoted to a review of points of possible exposure to vinyl chloride as a result of operating practices, and it was generally agreed that the tank car loading area probably represents the location having the greatest possibility of repeated personnel ex posure, particularly where the venting of non-condensables from "empty" tank cars is required. It was Indicated that all VCM producers looked unfavorably at the customer practice of padding cars with nitrogen for unloading purposes. Some companies said they did not permit this practice at all and were surprised that anvone would per mit customers to use this method for unloading. It was the consensus of VCM manufacturers that a concerted effort must be made by the industry to discourage the further use of nitrogen padding. As you are aware, Roblntech has made a practice of using nitrogen padding and I would request that they again be approached on the subject of discontinuing the practice. In view of the Goodrich report, the problem is much more serious than just the yield loss involved. The venting of cars may be creating serious health hazards for our employees which we cannot permit to continue. In fact, it Is more probable that the Federal standard for VCM levels in plant atmospheres will be reduced drastically in the near future, a move which will dictate the discontinuance of tank car venting to the atmosphere. ASI-PR 0003459 Hr. A. J. Lichota -2 bruary 13, 197*1 I appreciate your assistance and suggest the discussions with Roblntech take place in the very near future, the results of which negotiations I await with great interest. * i WCK/dl cc: J. M. Quinn W, C. Koch Quality Assurance Manager ASI-PR 0003460