Document Q9ZqnQVqbw5R1qdQNVd1MQ35

( cc CONFIDENTIAL UNI ROYAL CHEMICAL Division of UNIROYAL, Inc. TO 6, A. Anderson Naugatuck May 9, 1975 cc: JOT - Naug. ACM - Naug. B. R. Leach Pa 1nes vl11e SUBJECT: Marvlnol Status At the Division Staff meeting of May 2nd I had many more charts available than I needed to use. It did not fit the presentation that the SPD Board chose to make for me to present the detail covered by these charts. Nevertheless consideration of the data contained Is Important In de termining the timing of the Marvlnol decision. It occurs to me for Instance, that certain of the concerns likely to be raised by Mr. Beretta or the Board of Directors relative to the status of our VC compliance might be answered by use of these charts. A set Is therefore attached. I feel that a few observations from the plant are appropriate for consideration as a decision Is approached regarding the timing to Implement the shutdown. These are: 1. Mr. Bommarlto, President of the URW International, has Indicated that he expects the PVC Industry to be more Interested In profits than in the safety of their employees. Continued procrastination on an early decision to announce that we will no longer manufacture PVC, If In fact we do not plan a commitment for adequate facilities for the manufacture of PVC, supports Bommarlto's observation. This can lead only to certain embarrassment of Uniroyal If we are held up as an example of a company who exploits Its employees. You will see from the charts relating to VC concentration In Bldgs. 107, 117, 108, 414, and 415, that while we have made measurable progress In reducing VC concentrations we are still far above the permissible limits required by the OSHA regulation. These data have been posted as dally results and weekly averages In each of these buildings for the past nine months. This Is being done since notification of employees is a requirement of the regulation. Any belief that anyone might have, that the Palnesvllle plant employees do not know the level to which they are exposed. Is therefore naive. Me have also shared with the Union Negotiating Com mittee our plans for engineering compliance for the future. The chart listing the engineering controls possible Is an URL 14398 INTERCOMPANY CORRESPONDENCE v 2 example (this particular chart was provided to the OSHA Inspector on May 7). 2. While we at present have no difficulty In selling our resin at current VCM content this will become Increasingly difficult as other suppliers make the needed process improvements which we are not making. This is likely to be a lesser problem In the Plastlsol types than in Suspension. Especially Suspension resins In bulk will represent a level of vinyl chloride In the customers operation which I doubt that many will want to accept as a responsibility. In fact, our Allied plant (Masland) Is reporting problems with OSHA compliance when using Palnesvllle bulk 22. In brief, I feel our resins will not be competitive because we have not taken the necessary steps to make them so. This cannot be accomplished by hoping that a miracle will occur but requires equipment Installation In the neighborhood of a million dollars for accomplishment (Items 10 and 11 on the Engineering Control sheet). 3. Even If the commitment of 3.9 million dollars for engineering controls is made this will only, by Itself, precipitate the need for additional capital commitments for the future. These are detailed on the sheet labeled "capital expenses". As we have often discussed. It does not make sense to talk about replaclna the wornout equipment in Area I. When the future controls likely to be placed on the transportation of VCM are considered. It seems far more reasonable to plan a new plant for Gelsmar than to put any additional money Into the old plant at Palnesvllle. 4. In order to make the best utilization of our personnel resources at Palnesvllle we have chosen to move some of our better people to other locations. Certain of these have already been moved In anticipation of the date of 12/31/75 being certain. The Palnesvllle plant staff has therefore taken onto Itself the responslbl11ty of operating effectively for the remainder of this year with certain of our better people removed from the organization. This Quite obviously represents an exposure in the area of continuing high quality and high productivity from our operation with reduced staffing. If It was not the Intent of the Company to discontinue Marvlnol manufacture on December 31 then I have taken on responsibilities more than I should have In terms of best utilization of our better personnel. 5. I cannot, as I think over the Implications, believe that serious consideration can be given to sending Bob Douglas to Master Negotiations In early February 1976 under either of these conditions: a. An announcement was made on September 30 that Marvlnol production would be discontinued on December 31 and the plant organization Is In the throes of all of the personnel problems represented by reducing wage and salary by one-half by the end of March. Or: URL 14399 T URL 14400 -3- b. An announcement was made on December 31 that Marvlnol production would be discontinued on March 31 and one-half the wage and salary staff would be eliminated by June 30. Either of these represents an Impossible condition for the Palnesvllle plant* the Division Industrial Relations Department and the Corporate Industrial Relations De partment. It seems far better to have taken our lumps and to be In a position of healing the wounds before Master Negotiations begin rather than to be Involved In all the emotional turmoil which will be present during the personnel reductions. In summary the longer we wait to take the necessary action the more problems we will have to suffer. Given the propo sition that we must take the action, I cannot believe the consideration of the possible additional NIBT (which may in fact be highly unrealizable) can be sufficient reason to delay this decision. It did not serve my purpose as a member of the Marvlnol SPD Board to argue this case last week any more strongly than I did. I feel much more strongly to have the decision made that I expressed last Friday. I would welcome the opportunity for further discussion with you, Mr. McNeill or anyone else to speed up the decision which I feel is now overdue. BRLmak Att: URL 14401 RESIDUAL VCM IN MARVINOL PPM VCM BY WEIGH! TYPE MARVINOL 10 53 5008 5051 ^ PRESENT OPERATION AS PACKAGED AVE. TANGE ASHIFC*D. TOTS BY CUSTOMER 152 15-940 7.0 i 751 85-^243 214 - - 511 39-910 13 424 657 37-2,920 60 615 1407 133-2,445 318 ; N.A. 23 3-133 6 - 6 4-8 N.A. - 11 N.D.-34 4 N.O. - Non-detectable N.A. - Not available ESTIMATED RESIDUAL VCM AFTER STRIPPING SYSTEM implementation MAXIMUM <5 <10 <10 <10 <25 <1 .0 <1.0 <1.0 CHK 4/30/75 URL 14402 PAINESVILLE PERSONNEL REQUIRING RESPIRATORY PROTECTION* NUMBER OF PERSONTlTL "REQUIRING RESPIRATORY PROTEUTIfllT 5/1/75 " present operation 290 AVERAGE % OF TIME requiring" respiratory1 protection 5-25 PPM VCM 0VeE" 2 5 PFM- (CMirrrR) ~ (AIR line SUPPLIED) 25% 8% total* 33% o CM after implementation of' proposed improvements 213 (Chanqe Is Paracrl 1) 10% *T1me In a day that masks must be worn by those who must wear masks. This total will be required after April 1, 1976. 12% CHK 4/30/75 IL & HO it PRACTICES ' ' -' .- ' ` - --- --~^L,7'^TklS^'l-lVE. EXPECTED VC LEVELS (PPM) AFTER CHANGES 4 ENGINEERING CHANGES "" 1* Solvent Cleaning A Recovery; ^ ' *" . - "51TTST" 107 BT5ST1 108 VC l PPM) CAPITAL"" 15 - 7.0 .. >" '. COST $ ~ V\v -. ; 560,000 "' ?* r'l- BLBfcT" 414- 30. '. v'" - . ,* '* .'a*' -i 20 BLIifl.. 415'-' * . 5.0. , "5125."" 42U0ZC 5: ' 5-.0 ' . ` S^:'! 2. Venting Reactors Prior to Entry ;; r, 157,000 - er 7-9' 16 rw- ; V^* 3. Recovery Seal Improvements ^.1 -C - 88,000 6 ;7:r|j;- ;r 14 . - V; ri,:^ ;-T; 5=:^'. 4. Ventilation of Process Bldg.-107,117,414 848,000 5, Control VCM Release at Unit Operations > 74,000 3 .r - V7 9: *- , " *Tw-: 3. . 5:<;-'. T:"ys : ST: 6. Delumper in Suspension Resin System^ ,100,000 3., :: _ .. 53^ : 7. -5000 Gal.Reactor Flush System ' _44,000; 3" ^ 5^/7" / 1^;.: 8. $.0. Process Bldg.Pressurized Room.- ^ 77/-' : 20,000 . ; 3" SL*V.r: ^V -. 5v- ; 9./ Breathable Air:' w--"-.-^" 510,000 3 r.-:/ :_'7; s~ .7 -rs^:' 10.V Suspension PVC Stripping A Product Decontamination "ir";; J- 735,000 ^v 3V T-V5" . 5 ^V./y '" . -V* M.O . X'r#:;- 11. . Plastfsol PVC Stripping A Product .. ^ Decontamination ^ t^ ; r-^ sir, ooo ? T.;...- - v 12. v1 HIBoller Disposal-Pure VCM Distillation- --7 7,000 `^*v7 J--* `. V \.x*-*w* i / . -jy--'s -CrV-'^ *.' 13.' Purge VCM Unloading Line ; 56^000' 14..v Paracril1 DZQ Finishing LIne Ventl 1 atlon - , 80,000 T5;^jhrC^^oSe:Veftt11atlon;'Brs5'S?5S?^ jESoOO^-' ' '3 ... - ' '-33-: ''i ;.;r3.^: i;r7 M.O **> * '':VX TVS^1 - - 5r.' " V %-r. ^ife: >llo5ir >1.0 4C.% .`.I'-T-V* ::>T5^ vu*?r V'. - ij| i.*j-T'"V3L i-' f?*.--ii. URL 14404 DRYER EXHAUST VCM CONTENT. PPM EMISSION POINT 1. WILLIAMS MILL (H-10) 2. SOLIDAIRE DRYER (M-5800 TYPE) 3. SWENSON MAIN COLLECTOR 4. BOWEN #1 " 5. BOWEN #2 M n m 6. S.D. MAIN COLLECTOR (SUSPENSION RESINS) vPRrrE.S-E--N--T-- OPERATION -------- RTonrr 49 4-120 17 3-100 26 5- 70 32 3-180 45 3-150 66 3-350 ESTIMATED VCM AFTER" STEAM" "STRIPPING Is IMPLEMENTED 1 ,0 - 3.3 5.7 4.4 4.8 CHK 4/30/75 AREAS & OPERATION ANTICIPATED EPA STANDARD ON VCM EMISSION (EXPECTED COMPLTMCE~DKTr^3M. 17751" ANTICIPATED STANDARD 1. MONOMER UNLOADING, STORAGE SAMPLING & TRANSFER 2. POLYMERIZATION AND STRIPPING AREAS 3. MONOMER RECOVERY VENT LOSSES 4. CONTROL VCM IN SLURRY 5. CENTRIFUGE > DRYER, BAGGERS AND STORAGE SILOS OR BINS 6. WATER EFFLUENT NO DISCHARGES DIRECTLY TO ATMOSPHERE. ALL LINES MUST BE VENTED & PURGED TO RCVM SYSTEM. MUST MEET OSHA STANDARDS. MAXIMUM ALLOWABLE DISCHARGE IS 10 PPM. USE OF ACTIVATED CARBON ABSORPTION UNIT IS FEASIBLE. MAXIMUM RESIDUAL VCM CONTENT OF 400 PPM (DRY WEIGHT) FOR ALL TYPES. STEAM STRIPPING IS FEASIBLE. MAXIMUM DISCHARGE OF 10 PPM FROM EACH SOURCE. STEAM STRIPPING WILL RESOLVE THE PROBLEM. NO STANDARD AS LONG AS PVC SLURRY CONTAINS LESS THAN 400 PPM OF RESIDUAL VCM. CHK 4/30/75 URL 14406 A. ENGINEERING CONTROLS B. MONITORING c. PERSONNEL PROTECTION D. EPA COMPLIANCE SUB TOTAL E. FIA INSURANCE REQUIREMENTS F. CONVERT 2ND BOILER G. REPLACE AREA 1 POLY AREA GRAND TOTAL CAPITAL EXPENSES CAPITAL $M 559 50 75 $4,561 2,000 1,200 15,000 $22,761 ALTERNATE: NEW PLASTISOL PLANT 0 GEISNAR FOR $35,000M BRL 4-30-75 EXPENSE $/YR rTT4T0TTO0" 130,000 210,000 40,000 $ 2,790,000 --- Suspension Resin Plant VCH Concentration In Air ( URL 14407 7 Dispersion Resin Plant VCM Concentration In Air V" VGM In A ir . PJff ftOVVV 1 I I 4 l 6 7 I 0 10 11 1i 13 14 lb 1* l 18 li SO Jl !Wj 24 ? J6 ;/ 28 39 30 3' 33 34 3* 34 ifc J 38 33 0 1> *3 43 44 4J 4 47 46 43 Sip SI M ii/20 5/26 6/30 7/26 8/25 9/29 10/27 11/2U 12/29 l/26 2/23 3/30 r5 YEAR OF 19 7^-7$ Dispersion Resin Plant VCH Concentration In Air I 60rH Idi i FiVi Suspension Resin Plant VCM Concentration in Air i URL 14410