Document R2yqQbkYbRRBQz2emX6zwExR8
LM6
Revised 10-15*76
Methods of Compliance
to the Permissible Exposure Limits OSHA Regulation 1910.93 q - Standard for Exposure to VC1
8FG Technical Center
OSHA regulation 1910,93d requires that employee exposures to vinyl chloride shall be controlled to 1 ppm or less of-VC! averaged over any 8 hour period and that no employee shall be exposed to vinyl chloride at concentrations greater than 5 ppm averaged over any period not exceeding 15 minutes. If exposures are above this, feasible engineering and work practice controls shall immediately be used to reduce exposures to at or below the permissible exposure limits.
At the Technical Center we have on going programs in both the engineering and process departments. Written plans for these programs arc attached and will be furnished upon request for examination and copying to authorized representatives of the assistant Secretary of Labor and the Director of OSHA. These plans will be updated at least every six months,
These plans will also be shown to employees who are exposed in excess of the permissible exposure limits to show them the steps being taken to reduce their exposure to within the permissible exposure limits.
LAB:jj
Lee Bennett VCM OSHA Administrator
NGC 22837
SPECIAL OBJECTIVE
A. Enaineerino Proiects Divert VCM vapors now vented to room
PROJECT
AVON LAKE SCHNICAL CENTER VCM
SSIONS CONTROL REPORT
STATUS REK.,i'
COMP. DATE
PERSONNEL ASSIGNED
COST ENG T0TA1
Spot Venti1 at ion
Complete
Gary Wi1 son Jim Ego
$50,000
$150,000
Disperse exhausted vapors hiaher in atmosphere Insure adequate bldg, venti1ation
Reduce or eliminate environmenta1 emissions Same as above
Replace high emission source pi lot plant equipment.
Bldg. 414 exhaust
stack
Building ventilation
a) B/414 E Emergency
Normal
b) B/414 W '*
c) B/414 S 11
d) 6/417
"
RD & RV discharge control
a) small polys .
b) lorae oolvs
Design & Construct a VCM
recovery disposal system
for West process.
Replace present 15 gal. polys with 55 110 liter polys.
Hoi d 3/77
Gary Wi1 son Jim Eoo Gary Wi1 son Jim Ego
$33,000 575,000
$120,000 $600,000
1976 1977 1977
Gary WiIson
$50,000
$200,000
Cahii1 Houston
$30,000
$100,000
Gary Wi1 son Jim Ego
$150,000 $600,000
Remove VC1 from 15 gai. poly charges prior to filtering or drummina. Eliminate employee exposure
Eliminate use of buckets of solvents for poly cl tanina Reduce VC1 in air
Design & install al5 gal. slurry steam stripper.
Install a safe- sample analy station in .B/4l4 Design & install a safe solvent cleaning system in B/414 Leak control
s
a. Install a Bendix GC monitoring system in B/414 for VC1 S- ECH.
b. Install a Bendix total hydrocarbon monitoring system in B/413 for PVC Laboratories.
Eliminate VCM exposure while centrifuging and traying resin from wash tank. Prepare S0P*s for PVC orocesses in 6/414
Monitoring System
Properly strip charge In wash tank to eliminate residual VCM
12/76
A. Siver1ing
1/7& 1/77
A. Siverling Smi th
Cont. Complete
Process & Ma int: Wi Ison
1/7& 1/78
F. Zieber F. Zieber
$ 2,000 $ 2,400 $ 6,400
0 0
$ 12,000 $ 24,000
$ 44,270
Revir 10-15-76
REMARKS
Extended local exhaust under 1100 gal. polys. Made canvas hoods for containing vapors from leaky valves & gaskets. Installed bench hood for matr. work up. This job is essentially conolete. Stack has been approved for Hydrin. The Geon Vsclets will be tied into this stack. Design is on HOLD. Working on improving performance of existing heating system at a cost of $23,000.
No action.
Budget estimate complete. Using post polymer ization plus high pressure condensation (4or). Working on layout and detail designs. Completion of first nhase olanned for second Quarter. 1977. 1nsta1 lacion of two new 55 1> ter polys with . blow down tanks and stripping and drying system. 10% complete. Reactors received. Process engineers are seeking a better definition of the orocess. EA approved and shop work started. Starting up
In fourth quarter of 1976.
Completed.
20% complete. ON HOLD.
:
Continuing
a. Increased number of sampling points to 10. Also tied In wind direction & velocity to area monitoring program.
b. Lab GC has been placed on hold because of an insufficient number of erroneous excursions.
!
We have not been centrifuging. Centrifuge has been removed from VCM building.
A number have been written and are ready for aonroval.
;
NGC 22838
cc: R. M. Kreager, D. J. Barnicki, F. Zieber, P. OeChant, . Alten, G. Wilson, F. Krause, C. Orben, V. Carson, 0. Popovich, N. Wearsch, L. Bennett