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NON-CASPALTY SUIT OSHA-VINYL CHLORIDE RE: THERMOPLASTICS COMPLIANCE PROGRAM DOCKET # 1964 BR 012718 \ \ f 4^ LEOMINSTER COMPLIANCE PROGRAM f V BOR 012719 \ ^//. , .J - ^1 0 '< ' ; r~~ INnS-COHPAHY aw office correspondence D. ColUttfr SUBJECT: OSHA Standard - Vinyl,Chloride Prom i Located AT: DATS i R. L, Mercier Leominster, Mass. December 18, 1974 a ^ .-'AS DBtttpm*c. h Dituiqn C+r*p*Tty Provisions are within this standard which allow for opportunities of employees and their designated representatives to observe the moni toring and measuring that is required. Requests for this opportunity must be made in writing, listing the employees concerned and their designated representatives by name. Upon request, we will schedule a proper time for this review. Likewise, there are provisions for examination of monitoring and measuring records. This, too, must be'handled by written request. All such requests are to be made, in writing, to N. M. Blackman. Vj .kC (k ''ytl', TJJ ADcct RLM:mdm cc: H. R. Jepsen, Jr.. N. M. Blackman NTOSH Compliance File ^ ^ R. L. Mercier I BOR 012720 \ Vi \ \ MONITORING METHODS - 1 PPM STANDARD The following are the approaches being used to monitor VCM exposure; 1. personnel Monitoring Eight-hour carbon tubes, specific for VCM utilizing Bendix PMCC and Bendix Flasher attached to a Gas Chromatograph. This is scheduled once per month for each individual exposed above the permissible exposure limit. It is scheduled quarterly for those exposed- above the action level but below the permissible level. 2. Area Monitoring t A Bendix total hydrocarbon analyzer is used to monitor areas of exposure. By calculating an employees length of time in a con trol area we can determine the "Maximum Expected Exposure to VCM" in these areas. This is to be done for all areas on every shift. Alarms indicating at 25 ppm have been installed to signify when a change in/masRh is to occur. fefiUuVHWT 3. Spot or Leak Checking Century OVA 98 Total hydrocarbon analyzers are in use to check areas not covered by the Bendix, to double-check Bendix results and to spot sources of leakage. This is scheduled to be done daily. \ 'i 7; BOR 012721 * i ? \ .. -m '''W'3'*;> ^ "'- i-.i "A.: K o= regulated areas F^ i%vJL^' iytfw Regulated areas for Leominster are Buildings 1, 2, 3,^4, 4Aj (!>, , < f. .. . *--4. ^S f7,\ty,'2l, 2^,1 23|, 3y and that portion of Building 10 South of the East-Meet hallway. ft.^ _ ,7^ The VCM unloading area will be regulated only while VCM cars are being connected or are connected rfor unloading. The FVC Bulk loading area will only be regulated while PVC Bulk is being loaded into rail cars or trucks. -- V ir \ BOR 012722 -\ i ' `i^ "* " ' V i: f>'v 6 INTrESR-COMPANY AND OFFICE CORRESPONDENCE TO> SUBJECT) J. Degenfelder R. MercieWr- ^ \ VCM Compliance program for day maintenance men, janitors, grounds keepers and their supervisors. Pitomi A. C. Mendelsohn Located ati Leominster, MA Datei December 26, ,1974 J( | D|Dwpi<Wpwtf.Aitf"* The objective of this program is to provide a means of control and record keeping for subject personnel who will be entering regulated areas daily, but on an intermittent basis and in various control areas. It is assumed that all subject personnel will be in a control area un less subsequent" work sheets show otherwise. PROGRAM At the start of each work day, fell subject personnel will report to the Safety Technician for entrance into the Roster and issuance of safety equipment. At the end of the day's work, each man will return his safety equipment to the Safety Technician and be entered into the Roster as leaving. The Maintenance Dally Time Sheet will be modified to include not only hours worked and on what project, but will also include the control area designation and the starting and finishing time of each job, A copy of these time sheets will be turned into F. McDonald daily. ACM/ar A. C. Mendelsohn `" ..... V cP ^ C^PUtt-e^T- 't *5 \4iJl `bfiTJO W>nn>* TH* ^ o Tvtt *iuMSec_ 7C / . \'4 /rf, - "r'****, r- ^ . .. > ;*c- ' \ ' - ;> - !:<r 4- ^ \ .. vW' ir.- ' -- * ^f- BOR 012723 -COMPANY AND OFFICE CORRESPONDENCE Toi J. Degenfelder Fromi A. C. Mendelsohn R. Merciar UOCATXO ATi Leominster, MA VCM Compliance program for entrance _ to regulated areas by visitors, DATIi 1 contractors and material deliverymen. December 26, 1974 ( Dtpt. \m The objective of this program is to provide a means for control of subject personnel and prevent entrance into regulated areas by unauthor ized personnel. Definitions: Yjgjtpr: A person who has business vith Borden personnel but the nature of his business does not require that he conduct his business in a regulated area. Contractor: Material Deliverymen: A workman and his authorized supervisor who will be performing work on the site in both regulated and non-regulated areas. This category will also Include people who must enter a regulated area for purpose of inspecting equipment* A driver and/or helper who are bringing materials to and from the site, usually by vehicle. All of the above personnel are not Borden, Leominster site employees. Regulated ___ Area ; An area so designated by the Manager of Vork Practices as being required to be so designated and posted, by the VC& GumpliffiTce Regulations. CO PROCRAM Visitora: Visitors will not enter the regulated areas. They will sign in and out with the telephone operator in building 20B. The telephone operator will contact the Borden employee being visited. The Borden employee will either meet with the visitor in the lobby or escort him thru and to nonregulated areas only, to conduct their business. On the completion of % BOR 012724 \ Page 2 business the Borden employee will escort or direct the visitor to the lobby to sign out.' The Work Practices Manager may designate other areas suitable for conducting business. Contractors: A.) Daily Workers: They shall apply to the Plant Engineer, who will issue a pass which shall expire no later than 1700 on Friday of the week in which it was issued. The pass shall designate whether it is for regulated.or non-regulated areas. If for regulated areas, it shall designate the areas for which the pass shall be valid. If the worker will be reporting for work on the following Monday, he may obtain a pass for the following week on the preceding Friday, Daily workers who will be in regulated areas will report to the Safety Technician for entrance on the daily Roster and issuance of safety equipment. On leaving the plant, the worker will return the safety equipment to the Technician, and be record ed on the Roster. The on-site contractor supervisor will maintain a time sheet as now used, but will, in addition indicate the time that he and his men were in specific regulated areas. (A maintenance form may be used.) B.) Occasional Contractor supervisors and others who must enter the regulated areas for businesst Every attempt shall be made to minimize these visits. These people shall be encouraged to come by appointment only. They shall enter the site similar to a visitor, via the telephone oper ator's lobby in building 20B. The visited party shall obtain a pass from the Plant Engineer and the Contractor will be escorted to the Safety Technician for Issuance of safety equipment and entrance into the Roster. Leaving the "site will be via the Safety Technician and the telephone operator's lobby. All type "A" passed will be returned to the Plant Engineer on completion of work or on Friday afternoon, which ever shall come first. All type "B" passes will be returned to the telephone opera tor prior to leaving the site. The telephone operator will, in turn, return such passes daily to the Plant Engineer. The Plant Engineer will maintain a list f passes issued and returned and submit daily a copy of this list to the Work Practices group. \ BOR 012725 \ % % < - z* -Page 3 \ Material-Deliveries: !r_ \ Material shall be delivered to and picked up frcxn non* regulated areas only. Trucks and other vehicles making deliveries and pick~ups shall stop outside building 4. It will be the responsibility of the Shipping Department to properly direct, or load, or unload these vehicles so that the deliverymen will not enter regulated areas. The Work Practices group shall so post a prominent notice by sign at the Lancaster Street entrance. The Elm Hill Avenue entrance will be used for emergency vehicles only. Contractors (both A and B) will wear distinctive markings on their safety hats. These markings may be affixed to the contractor's own hat, or for the occasional class B contractor, it will be affixed to a Borden*fumished hat. ACM/sr QjQ A. C. Mendelsohn * , 'ftit Vi 1 - v > ,;'*k _ ; BOR 012726 \ Name _Pate_ TIMS DISTRIBUTION ______________ Shift__ Maintenance Janitor Crounda Keeper Contractor a a a a BOB 0 1 2 7 2 7 Straight Time. \ ,'<vOvertime \ WORK PRACTICES PLAN \ To meet the specific requirements of the permanent OSHA standard for VCM exposure, we have worked out the following system covering changes in our work practices: I. Organization The new position of ''Operations OSHA Compliance Controller" has been established for full time coverage in the plant. The de tails of this position are included in the attached memo of November 26, 1974 (Manning for OSHA Compliance). These controllers will report to Phil McDonald, OSHA Compliance Foreman. McDonald will report directly to the Plant Manager. II. Employee Control The measurement and control of worker exposure will be handled by use of "control areas" as outlined in the attached memo of November 8, 1974 (Compliance with OSHA VCM Standard), These areas are finalized except for a few instances as we generate more data to determine the overall regulated area. In both the FVC and Polyco departments, the recording of workers time by control area will be kept daily by the OSHA Controller and sent to the Work Practices Group. In Polyco, the actual log will be kept by the Shift Foreman and turned over to the controller. For the Maintenance department (excluding shift men in PVC), a separate system will be kept by supervision in a straightforward manner. The maintenance program will also control access of outside vendors and con tractors. Cline Mendelsohn will send the details to you by the end of this week. Our training progran haa been underway for some weeks. Our philosophy is to Incorporate the requirements for worker exposure to VCM into our modified and expanded (standard operating procedures'^ Phil McDonald's master outline and schedule shows the) completed and planned training in this area. liCvO 1 J. *R. Degenfelder BOR 012728 \ e COMPLIANCE WITH 03HA VCM STANBAKD November 8, 1974 I will be the chief action coordinator for operations in determining our program in meeting the OSHA permanent standard for VCM exposure. The main engineering improvements of copolymer recovery, revised RVCM handling (D209), and full blending resin recovery in D406 have and will continue to be detailed in separate memos. The other main areas for operations are VCM monitoring and respiratory mask control. A. Monitoring 1. ? 2. 3. Control Areas - a control area is a geographic part of the plant which has more or less uniform VCM in air content and which fits the work pattern of operating personnel, e.g., Module 2/3, tank car unloading, all of new Polyco. Control areas will be fixed at least through January 1, 1976. v Monitoring philosophy will be based on measurement of a time weighted average VCM exposure for a control area for an eight hour shift. The expected work period for each employee will be expressed as hours per control area, e.g., four hours in Module 2/3, 0.9 hours in lunch room, etc. f Monitoring equipment will be the two Bendix units currently in stalled. Air sample intake will be taken by two to six individual tubes (spider) from different points in the control area, joined together to give one gas sample for analysis. Control areas off ^ large space, e.g., new Polyco, or nil VCM sources, e.g., PVC Office, will be measured by periodic air samples. 4. A periodic check (at least monthly) of personnel exposure will be made to check personnel analysis versus readings given by the monitor to insure system validity. 5. We currently can measure eighteen inputs in the PVC plant and six in Polyco. We can add new hardware to measure more inputs if we have more control areas. B. Mask Control Starting January 1975, personnel will^sign for - 1. Equipment receipt. : 2. Acknowledgement of conditions for use. 3. Acknowledgement of cause for dismissal if they do not follow 1 and/or No. 2. C. Operating Control The operating group is being expanded to monitor and reduce VCM random sources and enforce operating procedures and respiratory protection.. The elements of this expansion are; BOR 012729 fefMPLlAMCE WITH OSHA ' VCM STANDARD Page 2 " 1. One monitor per shift with two year technical degree or ^equivalent, -s 2. Monitor reports to Plant Manager or special representative, which will not be production superintendent or foreman. 3. Monitor can take action independent of shift foreman concerning leak monitoring, reduction, mask wearing, etc. He will keep shift foreman informed. The shift foreman will have final judg ment in case of any disputes, which will be reviewed on the following regular work day by the Plant Manager. 4. Additional check monitoring, simulated OSHA inspections, person nel monitoring, etc., will be done by Work Practices group. 5. Monitor will cover whole plant, including PVC latex, but with little emphasis on non-VCM source areas such as new Polyco. J, R. Degenfelder V \ BOR 012729A MANNING FOR OSHA COMPLIANCE " a---- November 26, 1974 Implementation of procedures to minimize worker exposure to vinyl chloride vapors (VCM) will require additional personnel in the operating organiza tion. Procedures and equipment added to meet the temporary VCM standard of April, 1974, added additional workload to the PVC shift foremen. The additional workload all ready undertaken and/or planned for implementa tion by 1/1/75 includes: A. Control Procedures 1. Monitoring and control of operating personnel within preset control areas. 2. Enforcement of use of respiratory equipment when required. 3. Closer supervision of operations defined as "hazardous" under the OSHA standard. B. Analytical Procedures * 1. Investigation of high VCM concentrations monitored by the Bendix units. 2. Prechecking of VCM content for hazardous operations such as filter changes, RVCM venting, monomer unloading, etc. 3. Pinpoint specific random VCM leaks for correction and feedback for engineering improvements. C. New Process Operations 1. Full stripping of specialty resins. 2. Bin purging with hot air. 3. Copolymer recovery system. 4. New approaches as they develop, y _ i New personnel are being hired for the position of OSHA Compliance Controller. 1. The OSHA Compliance Controller reports to a supervisor separate from the regular operating organization, and in turn to the plant manager. (Until mid-1975, there would tend to be more direct control by the plant manager.) 2. OSHA Compliance Controller, after graduating from training status, will have the authority of the shift foremen in matters pertaining to VCM exposure control. ! r \ BOR 012730 \ Atf-'' ^^ MANNING FOR OSHA CCMPLIAN< -I-. -tilrA. id* 3. In case of conflict between the Polyco or PVC shift foremen and the OSHA Compliance Controller, the shift foremen will have override authority. 4. Conflicts arising in #3 above will be analyzed and resolved each weekday by the plant manager or by telephone contact in emergency situations. J. Degenfelder f 1 "V/ , BOR 012731 \ -.-T4' Project 1 - Installation of Bendix Total Hydrocarbon Analyzer and Recording System with Multipoint Sampling of Regulated Areas - for Main Plant % This project was completed in summer 1974, and provides the major system for area monitoring and- plant surveillance. The selection of the THA equipment was predicated on the fact that at the time this was the best selection within the instrument options available, and provided reliable monitoring within the temporary 50 ppm standard. As the various work practice and other engineering programs have brought th^^_^ workplace contamination levels down to within the range of the j^Frrrli&eWt l"' standard, the need for a specific VCM instrument becomes more justifiable. By the same token, the instrument technology for specific VCM monitoring is still in a rapidly changing mode. At some future date, when instrument technology change has somewhat s.tabiy.zed^and the workplace air quality closely approaches that of the pS^&Wenfe srfcntiaVt?`, a commitment to the VCM specific instrumentation will be made. Project 2 - purchase of Century OVA Portable System and Bendix Flasher Units for Personnel Monitoring Purchase and phase-in of this instrumentation was completed summer and fall 1974, and provides for portable monitoring to extend surveillance capa bility to remote areas, and personnel monitoring for direct measurement of personnel exposure in the regulated areas. Project 3 - Installation of Base-Line VCM Specific Analyzer and Recording System for Laboratory Area This project underway (December 1974) will provide area monitoring of the PVC Laboratory Building. It is the first VCM specific analyzer brought into the division and will serve as a piloting model for the future VCM specific instrumentation needs of the main operating plant. _ 1 .< " \ ^. \\ 1 * v- ** BOR 012732 ,\ LEOMINSTER SITE AIR SUPPLY & VENTILATION PROGRAM Project 4 - Installation of Air Supply Fans to Building #8 Warehouse This project was completed summer 1974, to reduce contamination level in this building by air sweeping out stagnant pockets of VCM diffusing from bagged resin storage. Project 5 - Installation of Ventilation to Building #4 A Warehouse This project is underway (December 1974) to accomplish a reduced contamination level in this building- by air sweeping out stagnant pockets of VCM diffusing from bagged resin storage. Project 6 - Installation of Additional Spot Exhauster Stations in Poly merization Building - PVC Plant This project was completed sunnier 1974, and provided for increased spot ventilation control points in the Polymerization Building to assist in fume control from leakage situations or from open kettle operations. Project 7 - Installation of Supplementary Ventilation to polymerization Building - PVC Plant This project currently underway (December, 1974) will provide supple mentary ventilation air (heated in wintertime) from a remote location, to improve air quality in the polymerization Building through increased air changes with a "cleaner" air source. Project 8 - Installation of Remote Fresh Air Intakes for H & V Units at Polymerization Building - Polyco PVC Latex Plant This project currently underway (December, 1974) will provide "cleaner" supply air to the Polymerization Building, thereby promoting an improved workplace air quality.. Pro ject 9 - Installation of Latex Storage^ Tank Ventilation at Polyco PVC Latex Plant This project currently underway (Decem&er, 1974) will provide a process exhaust' to outside for these indoor tanks, and will thereby contribute to an improved workplace air quality. Project 10- Installation of Respirable Air Supply Header System at PVC Plant with Dedicated Non-Lube Compressor This project was completed summer 1974, and provides breathable air for respirator equipment at various plug-in stations in the main plant area. BOR 012733 ; \ j. * RETfiTATTONS/ISOLATIONS PROGRAM , i, Project 11 - Relocation and Enlargement of In-plant Lunch Room, Locker Room and Canteen Facilities to North Side of plant Area This project was completed fall 1974, and provides a modern employee facility at a remote plant location properly situated and ventilated so as to be incompliance with permanent standard air quality.^ ,,-------- project 12 - Isolation of Recovery Systems by Partitioning Off Area from Polymerization Section This project completed in fall 1974^{provided of a separate ventilation zone for the recovery systems at negative pressure with respect to the polymerization Section, so that recovery system leakage problems would not contaminate the Polymerization Area. Project 13 - Isolation of Main In-Plant Personnel Walkway (from Locker Room to Plant Area) from Building #8 Warehouse This project completed in fall 1974, provided a personnel tunnel between locker-lunch facility and plant area,with controlled ventilation to furnish uncontarainated air to this walkway. Project 14 - Relocation of Wall Exhausters in Polymerization Building for Improved Spot Control This project completed summer 1974, relocated several wall exhausters to more optimum locations to provide concentrated exhaust capacity at several pieces of offending fixed equipment, thereby reducing the effect of these local emissions on the workplace air quality. Project 15 - Modifications to Recovery Systems to Provide for Local RVCM Storage and Recycle Rather Than Remote Storage and Recycle This project completed fall 1974, reduced the contamination problem associated with extensive recovery system cleanouts due to fouling problems by providing for minimum piping runs and Storage volume of RVCM prior to reuse V <e . BOR 012734 J..v, m" ^ < *; LEOMINSTER SITE .--, PROTOTYPE PROCESS IMPROVEMENT PROGRAM \' ' Project 16 - Installation of Prototype Stripping Module for Suspension Resins The installation phase of this prototype project was completed fall 1974. Piloting work is underway to determine process parameters for im proved recovery and stripping of resins. A successful consummation of this prototype project could pave the way to process revisions which can effect better workplace air quality by reducing the level of process emissions to the general plant area. Project 17 - Installation of prototype Copolymer Recovery System for Suspension Resins This installation is underway. When completed it will be piloted to determine process parameters for recovery of VCM from copolymer resins Successful consummation of this prototype project could also pave the way to process revisions leading to bettfer workplace air quality by reducing process emissions to the general plant area. ' `;-V ; !" i r\ \t. : " \ .'*** BOR 012735 V RESPIRATORY EQUIPMENT O' 1. Up Co 25 ppm measured over a 15 minute period,|respirators ape optional! for 1/75 to 1/1/76. \&L * ^ ;<*- 'TKa. >\?u^afc. ^ i> 2. Up to 25 ppm, carbon cannister (Scott 084-0VL). will be available for use. These arc acceptable for^oThours at 25 ppm. Regardless of the minimum time used on a cannister, if the cannister has been used at all, it will be discarded at the end of each shift. 3. For use up to 1000 ppm, continuous flow, Type C, full or half mask respirators are available. 4. For above 1000 ppm, self-contained breathing apparatus in the demand mode (Scott Air Pak II) are available for use. *" ^ V* . BOR 012736 &SPIRATOKf PROTECTION PROGRAM V ( "TC ^ While effective engineering methods are being developed to eetrtrol VC/^jS. ^, 'S'v? >, y-Lo^Lf e*pes^$ -rt -ru, rtJj-tii'.ri* I,-,- * respirators will be used to prevent those-alleged occupational diseases \ caused hy air qontamitiaieJ by~VC. ***0 '04 1 Employees shall not be assigned work involving the use of respirators until it has been medically determined that they are physically able to perform work while using respiratory equipment. The medical status of personnel using respirators will be checked on an annual basis. W>, Of' } 1. Respirators will be supplied by the Safety Department when/such equipment is necessary, to protect the,health ai the employee. f 2. Respirators were selected based on availability and suitability for the intended purposes. * 3. A Control and Maintenance Program for respirators will be the responsibility of the Safety Department. 4. An initial training course in the use of respiratory equipment shall be the responsibility of the Safety Department. Thereafter Operations will instruct their personnel on a quarterly basis. 5. Employees shall take care not to damage any respiratory equipment assigned to them. ; 6. Employees shall report any malfunctions of the assigned respiratory equipment immediately to their foreman who will In turn notify the Safety Department Technician. VviTVi jo BOR 012737 *  *v., - 2 - Q TRAINING AND EDUCATION o" rf--- Initial training of all supervisors and employees, in the use of respiratory- equipment, shall be the responsibility of the Safety Department, as well as the Initial training of all new employees. Any employees changing job classifications to one which requires use of respiratory equipment will also undergo an initial training by the Safety Department. A strictly enforced requirement will be a "refresher course" given by Operations on a quarterly basis, in the|use^and care of respira* L- >rwruiij, tory equipment pertinent to the employees specific job. The Safety Department will provide any assistance required in assuring effec tive training. L|^\_ z^y^t* i^v^ty-l "d C "-O' Th^vOiTH lAiu^V- *S "Tt , w-\ eniiTt^'*'^, ML ^tt-~* Kt-'( '-^.V n*`MJ^1 TOvi Training shall include: Proper fitting and integrity check Proper use and limitations Inspection for defects I 'V;&. - >* fjrrwcot ^ IfCiSEJ>W*>' ($r i./.JfeM-' "> 1 ^60^5 0* 'X * f\jU Respiratory equipment shall be acquired from the Safety Equipment Control Centers. Individuals will enter their signature on the log provided when drawing respiratory equipment. When the equip ment is returned, the Safety,Technician will so designate by entering his signature on the log and making note of the condition of the Tf' v returned equipment. The Safety Technician shall be responsible for the washing, disin fection and bagging of returned equipmedt before reissuance. No equipment shall be reissued or accepted for.use unless this procedure is followed. 'i X' ' BOB 012738 rh >'j*vv. <* sr... : - v ^ The Safety Technician ehall inapect each piece of returned equip ment for defects or damage. Defective or damaged equipment shall under no circumstances be issued, but shall either be repaired inmediately or removed from service. t I \ BOR 012739 SUBJKCTi INTER-COMPANY AND OFFICE CORRESPONDENC-E George Revis - 111! polls J. R. Degenfelder FaoMi 4 R. L. Mercier Located ati Leominster, Mass. Protective Garments . DATIi December 10, 1974 I Brtnth j\ OCl+MiiW^S7 Two types of protective garments are required to meet the new Federal Standard. Type I - Cotton Coveralls Usage - Wherever an employee will be exposed to fresh, wet PVC containing residual VCM. Examples - Reactor cleaning, removing wet cake from centrifuges or driers. Type II - Impervious f Usage - Wherever an employee maybe exposed to liquid vinyl chloride. Examples - Opening VCM lines, VCM pumps, etc, where liquid may remain. Protective garments shall be provided clean and dry for each use. The Work Practices Group will provide the protective garments for Leominster. George, you must provide your own Type 1 for llliopolis. The Type XI garments are currently on hand for both sites. The safety man assigned to the mask program will be responsible for Issuing, control and cleaning of protective garments. RLM:mdm cc: H. R. Jepeen, Jr* R. Landon - llliopolis J. Lee H. A. Peed v NXOSH Compliance File ,11'. * * & . % ,* V.-WK-> * 3 jr ,*;** .< : R. L. Mercier BOR 012740  T^ * Ivp1 / ---"*---- jr/f \ fWCj-1 M-jffe' TO" &t\PM^r -t-Ai ,{> & a,.*# l'b'^*tMyuu4+t ii>> V-*H 10, December 20, 1974 ip - MteAvJ*- fcJUXq&A & viP^i' dJujWT', EMERGENCY PLAN - PVC DEPARTMENT , #>efinitlon: An emergency la defineda3\ the existence of a concentration of 3600 ppm vinyl chloride in air resulting from an uncontrolled source^ w<i\ sc ft- iy-^-kr--~~p*L (Jl-L ^veu>i- Eg ,c\ftA iXr 4 Equipment: -re 9t E/-^*^ ^ -^***:v vE~ Lf^r c+uniJ? H tVc -kwvM- <* : "^-rf - / a * , Cct-* T. *< tff pvr. i^oc in *-% r> < ,V~ 1' " V - -1. * r" The only^respiratory equipment approved for use in dealing with an emergency is the Scott Air Pak. These units are located as follows: 1 - MCC No. 3A emergency center 2 - Shift foreman's office 1 - ModuleNo. 4 1 - Module No. 7 1 - Module No. 1panelboard -------- Alert: The alert will be sounded by dialing 9-9-9 on the Page-Call system. This alarm will ; sound for over two minutes and can be heard anywhere in the department. The senior j PVC Lab Technician will inform the Production Superintendent (D. L. Young) and the \ Plant Manager (J.` R. Degenfelder) and then evacuate. 1 * < Evacuation: f ] All personnel except the shutdown personnel will evacuate to the PVC parking area. Th j will not leave this area for any reason except as authorized by the shift foreman or OSHA controller. Shutdown Personnel: Shutdown personnel who are required to stay in the operating area, using the Scott Air Pak are: Shift Foreman Lead Operator VCM source control OSHA Controller Personnel accountability Dryer Operators 2 Reactor Operators Equipment Shutdown Personnel Accountability: The OSHA controller will ensure that all people other than shutdown personnel evacuatt A check against the sign-in roster will be made. On the weekday shift, the OSHA controller will report back to the Shift Foreman to offer assistance. Shutdown: V For the first 15 minute's, the 3 operators will monitor only the reactors and dryers. After 15 minutes, any charges under 5 hours runtime will be stopped with AMS accordii to standard procedures. The feed will be shut off all three dryers. Further directii will be by the shift foreman. All Clear: The VCM concentration will be checked in each control area before sounding the all-cl This is the same signal as the fire alarm all-clear (4-4-4); f Si^i. - WO -yvf>.UL Ijtrttiie 0 -f \\ 1 \ J. R. Degenfelder ;v.; * . V HiGT w . ' ftfL Q' ~t" 4 - / ,A p5^Mye>H. fl> O&PMJ*. 1W 'TX)\lf* JWl "'ArU**l-> ZlrLmt4\'VZ T2An^*^ ^ kO>*v-U^ AJP6^pi-*^C twrQ^r a- St*jUS *T TRAINING PROGRAM FOR VCM COMPLIANCE '1 L , . U*^C * >*** |i*i>^> ^_ ,, . * *;fl'^r''"> TH*r- olt, Itrylr *- t^ps^ . UpT-A-1 P5 fcZtr --flj+\c-* 7^ :M4 1. OSHA controllers will ,be assigned on a ssi hift basis by the end of January, 1975. - 2. Daily rosters to be maintained. a. All personnel to sign the log at the safety technician station. b. Time spent in specific areas to be logged by the controller and verified at end of shift. 3. Hazards and toxicity of VCM classes to be held on a scheduled basis. a. January b. May c. September d. December 4. Classes on reduction of VCM excursion based on operating conditions were held as follows: Operation of recovery systems - 11/14/74 Operation of recovery systems - 11/19/74 and 11/25/74 Operation of recovery systems - 12/2/74 Kettle Operator Training Kettle Operator Training - 12/2/74 - 12/6/74 5. Initial VCM compliance classes have been held as follows: A Shift - 12/19/74 B Shift - 12/20/74 D Shift - 12/20/74 C Shift - 12/23/74 Supervisory and Maintenance Personnel - 12/24/7. Professional and Technical Personnel - 12/24/74 6. Furtter improvements in procedures for reactors and recovery equipment are in process with emphasis on emission control and reducing the personnel exposure factor. 7. Classes are to be held following the procedural changes and twice annually thereafter. 8. Procedures to be written for reduction of residual VCM in the slurry state utilizing D4O6 will be complete 1/15/75. 9. Training on the use of air masks same schedule as item 2. 10. Care of air masks. 11. Training of shift supervision to upgrade overall safety levels and reduce VCM emissions. BOR 012742 \ a *> -* $ ' - Mr PROCEDURES FOR VCM EMISSION CONTROL Cleaning.of reactors. a. Blanking. b. Use of reactor alarm cart. c. Use of air masks.* d. Safety entry check off list. Equipment pre-checks prior to charging. Pressure tests prior to charging water, VCM or Vac. Dogging of reactor manholes for effective sealing. 5. Recovery procedures for emission control. .6 Basics of instrument control and detection of malfunctions. 7. Reactor transfers. .8 Monitoring of vessel pressures during charging and heat up phase. $***<> ^ ChLL hMuL cosuL) ,n V k s** .Jl, " . V.'" bob 012743 , PROGRAM OF MEDICAL SURVEILLANCE ' (1) At the time of initial assignment, or upon institution of medical surveillance; (1) A general physical examination shall be performed, with specific attention to detecting enlargement of liver, spleen or kidneys, or dysfunction in these organs, and for abnormalites in skin, connective tissues and the pulmonary system CSefi Appendix A). (ii) A medical history shall be taken, including the following topics: (A) Alcohol intake; (B) Past history of hepatitis; (C) Work history and past exposure to potential hepatotoxic agents, in cluding drugs and chemicals; (D) Past history of blood transfusions; and (E) Past history of hospitalizations. (iii) A serum specimen shall be obtained and determinations made of: (A) Total bilirubin; (B) Alkaline phosphatase; (C) Serum glutamic oxalacetic transaminase (SGOT); (D) Serum glutamic pyruvic transaminase (SGPT): and (E) Gamma glustamyl transpeptidase. (2) Examinations provided lu gguunlauue wlfh'TTiia' pAlHgiaph shall be per formed at least: ' (i) Every 6 months for each employee who has been employed in vinyl chloride or polyvinyl chloride manufacturing for 10 years or longer; and (li) Annually for all other employees. (3) Each employee exposed to an emergency shall be afforded appropriate medical surveillance. S # \ BOR 012744 V PROGRAM Ur MnuiUrn. . -f - - W (4) A statement of each employee-s suitability for continued exposure to vinyl chloride including use of protective equipment and respira tors, shall be obtained from the examining physician promptly after any examination. A, copy of the physician's statement shall be pro vided each employee. (5) If any employee's health would be materially impaired by continued exposure, such employee shall be withdrawn from possible contact with vinyl chloride. (6) Laboratory analyses for all biological specimens included in medical examinations shall be performed in laboratories licensed under 42 CFR Part 74. f (7) If the examining physician determines that alternative medical exam inations to those required by paragraph (k) (1) of oJe^kon will provide at least equal.assurance of detecting medical conditions pertinent to the exposure to vinyl chloride, the employer may accept "\Vr such alternative examinations as meeting the requirements of)paragraph Pr}- (1) nf ^ nnnun) if the employer obtains a statement from the examining physician setting forth the alternative examinations and the rationale for substitution. This statement shall be available upon request for examination and copying to authorized representatives of the Assistant Secretary and the Director.' (8) Persons will not be assigned to tasks requiring use of respirators un less it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance annually). When required teats show abnormalities, the tests will be repeated as BOR 012745 pgrr.KAM OF MEDICAL-SURVEILLANCE ^ W ^ practicable, preferably within 3 to 4 weeks. If tests remain abnormal, consideration will be given to withdrawal of the employee from contact with vinyl chloride, while a more comprehensive examination is made. f v i *4 BOR 012746 (Name of Employee) - in accordance with Occupational Safety and Health Administration regulation s^CFR ft. Part 1910.93q Cfc'W) (4r)-Ck) and American National Standard Z88.2-1969 , Practices for Respiratory Protection, paragraph 3.7 and with knowledge of his duties, I find (him/her) (qualified/unqualified) to uoa rasplm-Mgry proteegive--equipment in the performance of (his/her) vork^ Tvt nit (P A complete examination form for this person is on file in my office at Address: Doctor: Employee; V _ BOR 012747 LOGRAM POR OS HA COMPLIANCE T.AHELIHG OF SHIPMENTS I, Drv bulk rail cars and liquid tank cars. (a). Stencil - one inch letters, black on white. ' POLYVINYL CHLORIDE CONTAINS VINYL CHLORIDE VINYL CHLORIDE IS A CANCER SUSPECT AGENT (b). Stencil to be on each side of rail car. (c). Dry bulk to be at the center of the car, one third of the way up from the bottom. (d). Liquid tank cars to be 1/2 way between the ladder and the end of the car, one third of the way up from the bottom. II. Box Cars. ( (a). All car doors to be sealed with car seal. (b). Seal to have tag affixed. POLYVINYL CHLORIDE CONTAINS VINYL CHLORIDE VINYL CHLORIDE IS A CANCER SUSPECT AGENT III. Dry Bulk Trucks and Liquid Tank Trucks. (a). Common carrier and liquid tank trucks. Two hatches and the unloading line will be sealed with car seals. These will have tags affixed to them with the same legend as in Item 2. (b). Borden Dry Bulk Stencil with 1/2 inch letters, black on white with the same prescribed legend. Stencil to be on the rear of the truck just over the unloading line. IV. Van Trucks. (a). All full truck shipments will have the doors sealed with a car seal. The seal will have' a tag affixed with the same prescribed legend. (b). All less than full truck shipments will have no further marking other than the marking on the individual containers (bags, drums or boxes). Partial pallets will be wrapped and strapped. The wrapping will'have the proper stencilling applied. BOR 012748 PROGRAM FOR OSTIA COMPLIANCE LABELING OF SHIPMENTS V, Bag Marking. (a). New Bags All new bags purchased after the standard becomes effective will be printed with the proper legend on the top end of the bag in 1/4 inch printing, blue on natural kraft. (b). Packaged Resin All resin which is packaged and in inventory at the time ^the new standard takes effect will be stamped with the proper legend prior to shipment. (c). Old Bags All old bags, unfilled at the time the new standard takes effect, will be stamped with the proper legend. VI. Drums. i All drums will have a label affixed to them with the proper legend. f \ BOR 012749 SYSTEM TOR REPORTING EMERGENCIES All emergencies must be reported to the OSHA Area Director within 24 hours. In Leominster, R. Mercier has responsibility. For Illiopolis G. Bevis has the responsibility. The report will be sent by registered mail, return receipt requested, and include the following information: 1. Date of the Emergency 2. Approximate Time 3. Duration 4. Cause 5. Number of Employees Exposed i Upon request of the OSHA Area Director, further information will be made available. i * .< . :} " .'c . t l - M-rve^r r - a . iC^> *' v. -r v.> *-L*) Cz.} p: ,* .,*S" :l7-` i^,1 .. ' v_t\, -. ;r, - -/f `i " \ Wit*.'-t - ;y - .--^g % . * . BOR 012751 NOTIFICATION OF EMPLOYEES EXPOSURE /Employee^ whose exposure, as measured by the Personnel Monitoring System, is in excess of the permissible exposure limit, shall be /D ^**4 C notified/within 10 working days of their exposure level. This notification will be in writing according to the attached form. There is a provision on the form requiring the employee's signature f to insure that each employee has been properly notified of the inci dent. Programs to reduce the exposures' will be posted and periodically updated. ^This will/inform the employees of the steps being taken to reduce the exposures below the permissible exposure llmit.^ , "ft 2 * t-. *! y'A'yv '> - . . r \ -irv"t-1 ' i- ?'*- , J, ^ ,U - . J / . f*m 7- ;k:; r *. ' *<r v wr - t- yit ' 1 -/Jr., . r*V- Wf*b` tf S , ir r . T - 'V 'jM, ' , i&V: - . ji.y 4.^j?; '-M&*i*,-fJ'*< - .j` ' -7% "f Jr* . ^ 'f i/'* > . - * ,'t- >; ^7r; . / 't / BOR 012752 \ 4. ICATTCR in racEf''"^ 07 THE PERMISSIBLE LIMITS NAME: DATE: IlV, 'SkffyUjbSr1" level or expooute: METHOD OF MONITORING: Personnel Monitoring System using Bendix PMCC Tubes, ~ Sipin Pumps, Bendix Flasher unit and Gas Chromatograph. TYPE OF RESPIRATORY EQUIPMENT WORN: SPECIAL COMMENTS: Note - The copy In tha employee Persomel File must be signed by the employee indicating that he received a copy. Copies: 1. En^ioyee - , -'v* ; .Vj5' . * . , **A> * > . t/%.% r . ' , r>` * / <r.; . 5: 4j, * 2. Employee Personnel Pile ~ -.* 3, Plant Manager . 30 1 "IXcj * 4. Production 8upearin$epdent <~ej 5. Designated Union Official . ;K . 'V . ' t-- o' n'-; ^ -ji. BOR 012753 .4