Document X4e34NJ5Z5JZJVdL6736pM1d

ia2#is- Revised Methods of Compliance to the Permissible Exposure Limits OSHA Regulation 1910.93 q - Standard for Exposure to VC1 BFG Technical Center OSHA regulation 1910.93q requires that employee exposures to vinyl chloride shall be controlled to l ppm or less of VC1 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 are attached and will be furnished upon request for examination and copying to authorized representatives of the assistant Secretary of tabor 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 22817 SPECIAL OBJECTIVE A. Enclneerino Projects Divert VCH vapors now vented to room PROJECT Spot Ventilation AVON l. E TECHNICAL CENTER VCM EMISS-IONS CONTROL REPORT STATU? REPORT COMP. DATE PERSONNEL ASSIGNED COST ENG TOTAL Complete Gary Wilson Jim Ego $50,000 $150,000 Disperse exhausted vapors hiaher in atmosDhere Insure adequate bldg. venti1 ation Reduce or eliminate environmental emissions Same as above Reduce or eliminate environmental emissions Replace high emission source pilot plant equipment. Bldg. 414 exhuast stack Building ventilation a) B/414 E Emergency & Normal b) B/414 W " c) B/414 S " d) B/417 RD & RV discharge control a) small polys Design & Construct a VCM recovery system for West process. Design & construct a VCM monomer disposal system Replace present lb gal. polys with 55 6 HQ liter polys. Hold 12/75 Gary Wi1 son Jim Eao Gary Wi1 son Jim Ego $33,000 $75.000 1976 Gary WiIson $50,000 197f> Clock Konya $40,000 r7S Clock $30,000 Hubbard ________ __ _________ ______ __ __________ 1977 Gary WiIson 5150,000 Jim Ego $120,000 $600,000 $200,000 $160,000 $130,000 ____ $fe00,60O Remove VC1 from 15 gal. poly charges prior to filtering or drumminc. Remove VC1 from 30 gal. poly charges prior to filterino or drumminc. Eliminate employee exposure Eliminate use of buckets of solvents for poly cleaning. Reduce VCI In air Design & install a 15 gal, slurry steam stripper. Design & instal1 a 30 gal, slurry steam stripper. Install a safe sample anal station in B/414 Design & install a safe solvent cleaning system in B/414 Leak control is a. Instal1 a Bendix GC monitoring system in B/414 for VCI & ECH. b. Install a Bendix total hydrocarbon monitoring system in B/413 for PVC laboratories. Monitoring System 7/76 G. Wi) son 5/76 G. Wi1 son 1/76 A. Siverling $ 2,000 F777--------- Sml th "5 Cont. 12/1/75 Process & Mainf. Forsythe $ 6,400 $ 16,000 $ 12,000 $ 24,000 $ 44,270 October 24, /V7S" REHARKS Extended local exhuast 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 complete. Not needed unless EPA standard dictates. Design is on HOLD. Working on improving performance of existing heating system at a cost of $23,000. No action. Design started. No action. Installation of two new 55 1iter polys with blow down tanks and stripping and drying system. 10% complete. Reactors on order. Process engineers are seeking a better definition of the process.________________ Will issue EA as soon as possible. EA approved. Work will start November 1. Fume hood installed. Flush bottom valves to be installed 12/75. zOX COR?fete. Contiruing Installing remaining lights $ Korns by 12/75. System working wel1. Monitoring air Intake in B/417 and plant instrument air. It NGC 22818 cc: R.M. Kreager, D.J. BarnickI, F, Zfebe P. DeChant, J.'Alten, G. Wilson, F. Krause, C. Orben, V* Carson, D. Popovich, N. Wearsch, L. Bennatt NOC 22819 * AVON L .E TECHNICAL CENTER V MISSIONS CONTROL REPORT STATUS RfcrORT SPECIAL OBJECTIVE 3 Process Proiects.. Eliminate VCM exposure while samp ling a reactor & subsequent weighing of sample. PROJECT 1. Take sample in closed containers. 2. Wear respirators 4 rubber gloves. 3. Weigh sample in well COMP. DATE Cont. PERSONNEL ASSIGNED F. 21eber COST ENG. TOTAL 0 Eliminate VCM exposure while transferring a charge from poly to wash tank. 1. New stainless steel line with sweeping bends have been installed to elim inate plugs & leaks. 2. If line plugs, will use impervious suits, air masks, rubber gloves & rubber footwear while Done Cont. F. 2ieber P. Zieber 0 0 Eliminate VCM exposure while removing manhead from reactor. After blowing down charge, boil out reactor with watei and use a suction hose at 6/75 manhead while loosening bol s. In addition, atmosphere ne; manheed will be tested witi an OVA meter while loosenii bolts. If test shows VCM oresent. boll out reactor ; aln. Eliminate VCM exposure while centrifuging and Properly strip charge in wash tank to eliminate 1/76 traying resin from wash residual VCM tank. Eliminate VCM exposure while cleaning reactors. 1. Before entering a poly take OVA readings of tht interior. If above 25 pi 10/1/75 boil out again. 2. When entering a poly, w< r an impervious suit and . r tine mask, head covers, ubber aloves & rubber footwea Prepare SOP's for PVC processes in B/414 1/76 F. Zieber F. Zieber F. Zieber F. Zieber 0 0 D 0 REMARKS REMARKS No longer a problem. New hood for running T . S. wor ks very we 11 . Procedure working fine. Have also installed a larger valve under 3000 gal. wash tank. This eliminated a lot of the plugging. Procedure working fine. A new system does an excellent job of removing residual VC1. It consists of evacuating the polymerizer with steam on the Jacket. An SOP has been written. We have not been centrifuging. No problem since using new method of boiling out reactor. Doing personnel monitoring while operator is in poly to establish effectiveness of procedure. A number have been written and are ready for annroval. V V' SPECIAL OBJECTIVE A. Enainear 1 no Proiects Divert VCM vapors now vented to room Disperse exhausted vapors higher in atmosphere Insure adequate bldg, ventilation Replace high emission source pi lot plant equipment. Minimize regulated areas. Reduce or eliminate environmental emissions Same as above PROJECT Spot Ventilation Bldg. 414 exhaust stack AVON LAKE TECHNICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT COMP. DATE PERSONNEL ASSIGNED COST ENG TOTAL 3-1-76 Gary WJ1 son Jim Ego $50,000 $150,000 Hold Gary Wilson Jim Ego $33,000 $120,000 Building ventilatioi a) 6/414 E Emergency Normal b) 6/414 W c) B/414 S ' d) B/417 " > 7 12-75 12-75 ? Gary WiIson Jim Ego $75,000 $600,000 Replace present 15 < polys with 55 ft 110 1iter polys. 1977 Consolidate VCM usln laboratories a) construct analytl addition to 6/423 b) Move 3.1 11 ter po to B/414 cl Move eeneral lab RD ft RV discharge co a) small polys bl larae oolvs Design ft construct s recovery system for orocess. HOLD 1 lab ' lab > B/414 jrol 1976 Efl T575 St Gary Wilson Jim Ego R. Cahill E. Webber G. WIIson Smith 'G'loclc Hubbard $150,000 $50,000 $35,000 $50,000 $40,500 $b00,000 $500,000 $115,000 $200,000 i 160,000 REMARKS Integral part of general building vent ft exhaust stack. Estimate covers design ft installation of spot ventilation hoods ft droos. comoleted. A general exhaust systam Is being designed. We plan to pipe fresh air to point of need and exhaust air from point of contamination. We may or may not use a large stack. May use several smaller ones. Replace present heating-ventilation equip ment with new heaters ft emergency exhauster. Use spot ventilation where practical. 1imlnate windows ft repair all major air leaks In building. Emphasize good air distribution. Temporary is completed. Permanent Is started. Detail estimate almost complete. Hope to submit EA in July. 1975. Installation of two new 55 liter polys with blow down tanks and stripping and drying system. 10% complete. Reactors on order. Process engineers are seeking a batter definition of the orocess. a) Detailed design put on hold by top management. b) Detailed design put on hold by top management. c) Hold. Thus far this area does not requ1 re regu1 ating. No action. No action. NGC 22820 NGC 22821 SPFCIAt OBJECTIVE Reduce or eliminate environmental emissions Same as above Eliminate employee exposure AV LAKE TECHNICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT PROJECT Design & construct a VCM monomer disposal system Spot ventilation exhaust Install a safe sample analysis station in B/414 COMP. OATE 1973 -------- T57E-- I o-l -75 PERSONNEL ASSIGNED Clock Hubbard W1 Ison Eao Smith COST ENG $30,000 TOTAL $130,000 $25,000 $100,000 $ 2,000 $ 12,000 Eliminate use of buckets of solvents for poly clean!no. Reduce VC1 In air a. Install a Bend lx GC monitoring system in B/414 for VC1 ECH. b. Install a Bend lx total hydrocarbon monitoring system in B/413 for PVC laboratories Space for analytical groups B. Process Projects Eliminate VCM exposure whi le santpl i ng a reactor subsequent weighing of sample. Design Install a sa solvent cleaning syst% In B/414 Leak control Monitoring System 12-75 Sml th Cont. Process Maint. r-i-75~~ Forsythe Coordinate B/412 West lab modifications 1976 R. Cahill E. Webber 1. Take saople in clo< containers 2. Wear respirators rubber gloves. 34 Weight sample In we ventilated hood i l ContIn. F. Zteber $ 2,400 $ 24,000 $fc,400 $44,270 $9,800 $98,241 0 REMARKS No act Ion. Small Improvements belIng made. Awaiting flush bottom vslves for 15 30 gal. reactors. Will need ventl1 at Ion for fuse hood installed on 3rd floor west side. Need EA or GPO to cover labor costs. 20X complete. 20J complete. Continuing a. Installed operating. Will not measure ECH. Personnel monitoring has shown level of ECH Is very low. Three horns lights arc missing. Computer program Is operational. b. Installed and operating. Computer program warning system are also ooerationai. Complete Procedure is working satisfactorily. NGC 22822 AVO, LAKE TECHNICAL CENTER VCM EMISSIONS CONTROL REPORT STATUS REPORT COMP. PERSONNEL SPECIAL OBJECTIVE Eliminate VCH exposure PROJECT 1) New stainless steel DATE Done ASSIGNED P. Zieber while transferring a lines with sweeping charge from poly to bends have been wash tank. installed to ellmin ate plubs & leaks. II 2) If line plugs, will Contln. F. Zieber use Impervious suit air masks, rubber gloves & rubber foo Eliminate VCM exposure wear while unpluggl. 1 ine. Strip charge in wash t k small F. Zieber while transferring resin from to eliminate residual Polymer]zers wash tank to filter box and transfer of wet cake to VCM 9-1-75 containers. Prepare SOP's for PVC processes in B/414 9-1-75 Eliminate VCM exposure After blowing down cha e, b//b F. Zieber h, zieber while removing manhead boil out reactor with ter from reactor. and use a suction hose t manhead while loosenIn bolts. In addition, at >s- phere near manhead wl1 be tested with an OVA met while loosening bolts, f test shows VCH present boll out reactor aasIn. Eliminate VCM exposure Properly strip charge . 6/1/75 F. Zieber while centrifuging and wash tank to eliminate traylng resin from wash tank. residual VCM Eliminate VCM exposure 1. Before entering a p y, 4/1/75 F. Zieber while cleaning reactors. take OVA readings o the interior, if above . ppm, boll out again. 2. When entering a pol wear an impervious .it and air 1ine mask, ad covers, rubber glov , * rubber footwear. COST ENG TOTAL 0 0 ----------------------o---------------------------- 0 0 REMARKS Procedure working fine. Procedure working fine. Must design fr install stripping unit. Also trying to correct with procedures. Som progress made. A number have been written and are ready for approval, Reactors are being completely rilled with water and boiled out. Working very wet 1, We have not been centrifuging. if we get any "OVA" reading above the background, we boil out again. Protective clothing is being worn.