Document XOBVRxzQ5xm3dqqBxyB891M74
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January 8, 1991
Mr. Stephen B. Kemp Industrial Hygiene Manager Corporate Medical Occidental Chemical Corporation Occidental Chemical Center 360 Rainbow Boulevard South Box 728 Niagara Falls, NY 14302
Dear Steve:
We are pleased to submit the attached draft report of the employee exposure monitoring and area noise measurements , li; accomplished at the Pasadena, Texas, PVC Resins and Compounds Plant during the week of December 10, 1990. We trust that this monitoring effort meets the OSHA requirements to award this plant the STAR Status under the OSHA VPP. Please review the report at your earliest convenience and provide your comments to me. We will integrate your comments and remove the "Draft" header for submission to OSHA through you.
If you have any questions or comments, please do not ` ' 1 1'' hesitate to call me at 1-800-283-7727 (ext 6721).
Thank you for this opportunity to provide our Industrial Hygiene services. We look forward to continuing our support of OxyChem Corporate Medical in addressing health issues in the work place and community.
Sincerely,
Edward A. Guida, PE, CIH Manager Occupational Health Services RiskFocus Virginia Office
OCC 10927
Wersaft: ENVIRONMENTAL RISK MANAGEMENT
EMPLOYEE EXPOSURE MONITORING OCCIDENTAL CHEMICAL CORPORATION
PVC RESINS AND COMPOUNDS PLANT PASADENA, TEXAS
Prepared for Mr. Stephen B. Kemp IH Manager, Corporate Medical
OxyChem 360 Rainbow Boulevard South, Box 728
Niagara Falls, NY 14302
Prepared by RiskFocus VERSAR Inc. Springfield, Virginia
January 1991
OCC 10929
Foreword
This report was prepared under the management and supervision of the RiskFocus Division of VERSAR Inc., located in the Washington, D.C. metropolitan area. RiskFocus provides comprehensive stewardship for product integrity and registration, worker safety, waste disposal, regulatory interpretation and compliance, and risk communication.
Authorship of this report is credited to Edward A. Guida, PE, CIH. Quality assurance is credited to Scott R. Baker. Further information about this report may be obtained by writing directly to the Director, RiskFocus Division or by calling (703) 642-6884.
Robert G. Tardiff, Ph.D., ATS Director, RiskFocus Virginia Office
Ref No 23-6474.015.01
i
OCC 10930
D R A FT-1
Table of Contents
Foreword.......................................................................................................................... i
I. Introduction....................................................................................................... 1
II. Background....................................................................................................... 3
A. Scope of Services ................................................................................... 3
1. Two-Day Plant Pre-Survey....................................................... 3
2. Monitoring Plan.........................................
4
3. Monitoring Survey..................................................................... 7
B. Risk Assessment Criteria..................................................................... 9
III. Findings and Discussion ................................................................................ 12
A. Noise Dosimetry...................................................................................... 12
B. Air Sampling.......................................................................................... 16
1. PVC Loading ............................................................................... 16
2. PVC Production........................................................................... 18
4. AFE Shop........................................................................
22
5. PVC Maintenance -- Welding ................................................. 24
6. QC and Environmental Laboratory.......................................... 24
C. Area Noise Survey................................................................................. 27
IV. Conclusions and Recommendations ............................................................... 30 A. Noise Exposure ...................................................................................... 30 B. Air Sampling.......................................................................................... 31 1. PVC Loading .............................................................................. 31 2. Dryer Operators.......................................................................... 31 4. Solution Preparation ................................................................. 32 5. AFE Shop -- Welding................................................................. 32 C. Area Noise Survey................................................................................. 33
V. References.......................................................................................................... 34
APPENDIX................................................................................................................... 35
ii
OCC 10931
DRAFT-1
Employee Exposure Monitoring Occidental Chemical Corporation PVC Resins and Compounds Plant
Pasadena, Texas
I. Introduction
At the request of Mr. Stephen B. Kemp, OxyChem Corporate Medical Industrial Hygiene Manager, RiskFocus was retained to lead an Industrial Hygienist (IH) Team in the accomplishment of employee exposure monitoring at the OxyChem Pasadena, Texas, PVC Resins and Compounds Plant. The Pasadena Plant manager had applied, in February 1989, for OSHA STAR Status under the OSHA Voluntary Protection Programs (VPP). In essence, the STAR Status from OSHA is recognition that organizational safety and health programs exceed OSHA requirements and that employees as well as managers strive for safe and healthful work environments. Facilities granted STAR Status are removed from the OSHA inspection list, but audits of injuries/illnesses and accident investigations may be accomplished according to OSHA VPP procedures. OSHA, as a result of their audit of the safety and health programs, granted a provisional STAR Status to the Pasadena PVC Plant contingent that certain employee exposure monitoring be accomplished within a 90 day period following the OSHA audit which ended on
1
OCC 10932
D R A FT1
November 9, 1990. The need to measure employee exposures to PVC dusts, welding fumes, and noise was specifically identified by the OSHA auditors during the OSHA closing conference. According to one OxyChem senior Industrial Hygienist, as a result of a teleconference with one of the OSHA auditors, solvents should also be sampled.
This report describes the risk assessment accomplished by the IH Team. Section III, Findings and Discussion, contains the results of the noise measurements and exposure monitoring in light of the risk assessment criteria. Where overexposures are found, the adequacy of existing exposure controls are discussed. In Section IV, conclusions regarding the employees' exposures are discussed and recommendations to control their exposures are provided, where needed. The air sampling, noise dosimetry, and area noise measurement data sheets are included in the Appendix.
2
OCC 10933
II, Background
D R A FT -1
A. Scope of Services
The objective of this task assignment was to accomplish exposure monitoring as specified by the OSHA auditors to assure the OxyChem officials that the STAB Status would be awarded. As a result of this task assignment, a two day plant presurvey, developing a monitoring plan, and a one week monitoring survey were accomplished, Mr. Edward A. Guida, PE, CIH, Manager of Occupational Health Services, KiskFocus, leads the IH Team for the monitoring survey, the exposure monitoring management, and reporting.
1. Two-Day Plant Pre-Survey Mr. Guida visited the Pasadena FVC Plant on November 29 and 30, 1990, to become familiar with plant operations and processes as well as collect data needed to develop the monitoring plan. The monitoring plan included noise dosimetry, PVC dust sampling, and welding fume sampling as specified by the OSHA auditors. Sampling for organic chemicals in the laboratories and in the solution preparation area were also included in the plan. Exposures to vinyl chloride monomer (VCM)
3
occ 10934
DRAFT-1
during filter changes at the Liquid Loading Rack had not previously been measured; sampling for VCM during filter change was identified. Area noise surveys were performed to supplement noise dosimetry measurements.
2. Monitoring Plan The monitoring plan developed for the Pasadena PVC Plant included area noise surveys, noise dosimetry, and a personal air sampling strategy to measure employee exposures to chemical substances. Tables 1, 2, and 3 summarize each aspect of the planned environmental testing for this plant.
Table 1
Area
AREA NOISE SURVEYS Noise Source
Waste Treatment Plant F-8 Boiler Plant
Compressor Boilers
Steam Plant
Boilers
AFE Shop Machine Shop
PVC Maintenance Shop
Shop Equipment
Shop Equipment including Sandblast Cabinet and Press. Washer
Port. Welder & Compressor
PVC Bagging PVC Refrigeration Compressors
Bagging Machine Refrigeration Equipment
#1 and #3 Dryer PVC Loading (Rail Car) Car Cleaners Recovery Area
Blowers #1 and #3 Dryer Blowers Equipment Equipment
4 CC 10935
PR AFT-1
Table 2
Area
F-8 Boiler Steam Plant AFE Shop Machine Shop Liquid Loading Rack PVC Bagging Reactor Building Dryer Buildings (6) PVC Loading (Rail Car) Car Cleaners Recovery Area
NOISE DOSIMETRY Number of Employees Per Shift
5
- 5 (welders/boiler-makers) 6 (plant wide exposures)
2 (1 OxyChem, 1 Contract) 1
3 (two 12-hr shifts) 2 (two 12-hr shifts) 2 (two 12-hr shifts)
4 1
5
OCC 10936
DRAFT-1
Table 3
Area
AIR SAMPLING STRATEGY
Substance
No. of Employees Per Shift
AFE Shop QC & Env. Lab
Welding Fumes (NOC) Zinc Oxide Sand (Silica) (Respirable) Sand (Silica) (Total)
Freon 113 Carbon Disulfide
6 6 6 6
2 1
Machine Shop Liquid Loading Rack PVC Maintenance Shop PVC Bagging
QC Lab (PVC Plant)
Solution Prep
Dryer Buildings (6)
Welding Fumes (NOC) Vinyl Chloride (during filter change) Welding Fumes (NOC)
PVC Dust (PNOC) (Respirable) PVC Dust (PNOC) (Total) Cyclohexanone Acetone Dioctylphthalate Isopropanol Isobutanol Methyl Cellulose Polyvinyl Alcohol PVC Dust (PNOC) (Respirable)
PVC Dust (PNOC) (Total)
PVC Loading (Rail Car)
Car Cleaners
PVC Dust (PNOC) (Respirable) PVC Dust (PNOC) (Total)
PVC Dust (PNOC) (Respirable) PVC Dust (PNOC) (Total)
6 1
1 (two 12-hr shifts)
1 1
2 (two 12-hr shifts) 2 (two 12-hr shifts) 2 (two 12-hr shifts) 2 (two 12-hr shifts)
3 (two 12-hr shifts) 3 (two 12-hr shifts) 3 (two 12-hr shifts)
2 (two 12-hr shifts plus maintenance employees) 2 (two 12-hr shifts plus maintenance employees)
2 (two 12-hr shifts) 2 (two 12-hr shifts)
4 4
6
OCC 10937
DRAFT-1
The Area Noise Surveys table (Table 1) shows the areas of the plant where sources of potentially hazardous noise emissions could occur. The noise emissions were measured with a sound level meter set to the A weighting network on slow response. The noise measurements would provided data that could be useful in noise abatement efforts. Noise dosimetry is identified on an area/job basis to measure employee noise exposures during their job activities. The air sampling is also identified on an area/job basis to measure employee exposures to airborne contaminants as a result of activities in the work area or according to a job.
3. Monitoring Survey The IH Team accomplished the noise measurements, noise dosimetry, and air sampling during the week of December 10*14, 1990. The sampling was prioritized to ensure that PVC dusts, welding fumes, and noise dosimetry were collected during the monitoring survey. Area noise surveys and air sampling for organic chemicals were given a secondary priority. All planned environmental testing and monitoring was accomplished.
The monitoring plan accounted for the fact that the production of PVC products at the Pasadena Plant requires around-the-clock workshifts. Where shift work was identified, monitoring during evening and night shifts was scheduled to address the temporal affects of employee exposures during different shifts. Employees have been assigned to work groups and scheduled to different shifts according to a published schedule. Accomplishing exposure monitoring during all shifts provided data to estimate all employee exposures as they rotated work shifts.
The following personnel comprised the IH Team:
Edward Guida, PE, CIH John Davis, CIH Robert McKinley, CIH
RiskFocus Occusafe Occusafe
7
occ 10938
P RAFT-1
Tom Olendorf
OxyChem
The following OxyChem Pasadena Plant personnel were contacted for this monitoring survey and provided plant escort for the exposure monitoring:
Jim Oliver William Seale Ray Hudson
Manager, Safety, Security & Loss Control Safety Safety
A brief closing conference to discuss the monitoring survey was conducted on December 14, 1990. The following OxyChem personnel were in attendance.
Pasadena PVC Plant Officials:
Jim Oliver
Manager, Safety, Security & Loss Control
Charles Brown Human Resources
Gary Jones
Production Manager and Acting Plant Manager
Scott Harp
PVC Production Superintendent
David Payne
PVC Production Engineer
Bill Miller
Maintenance Superintendent
Larry Burman Technical Services Manager
Bill Seale
Safety
Ray Hudson
Safety
Martha Ackel
QC and Environmental Laboratory
OxyChem Corporate Medical representatives:
Steve Kemp
IH Manager
Tom Olendorf Associate IH
The monitoring activity was described. Air sample results were not available and noise dosimetry results had not yet been evaluated. The area noise survey
8
OCC 10939
DRAFT-1
results were discussed briefly; the discussion focused on abatement efforts at the Dryer blowers.
B. Risk Assessment Criteria
The criteria used for this risk assessment included the OSHA Permissible Exposure Limits (PELs) and the ACGIH Threshold Limit Values (TLVs). Where work shifts exceed eight hours, arithmetic adjustments in these exposure limits were made to ensure that adequate health conservation measures would be taken if they were not already in place. Table 4 shows the eight-hour time-weighted hour (TWAg) TLVs and PELs and short-term exposure limits (STELs) for noise and the chemicals monitored during this survey. Blank cells in the table indicate that OSHA and/or ACGIA has not established a TLV or PEL for that substance.
It must be realized that the definition of an STEL is different for ACGIH and OSHA. The ACGIH STEL definition allows four 15-minute exposures per work day with at least one hour between exposures. The OSHA definition allows one 15minute exposure per work day.
PNOCs are defined as "particulates not otherwise classified." For particulate air contaminants for which there is no PEL or TLV, the PNOC exposure limit is applied. A cyclone attachment to the air sampling filter cassette is used to separate the particulates so that the dust fraction with mean aerodynamic diameters less than 10 microns can be collected. These particles are defined as respirable. Total PNOCs (particles of all sizes) are collected on a filter cassette without the cyclone. For this project, PVC dusts were collected as PNOCs (respirable and total) and exposure levels were assessed using the PNOC exposure limits.
9
occ 10940
D R A FT-1
While the ACGIH TLVs are listed here as occupational exposure limits, TLVs are recommendations to be used by professional industrial hygienists in the evaluation of occupational settings. TLVs are not regulatory; the OSHA PELs are regulatory and enforceable as federal laws. The TLVs are used to supplement the OSHA PELs in the evaluation of employee exposures at the Pasadena PVC Plant in the context of "wellness" in the work place.
Among the metals listed in Table 4, the last 13 chemicals (from beryllium to zinc) constitutes a welding fume screen (testing standard) for each welding fume air sample analyzed by the IH laboratory. It is not the intent of this air sampling strategy to test for these metals individually unless there is a compelling reason, as is the case for zinc oxide. Zinc oxide fumes are generated during welding of galvanized components.
10
OCC 10941
DRAFT-1
Table 4
OCCUPATIONAL EXPOSURE LIMITS1
Substance
TLV-TWAg TLV-STEL PEL-TWAg PEL-STEL
(mg/m3) (mg/m3) (mg/m3)
(mg/m3)
Noise PNOC (Total) PNOC (Respirable) Carbon Disulfide Isobutanol
85 dBA 10
31 (skin) 152
90 DBA 15 5
12 (skin) 150
36 (skin)
Acetone Isopropariol Cyclohexanone Dioctylphthalate
1780 983 100 (skin)
5
2380 1230
1800 980 100 (skin)
2400 1225
Zinc Oxide (fume) Beryllium Cadmium
5 0.002 (A2)
0.05 (C)
10
5 0.002
0.1
10 0.025 (peak)
0.3 (C)
Cobalt Chromium Copper Iron Manganese Molybdenum Nickel Lead Antimony Vanadium Zinc
0.05 0.5 0.2 5
1 5 1 0.15 0.5 0.05 5
0.05 0.5 0.1 10 31 5
1 0.05 0.5 0.05 10 5
3 10
1 American Conference of Governmental Industrial Hygienists. 1990. Guide to Occupational
Exposure Values--1990; ACGIH, Cincinnati, OH 2 Sax, Irving N, 1984. Dangerous Properties of Industrial Materials, 6th Edition; Van
Nostrand Reinhold Company, New York; page 1224.
11
OCC 10942
III. Findings and Discussion
D RAFT-1
The results of the exposure monitoring for noise and air contaminants are discussed in this section in light of the applicable occupational exposure limits (OELs). Area noise measurements are discussed as they pertain to employee exposure, hazardous noise area designation, and hazardous noise abatement.
A. Noise Dosimetry
Noise dosimetry was performed on employees throughout the plant during the week of December 10, 1990; day and night-shift exposures were measured. Metrosonics model 3100 noise dosimeters were used to measure exposures during full working shifts.
The Metrosonics dosimeter with the Metrosonics computer software is capable of extensive evaluation of the collected noise data. For the purpose of this survey, only the time weighted average (TWA) exposure data are used to evaluate the employee noise exposures (see Table 5). The TWA exposure measurement includes
12
OCC 10943
Table 5
D R A FT-1
EMPLOYEE MUSE EXTOSURES Pasadena PVC Plant
Saiple Nimber Sampling Date Work Shilt/Length
Work Area
Job Title
Sampling Time TVA
91560 91555 91556 91574 91559 91569 91562 91561 91557 91558 91563 91564 91571 91572 91565 91566 91567 91573 91552 91553 91554 91551
12/11/90 12/10/90 12/10/90 12/13/90 12/10/90 12/13/90 12/11/90 12/11/90 12/10/90 12/10/90 12/11/90 12/11/90 12/13/90 12/13/90 12/11/90 12/11/90 12/11/90 12/13/90 12/10/90 12/10/90 12/10/90 12/10/90
D/8 N/12 N/12 D/8 N/8 D/8 D/8 D/8 N/12 N/12 D/12 D/8 D/12 D/12 D/12 D/12 D/12 D/8 N/12 N/12 N/12 N/12
ATI SH3P DRYER AREA DRYER .AREA F~8 BOILER AREA LIQUID LOADING LIQUID LOADING MAD/IEMANCE MAIN STEP OFTSITES FVC LOADING fVC LOADING PVC LOADING PVC LOADING PVC LOADING FVC LOADING PVC PRCUUCTKK
pvc pRcbucnrw
wc PRtmnaj PVC PKEUCnCN REACTOR BOTCH REACTOR DECK REACTOR DECK RECOVERY
FINISHER OPERATOR TECHNICIAN OPERATOR TECHNICIAN BOILER OPERATOR OPERATOR TECHNICIAN LIQUID LOADER MAINTENANCE TEDINICIAN SIEAH PUNT OPERATOR OPERATOR TECHNICIAN OPERATOR TECHNICIAN PVC LOADER PVC BMXXR PVC BAGGBt CAR CLEANER DRYER OPERATOR BOTH REACTOR OPERATOR RECOVERY OPERATOR CAR (LEANER OPERATOR TECHNICIAN OPERATOR TECHNICIAN OPERATOR TECHNICIAN OPERATOR TECHNICIAN
7.55 11.02 12.01
7.30 8.30 7.02 6.24 5.21 8.52 11.19 6.49 6.51 9.58 7.00 9.28 9.27 9.24 7.52 7.52 10.49 10.57 10.34
87 93 88 81 77 92 79 83 88 97 87 89 91 91 96 87 86 89 85 86 85 88
13 Occ 10944
D R A FT-1
all noise exposures integrated in the dosimeter above 80 dBA. This 80 dBA cut-off is consistent with the OSHA Occupational Noise Standard, 29 CFR 1910.95, Appendix A, which shows reference allowable exposure durations for TWA noise exposures as low as 80 dBA.
Two noise criteria were used to evaluate the risk to high-intensity noise exposure: one for eight-hour work shifts and one for 12-hour work shifts. The TLVand PEL-TWAg shown in the Risk Assessment Criteria section (Section B) of the Introduction applies to the eight-hour work shifts. For 12-hour work shifts, the criteria must be reduced to compensate for the longer exposure time. The noise PELTWA12 is 87 dBA; the noise TLV-TWA12 is 82 dBA.
Throughout this plant, high noise levels were encountered. However, a comprehensive hearing conservation program was evident. Hazardous noise areas were posted and hearing protection was worn by exposed personnel -- employees and visitors. Many forms of hearing protection were available including several kinds of ear plugs, semi-insert hearing protectors, and ear muffs. The employees carry hearing protection as a part of their safety equipment ensemble and the IH Team members observed consistent use of hearing protection in the designated hazardous noise areas. This practice ensures that high noise exposures were controlled to prevent hearing loss.
The available hearing protection was adequate to protect employees from the adverse effects of the high intensity noise. The lowest noise reduction rating (NRR) noted on a hearing protection device equalled 22 dBA (with the semi-insert hearing protector). Using the OSHA method to estimate protection, which involved subtracting 7 dB from the NRR before subtracting the NRR from the measured noise exposure, the NRR equalled 15 dB. The highest TWA noise exposure measured was 96 dBA on a Dryer operator. Reducing this exposure by 15 dB results in an exposure
14
OCC 10945
DRAFT -1
of 81 dBA, 6 dB below the PEL-TWA12 and 1 dB below the TLV-TWA12. Use of ear plugs and/or ear muffs would improve the protection further.
In the Dryer area of the plant, noise levels were noticeably higher and of a unique quality. At Dryers numbers 1 and 3, there are blowers that emit a pure tone of 600 Hertz (Hz) at about 108 dBA. The employees working in the Dryer area and the Rail Car loading area, which includes Rail Car loaders and Rail Car cleaners, are affected by this noise emission. TWA exposures in excess of the OSHA PEL in these areas were caused by these high-level noise emissions. Hearing protection was worn by all personnel in these areas.
Efforts to control the noise emissions from the Dryer blowers is ongoing. Past efforts with passive devices have not been effective because of maintenance problems and clogging with PVC resin. Engineers are continuing to investigate alternate methods to reduce the noise emissions, including replacement of the blowers. Active noise control devices should be investigated. Active noise control devices maybe most effective in the low frequency range. They work on the principle of noise cancellation by adding a high intensity noise to the process out of phase with the noise emission to cancel the process noise.
The noise exposures at the Liquid Loading area were expected to be low. Measurement on one individual involving night-shift dosimetry was 77 dBA, which validated this expectation. However, the day-shift measurement on a different employee was 92 dBA; this level was not anticipated. This day-shift employee was involved in filling and switching tank car operations in the PVC Loading area including operating a "trackmobile." Noise measurements were not collected on the trackmobile; but trackmobiles at other OxyChem plants have been noted as being
15
OCC 10946
P R A FT-1
very loud.1 The employee wore hearing protection during his activities in the PVC Loading area and while operating the trackmobile.
The PVC Baggers were exposed to noise that measured 89 dBA for an eighthour shift and 91 dBA for a 12-hour work shift. One level exceeded the OSHA PEL; both exceeded the TLVs. It was noticed that a compressed air device on the bagging machine emitted a high intensity noise. The Bagger has been designated a hazardous noise area and the Bagger wore hearing protection.
B. Air Sampling
1. PVC Loading Seven day-shift and eight night-shift personal air samples for PVC dusts (identified as PNOCs) were collected on Rail Car loaders. Four of the day-shift and four of the night-shift samples were collected using cyclones to separate the respirable fraction.
These employees load PVC resin material into Rail Cars from overhead silos. The loader controls the resin flow through a flexible duct from the silo to the Rail Car port. The loader also clears apparent "clumping" with a long rod.
All of the employee exposures to PVC dusts in the PVC Loading area, as demonstrated by air sampling, were well below the applicable exposure limits (see Table 6). Exposures measured during the day-shift were similar to the levels measured during the night-shift.
1 Teleconference between Mr, Ed Guida, RiskFocus, and Mr. Tom Olendorf, OxyChem, on January 7, 1991. Mr. Olendorf referred to his knowledge about the trackmobile noise environment at the plant located in Matagorda, Texas.
16
OCC 10947
Table 6
DRAFT-1
TOA EXPOSURE MEASUREMENTS PVt loading - Pasadena PVC Plant
Sanple Nuober Sailing Date Work Shift
Jet Title
91501 91503 91508 91509 91533 91534 91541 91542 91511 91512 91523 91546 91605 91607 91608
12/10/90 12/10/90 12/10/90 12/10/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/12/90 12/12/90 12/12/90 12/12/90
N CKRATCR TO3i.
N OPERATOR ran.
N OPERATOR ran.
N OPERATOR ran.
N OPERATOR ran.
N OHRATOR ran.
N
N
OPERATOR ran. OPERATOR ran.
D PVC UXOR
D PVC IAAKR
D pvc muiR
D PVC LOAKR
D PVC LOAKR
D PVC LOADER
D PVC LOAKR
Saeailing Tine
332 352 319 333 342 340 318 320 447 374 211 327 404 206 215
Material
Results (ng/n3)
HCC-TOISL hcc-toial HOC-TOIJL ROC-TOTAL FNX-KESP. HOC-RESP. HOC-RESP. PNOC-KESP.
HOC-TOTAL
EEOC-TOTAL HCC-TOIAL
HOC-RESP.
PNOC-KESP. HOC-RESP.
HOC-RESP.
0.24 0.64 0.63 0.16 0.068 0.17 0.055
<0.017 0.15 0.74 0.20 0.071 0.12 0.056 0.17
17
OCC 10948
DRAFT-1
While air sampling indicates that no employee overexposures would be expected in this work area during the loading activities, cleaning the Rail Cars with compressed air entrains high levels of PVC dust in the environment. Such high dust levels can irritate or injure the eyes, obscure vision, and excessive dust on walking surfaces can cause slipping and falls. A vacuum system is used to clean interiors of Rail Cars. Use of such a system to clean spillage would eliminate PVC dust entrainment in the air and collect the resin for resale.2
2. PVC Production The results of the air sampling conducted in the PVC Production areas, Car Cleaning, Dryer operations, QC Laboratory operations, and the Bagging operation are shown on Table 7.
a. Rail Car Cleaners. Eight day-shift air samples for PVC dusts were collected on the Rail Car cleaners during cleaning operations. Four of these air samples were for the respirable dust fraction. All exposures were well below the applicable exposure limits. No overexposure conditions are expected during Rail Car cleaning activities.
b. Dryer Operators. Eight day-shift and eight night-shift air samples for PVC dusts were collected on the Dryer operators. Half of these air samples were for the respirable dust fraction. All of the night-shift exposure levels and all of the day-shift respirable dust exposure levels were well below the applicable exposure limits. Three of the day-shift total dust levels were significant: one exceeded the PEL-TWAg, two exceeded the TLV-TWAg, and one exceeded one-half of the TLVTWAg.
2 Correspondence from Mr. John Davis, CIH, Occusafe, to Mr. Ed Guida, RiskFocus, dated December 28, 1990.
18
OCC 10949
Table 7
D R A FT- 1
TVA EXPOSURE WASUHEWNIS FVC Production - Pasadena FVC Plant
Sanple Winter Sailing Date Work Shift Joi> Title
91530 91531 91545 91606 91609 91610 91629 91630 91502 91504 91506 91507 91510 91514 91515 91516 91526 91527 91537 91540 91547 91548 91611 91612 91529 91529 91536 91538 91538 91539 91616 91620 91626 91626 91628 91631 91513 91525 91615 91624 91618 91627
12/13/90 12/13/90 12/12/90 12/12/90 12/12/90 12/12/90 12/13/90 12/13/90 12/10/90 12/10/90 12/10/90 12/11/90 12/10/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/12/90 12/12/90 12/12/90 12/12/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/13/90 12/13/90 12/13/90 12/13/90 12/13/90 12/13/90 12/11/90 12/11/90 12/13/90 12/13/90 12/13/90 12/13/90
D out acwra D CAR (TONER D CUt (TONER D (AR (TONER D CAR (TONER D CUt (TONER D CUt (TONER D CUt (TONER N DRYER OPERATOR N dryer CURATOR N dryer OPERATOR N WYER OPERATOR N DRYER OPERATOR D DRYER OHRATOR D DRYER OHRATOR N DRYER OPERATOR D DRYER OPERATOR D DRYER OPERATOR N DRYER OPERATOR N dryer OPERATOR D DRYER OPERATOR D DRYER OPERATOR D dryer OPERATOR D DRYER OPERATOR N LAB TOCHNICQN N LAB THMGCIAN
N LAB irntMTCTlM
N LAB THCJtaCIAN
N lab TmsnciAN
N LAB TfESaOAN D LAB TBC&aaAN D LAB TEnKIdAN
D lABTEiaaCDN 0 LAB TETHnOAN
D LAB TECHNICIAN
D LAB TEONEOAN
D FVC BAGGER
D FVC BAOSR
D FVC BAQGOt
D PVC BAGGER
D SOU/ITON FREP D SOLUTION PREP
Hue
Material
259 265 327 325 170 151 230 225 184 352 318 394 479 412 402 345 237 224 314 483 373 395 233 201
228 422 422 432 209 178 344 344 237 117 430 157 290 322 254 247
RDC-TOIAL DUST rbc-toial DUST HGC-RESP. DUST RJOC-RESF. OUST PHX-RESP. DUST RDC-RESP. DUST PNOC-TOIAL DUST HOC-TOTAL DUST ROC-TOTAL DUST fndc-toial dost RBC-TOIAL DUST HBC-RESP. DUST RJOC-TOIAL DUST RJOC-TOIAL DUST HOC-TOTAL DUST HCC-HSP. DOST RJOC-TOIAL DUST HOC-TOTAL DUST HJOC-RESP. DUST
ROC-RESP. DUST HCC-RESP. DUST ROC-RESP. DUST ROC-RESP. DUST ROC-RESP. DUST ACETONE ISOFROFNCL
cyochemwhe
AfETTHE ISCPtmKL CYOIKXAM3E ACETOE
DTOCTYL FRIHAUOE
cyoikxakme
aamnxK
DIDCYTL mraiATE DIOCYTL raiHAlATE ROC-TOTAL DUST ROC-TOTAL DUST ROC-RESP. DUST ROC-RESP. DUST
VM t p NAPHIHA
VM * P NARdflA
Results (mg/m3)
0.068
0.12
0.35 0.036 0.035 <0.039 0.11 0.17 1.2 2.4 0.97 0.13 0.30 16.0 5.6 0.30 0.25 U.O 0.24 0.93 0.062 0.69 0.35 0.26 <2.4 <2.5 <0.24 2.88 <2.5 <0.08 <2.4 <0.005 0.68 0.68 <0.004 <0.006 0.68 1.22 0.26 0.11 <4.6 <4.6
19
OCC 10950
DRAFT-1
The high PVC dust levels were measured during cleaning of dryer magnets with compressed air hoses. The observed dust levels during this operation were very high; these air samples validated the observations. Although the respirable dust fractions were below the PEL, which indicates that dust depositions in the lower respiratory system were at unacceptable levels, reduction ofthe high total dust levels during magnet cleaning is necessary to comply with the OSHA PEL and conform to the ACGIH TLV. Personal protection worn during this cleaning operation included a single-use disposable dust respirator.
The protection provided by this respirator is questionable because it cannot be fit tested. The use of a properly fitted and NIOSH-certified dust respirator is required to provide adequate protection to the employee from dust overexposures. A permanent engineering control for excessive dust emission must be investigated.
Blowing components with compressed air for cleaning is inefficient and, as is seen here, can present dust level conditions in excess of the OSHA PEL and the ACGIH TLV. Furthermore, dusts that are blown from the components must subsequently be cleaned up. A vacuum system appears to make more sense in that it cleans component and collects PVC resin in a single step. Subsequent clean-up is not necessary. The vacuum can also be used to pick up other build-ups of fugitive resin emissions in the dryer buildings.
c. Laboratory Technicians. Eleven air samples for acetone, dioctylphthalate, isopropyl alcohol (isopropanol), and cyclohexanone were collected on the laboratory technicians in the Quality Control (QC) Laboratory of the PVC Production plant. All of the levels were below the sample detection limit with the exception of one acetone measurement and all of the cyclohexanone levels.
The exposure levels measured for acetone and cyclohexanone were well below the applicable exposure limits. Laboratory procedures involving these materials were
20
OCC 10951
DRAFT-1
performed in the laboratory hood. No further actions are necessary to control the airborne exposure route.
Cyclohexanone can be readily absorbed through the skin, as evidenced by the "Skin" notation on the PEL and the TLV. The PEL and TLV control the body burden caused by the airborne route of entry and do not address the body burden caused by skin absorption. Therefore, direct skin contact must be carefully controlled. The laboratory technicians wear protective eye wear and gloves when using cyclohexanone. These procedures adequately control exposures.
The levels of dioctylphthalate were below detection limits; however, these measurements might have been underestimates of actual airborne levels. For heated dioctylphthalate, the air sampling technique specified an air sampling train consisting of a glass fiber filter to be placed in tandem with a midget impinger filled with a 50% aqueous solution of isopropyl alcohol. This method collects any aerosols on the filter and vapors in the alcohol solution in the impinger. Only the filter is needed if the chemical is used at room temperature. When preparing to collect the air samples, monitoring technicians were told that dioctylphthalate was being used at room temperature. Therefore, the air samples were collected with the filter only. It was discovered afterward that the dioctylphthalate was heated. This sampling should be reconducted with the glass filter and the midget impinger in tandem.
d. PVC Bagger. Four personal air samples for PVC dusts were collected on the PVC Bagger during day-shifts. Two of the samples measured total dust levels and two measured the respirable dust fraction. All measured airborne levels were well below the applicable exposure limits. No further actions to control employee exposures were indicated as a result of this air sampling.
e. Solution Preparation. Two air samples for varnish makers' and printers' naphtha (VM&P naphtha) were collected on a Solution Preparation
21
OCC 10952
D R A FT1
employee during operations involving the use ofAK 20 Catalyst. VM&P naphtha was the only regulated substance in the catalyst formulation that could be sampled during this monitoring survey.
The measured levels of VM&P naphtha are below the sample detection limit. The monitored employee was wearing an air purifying respirator, gloves, apron, and face shield during his activities with the catalyst. These measurements indicate that the employee was adequately protected during catalyst use. However, there are other chemicals used in the Solution Preparation area. Further air sampling during the use of other materials is needed to fully characterize exposures in this area.
4. AFE Shop a. Welding. Three personal air samples were collected on welders
in the AFE Shop during actual welding operations (see Table 8). Operations performed during air sampling included welding of carbon steel with a few tacks on galvanized, cutting, and grinding carbon steel, and tack welding galvanized steel in a sump pit entry at the Waste Treatment plant. Protective equipment observed to be worn included welding mask and ear plugs. (Welding is conducted on carbon steels, stainless steels, galvanized carbon steels, and other metals to a lesser extent including aluminum, brass, hastaloy, and iconel.)
Except for tack welding on galvanized steel in the sump, all exposure measurements were well below the applicable exposure limits. The welder who was tack welding in the sump pit was overexposed to zinc and zinc oxide, and his exposure to iron was significant (over one-half of the TWAg exposure limit for iron). The orientation and proximity of the task to the welder, the awkward position that the welder must assume, and the poor ventilation in the sump pit contributed to this overexposure condition. Ventilating the pit will reduce exposure as will wear a fume air purifying respirator. However, a respirator will probably be difficult because of the location of the task.
22
OCC 10953
Table 8
D R A FT-1
TWA EXPOSURE MEASUREMENTS AFE shop - Pasadena PVC plant
Saople Nmber Sanding Date
91518 91518 91518 91518 91518 91518 91518 91518 91518 91518 91518 91518 91518 91518 91519 91519 91519 91519 91519 91519 91519 91519 91519 91519 91519 91519 91519 91519 91522 91522 91522 91522 91522 91522 91522 91522 91522 91522 91522 91522 91522 91522
12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90
12/11/90 12/11/90 12/11/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90
Shift Jab Title Sanding Tine
Material
D WELDER D WELSH
D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH 0 WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELDER D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH 0 WELSH D WELSH D WELSH D WELSH D WELSH D WELSH D WELSH 0 WELSH D WELSH
258 ANTBCKY
258 BENYIUlPf 258 CADMIUM
258 CSCKUM 258 OCBMT 258 (Unit
258 hcn 258 LEAD 258 MAMANESE 258 KUTCDENUM 258 NICKEL 258 VANADIUM 258 ZINC
258 ZINC COOS 204 ANTIMONY
204 EHWUIUM 204 UKlfl 204 aoofnji
204 oobmj 204 COPTEH 204 IKK 204 HAD 204 MANGANESE
204 204 NICKEL 204 VANADIUM
204 ZINC 204 ZINC coas 424 ANnUNY 424 smuim 424 auiaiit 424 (SHcraiM 424 acnur 424 CCPFEH
424 WQi
424 LEAD 424 MANGANESE
424 MOLYBSMH 424 NICKEL 424 VANADIUM 424 ZINC 424 ZINC aas
Results (ug/al)
0.0005 <0.0005 <0.0005 <0.0005
0.0006 0.0009 0.10 0.0005 0.0019 <0.0048 <0.0005 <0.0005 0.012 0.014 <0.0006 <0.0006 0.0006 0.029 <0.0006 0.023 2.7 0.0026 0.31 <0.006 0.0078 <0.0006 14 17 <0.0003 <0.0003 <0.0003 <0.0003 <0.0003 0.0012 0.15 <0.0003 0.014 <0.0031 <0.0003 <0.0003
0.14 0.17
23 occ 10954
D R A FT-1
Careful planning of field welding is needed to ensure that overexposures are avoided. Review of the task and task environment should address the possibility of air contaminant exposure and methods to prevent overexposure. Welding should be done in the shop, as much as possible.
b. Abrasive Blasting. No abrasive blasting was performed during this monitoring survey; monitoring during these operations is needed to measure exposures and validate protective procedures.
5. PVC Maintenance -- Welding Three personal air samples were collected on PVC Maintenance Shop welders during actual welding operations (see Table 9). Operations performed during this sampling involved welding on stainless steel using tungsten inert gas (TIG), referred to as heliarc by the shop personnel, "stick" welding on stainless steel, and a small amount of TIG welding on galvanized steel.
Exposures to welding fumes for these employees were well below the applicable exposure limits. These measurements indicate that no further exposure controls are needed during welding operations evaluated in this shop.
6. QC and Environmental Laboratory Two personal air samples were collected on a laboratory technician for carbon disulfide during the processing of VCM monitors. One sample was collected for 15 minutes to measure the STEL exposure (see Table 10). The other sample was collected during the remainder of the morning; afternoon work did not involve exposure to carbon disulfide. The technician wore gloves and performed the work in a laboratory hood. All exposure measurements were well below the applicable exposure limits; no further exposure controls are needed.
24
OCC 10955
r
Table 9
D R A FT- 1
DR ECPOGDRE MEASUREMENTS IVC Maintenance - Pasadena IVC Plant
Sa^jle Ninter Sailing Date Work Shift Job Title Sailing Tire Material Results (ng/a>3)
91517 91517 91517 91517 91517 91517 91517 91517 91517 91517 91517 91517 91517 91517 91521 91521 91521 91521 91521 91521 91521 91521 91521 91521 91521 91521 91521 91521 91602 91602 91602 91602 91602 91602 91602 91602 91602 91602 91602 91602 91602 91602
12/11/90 12/U/90 12/U/90 12/U/90 12/11/90 12/11/90 12/11/90 12/U/90 12/11/90 12/U/90 12/U/90 12/U/90 12/U/90 12/11/90 12/H/90 12/11/90 12/U/90 12/U/90 12/U/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/11/90 12/U/90 12/11/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90 12/12/90
D WHUK
D won*
D WEUER
D man D man D man D man D man D man D man D man D man D man D man D man
D WEUSt
D WEUXX
D WQXBt
D man D man D man D man D woxot D man D man D man D man D man D man D man D man D man D man D weion D man D man D man D man D man D man D man D man
328 AOTMOflf
<0.0004
328 EBOflilW <0.0004
328 CMMUM
<0.0004
328 (BKWIM
0.0019
328 mwai.T
<0.0004
328 OOFFOt
0.0011
328 IKK 328 1HD
0.0042
O.OOU
328 MANSNESE
0.0046
328
mmoot
<0.0038
328 NICKEL
328 vwDHK
0.0004 <0.0004
328 zinc
0.0040
328 ZOO COCKE 0.0049
150 jurmanr
<0.0008
150 amuitx <0.0008
150 CMKIUN
<0.0008
150 caoffiK
150 aawr
<0.0008 0.0008
150 COPPER
0.0008
150 IKK
<0.0008
150 tfXD
0.0041
150 mammes <0.0008
150
KUHKMK
<0.008
150 Nicm
<0.0008
150 vanadium
<0.0008
150 2DC
0.0035
150 ZINC COCKE 0.0043
444 anxHf
<0.0003
444 meaum
<0.0003
444 amaiK
0.0037
444 caooiK
0.0006
444 CCBMJT
444 ccmx 444 not
<0.0003 0.0003 0.0071
444 LEAD
0.0003
444 MAKMGSE
O.OOU
444
EOOTHU1
<0.0028
444 NKXEL
0.0003
444 VMMKIK
<0.0003
444 ZINC
0.044
444 ZINCCOaiE 0.055
25
OCC 10956
; D R A FT- 1 Table 10
m EXPOSURE >OSUROffOTS QC ani OmioncHital Lab (Offsite) - Pasadena IYC Plant
Sanple Ninter Sanpling Date Work Shift Job Title
Sailing Tine Material
Results tajfol)
91617 91619
12/13/90 12/13/90
D LAB 7HSMICUN D LAB TOIMICIM)
15
CWH DI3JLFI
<0.713
188
ORBCN DISUIH
0.806
26 0cc 10957
D R A FT-1
C. Area Noise Survey
The area noise survey confirmed where hazardous noise exposures are possible and validated the posting of hazardous noise signs in specific areas of the plant. The survey data are summarized in Table 11.
Table 11
AREA SOUND LEVEL MEASUREMENTS SUMMARY
Area
Location
Noise Source
Steam Plant AFE Shop F-8 Boiler PVC Maintenance Shop Main Machine Shop PVC Bagging Machine
Control Room Steam Plant Area Shop Area Lunch Area Control Room Desk Boiler Area Shop Area Office Shop Area Bagger Station
Background Equipment Equipment, ventilation fan Roof Fan off Background Equipment Background, Equipment Background Background Vacuum, Conveyor
Stacking End of Conveyor
Compressed Air Conveyor
Refrigeration Compressor Area PVC Loading
Recovery Area Dryer Area
Weighing Scale Area
Locomotive RE1255 Locomotive RE506 Area Area Area
Conveyor, Compressed Air Equipment
Locomotive Locomotive Dryer Blowers Equipment Blowers, Equipment
dBA 59-60 82-96 82-86
77 67 83-101 60-82 61 63-68 90-91 95 86-87
86-88 85-95
87-92 80-81 90-106 79-92 87-108
27
OCC 10958
D R A FT-1
Steam generating plant control rooms were relatively quiet, as expected. Boilers and supporting equipment emitted noise as high as 101 dBA thereby justifying identifying these areas as hazardous noise areas and requiring hearing protection. Noise dosimetry did not show hazardous noise exposures since the employees assigned to this work area do not spend a majority of their working day outside of the control rooms.
There are high noise emissions in the maintenance shops but hazardous noise exposures would not be expected from shop exposures. However, employees do perform tasks throughout the plant and are exposed to other high intensity noises. These employees follow hearing conservation procedures and have hearing protection with them when they move about the plant.
Noise emissions from the PVC Bagging equipment validate the hazardous noise exposures measured with noise dosimeters. Hearing protection must continue in the area of this activity.
Equipment in the Refrigeration Compressor Area and the Recovery Area emit high intensity noise. A hazardous noise exposure was measured in the Recovery Area with noise dosimetry. These areas are posted as hazardous noise areas and hearing protection is required. No further action is required.
The PVC Loading and Dryer areas are affected by the blowers at Dryers # 1 and 3. A high sound pressure level of 108 dBA was measured at the Dryer area. A level of 106 dBA was measured at the Loading area. A test with an octave band analyzer revealed that the pure tone component from the blowers existed in the 500 Hz octave band (a plant engineer indicated during the closing conference that his analysis showed the frequency to be 600 Hz, which is in the 500 Hz octave band). The areas adjacent and near the Dryers have the highest potential to damage hearing with relatively short exposures. These areas are posted as hazardous noise areas and
28
OCC 10959
DRAFT-1
hearing protection is required. Because the sound pressure levels are over 100 dBA, it is recommended that the semi-insert hearing protector not be allowed as hearing protection in these areas. The ear plugs and ear muffs provide a higher level of protection and should be worn in these areas. Sound cancellation technology should
A be investigated as an effective noise reduction measure at these Dryer blowers.
3 Ibid.
29
OCC 10960
D R ATM
TV. Conclusions and Recommendations
Where exposures were found to be below the applicable exposure limits, existing employee protection strategies were considered to be adequate and no further comments are provided.
A. Noise Exposure Hazardous noise exposures levels were measured at the Dryers, in the PVC
loading area, and at the Bagging machine. Two Dryer blowers emitted a noise level as high as 108 dBA and the Bagging machine emitted 86-95 dBA, as determined by sound-level meter measurement. These areas were designated hazardous noise areas, where hearing protection is required and where signs are posted. Employees were observed wearing proper hearing protection.
Dryer blower noise is the highest noise level encountered during this monitoring survey. The sound emitted is a pure tone at 600 Hz. While pure tone noises are no more damaging to hearing than broad band noise, maximal hearing
30 occ lo 961
DRAFT-1
protection is recommended. Semi-insert ear plugs provide the lowest NRR (22 dB) and the poorest protection. Adjusting protection with OSHA procedures leaves a NRR of 15 dB. Employee exposures remain above 90 dBA with the semi-insert ear plugs. For this area, properly fitted and inserted ear plugs and/or ear muffs are recommended. Efforts to reduce the noise at the blowers or replacing the blowers are the recommended permanent solutions to the hazardous noise problem at the Dryers.
B. Air Sampling
1. PVC Loading Although high dust exposure levels were not measured, high dust levels were observed during compressed air cleaning. High dust levels can obscure vision, irritate or injure the eyes, and cause slipping and falling. Cleaning with a vacuum system should be investigated.
2. Dryer Operators Dryer operators were overexposed to PVC dusts (total) during magnet cleaning with compressed air. The IH collecting the air samples noted very high dust entrainment in the environment during this cleaning operation. Air samples validated the observation. Personal protection included single use disposable dust respirators. These respirators provide questionable protection because fit testing is impossible.
Reduction of employee overexposures to dusts during magnet cleaning requires engineering controls and can include a properly fitted NIOSH-certified dust respirator. Single use, disposable respirator use must be discontinued immediately unless the quality of fit can be determined. The process of cleaning the magnets with a vacuum system should be investigated as an engineering exposure control. A
31
OCC 10962
D R A FT-1
vacuum system appears to make more sense because it cleans and collects the PVC resin in a single step.
3. Laboratory Technicians No overexposures were identified with air samples collected in the QC Lab of the PVC Production Plant. Samples of dioctylphthalate were for the aerosol only; the midget impinger was not used to collect vapors that could be generated by heated dioctylphthalate.
It is recommended that additional sampling in the QC Lab be performed to measure total dioctylphthalate exposures -- both aerosol and vapor phases. The air sampling train must consist of a glass fiber pre-filter in line with a midget impinger containing a 50% aqueous isopropyl alcohol solution.
4. Solution Preparation Not all Solution Preparation exposures were measured during this monitoring survey. It is recommended that employee exposure monitoring continue until all exposures have been measured.
5. AFE Shop -- Welding Tack welding on galvanized metal in the sump pit resulted in the welder being overexposed to zinc oxide and zinc fumes. There was no ventilation in the pit and the welder did not wear a respirator.
This operation will arise infrequently but it reveals the possibility of overexposures during unique tasks. It is recommended that unique tasks be reviewed for possible health consequences and that controls be established before they start. Ventilating the sump would reduce the exposure; a fume respirator, difficult for the welder because of the awkward position that he was in, would also control fume exposure.
32
OCC 10963
DRAFT-1
C. Area Noise Survey The area noise survey validated noise overexposures measured with noise
dosimetry. The high noise areas noted with sound-level meter measurements validated the hazardous noise area designations and postings observed at the Pasadena Plant. No further recommendations are necessary.
33
OCC 10964
V. References
D R A FT-1
American Conference of Governmental Industrial Hygienists; Guide to Occupational Exposure Values -- 1990; ACGIH, Cincinnati, OH; 1990.
Sax, Irving N.; Dangerous Properties of Industrial Materials, Sixth Edition; Van Nostrand Reinhold Company, New York; 1984; page 1224.
34
OCC 10965
D R A FT-1
APPENDIX
35
OCC 10966