Document XR72RMZvZzmV4LoRyxVOdke1y

(conoco) Interoffice Communication To R. T. Ferrell From E. L. Kieschnick oate August 9, 1974 subject OSHA Compliance Program for Oklahoma City /?r-o t Since March, 1974, approximately 4,000 engineering man hours and 40 projects have been directed toward establishing and reducing VCM exposure levels in the Oklahoma City plant. Some of the major improvements to date are: PROJECT DESCRIPTION INITIAL CONCENTRATION(ppm) RECENT MAXIMUM CONCENTRATION(ppm) 1. Manual rinse of reactors between batches terminated 10,000 NONE 2. Enclosure and vent system for Chem Wash Sweco 10,000 10 3. Enclosed seal for the slurry blend tank exhauster 8,000 25 4. Negative pressure system on M-500 dryer Sweco 1,000 5 5. Manifolded recovery system to a remote area 1,000 10 As sources of high VCM emission have been resolved, the sampling program has been redirected to the remaining areas of greatest potential for worker VCM exposure. Consequently, in the 4 weeks prior to August 9, the personnel dosimeter sampling program has concentrated on job functions that represent only about 8% of the total manpower effort at Oklahoma City. Results from these 4 weeks of testing are summarized by exposure range on the following page. CCR 000010727 R. T. Ferrell Page 2 August 9, 1974 VCM CONCENTRATION (PPM) 0 to 5 5 to 10 10 to 25 25 to 50 Over 50 120 dosimeter samples. % OF TOTAL* SAMPLES 55 19 13 tf.D 5 /j 8 AO JOB FUNCTION Resin resift in dryer building? reactor chem wash; reactor "one hour" resin sample; clean-up. Reactor dump, charge, chem wash and recovery; hopper car loading. Reactor dump; maintenance on VCM equipment. Reactor dump; reactor' cleaning; maintenance on VCM equipment; VCM rail car unloading. VCM rail car unloading; reactor cleaning; inerts venting of VCM receivers. Based on the above data plus information derived from area surveys with the Century OVA monitor an action program to meet OSHA restrictions on personnel exposure is presented in the attached table. This program is based on the premise that we must meet a requirement of 10 ppm TWA and 25 ppm ceiling for employee exposure by October 5. In addition to the employee exposure restrictions, it has been presumed that OSHA will place a restriction on the VCM content in dried resin. The current CONOCO objective of 1000 ppm by October 5 apparently represents no problem to Oklahoma City since limited tests of our resin indicate VCM contents of 300-800 ppm. However, projects with number 3 and 6 priority will help to better define our capabilities in this area. E. L. Kieschnick Process Engineer ELK:ma Attachment CCR 000010728