Document YrBO05XDGN7GKXxEDxgGbGdgV
Tiireston?
INTEROFFICE
NOVEMBER 12, 1975
fr
TO MR. C. J. KLEINERT
FROM C. W. ENGBLOM
SUBJECT
REFERRING TO LETTER OF
VINYL CHLORIDE SAFETY ASSOCIATION MEETING OCTOBER 30-31. 1975 - HOUSTON, TEXAS
RECEIVED NOV 1 3 1975
Mr. V. W. Madden and I attended the meeting. Seventy-five peopl^
thirty-five facilities were there. A list of those in attendance is attached.
1. Pilot Plant Problems: A. A. Peterson, Union Carbide Corp.
Mr. Peterson described typical problems encountered by a Pilot Plant located within or in close proximity to a production complex. VC emissions from the manufacturing unit naturally affect their operation and vice versa. He also claimed that not enough attention is given to safety or medical considerations when handling new raw materials (solvents, catalysts, etc.) not used in production.
To avoid set-ups, Air Products polymerizes the first Pilot Plant scaleup of a research recommendation to only 30# conversion and vents. Union Carbide has eliminated much of their sampling of Pilot Plant batches.
Everyone has area monitoring of their Pilot Plants. No one plans to shutdown their Pilot Plant but several have suspended operations for varying amounts of time. Air Products plans to move their Pilot Plant outside the production unit. Stauffer wants to install a monomer recovery system for their Pilot Plant, however others appear to be content to vent their steam jet exhausts through extended stacks.
2. Large Coverage Insurance Problems: John Barr, Air Products.
Since the merger of FIA and OIA, property damage and business interruption coverage has been limited to approximately $15 million. - Air Products is in the planning stage for a large reactor plant and this ruling has the effect of limiting plant capacity. Panasote, Passaic, New Jersey, are having similar problems and are also required to report emergencies to FIA. They feel this is partially due to their location in a densely populated urban area.
Five companies are totally self-insured, and several others had some form of partial self-insurance. Mr. Barr discussed the possible formation of a mutual protection agency. The petroleum industry pools funds as a form of self-insurance - Oil Insurance Limited.
Many felt that this problem is not peculiar to the vinyl chloride industry. Others in the chemical industry are experiencing similar problems. FIA surveys show that 80# of chemical industry claims are caused by explosions.
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3* Corrosion Around Sight Glasses and Nozzl a: Glenn Schaaf, B. F. Goodrich.
Goodrich has observed stress corrosion cracking in a number of vessels constructed of type 304 and type 321 stainless steel; in passivated as well as in unpassivated vessels. The attack appears as a branched pattern of cracks which start at a weld area and extend into the unwelded plate material. None of the vessels in which stress corrosion cracking has been observed were cleaned by high pressure water until a considerable period of service had accumulated. No attack was seen on vessels with less than three years of service. A Goodrich paper detailing the problem is attached.
Four companies had similar reactor problems. Several people observed cracking in centrifuge bowls. Four facilities experienced stress corrosion cracking in process piping. One company observed cracking on vibrating screen frames. They are now using monel frames to eliminate the problem. One company x-rays their vessels every two years.
4. OSHA COMMENTS:
a. Citations
Stauffer Chemical, Delaware City, had an inspection last June and received two citations. The first was for failure to label scrap drums. The second was for exposing an operator in their Poly Building to 23 ppm without a mask. Stauffer took readings at the same time and obtained results of 1 ppm. The Poly Building was shutdown at the time. The second citation was subsequently dropped.
Dow Chemical, Midland,^Michigan,had an incident in which two mechanics were exposed to liquid VC when disassembling a reciprocating compressor. They reported the incident to OSHA and were later cited for failure to provide respiratory protection and for exposing an employee to liquid vinyl chloride.
Goodyear, Niagara Falls, received a citation for exposing a compound operator to 1.4 ppm T.W.A. without a mask. The charge was subsequently dropped. Goodrich, Avon Lake, and Borden Chemical received similar citations which were later dropped. General Tire, Astabula, Ohio, were cited for exposing an operator to a 3 ppn> T.W.A. without a respirator. The charge has not been dropped and a court challenge is pending.
Great American had an inspection and were cited for two non-serious violations involving poor housekeeping in the compound area and in a mask storage area.
b. VCM AREA MONITORING
Panasote, Passaic, New Jersey, has a 40 pt. Ecom infra-red system equipped with a Michelson interferometer. The interferometer makes the IR system 1,000 times more sensitive by liminating interferences. The monitoring system is tied to a Texas Instruments computer which calculates T.W.A. exposures for their 51 employees.
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The computer is programs d to calculate T.W.A. based n c ntinuously updated monitoring data, tim studies on worker habits, and dissapation rate information on vinyl chloride. They have a 99+# confidence level in the data generated as compared to personnel monitoring data obtained via charcoal tubes. They have petitioned OSHA for a variance to us this system to supplant personnel monitoring and feel they will receive a favorable response. Their annual personnel monitoring costs were estimated at $50,000. A "ballpark" estimate of system cost was $350*000. They plan to publish the results of their work shortly.
Two PVC producers felt they would be below a 1 ppm T.W.A. by April 1. Twenty-si* believe they will be below a 5 ppm T.W.A. by April 1.
c. Deregulation of Areas
Hooker has a bagging area which is regulated only when bagging.
Continental Oil deregulates the VC loading rack when not loading.
Georgia Pacific is ready to deregulate the entire plant based on area and personnel monitoring. It is my understanding that they have a large reactor, open air, computer controlled plant.
d. Females in Plants - OSHA vs. EBP
Four companies don't allow women capable of having children to work in regulated areas. Twenty-three have females working in regulated areas.
. Residual Monomer in Resin
Glenn Schaaf, Goodrich, presented a brief description of their stripping columns. Residual levels are running 0.1 to 1.0 ppm for porous homopolymer with no deterioration in final properties. Maximum throughput rate is 20,000 dry lbs./hr.
f. Availability of Canisters
. The manufacture of charcoal canisters was not permitted after June 1, 1975, unless they had an end life indicator. The purchase of canisters without end life indicators is prohibited after January 1, 1976. Six companies claimed some of their employees are using canister masks below 25 ppm.
MSA turned in two models with end life indicators to NIOSH for approval, but were turned down because the color differential was not distinct enough. Scott also submitted a model that was rejected. MSA and Scott turned in combination mwks (airline or canister) for approval. Both were rejected.
g. Massive Release
There wer nearly as many definitions of "massive release" as companies in attendance. The only common denominator appears to be that no one
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ties their d finition t a particular ppm level. Many people felt that reporting a massive release t OSHA invites a subs quent insp ction.
5. EPA Considerations: Bill Madden, Firestone.
Bill described the recent meeting the SPI subtechnical committee had with EPA. The purpose of the gathering was to discuss EPA's latest document and recommend changes. Some of the changes discussed were in the following areas:
a. Exclusion of Pilot Plants, research facilities, and possibly control labs from the provisions of the proposed standard;
b. Change measurement sensitivity requirement for portable instruments to 5 Ppm;
c. Eliminate the requirement -for having a rupture disc between a pressure vessel and its* relief valve;
d. Allow manual vents; e. Allow venting of 25 gals, of vapor at S.T.P. from vessels other
than reactors. EPA's current proposal permits venting 256 of the vessel volume; f. Reduce recordkeeping and product testing requirements.
Bill feels there is little chance of EPA bending on items 5 and
6. Basic Safety: Pete Bogart, Tenneco
This talk was in response to a growing feeling of many within the organization that the association has strayed from its original mission of promoting safety in VC and PVC plants. He asked everyone to consider the following basic questions as they relate to their own organization.
a. Do we put economics before safety especially as it relates to providing safe equipment (tools, ladders, etc.)?
b. What provisions have we made for people to signal they are in trouble?
c. Are emergency notification systems easy to use? d. Are people sufficiently trained to handle an emergency? Is
emergency equipment adequate? . e. What is the quality of treatment at local hospitals? Are they
familiar with the chemicals we use? f. What is our criterion for allowing injured employees to return
to work? Are we just interested in avoiding lost time accidents? g. How effective are our safety training programs?
The talk generated much discussion particularly about individual safety programs. These programs were many and varied but all seemed to contain some kind of employee suggestion system.
7. True Confessions
Diamond Shamrock, Deer Park, Texas had a fatality on October 1, 1975* The man was 22 years old with 2 years experience. His assignment that night was to drop finished batches from the reactors to the stripp rs. He was found by high pressur cleaners lying on the bottom of a 2,000
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gall n PVC reactor when they noticed a ladder in the reactor. The reactor had not been safed out for entry or ventillated for flushing. They have a dropline ventillation system similar to ours in Pottstown. He was immediately raised from the reactor by means of wrist manacles but was already dead. The rescue worker did not wear a respirator. An "0" ring and a flashlight were also found at the bottom of the vessel.
The coroner listed the official cause of death as asphyxia from vinyl chloride. He also had a skull fracture but no internal hemorrhaging. OSHA were notified and made an inspection. They later came back and took statements from the operators who had made depositions on the night of the incidents. 03HA then asked Diamond to simulate the reactor condition at the time of the incident. This was done and charcoal tube samples were taken for VCM analysis by OSHA and Diamond 2 feet below th manway opening and at the bottom of the reactor. Diamond found 1200 ppm two feet below the manway; the speaker did not know the result at the bottom. OSHA results were unknown at the time of the meeting.
Diamond held a corporate safety review and concluded that the man either fell off the ladder or fell through the manway probably trying to retrieve the "0" ring or flashlight. As a result of the review, several new safety measures have been instituted. High pressure flushers are required to wear safety belts with a short line attached to a post near the reactor. Anyone entering a vessel is equipped with an alarm device which he must acknowledge every three minutes to signal that he is alright. Diamond do not use manway attendants. Oxygen is now available in the control room and ladder lengths have been standardized.
Following the presentation, there was much discussion from the floor. Great American locks their manways with chains to prevent unauthorized vessel entry and only the lead operator has a key. Goodrich has a local horn system which the person in the reactor must acknowledge at certain time intervals by pulling a rope to indicate that he is O.K. If he doesn't, a general alarm sounds. Several others have modifications of the same system. Borden reported some incidents of sabotage of their horn system. Most companies require manway attendants. Some questioned the value of manway attendants since the job is boring and they tend to read or even sleep. Many facilities require the use of bump caps (similar to a baseball batting helmet) while in a reactor. John Barr, Air Products, commented that OSHA is reviewing vessel entry and safe out procedures.
Georgia Pacific reported a vinyl spill when transferring one sphere to another due to operator error. The vessel was hydrostaticed and the relief valve opened. Their computer printed out a high VC level alarm but no one understood the message.
Stauffer reported a catalyst chest explosion when apparently either SBP or IPP was stored in the wrong catalyst storage refrigerator. No one was injured.
Hooker reported that a man passed out when VC vapors somehow got into his mask. The vapors w re coming from a vess 1 being filled with water. During his description, the Hooker representative mentioned that this
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tank had a valve (locked open) b tween th v es 1 and the rupture diac. This sounds like a dangerous practice to. His comments generated much debate about relief systems in general. Certain Teed, a large reactor plant* described a unique relief system. They have two separate relief lines each equipped with a valve under a rupture disc and relief valve. When one valve is opened* the other one is automatically closed. It seems to me such a system would require very careful surveillance. The recent lost time accident at Perryville was described.
C. W. ENGBLOM lfc cc: Dr. R. 5. Brookman
Messrs. R. W. Arnold D. M. Connor P. J. Foley - Perryville R. s. Frain J. R. Hilt F. F. Hoy - Perryville G. D. Lloyd (2) W. W. Madden V. L. Pollard - Akron K. L. Rauscher (2) D. F. Salopek - Akron
attachment
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VINYL CHLORIDE
ASSOCIATION
ATTENDANCE ROSIER - XTOBER 30 & 31, 1975
MARRIOTT MOTOR INN - HOUSTON, TEXAS
COMPANY 1R PRODUCTS 5CONDEL, S. A. UED CHEMICAL CCBP. EDEN CHEMICAL
5 CHEMICALS INTERNATIONAL ilTISH INDUSTRIAL
PLASTICS 2RTAIN-TEED
WOCO
EAMOND SHAMROCK Otf CHEMICAL
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attendee
J. T. Barr
T. Vega
V. C. Koch
J. Rogers A. Godfried R. Mercier J. R. Degenfelder
G. Harrison
T. H. MacEwan D. Middletoy
V. L. Potegt C. A. Gellner R. A. Bollich
C. E. Gremillion R. V. Seymour D. Porchey R. Ferrell
E. R. Henderson E. McCaleb
C. A. Christian B. Bors-Koefoed R. Oubre C. Bird R. Dostal
TITLE
Technical Mgr.
Plant Manager
Mgr. Occ. Health
Gen. Foreman Proc. Des. Engr. Mgr. Work Practice Plant Manager
Oper. Mgr. Plastics
Development Mgr. Production Mgr.
Personne1/Sa fe ty Plant Manager Production Supvr.
Safety Director Resin Oper. Supt. Res. Group Leader Plant Manager
Plant Manager Resin Prod. Mgr.
Technical Mgr. Prod. Supvr. Unit Mgr. Safety Supvr. Section Kgr. Resins
ADDRESS
TELEPHONE NO.
656 E. Swedeuford Rd., Wayne, Pa. 1908?
215-687-6150
Barcelona, Spain
P. 0. Box 1139R, Morristown, N. J. 07960 201-455-3042
P. 0. Box 27, Illiopolis, Illinois 62535 217-486-2411
511 Lancaster St., Leominister, Mass. 01453 617-537-1713
Ditto 11
Ditto 11
Devonshire House, Mayfair Place, Piccadilly 01-629-886'; London, England
Aycliffe Co., Durham, England Ditto
032-571-5122 Ditto
P. 0. Box 253, Sulphur, La. 70663 Ditto
It
318-882-144: Ditto
II
P. 0. Box 605, Westlake, La. 70669
318-882-055C
P. 0. Box 91, Rt. 25, Aberdeen, Miss. 39730 6OI-569-8IIJ
Drawer 126?, Ponca, Oklahoma 71601
405-762-345^
5200 SE 59th, Oklahoma City, Ckla.
405-672-4553
River Road, Delaware City, Delaware 19711 302-834-456]
Deer Park, Texas
713-476-221;
Freeport, Texas Ditto
P. 0. Box BB, Freeport, Texas 77541 Ditto
Bldg. 564., Midland, Michigan 48640
234-424: ?13-233-638 713-235-635* 713-233-6381 516-636-1452
INYL CRLORIDeAAT ASSOCIATION TTEHBAKCE BOsHR^^CTOBER 30 Sc 51. 1973 ARRIOTT MOTOR INN - HOUSTON, TEXAS
COMPANY
ATTENDEE
LECTROCHEMICAL IND.
0. Wilinski
SSO CHEMICAL CANADA
J. J. Brown
THYL CORPORATION
C. Mehl 0. K. Brown
IRESTCNE PLASTICS
C. Engblon V. V. Madden
ENERAL TIRE & ROBBER EGRGIA PACIFIC
. F. GOODRICH CHEMICAL OODYEAR TIRE & ROBBER
REAT AMERICAN CHEMICAL OCHER CHEMICAL
KPERIAL CHEMICAL IND.
NDUSTRIAS RESISTOL, S. A.
EYSOR-CENTOHY
IGKOCHEM
p)
nn
'8 -8
H. Jewett
H. Zimmerman E. A. Konderoa B. Babbitt M. Snuils
G. D. Scbaaf
A. Dixon J. M. Gilmore
J. C. Floros
M. Soble V. T. Kubat
D. J. Wheeler
A. Soriano M.
S. K. law
S. Harrod
PAGE 2
TITLE
ADDRESS
TELEPHONE HO.
Production Mgr.
P. 0. Box 1929, Haifa, Israel
Process Supt.
Box 3004, Sarnia, Ontario, Canada
339-2902
Production Supvr.
P. 0. Box 341, Baton Rouge, La. 70821
Sr. Tech. Serv. Engr.
Ditto
504-359-264^ 504-359-231i
Mgr., Process Eng. Coordinator-Spec.
Projects
Firestone Boulevard, Pottstown, Pa. 19464 215-326-255':
Box 699, Pottstown, Pa. 19464
215-326-200C
Plant Manager
Box 68, Ashtabula, Ohio 44043
216-998-112C
Mgr., Tech. Ser. Production Manager Production Supt. Tech. Coordinator
P. 0* Box 639* Plaqueminet La. 70764 Ditto ii n
504-687-632: Ditto
II
II
Process Specialist
6100 Oak Tree Blvd., Cleveland, Ohio 44131 2l6-524-020<
Production Supt. Plant Manager
P. 0. Box 578, Plaquemine, La. 70?64 5408 Baker, Niagara Falls, N. Y. 14302
504-387-315 716-283-768
Manufacturing V. P. 63O Water St., Fitchburg, Mass* 01420
617-343-697
Env. Control Mgr. Plant Mgr. - Resins
P. 0. Box 436, Burlington, N. J. 08016 Ditto
609-499-230. Ditto
Prod. Manager
Hillhouse Works, Cleveleys, England
6161
Production Manager
Masaryk 60, Mexico 5 D. F., Mexico
531-75-00
Mgr. Eng.
2600 Springbrook Rd. Saugus, Cal. 91350
805-259-236.
Tech. Mgr.
Box 488, Geismar, La. 70734
504-387-668
NYL CHLORIDE^ME ASSOCIATION
TENDANCE ROSTER ~OCTOBER 30 &~31. 1975 iRRIOTT MOTOR INN - HOUSTON, TEXAS
COMPANY
ATTENDEE
NTASOEE COMPANY
K. K. Sheth J. C. Coppoka R. V. KcCune H. Rzempoluch
G INDUSTRIES
P. W. Miner W. L. Oglesby J. Denison R. Stack
lUMEROS DE MEXICO, SA DE VC
J. P. Dues
IMEX R0M0CICNE5 INDUSTRIAIES
MEXICANAS, S. S.)
J. Alvares R. Kuri
ELL CHEMICAL CO.
D. Q. Miller M. E. Davison B. Reynolds
INTECH
J. Brau M. Potyondy
AUFFER CHEMICAL CO.
R. Asti B. Hager G. E. Lessley H. J. Langner
NNECO CHEMICALS
O O n-
P. L. Bogart B. Heal D. Rhoads J. Byrnes
J
PAGE 3
TITIE
ADDRESS
TELEPHONE NO,
Mgr. Resin Prod. Mgr. Ind. Eng. V. P. Mfg. Plant Manager
26 Jefferson St., Passaic, N. J. 07055 Ditto tt
P. 0. Box 19, Pt. Pleasant, W. Va. 25550
201-777-8500 Ditto
II
304-675-1020
VCM Foreman
P. 0. Box 1000, Lake Charles, La. ?0601
EC-VC-HC1 Gen. Foreman
Ditto
VCM Supt.
P. 0. Box 3^72, Ponce, P. R. 00731
Sr. Tech. Serv. Eng. One Gateway Center, Pittsburgh, Pa. 15222
318-882-1200 Ditto
805-843-4115
412-434-2403
Production Engr.
Ins. Sur. 1700, 5 Piso, Mexico, 20 DF
5-85
Plant Manager Safety Manager
Ap&rtado Postal 604, Pueblo, Mexico Ditto
42-9620
Mgr. "G" Operation VCM Supervisor Supt. - Op.
Deer Park, Texas 77556 Ditto
P. 0. Box 10, Norco, La. 70669
Mgr. Erap. Rel. Technician
5618 Hwy. 332, E., Freeport,Texas 77541 Ditto
Plant Manager Per. Manager Ass't. Pit. Mgr. Plant Manager
Box 320, Delaware City, Delaware 19706 Ditto
P. 0. Box 1110, Long Beach, Cal. 90801 Ditto
Safety Manager
River Road, Flemington, N. J. 08822
Safety Supervisor
P. 0. Box 116, Burlington, N. J. 08016
Mgr. Saf. & Loss Prev. Park SO Plaza We6t-1, Saddle Brook, N.J.
Safety Engineer
P. 0. Box 849, Pasadena, Texas 77501
713-479-2331 Ditto
504-^t^-n^5]
713-233-7861 Ditto
302-834-4575 Ditto
213-834-8571 Ditto
201-782-4011 609-386-9200 2OI-6H0-389I
479-3411
riNYL chdoridSHBy ASSOCIATION iTTEHDANCE ROSTER - OCTOBER 30 & 1.1921 URRTOTT MOTOR INK - HOUSTON, TEXAS
COMPANY
ATTENDEE
INION CARBIDE
R. L. Frantz C. E. Herald A. A. Peterson
fNIROIAL CHEMICAL
V. M. Iliff
IACKER-CHEMIE
W. Freiealeben
M
PAGE 4
TITLE
Dept. Head Sr. Process Engr. Production Engr.
Plant Engineer
Director Mfg.
ADDRESS
TELEPHONE NO.
P. 0. Box 471, Texas City, Tex. 77550 8000 McConkl Are., So. Charleston, W. Va. P. 0. Box 471, Texas City, Tex. 77550
713-945-741] 747-224*
713-945-741]
P. 0. Box 460, Painesville, Ohio 44077
216-357-757*
8000 Munchen, Prinzregentenstrasse, Germany 089-210-929-
EUCIDOL DIVISION rENNVALT CORPORATION
INATOIE J. SIPDJ CO.
iOURI CHEMICAL CQRP.
COMPANY REPRESENTATIVES HAVING DISPLAYS
7866 Hidden Hollow Drive, Mentor, 0. 44060 386 Park Avenue, New York, N. Y. 10016 2133 Lockport-Olcott Road, Burt, N. Y. 14028
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