Document b53d4MerQyM6kRkxG7egjg2bD

0 > INTERNAL CORRESPONDENCE UC 149- Z CHEMICALS AND PLASTICS TO (NAME) COMPANY location Mr. R. L. Frantz, 515 Mr. K. E. Ross, 515 Mr. C. E. Fry, 514 Mr. J. E. Giffln, 514 copy to Mr. R. N. Wheeler, 514 Dr. N. L. Zutty, NYO Dr. A. B. Steele, NYO Mr. J. L. Carvajal, 514 Mr. R. W. Sesler, 515 Mr. D. E. Deese, 515 Mr. J. B. Leverton, 515 Mr. D. A. Dechman, 515 Mr. G. F. Tacquard, 515 date P. O. BOX 471, TEXAS CITY, TEXAS 77590 July 12, 1974 subject VCM Levels The various chromatographs for monitoring VCM exposure in the production units have now been in operation for a long enough period (with the exception of the solvent unit at Texas City) that excursion levels as well as area TWA exposure levels should be pretty well established. In addition, the chronic problem points in terms of emissions, equipment, and procedures should be well defined. Accordingly, this is to request that these problem areas be documented and that an orderly program for reduction in emissions be formalized in writing. Priority will, of course, be given to eliminating those emissions that cause personnel to be placed in air masks. Also, please advise to the best of your ability the maximum 8-hour TWA exposure level for your unit. Actual Industrial Hygiene measurements might be of more value here than the VFA's. What level of excursions are showing up on the VFA's? Although we wouldn't knowingly expose anyone to over 50 ppm, are there enough readings over 50 that personnel might be exposed unknowingly? This data is aimed at "getting our ducks in a row" for the pending OSHA permanent standard that should be issued about September 5 to be effective October 5. e appreciated. MEE/ebm ^rC-'ZL--^l--------M. E. Eisenhour UCC 090700 i ffffijl INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS RCD. 9/ UC U*?2 !/t- PLANT MGRS. F!! 'S I*. O. BOX 471, TEXAS CITY, TEXAS 77S90 to (name) Mr. M. E. Eisenhour COMPANY location TEXAS CITY PLANT oate July 16, 1974 copy to Dr. A. B. Steele, NYO Dr. N. L. Zutty, NYO Mr. D. L. Goris, 515 Mrl R. W. Greenwood, 515 Mr. D. D. Robinson, 511 Dr. W. R. Manning, 511 jMr. J. T. Tannos, 515 Mr. R. W. Sesler, 515V Mr. R. L. Frantz, 515 Mr. K. E. Ross, 515 Mr. J. F. Dodd, 511 Mr. C. E. McConnell, Jr,, 511 Mr. F. L. Keller, 515 Mr. D. R. Reem, 515 Mr. W. P. Reeves, 515 Mr. D. L. Engle, 515 Mr. W. E. Burndrett, 519 Mr. G. M. Everitt, HO subject Vinyl Chloride in Texas City Plant Vent Stream_____________ Thanks or your letter of July 5. We will seriously consider VCM recovery from the Suspension Unit and Amines Unit vent streams. We will have to incinerate these streams even with VCM recovery scrubbing systems to avoid HC1 plume problems. Our main effort is directed toward installation of an incineration system ahead of the May 31, 1975 state deadline. Evaluation of VCM recovery by butyl acetate absorption is in progress now and will continue as a separate and parallel effort; but without the critical May 15 deadline. A snapshot of our current thinking is to incinerate the two streams in existing, idle Dowtherm boilers. A small absorber/stripper system at the Suspension Unit can probably be justified. VCM recovery of the ucc 090701 2- - Amines Unit stream will be more difficult to justify as the volumes are lower and the many impurities could cause problems. We will keep you in touch on our progress. Let me know if you disagree with our approach. /cs D. A. Dechman UCC 090702 Id: " r cc: F rom Mr. D. L. Engle Date: July 17, 1974 Mr. D. A, Dechman Mr. M. E. Eisenhour Mr. R. L. Frantz PLANT MGRS. FI! IS Mr. K. E. Ross Mr. G. F. Tacquard Mr. W. -R.-van der, HppyptUJ^-B--Leu&rton/lX-Heese p. W. Sesler Re: OSHA Citation Vinyl Chloride July 15, 1974. S-2219-88-74 Area 3280 Region 6 Current status is as follows: Copies have been provided to Ken and Bob for posting and all recipients of this note have a copy of the citation or have a copy routed to them. Ken and Bob will have the responsibility for follow-up and communications on planning August 22, 1974 and abatement January 22, 1975. t UCC 090703 Ui. DEPARTMENT OF LABOR rr. ~i U. S. DPJtRiNNT Ot US! OCCilPAiIONAi SAFETY AND HEALTH AOMliUSIHAIlUH 2320 LA BRANCH. ROOM 2118 HOUSTON, TEXAS 77004 L PHONE: (713) 226-5431 fTbr Union Carbide Corporation |2' ATTNs Mr. D. L. Ehgle, Plant Mgr ' Chemicals and Plastics Division 1 p o Box 471 ! Texas City, Texas 77590 CSHO NO. S-2219 AREA 3280 DSHA'l NO n ab ,-4 REtAlON 6 run. rr rm r Subject: Citation(a) for Alleged Occupational Safety and Health Violation^) An inspection of a place of employment has revealed conditions which we believe do not comply with the provi*.inns of the Occupational Safety and Health Act of 1970, (29 Ufl.C. 661 et teq.). The nature of such alleged violation^.) is described in the enclosed dtation(s) with references to applicable standards, rules, regulations and provisions ol' the aid Act. These conditions must be corrected on or before the date shown to the right of each alleged violation therein. The Act requires that a copy of the enclosed citation(s) be prominently posted "in a conspicuous place upon receipt" at or near each place a violation referred to in the citation occurred. It must remain posted until all violations cited therein are corrected, or for 3 working days*, whichever period is longer. A sufficient number of copies of the attached citation(s) should be prepared to permit posting in accordance with the requirements of the Act. The Act provides for penalties for violation of the posting requirements. You are hereby notified, or will soon be notified, whether or not penalty(ies) will be proposed as a result of the cited violation(s). You have the right to contest any or all parts of either the citation(s) or the proposed penalty(ies) before the Occupational Safety and Health Review Commission. The Review Commission is an independent agency with authority to issue decisions regarding citation(s) and proposed penalty(ies). If you do contest, you should submit a letter to the Area Director at the address shown above within 15 working days* after receipt of the certified mail notice regarding proposed penalty(ies). If you fail to contest within the 15 working day period, the cilation(s) and the penaity(ies) as proposed, shall be deemed to be a final order of the Review Commission and not subject to review by any court or agency. If an employer contests the citation, the abatement period specified therein does not begin to run until the date of the Commission's final order in the case PROVIDED the employer initiated his contest in good faith and not solely for delay or avoidance of penalties. You have a right to request a discussion with the Area Director concerning any results of the inspection (abatement dates, citations, penalties, etc.). Please direct correspondence to, or call, the Area Director at the address shown at the top of this letter. A request for an informal discussion cannot extend the 15 working day period allowed for filing a notice of contest. Therefore, a request for an informal discussion should be brought to the attention of the Area Director prior to the end of the 15 working days allowed for filing a notice of contest, preferably as soon as possible. An employee or representative of employees may file a notice (letter) to contest the reasonableness of the time stated in the citation for the abatement of the alleged violation(a). Alleged violations that are not contested shall be corrected within the abatement period specified in the citation. A followup inspection may be made for the purpose of ascertaining that the employer has posted the citation(s) as required by the Act and corrected the alleged violations. Failure to correct an alleged violation within the abatement period may result in further proposed penalties for each day the alleged violation has not been corrected. Timely correction of an alleged violation does not affect the initial proposed penalty. Correction of alleged violations which have an abatement period of 30 days or less should be reported in writing to the Area Director promptly upon collection. Reports of corrections should show specific corrective action on each such alleged violation and the date of such action. On alleged violations having an abatement date of more than 30 days, a written progress report should be submitted each 30 days. The progress report should detail what has been done, what remains to be done, and the time needed to fully abate seen such violation. When the alleged violation in fnlivabated. the Area Director should be so advised? ^ ' '" ' The Act provides that whoever knowingly gives false information is subject to a fine up' to $10,000, imprisonment up to 6 months, or both. If you wish additional information, you may direct such request to the undersigned at the address shown above. *Und*r th* Occupation*! Safety and Health Act, the term "Working Day" mean* Monday* through Fridays but doas not indud* Satur days, Sundays, or Federal Holidays. 3. Cttstion(s) BndossJ Quantity Pagas m ^^ ^ pr nr w w y ^np Lfc u i-t. La licet WtUful lUpastad 4* Notification of Proposed Penalty mntneed SI Yas No U5. Department of Labor by Area Director B. ft SWwA /.jd'-THOMAS T. CURRYfl 1/ Date .Till y 15,^ l# 74 1 | oshacc Mv. tm. 1172 UCC 090704 a tk