Document baQBQ5e7KeE4vK34j9eG0wmkZ

^Goodrich ro J. W. Gressler POM ________ R. C. Lockemer subject INTER-ORGANIZATION CORRESPONDENCE FIELD POINT OR D6PT & BLDG. NO ALGC__________________________________ FiaD POINT OR DEPT & BLDG NO ALGC -- Environmental Affairs OSHA Progress Report - October, 1982 (DATE YOUR LETTER ! DA IE THI5 LETTER 11-17-82 1. Summaries of personnel and area monitoring conducted during the month are presented in the attached tables. 2. Three employees from Estane B/433 were treated in the dispensary for irritation of the eyes, ears and nose from bagging K-739 powder produced at ALTC. All three employees were wearing toxic dust masks, shower caps and mono-goggles when the exposure occurred. The K-739 was originally brought back from ALTC in Fiberpak drums and dumped into eight Tote bins at the B/437 loading dock. Latex employees dumping the material wore nuisance dust masks and did not experience adverse effects. Dusting during the operation was minimal. The tote bins were then brought into B/433, inverted and emptied into a bagger. The K-739 is very fine and, instead of flowing freely out of the bin, "burped" out creating a dust problem. It appears that the severe dust problem combined with the hygroscopic nature of K-739 caused the employees' symptoms. The operation was shut down by the foreman when the exposure problem surfaced. The tote bins have now been transferred to ALTC. A Board of Review was held to identify the problems and establish requirements to prevent future occurrences. A report is forthcoming. 3. Employee exposure to copper oxalate during PVC compounding was measured. Both the weighman and the Banbury operator in B/438 received exposures below detectable limits. 4. Long term area monitoring for MDI was conducted on Estane Line 4 during normal operation. Samples taken at the mixer, Berringer and pelletizer were below detectable limits ( < 5 ppb). Since the sampling pumps were stationary and represent maximum exposure levels near the line during normal operation, operator exposure should be well below the allowable of 20 ppb based on an 8 hr. TWA. DISTRIBUTION: B. R.Welch W.E.Horton C. Bayard J.R.Shellenberger D. D.Quester J,C-Meek E.C.Gilbert T.J.Biskupich iSr. B. Ka t z enraey er D.J.McDonald D.J.Barnicki J.C.Ritz T.S.Bialke H.Waltemate J.S.Kiel-Ped. D.J.Gargas Dispensary BFG46591 2G146001 2 5. Short-term area monitoring for MDI was conducted on Estane Line 3 during a shutdown. The sampling pump was located in the area of maximum exposure near where the MDI heat exchangers are Mblown-outM with nitrogen. The monitoring result was below detectable limits. 6. Attached are two corrected pages for the September, 1982, OSHA Progress Report. Please replace the original pages for September with these pages. RCL/bp Robert C. Lockemer zm m oz BFG46592 SUMMARY OF PERSONNEL MONITORING Parameter Allowable Cone. 8 hr. TWA Oct 198 2 No. of Samples Month Avg. Cone. No. Above Allowable Year-To-Date No. of Avg. Samples Cone. No. Above Allowable VCM* Plant B/432 B/438 B/449 u/451 B/452 B/454 B/455 B/457 B/4S8 B/459 B/461 B/462 B/463 B/464 B/465 B/466 B/468 /471 1 ppm 35 . 75 5 272 2.41 81 * 2 9 2 3 .23 .18 .13 .08 2 .18 9 2.12 2 .24 6 .61 4 1 1 9 23 3 17 7 4 6 121 1 5 51 1 22 .02 .59 .15 .15 .15 .36 .21 .70 4.57 .02 .15 1.58 .29 .09 1 .17 2 rc C: O o 2 68 60 17 Includes all long term monitoring with and without tasks. BFG46593 SUMMARY OF PERSONNEL MONITORING Oct,_________, 198 2 Parameter Allowable Cone. 8 hr. TWA No. of Samples Month Avg. Cone. No. Above Allowable Year-To-Date No. of Avg. No. Above Samples Cone. Allowable Dust Total 10 mg/m3 Respirable 5 mg/m3 N^rse 30/5 85 dBA Metals Sb Cd Cr Pb Asb. Silica Organatin Selenium Benzene 500 ,ug/tn3 200 aig/m3 500 .ug/m3 50 /ug/m3 2 Fiber/qc .14 mg/m** 100 mg/m. 200 ,ug/nr* 1 DDIQ Area Personnel Monitoring 107 48.66% 85 db 1 VC1 % Actual < 1 (No.) Month % 12 66.38 6 .22 1 .08 2 5.6 2 4.0 1 0.1 4 Year-to--Date (No.) % B/451 B/46Z B/463 B/464 2 9 2 6 (Breakthru Frequency = 4 (Tandem Samples /*/" t = 35 117 ?ny 100% 56% 100% 83% 9 121 5 51 78% 50% 100% 67% BFG46594 1 1 : i > 1 PPM LONG TERM TEST NAME DATE DF TEST PPM RESP. JOB CODE EMPLOYEES DESCRIPTION OF WORK AREA M. Alten D. Collins P. Lewis R. R. Woodings J. Kemer 10-4 10-21 10-11 10-11 10-18 12.90 Yes 1.24 Yes 1.22 Yes 2.03 No 2.74 No 630 630 100 750 100 Strainers Strainers -- Foreman - Manhead leak HRC's Leak detection outside of building 461 - - .461 .. 461 461 ~ 464 Copper Oxlate MDX MDI AREA TE STING 9-29 ^53 4 900 Weigh 10 batches vqg/m 70211 White 120 4 650 Banbury Opr. 70211 White 120 9-17 PPB <4.88 <5.11 <5.05 ---- ---- Mixer Line 4 Berringer Line 4 Pelletizer Line 4 10-18 PPB *7.33 Shutdown #3 Line Blowing out the lines 438 438 477 433 S009VI9Z Envir. - 4-c BFG46595 7-21-82 GC / SUMMARY OF PERSONNEL MONITORING September , 198 2 Parameter Allowable Cone.. 8 hr. TWA No. of Samples Month Avg. Cone. No. Above Allowable Year-To-Date No. of Avg. No. Above Samples Cone. Allowable Dust Total 10 mg/m^ Respirable S mg/m^ *T"ise 85 cLBA Metals Sb 500 >ug/m^ Cd 200 Jig/m* Cr 500 yug/m^ Pb 50 /ng/m3 Asb 2 Fiber/^c Silica .14 mg/m- Organatin 100 mg/m Selenium . Benaane 200 Mg/m --1 ppm- . ... . , 1 1 Area Personnel Monitoring 107 48.66 85 db 1 219.5 1 -(LI- - VC1 % Actual < 1 (No.) Month % 12 66.38 6 .22 1 .08 2 5.6 2 4.0 1 0.1 4 Year- to-Date (No.) % B/451 B/461 B/ 463 B/464 1 11 -- 1 100 64 -- 100 7 112 3 45 71 50 100 64 BFG46597 NAME G. Mucha K. Wahl D. Collins P. Lewis 7. Weigand > 1 PPM LONG TERM TEST September DATE OF TEST PPM RESP. JOB CODE EMPLOYEES DESCRIPTION OF WORK AREA 9-16 266.00 yes 9-24 9-24 9-14 5.86 no 2.12 no 1.32 no 750 600 630 100 Poly entry - found leak in botton valve. Came back out - repaired Aired out' poly before reentry 461 Charge oj>erator 461 B.D.'s recovery 461 Foreman 461 Building 43$ Lead Test 9-17 219.5, &m Toxic dust mask 900 Weighing-70 batches Mat: - * 87302 Blk. 295 Weighing involved 4 hrs. of the 6"3vr. "test . 438 80091^9?: Envir. - 4-c BFG46598 7-21-82 B.Welch/R.Lockemer WO*-* T.S. Bialke_____ FiffLO poi(T or oCR*>FT,^tNr'a oi_a*. t*q. Akron__- D/0Q2Q. 5-H Respirator Usage during VCM Railcar Line Disconnecting I do not agree with your recommendation contained in your 1/14/83 letter (attached) for making the usage of the airline respirator optional while disconnecting lines from VCM railcars. Suitable respiratory protection is needed when disconnecting VCM railcars because there is a potential for exposing an employee to very high concentrations of VCM if one of any number of things go wrong. Your monitoring shows that under normal conditions, if everything goes according to procedure, the probability of an employee being exposed to VCM above 10 ppm is remote. However, if something should go wrong, the magnitude of the resulting exposure could be overwhelming. If it can be guaranteed that under no circumstances will more than a few milligrams of VCM be released if something goes wrong during a railcar unloading, I would agree that respirators are not needed. 'But we are in the field of accident and illness prevention and there is a possi bility (however remote) that thousands of pounds of VCM could be released in a short period of time. In such a situation, the area G.C. would not alert an employee soon enough that he needs to put on a respirator; conceivably an employee already in a respirator may be the only thing between the A.L.G.C. plant and disaster. The "tripping" hazard can be eliminated by requiring the tank farm employees wear a Scott air pack. If the Scott is too ' cumbersome, pther SCBA's are available. Bio-Marine makes a light weight, highly mobile unit. v cc y P.. B . . /H _W n-i H.Waltemate/T.Montalbano J.Gressler T. S. Bialke ^ n. <T. o o BFG46599 R. C. Lockemer E.B. Katzenmeyer, Jr. .... Avon Lake. G.C. f , * , fv Akron - D/0020, 5-H 9-21-83 August Progress Report I noted that you experienced 32% breakthru on vinyl chloride samples during August. This seems high and suggests continuation of this problem. Would appreciate your thoughts on this matter and a chance to review your data. Have you implemented the lower detection limit concept yet and are connec tions on sampling tubes tight? v T008iT92 BFG46600