Document dDRLyna4kn61yZxMNZx5y2QD6

Interoffice Communication To Frnm 3te suhjeci D. A. Kuhn P. L. Fetzer February 3, 1978 Dockmen VCM Exposure Summary conoco) This report summarizes the VCM exposure during 1977 to the refinery employees working at the VCM ship loading facility. It should be emphasized that the refinery employees wear fresh air protection during each job operation and whenever the operator works the VCM loading dock. It has been the practice of the VCM plant to monitor each VCM ship loading as thoroughly as possible in order to pin-point problem areas. The normal testing conducted includes the following; hose connection, hose unblinding, hydroquinone addition, cargo sampling, vent recovery and dock shack work areas, hose disconnect and reblinding operations. In addition, 8-hour monitoring is to be conducted which overlaps many of the individually monitored loading operations. The Ship Loading Summary Report for 1977 is attached which summarizes by ship name and loading dates, the VCM exposure for each operation tested during the loading operation. This information was separated by job operations, tabulated by various VCM exposure levels for complilation in table I. The work time associated with the loading hose operations ranges between ten and 50 minutes. The fifteen minute VCM exposure limit (5 ppm) was selected as the most applicable criteria to determine if over exposure had occurred. If the exposure had exceeded the 5 ppm VCM value for the duration of these hose operation tests, the individual would have exceeded the exposure limit for a given 15 minute interval. The work time associated with the hydroquinone addition requires from one to three hours to complete the operation, hence the 8-hour exposure limit ( 1 ppm ) was selected to determine over exposure. Likewise the work conducted in the vent recovery and dock shack areas are of long durations (4 to 8 hours) and the 1 ppm limit was also used in these classifications. The over exposures are summarized in table II. The data indicates that over exposure occurs between 20 and 50 percent of the time on all job functions. The exposure for the longer duration test indicate that between 10 and 38 percent exceed the 1 ppm 8-hour limit. The data shown in table I but taken from another source was evaluated on a time-weighted average (TWA) basis. The same criteria used in evaluating the data in table I will be applied to that information found in the 1977 VVC O0Om 61 D. A. Kuhn Page 2 Personnel VCM Exposure Data Log. The resulting data has been summarized in table III and shows the dockmen exposure at several VCM levels and time breakdowns. The over exposure distribution for the TWA data is shown in table IV. The total number of testing of less than one hour (146) agrees quite well to the total number of loading hoses operation testings (142) and the over exposures values also agree quite closely, 45 and 46 ppm respectively. It should be pointed out that the totals in table I and table III differ by four. This difference is due in part to different people being responsible for the two source documents. It is of concern that the rate of over exposure/violations is so high. It is apparent that the major portion of all violations involve hose operations i.e., unblinding or blinding lines, and connecting or dis connecting loading hoses. It could quickly be assumed that the work practices are inadequate; however, an examination of the attached Ship Loading Summary Report reveals a large difference exists in the actual VCM exposure for the same job operation. This data indicates that it should be possible to reduce the vinyl concentration to the lower exposure levels for each operation. The work practices used in all loading operations were desinged to minimize the VCM exposure. Based on the data, one can assume that the procedures were followed when the exposure levels are low and conversly not followed when the exposure levels are high. Other possibilities as to the cause of high exposure certainly exist, i.e., bad or leaking valves aboard ship. These causes would be pointed out by repeated high values for the same ship throughout the year. This does not appear to be the case as indicated by the data in table V and further demonstrated by a close examination of the attached Ship Loading Summary Report. Examination of the data in table IV (the ships selected represents the ones most frequently loaded) indicates a significant spread in the VCM exposure level for each operation for each ship listed. To me, this further indicates that work practices are not followed to the same extent each time. During August and part of September, several changes were made at the VCM loading dock which should have reduced the VCM exposure to the dock employees as these were a source of vinyl emission. However, little change was noted in vinyl exposure results as indicated in the Ship Loading Summary Report. One area of dosimeter testing where a serious problem exists is with the eight-hour personnel testing. Considering the size of the progression unit of the refinery personnel working at the dock; the frequency and duration of the ship loadings, the total number of 8-hour personnel dosimeter testing should number about 70. The total number of 8-hour or for that matter above four hours only totaled 33, approximately one-half of the expected number. This indicates that there were employees working with the vinyl loadings who were not monitored quarterly and may not have had any 8-hour testings conducted. I do not feel that it is our responsibility to police the refinery personnel to insure they are complying with the statuates of the OSHA VCM Exposure Standard. We do however, inform the dockmen at each VCM loading as to what VVC 000019362 D. A. Kuhn Page 3 dockmen has worn an 8-hour monitor during a given month. This information is listed on a sheet which also requests the specific job function testings to complete for the loading. This information is taken to the dock when the shift supervisor inspects the ship prior to its loading. I trust the data presented concerning the dockmen VCM exposure will provide you with the necessary information to discuss with your counterpart in Refining. I am at your service if I may be of further help. P. L. Fetzer bv' ( v -WVH-GLF-HTM-RDG WC 000019363 TABLE I DOCKMEN VCM EXPOSURE JOB FUNCTION TESTING DISTRIBUTION (A) Job Function Testinq Hose Operation:(B) Connection Unblinding Blinding Di sconnect Hydroquinone:(C) Addition Vent Recovery Area (C) Dock Shack Area (C) and other 8-hr Tests "PPM VCM 0-1 15 10 10 6 13 4 28 86 NUMBER TESTED 1 -5 5 - 15 over 15 Total 15 3* 4* 37 19 4* 6* 39 9 5* 14* 38 12 6* 4* 28 6* 1* 1* 21 0 00 4 3* 0 0 31 64 19 29 198 Information taken from 1977 ship loading dosimeter data report These operations normally require less than 1 Hour - Assume 15 minute limit of 5 ppm (C) These operations normally require 1 to 8 hours - assume 8 hour limit of 1 ppm * Oyer exposure VVC 000019364 TABLE II DOCKHEN VCM EXPOSURE JOB FUNCTION TESTING VCM OVEREXPOSURE DISTRIBUTION(A) Jab Function Hose Operations: Connection Unblinding Blinding Disconnect Hydroquinone Addition: Vent Recovery Area: Dock Shack Area and other 8-hr tests No. Below Limit 30 29 19 18 13 4 28 141 No. Over Exposure Limit 7 10 19 10 8 0 3 57 No. Tested 37 39 38 28 21 4 31 198 % Over The Exposure Limit 18.92 25.64 50.00 35.71 38.10 0 9.68 (A) Data from table I VVc 0000^365 TABLE III DOCKMEN VCM EXPOSURE TIME-CONCENTRATION DISTRIBUTION(A) PPM Time (Hours) VCM 0-0.5 0 - 0.25 16 0.25 - 0.5(B) 10 0.5 - 1.0(B) 3 1.0 - 4.0(C) 8 4.0 - 8.0(C) 27 64 0.5-1.0 7 8 4 4 1 24 NUMBER TESTED 1.0-5.0 5.0-15.0 31 17 5 *9 *4 66 *11 *5 *3 0 *1 20 -ever 15 *10 *10 *6 *2 0 28 Total No. by Time Range 75 50 21 23 33 202 % by Range 31 .68 11.88 32.67 9.9 13.86 (A) Data taken from 1977 Personnel Dosimeter VCM Data Log (B) Exposure limit in this time frame was assumed to be the same as the 15-minute limit (C) Exposure limit in this time frame was assumed to be the same as the 8-hour limit Exceeded VCM exposure limit VVC 000019366 TABLE IV DOCKMAN VCM EXPOSURE TIME-OVEREXPOSURE DISTRIBUTIONA) Time-Hours 0 - 0.25 0.25 - 0.5 0.5 - 1.0 1.0 - 4.0 4.0 - 8.0 PPM Limit 5 5 5 1 1 No. Below Limit 54 35 12 12 28 141 No. Over Exposure Limit 21 15 9 11 5 61 Total No. by Time Range 75 50 21 23 33 202 l Over Limit 28.00 30.00 42.86 47.83 15.15 30.69 (A) Data is taken from table III WC 000019367 TABLE V DOCKMEN VCH EXPOSURE EXPOSURE BY SHIP ON HOSE OPERATION TESTING Ship Name Coral Isis Epsilon Gas Delta Gas Georgia-Pacific Barge Times Loaded 3 4 6 Hose Connect High Low 21.2 3.1 1.83 0.9 4.24 0.20 17 400 .01 PPM VCM Remove Blind Hiqh Low 2.1 1.58 32.97 1.35 4.61 0.28 Insert Blind Hi qh Low 6.0 0.12 54.5 i.n 3.96 0.71 150 0.01 118 0.01 Hose Disconnect Hiqh Low 993 6.0 204 0.94 566 2.03 205 0.01 VVC 00001 936a