Document danvQL99MpdedkVYjzQ1b5VM6

Form: 17G6D \f Akron, Ohio T<~> D/0020, B/5-H ' ORGANIZATION CORRESPONDED Date December 13, 1966 Attention Mr. Wc E. McCormick___vmm Welland Plant. \ T.fitter 12/9/66Subject cc: P. B. Mason R. A. Woodrow F. R. Hoddle Thank you Tor your letter and the accompanying report by Mr* Modrell. We agree that further testing is necessary. We were somewhat startled to see such high figures. As you may recall, the flame ionization meter readings averaged 33 ppm VC1 in the polymerizers and 6 ppm on the floor. The tests conducted by Mr. Wahl of the Department of Labour averaged less than $0 ppm,supporting the flame ionization meter results. It would therefore seem advisable to conduct additional tests,preferably by an alternate method. It has been observed generally that the readings tend to in crease during the cleaning period due to VC1 being liberated as the polymer is scraped loose. This is not the case with your readings as you have indicated, and it may be necessary to have more sophisticated testing prior to entry. We trust that the test results from the other samples taken will .be made available. We are particularly interested in the concentrations of other components. December 28th should be satisfactory for Mr. Modrell1s ftext visit. I expect personally to be on vacation; however-, Mr. Julius Nagy will be able to provide all necessary assistance. The Customs broker that we use at the Peace Bridge is J* C. Wilson, but'I am advised that it will not likely be necessary to contact them. A declaration of the instrument should be all that is necessary. We will be happy to make reservations for Mr. Modrell at the otel. D. A. Brooks bd/ 25816020 BFG44850 I!s<- I h < bn ok of this hoot. for your reply if possible Welland, Ontario f D.A. Brooks Akron-D/002O-B/5 12/9/66 1 am enclosing a copy of the report of the studies Mr. Modre 11 recently at your Plant la the polymarizers. The results that ve found were considerably higher than ve bed hoped for and 1 do not believe will very veil rapport our argument for the removal of the sentinels. We should Tfttra additional studies, as Hr. Modreil has suggested, in an attempt to try to determine the relationship of tine of ventilation and quantity of air removed with respect to the vapor concentrations in polynerleers. If agreeable with you, we would Ilka to do this beginning December 28. Hr. Modreil will again cocao to your Plant and remain there for one or two days. This tine he pill have with him an instrument to bring Into Canada and then return It to the States on his departure. We will prepare the necessary Import papers here, but 1 would appreciate your advising no as to what broker he should see at the B&ace Bridge. Ha will be driving Into* Canada the morning of December 28 and will crofts at the Peace Bridge. Ha Will need a room at the Calm Croft Hotel for the nights of December 28 and 29. If for any reason these arrangemonts are not satisfactory with you, please advise me promptly and suggest an alternate time. cc: F.B. Macon R.A. Woodrow F.R,, Boddle WS1/JS Enclosure W.E. McCormick 25816021 BFG44851 ( Report of Visit to Welland, Ontario Plant __November 9 & IQ, 1966 Several air samples were obtained in and around FVC polytaericer6 at the Welland Plant. Determination of vinyl chloride concentration in these samples was to serve as a basis for evaluation of personnel exposure dar ing poiycleaniug operations. X. ftecomraeadafcIona A, Perform additional sampling and evaluation of the atmosphere inside polymariters, prior to and during cleaning* Determine relationship between exhaust time (ventilation rate) and vinyl chloride concentration in the polymerise?. B, Current practice of relying on a me?o explosiveter reading before entering a polymerise? for cleaning dee* net afford an adequate measure of actual Vinyl chloride concerntxatioa in the range of industrial hygiene concern, It ie not recommended that the practice he discontinued at tine present time, but as a final result of the current study a more reliable index will be developed to indicate time of safe entry late the polymer&zets* II* Results The following table presents data on vinyl chloride concentrations at the various Locations sampled* CTVo additional samples not analysed at the time of this report will be reported later.) Vinyl Chloride Concentrations in Bolvaerlaars and Room Atreoephere Sample Description ___________________. . .. Vinyl Chloride, mm Midway Through Start tfff . Cleaning Cleaning _ In Urge Poly No. 20 101EP-F21 124. 124* Ini small Poly Ho. Id 101KP-F21 671. 205. In large Poly Ho. 27 iQZEB-Fl In large Poly Ho. 22 401C3 208, 203. \, 154. 254. In large Poly Ho* 3 121 (paste) 682. 116. General Atmosphere - 2nd Floor General Atmosphere - 3rd Floor 28. 56. Significant concentrations of vinyl chloride ware detected in all the polymerirers both before cleaning started and at a time approximately midway through the cleaning period. In two instances, at the start of cleaning (Polys Nos. 3 & 16), the recommended maxicitna allowable concentration 25816022 BFG44852 of 500 ppm was exceeded. However, the second sample In these polys.. n After cleaning bad progressed, showed vinyl chloride concentra tions well below the recommended maximum af 500 ppm. It would appear from these data that the Initial time of entry Into the polymerizers, following a period of ventilation, may present the most critical aspect of possible overexposure of personnel Co vinyl chloride vapors. A more detailed Investigation Is necessary to relate tine and rate of exhaust ventilation in the polymerleers to vinyl chloride concentration. RKH/Js 12/6/66 Robert t? Modrell 25816023 BFG44853 ) i' ( B.F. Goodrich Chemical Company Inter-Organization Correspondence To Location Subject W. E. McCormick Akron Date From November 29, 1966 E. G. DeCapita egd-51-66 Analysis of Atmospheres,from Vinyl Polymerizers The atmospheric samples you obtained from polymerizers at the Welland, Ontario Plant were analysed by gas chromatography. Quantitative results for vinyl chloride in the atmospheres are tabulated in the attached Appendix. The analyses were made using a gas chromatograph equipped with a flame ionization detector. The results were quantitized by relating sample peak areas to a graph obtained by analyses of standard samples prepared in your laboratory. A cross-check will be made when a standard sample now being prepared by Air Products Company is received. E. G. DeCapita cc: R. J. Wolf C. H. Lufter Technical Council C.T.F. Fil4 (3) dw BpG44854 Appendix X Vinyl Chloride Content of Polymerizer Atmospheres Sample Identity Poly Sample #1 Poly Sample #2 Poly Sample #3 Poly Sample #4 Poly Sample #6 Poly Sample #7 Poly Sample #9 Poly Sample #10 Poly Sample #11 Poly Sample #12 Atmosphere Sample #5 Atmosphere Sample #8 ppm Vinyl Chloride 124 124 208 154 671 205 205 254 682 116 28 56 25816025 BFG44855 Form ; 1706D /, INTPf 1?GAN1ZATI0N CORRESPONDENCE N7 November 2gf 1966 To___ AkronAction Mr. R> w* Modrell ^Vom Welland Plant r LetterSubject___________________________________________________________________________ _____________ cc : J. Nagy In reply to your letter of November 21st, the following is the information you requested* As- VOsT 1. The only calibrated volume we have on these vessels is the volume to the lip of the manhole. This is ji-yROfiLand IjjjTOO cu.ft* respectively. The volume including the top head is perhaps %% in excess of these figures* i/.zr^ /A 4 2. The capacity of the exhaust fan is 2,500 cfm. It is possible 7/^7 to have four exhaust hoses connected at once giving a mini- v mum air flow of 625 cfm* '' 3* There is no stipulated exhaust time before a cleaner enters the poly but rather the poly is exhausted until there is a zero reading on the explosimeter* 4* The average cleaning time, i.e., the time spent in the poly is lj.0 minutes for small polys and 60 to 75 minutes for large polys. The air samples were mailed to Avon Lake on November 21st. We trust they have arrived safely. W are looking forward to receiving the results of your tests and bd/ 25816026 BFG44856 Use the back of this sheet for your reply if possible . ) November 21, 1966 Mr. D. A. Brooks B.FlGoodrich Canada Limited Welland, Ontario Dear Mr. Brooks: In my discussions with Mr. Nagy during the recent visit to your Plant, I neglected to make note of certain Information for which ve now have need. Specifically: (i) volume of the large and small polys, (2) ex haust rate, or airflow, through exhaust hose in poly, (3) recommended exhaust time before cleaner initially enters poly, (4) average clean ing time for large and small polys. We have- not yet completed our work on the sample* but hope to do so shortly. In checking with Mr. DeGapat*, at our Avon- LqkgfcPlant, I found that he had not received the two or three additional* samples you were to mall him. Have these been delayed at . the Plant or possibly held up enroute? / i\ *., - ' . -v- ^ I wish to express my thanks, to both you and Mr. Nagy, for a pleasant and successful Plant visit. Your consideration is sincerely appreciated. Very truly yours. The B .F.Goodrich Company RWM/wlm cc: W.E. McCormick R. W. Modroll Department of Industrial Hygiene and Toxicology 25816027 BFG44857 Form : 1706D A kr on To___ D/0020, B/gK ( TBn ORGANIZATION CORRESPON( NCE bate Oc-tober 28, I966 Att.p.ntifin w- 3. McCormick T'rnm V'elland ?iar,t r Letter. cc: Subject P. B. Mason R. A. Woodrow POLYMERIZ3R TESTING Thank you for your letter of October 24th setting out the date for starting polymerizer testing. Reservations have been made for Mr. Modrell at the CairnCroft Motel, 2400 Lundy*s Lane, Niagara Falls, Ontario for November 8th and 9th. There are no advance preparations that we can make relative to bringing the test tubes through Canadian Customs. How ever, we do not feel that there will be a problem with a value of $2.00. Kr. Modrell should simply tell the Customs official why he is entering Canada. If there is any problem, which we doubt very much, it will be in taking the samples back to the UnitepP^bates. D. A. Brooks bd/ P.S. - It has occurred to me that I am scheduled to be in Akron on November 9th. I have, therefore, advised Mr. Julius Nagy, our Safety Man, of Mr. Modrell1 s visit so that he may be of assistance to him. Mr. Modrell should ask for Mr. Nagy when he arrives. DAB 25816028 BFG44858 Use the buck of this sheet for your reply if possible . WeIland, Ontario f\ David A. Brooks Akron-D/O020-B/5=H 10/24/66 Ve are nov prepared to proceed with the teats la the polyoerizers that we discussed several weeks ago. If agreeable with you, I will have Hr. Robert V. Modrell, an Industrial Hygienist In my Department, be at your Slant the morning of November 9. It may be desirable for him to remain on the 10th. Be will be driving and will arrive at Niagara Falls In the late afternoon of November 8. 1 would appreciate your arranging & ifoom for him at Niagara Falls* Ontario, and advise me of the location. Be will be bringing with him for use at your Plant, approximately two dozen small rubber-stoppered test tubes, having a total value of about $2.00. What procedure should ha use In bringing these Into Canada? He will be bringing then back here for analysis. cc: P.B. Mason R.A. Woodrow WEK/4* V.E. McCormick 2581SG29 Report of Visit to the tfelland. Ontario Plant September 1 * 1966__________________ I visited tbs Bellacd Plant for tbe purpose of evaluating manu facturing operations free the standpoint of Industrial health hazards, 1 mie^d these operations with the Plant Manager, Hr, David A. Brooks. % found no uneootroUsd existing health hazards. Plans sere node with Hr. Brooks to return to tbe plant by Eovetaber X end perfora atoaspberie studies inside of polymerise** for tbs purpose of obtaining proper data to pre sent to the necessary proving! govaraass&al personnel and* hopefully, obtaining rescinding e the present standby orders fee poly cleaners* vsi/oe 9*2fi-66 *. S. HeC^bide 25816030 BFG44860 ellartd, Ontario D.A.Brooks Akron-D/O02Q-B/5 -H 9/15/66 1 think 1 can explain the variance between Dr. Hastrocaitteo ` e comments to ate regarding the permissible level for vinyl chloride and the statecent that he made earlier this year. The American Conference of Goveruaeatcl Industrial Hygienists* of which Dr. Mastronaatteo is an active member, bad proposed, begliming In the Fall of 1965, that consideration bo given to reducing the level from 500 ppm. The ACCIH is the group that establishes, on its own volition, threshold limit values each year at its annual meeting in Hey* Although these ore values of a professions! association only* in Actual practice they have become, 1a many of our States end X suspect in your Provinces, official or quasi, official standards, frinarity through the efforts of the #XS& end during ay tern os President of it, we were able to slightly modify the procedure for establishing these values so that ACG1H nor circulates, usually in the Fall of the year, & list of values that it hes under consideration. to change mad invites consents from professional industrial hygienists end toxicologists. Shi1ft X have no access to any of the consents that sere received on vinyl chloride, X do know that AGGIE decided at its Hay, 1966 eating net to presently safe* any nsodificatioa in the level. X feel cure that Dr. a#tvQmateo*s present position has bees influenced by this decision, bat X suspect that at the sseeting that your personnel had with bin earlier this year, be was persuaded that AGGIE would sot effect a change. Fe shall proceed with the tests in your potyaBriwt,ai 1 have indicated, as soon as possible. X cannot promise definitely that we can. do it before the first of November, but va will sake every effort. cc: Dr. K..V. Yohe E.B. Mason R.A. Woodrow F.R. Soddle UEM/ja V.E. McCormick 25816031 3PG44861 BFG44862 Welland, Ontario David A. Brooks Akron-D/0020-B/5-H 9/6/66 Following my visit with you on September 1, I discussed the vinyl chloride question with Dr. Kastromatteo by "phone. X had planned to personally meet with him sometime Saturday September 3, but inasmuch as the weather turned quite rainy* X decided not to stay over in Toronto. Dr. M&strcmatteo feels that there Is a good chance of oar demonstrating safety in the polyroerizers sufficient to obtain a rescinding of the stand by order. He was very much in favor of the approach that 1 suggested--to develop considerable data on actual vapor concentrations in the polymerizers correlating this with ventilation*and from all of these data develop a specific proposal to-the Ontario Department of labor. Be indicated that he personally feels that the present requirement is overly severe, but it will require some real spade work to have it rescinded. Bo also stated that the Province of Ontario has not reduced the permissible level of vinyl chloride for 8-hour exposure and that it still remains at 500 ppm. therefore. It Is my recommendation to you that we proceed as you and I discussed. I will plan to have one of my personnel spend several days at' your' plant collecting the data. X would prefer to wait until about the first of November to do this, inasmuch as we axe currently quite busy and it will also be necessary for us to obtain some instrumentation for the proposed measurements. If you are in agreement with this, please let me know Imme diately and we will make our plans accordingly. cc: R.V. Yohe KJt. Woodrow F.R. Hoddle WEM/je W.E. McCormick 25816033 BFG44863 f> 2 r\ ! Inside the reactors, in vh ich the air was found by the other method to contain 22 to 68 ppm of vinyl chloride, one six minute simultaneous sample was taken with the Kitagawa Tubes at each location at which the five samples listed in the table were taken. In each case, the Kitagawa Tubes showed only a red stain approx imately one-sixteenth of an inch long and no green stain was detected. These tubes do not appear to be ai fficiently sensitive for a quick measurement of vinyl chloride in the concentrations found in the reactors in the present study. MH. Wall11 ,N 25816034 BFG44864