Document eD2QyoEVEVNp7mMVdbeKkvYe

PVC AT PAINE5VILLE A. Compliance Efforts to Date J&L JP* -v.' : V-< In 1965 new Federal legislation was enacted which made many new requirement* of industry. A* a result, we were required to install water pollution control equipment and to begin planning for air pollution control equipment. Soon afterward the OSKA Act of 1970 required that we survey and begin to up grade to new federal standards all aspects of the workplace. By the end of 1973 we were operating a primary water waste treatment plant, had made estimates for several alternative schemes for compliance with boiler emission regulations, had conducted a detailed plant survey for compliance with the OSHA Act of 1970 and had made considerable progress toward correcting the deficiencies determined by this survey. in January 1974 the vinyl chloride problem gave a new set of concerns whicti we had to add to a continued effort to satisfy those items mentioned previously, we quickly became expert in the terminology and equipment for monitoring levels of VC in our work areas and in the breathing zone of each of our employees. Preliminary equipment and process modifications were made and protective equipment ordered to reduce employee exposure. An educational program was begun to convince our employees that precautions were necessary for protection against both VC monomer and PVC dust. We attempted to gain a rational perspective in the discussions Involving NflOSH, OSHA and our own people regarding the true nature of the hazards of these materials. The OSHA hearings provided very little additional insight into the technical nature of the problem. We tried, at this point, to guess where the permanent atandard would be set and made engineering studies on what we would do to bring the plant into compliance. It was quickly apparent that major capital expenditures would be necessary. At thl*^point, we decided we must conduct our compliance program on two levels. First, we should do those things which could be done within the scope of the plant technical, production and engineering departments capabilities to reduce high exposures in the quickest way possible. The other level Is full compliance to the standard, which requires con siderable capital commitment and, therefore, should be treated ee a long range rather than short range consideration. PLAINTIFFS EXHIBIT IijdhAMV * c. Jr " >* . ' Table A lists those major iteme which we have completed to date which are a significant contributor to reducing employee exposure to VCM in the Painesville Plant. The approach was to males an estimate of the Intent of the regulation and then determine how we could most effectively comply with that in tent. It was necessary to determine for ourselves the best estimate of intent since conflicting and often changing inter pretations of VC regulations were all we had to go by. At all times our primary objective has been to reduce direct employee exposure. Where we could not reduce the exposure sufficiently by engineering controls, the use of respirators was required for certain operations. As funds became available from UNIROYAL with the improving economic picture in 1975, we obtained various allocations to make operational changes. The effectiveness of the program is reflected by the reduction in the average build ing levels from something greater than 20 ppm in early 1974 to leas than 10 ppm today. (See Table E). The average build ing level on a weekly basis covers many excursions to a much higher level during that period of 168 hours. The week of 4/20/75, for instance, shoved a peak of SO ppm in Bldg. 107 and a peak of 39 ppm in Bldg. 117. At present a mask is re- required anytime there is an exposure greater than 25 ppm of VC. On April 1, 1976,a mask must be worn anytime exposure is greater than 5 ppm. Most of our employees would be wearing a mask ths majority of thsir workday aftsr April 1, 1976. A major blow was the OSHA Inspection of May 5, 6, 6 7, 1975. The citation issued as a result of this inspection''indicated that it was the expectation of OSHA that full compliancs with the regulations should have been achieved by April 1, 1975. Conversations with the area director indicated that the changes made to that point and the engineering planning for compliance by April 1, 1976 were only mitigating circumstances in con sidering the penalty for not being in compliance as of April 1, 1975. | c k> $ co Not Included in the engineering and operational approaches were the studies made of the current state of each employee's health. These studies, which found no health effect directly traceable to VC or PVC exposure, nevertheless produced traumatic experiences for many people as various other health problems were uncovered by the detailed studies made. We conducted a prograarfor educating the employee and the employee's family as to the reported hazards, ths intent of our compliance pro jects and the significance of the various reports that ware producing local headlines. -r*-.. . *." ' * ^.r , r: rf In summary, we attempted every step of the vay to October 1, 1975 to provide for the health, well-being and employment of ail of our plant employees as best we could with available resources* We feel that this short term program was suceeasful in light of the many problems. The long term program to maintain a viable operation for the future is a separate subject. B. f/anq Range Projects SC 5k :.y While fixing leaks, installing exhaust systems at key areas and providing air breathing respirators attack the random high exposure levels, significant reductions to a consistent low level in operating areas require major changes to our facilities, A list of these major projects is included as Table B. Briefly, the major areas are reduction in the frequency of opening vessels, stripping of the slurry before it leaves the process areas, highly sophisticated monitoring systems, greatly increased ventilation, and major expenditures to reduce losses of VCM to ambient air. With the exception of a minor benefit from reductions in VC losses, none of these installations will contribute anything -to operating effectiveness or production economies. In fact, we must anticipate productivity losses from these Installations L>. as well as major Increases in energy related and maintenance related operating costa. We have employed the resources of UNIROYAL engineering personnel at all levels as well as several outside engineering firms in estimating the facilities required for compliance. To the extent possible, we have participated .* in information exchange within the FVC industry. The answers * available through this last source Indicate that there are no easy, cheap solutions. They confirm that effective answers can be had only by major capital expenditures. - C. Capital Not Related to VC ' ` Many capital projects are estimated for the foreseeable future which are either indirectly related to VC or unrelated to VC usage in this plant. These are shown in Table C. .. The additional steam requirements for operation of the equip ment required for compliance to OSHA and EPA regulations for VC will necessitate the addition of a third coal fired boiler. This is above and beyond the operation of the two coal fired and one oil fired boiler presently in use. This, in turn, will require better coal handling facilities for the increased volume of coal. Our insurance carrier has proposed numerous changes which must be made to the PVC plants in order to obtain future coverage. These changes will provide no operating economies; Much of the glass lined equipment in the Area 1 plant is near the end of ite useful life. If we are to continue that oper ation, this equipment must be replaced within the next 5-7 years. . Summary 1, Prior to October 1, 1975, the Painesville plant had spent about $1.1 million in capital and operating expense specifically for compliance with the VC standard. (Sum of "to date" columns from Table A and Table B.) ,, 2. Additional capital of $3.2 million is estimated for OSHA compliance along with $3.1 million for CPA com pliance. These are minimum figures since the results from ths changes can only be estimated. These changes will add at least $2.1 million to the annual operating cost of PVC manufacturing. (These sums are from the appropriate columns of Tables A 6 B.) 3. If a commitment is made to bring the plant into com pliance and continue to make PVC, an additional increment of $6.0 million will be needed to sustain this operation. Within about 5 years, major process equipment must be re placed at a cost of nearly $15.0 million. 4. The estimate of capital needs for the Painesville plant, if PVC manufacturing continues, is $12.3 million for compliance with known requirements and an additional $15.0 million for equipment replacement. > 5. Postponing any of the above will only add to the cost of doing it since costs will continue to rise. 6. An estimate was made that a new plant to replace the Area 1 plant could be built for $35-40 million. . 7. in view of these estimates as well as tha demand for capital money for other commodities, it was decided to tentatively announce the shutdown of the PVC plant. It la our conclusion that had tha OSHA permanent standard been set at a maximum of 10 ppm rather than 1 ppm we might have provided the necessary plant changes to continue operation. However, with the evaluations that haversince been made regarding alternative uses of available capital, we conclude that even a 10 ppm maximum does not now present a viable condition for UNIROYAL to continue the manufacture of PVC resins. 10/30/75 s e s ire m vt * ,1 iv V TABLE A STATUS OF PROJECTS AND'ACTIYTTICS AS OF OCTOBER. 1975 PROJECT RUPEER A* 1 -2 DESCRIPTION ' ii Respirators, Air Purification & Distribution leak Detection and Leak Correction TEiXnPnErNrDrETDn capitxt--etphtse 52.3 22.0 61.4 -3 Personnel Monitoring and Record Keeping 56.3 -4 Monitoring and Warning Systems for 107,117,414 23.5 -5 Operator Enclosure, Bldg.414 (AR-5222) 15.9 6 Exhaust System for 3 Screeners (AR-5339) 11.6 -7 Exhaust System for W M Centrifuge A Hopper 7.2 -6 ' " Extend A-1 Air Compressor Intake Stack $.8 -9 VC Medical Testing 22.1 -10 Breathable Air Compressor <AR-5317) 31.1 . -11 -12 Portable Reactor Evacuation (AR-S343) Remove Bldg. Siding - Ventilation Improvement 3.8 18.8 29.5 -13 Revisions to Seals-VCH Compressors 414 37.3 -M Reactor Modifications 107 A 117 33.3 RAcDoDuITrmIONrsAwL CAP 1TAC TtRBUIC EXPI 26.4 91.0 75.0 93.7 20,5 14.7 gQsez nan 91.6 340.3 V,./ 93.7 227.6 'W- TABLE B v MAJOR PROJECTSniHPTWVtAY OR PLANNED PROJECT HUMBER, DESCRIPTION B-1 Solvent Cleaning of Reactors (AR-5195) -2 Ventilation of Bldg- 414 (AR-5319) -3 Recovery Compressor Seal Improvements (A-l) >4 Ventilation of Bldgs. 107,117,10a -5 Tank for Hl-Boller Disposal Compliance Program OSHA (AR-P-5357) 6 " Item 1 Experimental Stripper -7 " Item 2 Ventilation of 107 t 117 Control Rooms >8 * Item 3 Ventilation at Bagging Stations -9 Item 4 Replace Recovered Monomer Pump -10 * Item 5 Fetterolf Valves for 414 Reactors -11 * Item 6 Reactor Evacuation -12 Item 7 Transfer Piping - 414 -13 "'-Item B Better Breathing Air -14 11 Item 9 Additional Area Monitoring -15 Canister Program for 5-25 ppm Range -16 Purge VC Unloading Lines -17 Control VC Release 0 Unit Operations -IB Paracrll 020 Finishing Ventilation 19 llarehouse Ventilation -20 PVC Slurry Stripping EPA -21 Gas Holder and Collection Systems (2) " -22 Stripping of Hater from Process Area " -23 Auxiliary Power for Process Area * -24 High Pressure Alarms for PressureVessels" -25 Activated Carbon for all Vents " -26 Required Sampling Program " 10/27/75 l LQ9ZZ T0 CAPITAL $M TO DATE 604.5 24.9 - 11.5 5-- .4 4.2 2-5.0 7-_ .1 -- - 662.6 CAPITAL $H ANNUAL ADDITIONAL OPER. EXPENS* 560.0 175.0 88.0 848.0 7.0 _ - 45.0 1.2 50.2 157.0 100.0 685.0 127..9 66.0 74.0 80.0 63.0 1245.0 1200.0 200.0 16 7.0 119.0 100.0 15.0 45.0 14.0.0 206.0 13.2 210.0 80.0 784.0 200.0 150.0 55.0 6173.3 1683.2 i PROJECT MUMPER C-l -2 -3 *4 -5 -7 TABLE C ADDITIONAL CAPITAL FOR FUTURE OPERATIOMS MOT DIRECTLY RELATED TO VC 0ESCR1PT10H Remove Particulate* Boiler 2 (w/PYC Operation) Install 3rd Coal Fired Boiler (w/PVC Operation) Upgrade Coal Handling Facilities Insurance Requirements for PVC Plants Replace A-l Poly Area (5 Year Project) Secondary Hater Haste Treatment Tertiary Hater Haste Treatment (by 1983) CAPITAL $M 495.0 1500.0 480.0 3500.0 15000.0 ? T 20975.0* s9; TABLE P SUMMARY OF FUTURE WEEDS j CAPITAL HEEDED AHHOAL OPERATORS ! gas maamm. $H -...TOEffa-tlL-- ! it u Projects from Table A 93.7 227.6 .i i 2 Projects from Table B 6,173.3 1.883.2 3. Projects from Table C 20,975.0 I 27,242.0 2,110.0 I f J 68SC ItJfl WEEK BEGINNING S-S-74 BIDS. 107 PROCESS 22 117 PROCESS 18 108 FINISHING 14 414 PROCESS 22 41S-FINISHING 14 10/28/75 TABLE E AVERAGE WEOirtCH LEVELS 4-20-75 12 14 12 10 9 The huge vinyl plastics industry, including Uniroyal, became the center of controversy last January when vinyl chloride was linked to a rare liver cancer, Shis article describes what we are doing, and have done, to protect employees working with this gas. V. f ^4' \ \ URL 16809 On Jan. 23, 1974 B.F. Goodrich announced that vinyl chloride gas might cause angiosarcoma, a rare liver cancer found in some of its employees. Since then 26 cases of this disease were uncovered in former and present vinyl chloride workers throughout the world. None involves a Uniroyal employee. Nevertheless, we immediately became engaged in a massive war waged to reduce employee exposure to these ftimes. Whirling fans. . . air respirators . . . gas analyzers . . . medical tests all became weapons in that war. A colorless gas, vinyl chloride is the basis of the world's most widely-used plastic, polyvinyl chloride. PVC can be manufactured into almost anything from underground pipes to phonograph records. "There's no real substitute for PVC," says Martin J. Kleinfeld, commercial planning director fbr the Chemical Division. "It's extremely versatile. It can be fabricated into many textures and used in many different ways." Uniroyal makes all its vinyl chloride in Geismar, La.? converting it Into PVC at Painesville, Ohio. Our share of this industry is very small -- just two percent of the nearly five billion pounds of PVC pro duced each year in the United States. URL 16810 -2- Nevertheless, that's an important two percent, with PVC we make such articles as Naugahyde, waterproof footwear and vinyl clothing. Tightening Government Standards Since the Goodrich announcement, the Occupational Safety and Health Administration (OSHA) has set out to sharply reduce vinyl chloride exposure. The original standard set in the I960'a was 500 parts gas per one million parts air. Today's standard, effective January 1, 1975 says: "No employee may he exposed to vinyl chloride at concentrations greater than 1 ppm averaged over any 8-hour period, and no employee may be exposed to vinyl chloride at concentrations greater than 5 ppm averaged over any period not exceeding IS minutes." "Nobody knows exactly at what level vinyl chloride becomes unsafe," adds Dr. Walter Harris, our corporate toxicologist. "We do know, however, that the cases of angiosarcoma discovered so far were in people exposed to high concentrations for long periods of time. Although there's no such thing as a risk-free environment, we are reducing that risk." During 1974 we have invested much money, time and energy into doing just that. Our goal has been two-fold: to maintain the continued health and safety of employees and to preserve their jobs in face of a serious problem. The greatest thrust has been at Painesville, since PVC plants usually experience the largest concentrations of vinyl chloride fumes. There we have waged a four-pronged attack involving medical surveillance, plant monitoring, engineering controls and protective equipment. t te a n a n -3Testing Employees Last May we began examining all Painesville employees and recent retiress, This evaluation consisted of a personal medical questionnaire, physical exam and five blood tests designed to spot abnormal liver conditions. Roughly 12 percent showed signs of a liver abnormality. "You would find almost the same percentage if you tested the general population," explains Dr* J* Dexter Forbes, corporate medical director. "Liver test abnormalities can be caused by many things, including too much liquor days and weeks before." Most of these employees passed a second screening held two weeks later* Those who did not went through more elaborate tests conducted by the plant physician. Dr* William Fletcher. A few still had persistent and unexplained abnormalities- They went through an extensive medical examination by a private liver specialist, who found a variety of causes-- but none related to vinyl chloride. "After nine months' review, we haven't found a single case of angiosarcoma among our employees," adds Dr. Forbes- "That also includes former employees whose medical records were examined for cause of death." This entire medical surveillance program has become a way of life at Paineaville- All employees will be rechecked at least once a year. Measuring Exposure Levels The plant monitoring program is designed to measure employee exposure to vinyl chloride. This involves taking air samples. URL 10812 -4- Several Painesville employees carry small plastic bags into which a pump pushes air from wherever the employee works, these samples are then injected into a gas chromatograph, which measures the amount of vinyl chloride in each bag. From this information a "job profile" can be put together, indicating typical exposure levels for each joh. Two other employees, carrying devices similar to geiger counters, make a daily check at 42 selected points around the plant, these devices automatically indicate any vapors present. Another instrument, a portable gas analyzer, is set up at various locations to take continuous readings. It produces a graph showing fluctuations in the vapor level. All vapor levels are recorded and posted for employees to read. "It's very important to let our people know what they*re exposed to and what we're doing about it," says plant manager Ben Leach. "They've been very willing to work with us to solve the problems." Reducing Employee Exposure Once an area of high exposure is identified, technicians and engineers immediately try to reduce or eliminate emissions. Since the monitoring began in April, this engineering control pro gram has reduced vinyl chloride concentrations by 60 percent. "We've done a lot in a short amount of time," Ben adds, "and we're doing everything we can to reduce it even more." In some instances, the solution was simply fixing or replacing a leaky valve. Other spots required better ventilation. Wall sections were removed and fans installed to increase circulation. -5- Major engineering changes are also taking place in cleaning the " vessels where vinyl chloride is converted into PVC resin. 'Traditionally, this has been the area of highest concentration of fumes. Since some vinyl chloride escapes polymerization, steps have been taken to reduce these vapors before the vessel is opened. The insides are steamed down, washed out and aired with high-pressure water hoses and vacuum pumps. Another project uses chemical solvents as cleansing agents. "That could be the ultimate answer," says methods engineering supervisor Jerry Brumbaugh. "If we find one that works wall, we could pipe it into the vessel and keep the lid closed most of the time." Even with improved cleaning techniques, however, some PVC sticks to walls and pipes inside the vessel. A tank cleaner then climbs inside the reactor and scrapes off those deposits, which can retain some unreacted gas. During this operation, workers use respirators to protect them from the sweet-smelling fumes. Protecting Employees Under the new standard, workers exposed to vapor levels above the allowable limit must be supplied with a respirator. Until 1976, however, they may choose not to wear that device a long as the level doesn't exceed 25 ppm. So far 180 air-supplied respirators have been issued to Painesville employees. These full-face masks are connected by hose to a filtering canister. Vessel cleaners, for instance, are breathing fresh, clean air from outside the building while chipping away at a reactor's insides. URL 16813 --6-- Other protective equipment includes coveralls and gloves, which reduce skin contact with the gas. Similar programs are being conducted at Geismar, although exposure levels there are considerably less because roost employees work outside* Gas emissions, which are very rare, quickly dissipate into the atmosphere* Exposure levels in fabricating plants almost always are well within OSHA standards* Nevertheless, they are all being monitored to make certain employees are not exposed to levels above the permissible limit* "We recognise, and accept, our responsibility to protect the health of all of our workers," says Martin Kleinfeld. "We feel that these programs are doing just that*" URL 16314