Document ea4kmyYO4717Q2RGJ9gVRZvy

APPENDICES TO PRELIMINARY REPORT ECONOMIC IMPACT STUDIES OF THE EFFECTS OF PROPOSED OSHA STANDARDS FOR VINYL CHLORIDE Contract No. L/A 74-1G7 Mr. James Kallenborn Acting Director of Planning, Evaluation and Research OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION U . S . DEPARTMENT OF LABOR MNWA Building Room 110 1726 M Street N.W. Washington, D. C. 20036 ' FOSTER D. SNELL, Inc. Hanover Road Florham Park, New Jersey 07932 August 23, 1974 s ; ' :. , ; t' *' . l i ^ '> s ^; < t! > I ( | ^ ^ BOR 0 0 0 7 7 4 t APPENDICES AB- DETAILED PROCESS DESCRIPTIONS AND PROCEDURES \ EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER VCM PLANTS C - ECONOMIC DETAILS D - PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE E - MONITORING EQUIPMENT F - MEDICAL SURVEILLANCE OF EMPLOYEES / t BOR 0 0 0 7 7 5 SHHnaaooHd qnv SNOudiHOsna sshoohj amivxaa V XIQNHddV 1 BOR 0 0 0 7 7 6 APPENDIX A ' DETAILED PROCESS DESCRIPTIONS AND PROCEDURES This Appendix presents design details, discussion of critical technological aspects and operating procedures regarding polyvinyl chloride (PVC) manufacture. A list of exhibits follows: Exhibit A-l presents the receiving, storing and distributing of vinyl chloride monomer (VCM) as it reaches the Union Carbide Corporation. Monitoring for the vinyl chloride concentration is noted. The unloading mechanism along with the storage parameters are also noted in this exhibit. The special features that are provided to minimize personnel exposure is summarized herein. . Exhibit A-2 presents a flow diagram of tank car unloading. This schematic is of advanced practice using spot ventilation. Exhibit A-3 deals with reactor design showing a technological overview by Snell. Exhibit A-4 provides a comparison of Conoco's large reactor PVC technology with historical reactor technology. Exhibit A-5 presents a detailed diagram of an older polymerizer design. .` . Exhibit A~6 presents a Pfaudler Glasteel Polymerizer, a modern polymerizer design. Exhibit A-7 is a typical schematic for polyvinyl chloride operator movements and plant layout. Exhibit A-8 presents a flow diagram for the PVC emulsion process. ^ I BOR 0 0 0 7 7 7 A-l V. EXHIBIT A-l(l) USDOL/OSHA N RECEIVING, STORING AND DISTRIBUTING VINYL CHLORIDE MONOMER-AFTER UNION CARBIDE L DESC RIPTION Union Carbide Corporation receives vinyl chloride at South Charleston, West Virginia in 48, 000- gallon tank cars shipped from Freeport, Texas. Due to the size of the car only five tank cars are unloaded / per week in an open area used for unloading various chemical tank cars. Monitoring this operation on three consecutive c.ar unloadings yielded the following results: Date June 28, 1974 July 2, 1974 Operation Hookup Car Disconnect Car Hookup Car Disconnect Car Time Required minutes 20 15 19 8 Sample Time minutes 20 15 19 8 Concentration ppm 4 15 1 6 <1 July 3, 1974 Hookup Car Disconnect Car 22 5 22 8 5 <1 000778 EXHIBIT A-l(2) USDOL/CSHA Vinyl chloride monomer is received by railroad tank car into a storage area located outside the boundaries of the plant proper. It is unloaded into a refrigerated sphere from which it is pumped to the consuming units, * Unloading is accomplished by equalizing the pressures in the tank car and the storage sphere and then applying vaporized vinyl chloride to the vapor space in the tank car. This provides positive suction / pressure on the pump which transfers vinyl chloride to the storage sphere. After all the liquid has been removed from the tank car, a compressor pumps vinyl chloride vapors from the car to a condenser and the condensed liquid is then pumped to the sphere. The vapor pressure in the car is reduced to 5 psig, and the car is then returned to the vinyl chloride supplier for refilling. The vinyl chloride in the sphere is maintained under its own vapor pressure (maximum of 29 psig) at a miximum temperature of 15C by the use of refrigeration, with vinyl chloride serving as the ( refrigerant. BOR 0 0 0 7 7 9 EXHIBIT A-1(3) USDOL/CSHA Transfer pumps and piping transfer vinyl chloride to the consuming units as required. 2. SPECIAL FEATURES PROVIDED TO MINIMIZE EXPOSURE OF PERSONNEL General (1) The receiving and storage area is remote from the consuming units. t (2) A high degree of automation is employed, so that there is little need for operators to be near the tank car or the sphere while unloading proceeds. (3) Nitrogen is not employed as a pressurizing medium, so there is very little venting to rid the system of inert gas during unloading or loading by the supplier. (4) Safety valve discharges and other vent streams are piped to a remote, elevated loaction for discharge. (5) All pumps handling vinyl chloride are provided with mechanical seals to minimize leakage. (6) Vent and drain valves not required for normal operation are maintained in closed position and plug ged with pipe plugs. BOR 0 0 0 7 8 0 Tank Cars EXHIBIT A-1(4) USDOL/OSHA (7) The tank cars are provided with dip tubes for top discharge only. The dip tubes are provided with excess-flow check valves; if the flow exceeds a pre-established value, the valve automatically closes. (8) The tank cars are provided with a tape liquid-level device, which eliminates the need for venting vinyl chloride in determining the liquid level in the car. Sphere (9) The sphere is located in a scperately diked area, with sufficient capacity to contain the entire contents of the sphere. / (10) Lines leading into the sphere are provided with check valves,-and discharge lines from the sphere are provided with excess-flow check valves. (11) The sphere and associated piping is insulated for 15C maximum temperature; the insulation is such that it will not decompose if subjected to fire. (12) The sphere is provided with water spray protection. (13) The sphere is equipped with a refrigerated vent condenser (-20C) through which inert gases are I vented to the atmosphere. BOR 0 0 0 7 8 1 4 Scavenging System EXHIBIT A-l(5) USDOL/OSHA (14) A scavenger compressor system is provided to remove vinyl chloride from lines or hoses which must be disconnected during loading or unloading operations. When scavenging is completed, such lines or hoses are purged with nitrogen to a remote vent stack. / Bor 000782 Source: l Testimony of Richard T. Hughes, Vice President, Union Carbide Corporation, before OSIIA, on Vinyl Chloride Occupational Exposure Standard, July 5, 1974. 0.000080 262 0.99 Lbs VC/Lb Prod' PPM VC Lbs VC/Hr EXHIBIT A-2 USDOL/OSHA TANK CAR UNLOADING - ADVANCED PRACTICE USING SPOT VENTILATION y To Storage Tanks 20.000 Gal or 30,000 Gal Unload Pump 180 GPM Vaporizer Pump ^ Vaporizer Wall Fan (Cl002) 0.000066 Lbs VC/Lb Prod 7 PPM VC 0.821 Lbs VC/Hr >1 rrQ EEvvaacuation Compressor Source: Snell industry interview BASIS 12,400 LBS/HR PVC y To Storage Tanks BOR 0 0 0 7 8 3 EXHIBIT A - 3(1) USDOL/OSIJA s SNELL'S REACTOR DESIGN AND CLEANING OVERVIEW * 1. REACTOR DESIGN CAN SIGNIFICANTLY REDUCE CHANCES OF EMISSIONS OF VCM Recent changes have been incorporated to the design of reactors which will contribute in several ways to minimize chances of emission. (1) The Trend To Larger Size Reactors Diminishes The Number Of Leakage Points * In early designs, 1947-1067, the reactors were kettles, usually glass lined, ranging in size from two to five thousand gallons.- The bulk of the equipment still in use falls in this category. However, new designs have been developed together with manufacturing methods and the most recent equipment incorporates reactors which can be as large as 18, 000 gallons if glass lined and even 35, 000 gallons (Shinetsu) if stainless. Glass lining techniques, transportation restrictions, and heat transfer con siderations will limit the size of glass lined equipment to 18, 000 gallons. Thd 35, 000 gallon stainless reactors may represent the heat transfer limit, since internal cooling by coils and other similar surfaces cannot be used on account of dead spaces and other points of potential formation of undesirable agglomerates, hard to clean. The factory cost of an 18, 000 gallon glass lined reactor is $350, 000, including agitator and drive. The cost of a stainless reactor (clad construction) of 18,000 gallon capacity should be competitive. < BOR 0 0 0 7 8 4 EXHIBIT A - 3(2) USDOL/OSHA Exhibit A - 4, following this Exhibit, summarizes the advantages and devel opment needs of large reactor technology. . Design steps such as elimination of the manual charging of minor ingredients, the possible use of ball and plug valves, reduction of the number of flanges can aid in limiting leaks from peripherals. (2) The Newer Design Bottom Entering Agitators And Baffles Can Significantly Reduce Possible Monomer Leakage / In the older design, shown in Exhibit A - 5, following Exhibit A - 4, the agi tator usually enters the reactor from the top, so that the seal around the shaft is containing the high pressure VCM atmosphere. High Pressure Dual Seal de sign is used, but since the sealing depends- in large part on the oil pressure in the ring, a problem may arise in case of power failure. The same problem arises (with lesser severity) with the top entering baffles. Seal deterioration around the baffles has been observed in several instances and creates a particularly insidious problem. A newer design, shown in Exhibit A - 6, following Exhibit A - 5, incorporates bottom.entering agitator and baffles; thus the seals are containing liquid. It | has the double advantage of making the containment easier and to give visual warning of leakages. i BOR 0 0 0 7 8 5 EXHIBIT A - 3(3) USDOL/OSHA . Fufthermore, the newer design of the bottom entering seals used in glass lined reactors incorporates a pre-seal in which water at a pressure slightly higher than in the reactor is deliberately allowed to leak in at about 15 g.p.h,, thus precluding the possibility of leakage to the outside. For the baffle installation, a new flush glass-to-glass seal has been developed; this design could not be used with the conventional nozzle entering baffle. . In the larger size reactors, baffles are used as an auxiliary cooling surface, adding an extra 25 sq. feet of heat exchange area to an 18, 000 gallon reactor. / (3) The Indirect Effects Of Bottom Entering Baffles And Agitator May Be More Important From The Standpoint Of General VCM Levels In The Plant The main reason which prompted the design change was the attempt at eliminat ing, or minimizing, the "Bath Tub Ring" effect. This is the formation at the gas liquid interface of agglomerates which cling to the solid surfaces and tend to build up to considerable size, sometimes break ing out in multipound chunks. This phenomenon is particularly bothersome at the comparatively low clearance between baffles and wall. With bottom entering baffles and agitator these effects are virtually eliminated since there is no hy-j draulic dead space for the agglomerates to form and grow. The reduction or elimination of formation of agglomerates lowers the frequency of strainer clean ing and thus significantly minimizes a source of potential exposure. Pipe clogging is less frequent. Perhaps the main advantage is that the need to open the reactor for inspection and cleaning is greatly reduced. i BOR 0 0 0 7 8 6 EXHIBIT A - 3(4) USDOL/OSHA 2. MANUAL REACTOR CLEANING IS A MAJOR CAUSE OF EMISSION PROBLEMS AROUND THE REACTOR While the most obvious problems associated with manual cleaning of the reactor are the possible emission of VCM upon opening the manhole and the exposure of the man entering the reactor, these do not consitute major engineering difficulties. Adequate venting proce dures either are in force or can be implemented to significantly limit exposure to VCM upon opening the manhole. Personal protective devices eliminate the risk of exposure of the man entering the reactor. t But these are two more serious and long-lasting effects of the manual cleaning operation: the deterioration of the manhole cover sealing surfaces due to unavoidable chipping from repeated opening and closing . the possibility that during hand cleaning operations a sight glass may be chipped leading to subsequent bursting under pressure Several methods have been proposed to reduce or eliminate the need to enter the reactor for cleaning. (1) Deterioration Of The Manhole Cover Seal Is A Significant Cause Of Leakage ( Bor 000787 Every time a manhole is opened in a glass lined reactor, there is a chance for the glass covering the outer part of the manhole nozzle to become chipped. EXHIBIT A - 3(5) USDOL/OSIIA In'addition, there is a possibility of deterioration of the gasket. A combina tion of a faulty gasket and a chipped manhole lip is a frequent source of a sig nificant leak. Until recently, little attention was paid to this feature due to the comparatively high ppm level considered acceptable around the reactor. (2) There Is A Design Improvement Which Will Reduce The Risk Of Deterioration Of The Manhole Cover Seal Recently designed glass lined reactors are equipped with an Inconel overlay which is fused to the glass lining in the vertical portion of the nozzle. / This design eliminates the chances of chipping the glass lining and permits a tighter tongue and groove metal-to-metal seal which, combined with a com pressed asbestos gasket, insures a much more durable and positive seal. Un fortunately this design cannot be applied to older reactors unless they are sent to the factory for reglassing. The turnaround time for this can be 60 weeks. Replacing the conventional manheads with Lenape's can alleviate leaks around the manhole. (3) Another Danger Area Is The Rupture Of The Sight Glass I During manual cleaning it is often necessary to free the nozzles holding sight glasses from accumulated solids. In the process sight glasses may be accident-, ally chipped, which may induce an undetected hairline crack resulting in a burst ing of the sight glass when the reactor is pressurized. BOR 0 0 0 7 8 8 EXHIBIT A - 3(6) USDOL/OSIIA Another source of sight glass rupture is the removal of the sight glass for cleaning. Upon re-installation, uneven tightening of the bolts is known to have induced stress in the glass with the result that when tiie pressure stresses were added the sight glass burst. A novel design incorporated in the late models of glass lined reactors eliminates this possibility. 3. IN SITU CLEANING METHODS WIFE PROVIDE A SOLUTION TO THE LEAKAGES CAUSED BY FREQUENT OPENING OF THE REACTORS / The ideal solution would be to eliminate the need for opening the reactor. Complete in situ cleaning would provide this solution if it could be made thorough enough. Several methods exist or are under development and a brief review of their characteristics is given here. (1) Historical Changes Have Already Reduced The Frequency Of Cleaning In all reactors involving a change from a liquid to a solid phase, such as encoun tered in PVC production, there is a tendency for the solid to agglomerate and ad here to solid surfaces under certain conditions. This tendency is a function of: nature of the solid and liquid phase(s) 1 quality of the reactor surface presence of stagnant zones in the reactor "Bath Tub Ring" effect BOR 0 0 0 7 8 9 < EXHIBIT A - 3(7) USDOL/OSHA It has been observed that in the course of the development of PVC production from its beginning in the 1040's to the present, two changes have contributed to reduce the frequency of cleaning: a trend to larger reactors has reduced the tendency for the agglomerates to bridge, say between baffles and side formula changes seem also to have resulted in a lower ten dency for the solids to agglomerate The result has been that the cleaning frequency has gone down from once every ^ batch to once every four or five batches. Yet this still may constitute an un acceptable frequency. . Furthermore, with the trend to large reactors (10, 000 gallons plus), structures had to be erected in the reactor to allow for reaching the required areas (usually in the nozzles on the top cover and at the liquid gas interface). A development was the use of hand directed high pressure (up to 10, 000 psi) nozzles. This is in fairly widespread use. (2) There Are Two Basic Methods For Automatic Cleaning With Some Variants: Water Wash And Solvent Wash One method uses water under pressure and relies on the mechanical impact of high kinetic energy water particles. i BOR 0 0 0 7 9 0 There arc two variants of the water method: EXHIBIT A - 3(8) IJSBOL/OSIJA very high pressure low volume spray--a typical instance would be 6, 000 psi at 50 g. p. m. for a 5, 000 gallon reactor. Cleaning time is twenty minutes low pressure high volume spray--typically, for the same 5, 000 gallon reactor, 200 psi at 200 g.p.m. Cleaning time is twenty minutes By and large the problem with water consists simply in separating the solid poly mer from the water stream. In fact, for large volume applications, water re-use may be justified. The other method uses solvents. At present, there are several solvents in use: EDC, Tetrahydrofuran, M-Pyrol, and one as yet undisclosed from Hobintech. The solvent method has two variants: in one method the solvent is allowed to completely fill the reactor the other solvent method is the use of an automatically controlled solvent spraying | BOR 0 0 0 7 9 1 The main drawback of the solvent methods is the need to recover the solvent (they are quite expensive, on the order of $0. 50 to $1. 00 a pound), and to a certain ex tent it displaces the problem to the cleaning of the heat exchangers or other solvent recovery devices. This is a major reason for which proprietary rights and patents cover these methods. * O EXHIBIT A - 3(9) USDOL/OSHA (3) The Cleaning Methods Are Proprietary But Are Offered For Licensing At present there are several methods offered for licensing. Two of them are basically water methods: GOODKICII HRC High Pressure Water - the method involves the use of very high pressure, retractable, multi-directional water sprays; manual cleaning is required approximately after every ten batches ^ the equipment cost is about $100, 000 (one unit needed per reactor size class); there is a $50, 000 usage fee; believed to be non recurring the method drawback is that reactors have to be opened to install the portable equipment, causing deterioration of the manhole cover seal the time lag for the institution of this method depends on delays in construction of thet special ized equipment, and in acquisition of the ancil lary equipment, pumps, tanks, etc. It is esti mated at about G to 8 months 000792 i . ' FFAUDLER Low . Pressure Water EXTIIJ31T A - 3(10) USDOL/OSHA the method involves the use of a patented retractable nozzle assembly which is per manently installed in the reactors. Its ad vantage is that with twenty minutes of clean ing after each batch, at least twenty-five batches can be processed before another type of cleaning is required. An interesting variant is the use of solvent on, say, every twentieth cleaning. This is claimed to make it unnecessary to enter the reactor for otl/er than annual or semi-annual routine inspection the spray nozzle assembly is estimated to cost about $25, 000 ancillary piping and equipment varies widely depending on the number of reactors and such other factors as plant layout, etc. Probably $10,000 per installed reactor is a good approxi mate figure. installation delays may be on the order of (.0 to 12 months the cost of adding solvent-capability may double the capital investment costs BOR 0 0 0 7 9 3 i EXHIBIT A - 3(11) USDOL/OSHA The other proprietary methods involve the use of solvents: . STAUFFER EDT - the heart of the method is the solvent recovery unit. A drawback is that is is a soak method in which the reactor is completely filled. Turn around time for a 5, 000 gallon reactor is about three hours the required equipment involves essentially cir culation pumps, solvent storage tank ancj a sol vent recovery unit a license fee based on capacity entitles the li censee to flow diagrams, thermodynamics and energy data, operating manuals, etc, the cost of the recovery unit is said to vary from $75, 000 to $150, 000 depending on solvent hand ling capacity. This does not include the engineer ing costs nor the storage. For a 5, 000 gallons per year of solvent purification a total installed cost of $250,000 to $300,000 appears reasonable BOR 0 0 0 7 9 4 such an installation may require up to 2 years and significant shut downs of production facilities have to be anticipated American Chemical is believed to use the Stauffer * method with EUC as the solvent. This may be an interesting solution for integrated plants, where EDC is available GAF Process ROBINTECH Process EXHIBIT A - 3(12) USDOL/OSI1A this process uses a trademarked solvent M-Pyrol and retractable spray devices per manently installed on the reactor. The clean ing devices are installed typically in 4" noz zles. They retract behind a quick opening gate valve during reaction a problem with this equipment is that gate valves are not very reliable as closing de vices in presence of solids, so that leakage cannot be ruled out under pressure. The/de sign does not incorporate the elaborate seals required to contain VCM should the gate valve not close completely the costs of equipment are similar to those for the Stauffer process and subject to about the same installation delays this process has been announced in trade jour nals. Details are not known about it at present l BOR 0 0 0 7 9 5 Source; Snell Analyses EXHIBIT A-4 (1) USDOL/OSHA COMPARISON OF LARGE REACTOR TECHNOLOGY WITH HISTORICAL REACTOR TECHNOLOGY-AFTER CONOCO A new Conoco PVC plant based on the largo reactor technology came on stream in 1071 in Oklahoma City, Oklahoma. Conoco also operates a small reactor PVC plant in Aberdeen, Mississippi, and the following data are related to small reactor plants based on our experience at the latter plant. Approximately 32 to 34 small 2200 gallon reactors arc needed to provide the same capacity that is obtained in 4 large reactors at Oklahoma City. This means that 8 times as many reactors must he charged, polymerizations contained, stri]>ped, dumped, cleaned, etc. The number of mechanical entities (valves, flanges, pumps, etc.) requiring maintenance (leak problems) is substantially loss in the large reactor plant, a strong positive factor in its favor. Moreover, most of the mechanical steps in the new plant are carried out by remote control while the operator keeps all phases under observation by moans or charts, schematic diagrams, lights, and closed circuit TV cameras. These comparisons' arc also based on consider a lions of the cooling water availability, product mix ana the particular chemical and engineering approach in use. I Most of the small reactor plants have been constructed with the reactors contained in buildings. Our large reactor plant has only a roof over the reactor building. The associated piping, instrumentation, etc. arc enclosed on the sides by a protective metal screen-like structure w])ich covers only about two-thirds of the vertical rise. Therefore, the reactor area is essentially "open air". The large reactor technology, when producing construction type resin, reguircs pcisonnel entry only about once every thirty days; in small reactors, entry for cleaning is about every 4 or 5 days. Reduced entry frequency is obviously pre ferred until the goal nf zero personnel entry can be achievrxl by .additional re search on "clean wall" jx?l tymeri y.ation formulations. Until that, time a combination of solvent cleaning followed by periodic personnel entry in the reactor to manually chip away jjolymer will be required. BOR 0 0 0 7 9 6 EXHIBIT A-4 (2) USDOL/OSIIA Our large reactor plant provides about a 98Z yield of PVC based on vinyl chloride rconomer charged whereas small reactor plant yield is only about 91 to 955.'. While the distribution of the yield loss is not fully defined, i/ti believe a significant reduction in atmospheric emissions is being obtained. In addition to tbe diffcicnees in product mix, this diJ ference in yield reflects the fact that fewer operational steps are required in large reactor technology which minimiy.es the loss of hnt'n solid PVC and gaseous Veil. This should provide a workplace with a lower risk for t.hc employee of veil exposure. Large reactor manpower requirements are approximately one half that of small reactors on an equal production basis. Two large reactors require two reactorrnen per shift. Sixteen small reactors, the number necessary to equal the production of two large reactors, require four reactormen per shift. On a per pound basis, large reaevors require 0.08-1 rcactormcn per million pounds per year while small reactors require 0.168. In view of what we believe to he positive advantages for large reactor plants, we plan to install additional large reactors to replace the small reactor sections of the Aberdeen plant when appropriate technology is available. At tlie present i. i me, large reactor technology is limited to a very specific range resins which find application in rhe construction industry. These types of resins do not have rigorous iequirements on several important PVC properties; c.g. fisheyes". Although higher quality resins suitable for wire and cable, calendering and other applications have been demonstratnd to bo technically feasible in our large reactor technology, significant: additional developmental of foil, will be required to denxanstrate production of these resins on a commercially piactical basis. To accomplish the goal of replacing our small reactors at Aberdeen and of providing resins required by the market, we believe that: the following is a very realistic timetable: BOR 0 0 0 7 9 7 ( EXHIBIT A-4 (3) USDOL/OSIJA ............... Basic R & D Program - 1 gear. ............... Engineering design and obtaining bids - 1 year ............... Plant construction and start up - 3 years Ibis engineering analysis indicates that 5 years are required to implement tech nology required to satisfy mar]:ct demands labile maintaining our employee VCM expose]e in keeping within our proposed standards. in the interim, wc plan to meet the proposed standards by restricting work practices (by use of protective equipment, etc.),until such time as wc are able to implement the replacement of str.a 11 xeactors wi th lai go rcactors. BOR 0 0 0 7 9 8 I Source: Submission to Docket Officer, Docket OSH-36, OSTIA, by R. W. Genwig, Vice President, Continental Oil Co. , June 27, 1974. * BOR 0 0 0 7 9 9 1 Source: Pfaudler Bulletin 1051, Glasteel Polymerizers 008000 HOS EXHIBIT A - 6 t ! i 1 f ?1 > | BOR 0 0 0 8 0 1 BOR 0 0 0 6 0 2 EXHIBIT A-8 USDOL/OSITA Source: Industry Interview by Snell. BOR 0 0 0 8 0 3 / APPENDIX B TM^URE_PATA^FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER (VCM) PLANTS ! APPENDIX B \ EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER (VCM) PLANTS This appendix presents exhibits summarizing the exposure data from a number of PVC and VCM plants. The appendix also contains a confidential inventory of PVC workers for 1974 (see Exhibit B-l), used for reference.purposes in Chapter III discussions of employment. An explanation of the elements of the coding that is assigned to the data sources follows: Random leading numbers only appear for VCM plants . Random leading numbers appear for PVC plants followed by possible symbols as shown PVC plant capacity S = small, less than 100 million lbs M = medium, 100 to 200 million lbs L = large, over 200 million lbs PVC plant age New = 0 to 10 years Int. = 11 to 12 years Old = over 20 years ( PVC plant siting C = cold climate W = warm climate BOR 0 0 0 8 0 4 B-l The exhibits pertaining to PVC plants are numbered B-2 through B-21. Those numbered B-100 through B-106 contain information on thqVCM plants. The data contained herein-will provide general location of VCM source in a plant, VC concentration in ppm, number of employees exposed at given work posts, and in most cases the measurement methods. There is some evidence that data obtained from manual sampling versus area monitoring may be biased downward. A PVC producer presented data showing the comparative results of sampling in the same area by manual methods and by means of five twenty points automatic sequential sampling chromatographs. The results are presented below: Number of Samples Average Point Range (95%) Manual sampling 218 10.14 0-46 Automatic sampling one full day 16.30 0 - 64 Without a statistical analysis of the population it is premature to affirm that a bias exists between manual and automatic sampling, particularly since one deals with a one-sided distribution. However, in view of the magnitude of the difference of the averages a real bias is likely. B0R 000805 B-2 i EXHIBIT B-l USDOL/OSHA CONFIDENTIAL INVENTORY OF POLYVINYL CHLORIDE WORKERS - 1914 Plant Start-Up Date 1957 1963 1961 1963 1946 1966 1968 1954 1953 1960 1970 1946 1956 1956 1956 1966 1963 1936 ' No. of Workers 64 46 80 155 35 158 120 130 300 40 55 300 60 27 76 140 187 272 Plant Start-Up Date 1947 1959 1955 1950 1971 1953 1965 1947 1965 1965 1942 1969 1955 1968 1965 1967 1957 1949 ' No. of Workers 140 74 150 74 30 241 200 350 70 180 266 90 98 150 95 160 70 322 5, 045 (1) Since the data is coded and confidential according to the source, it is not clear to Snell what the precise definition of "PVC Worker" is. , I Source: Statement of PVC Producers in the United States Relative to Health Experience of Workers in Plants Polymerizing Vinyl Chloride, Draft No. 3, 5/28/74, per private communication with Snell by Arthur B. Steele. Operations Manager, Union Carbide Corporation Chemicals and Plastics, July 26, 1974. BOR 0 0 0 8 0 6 BOR 0 0 0 8 0 7 Job Classification Suspension Area Foreman Homopolymer Reactor Operator Copolymer Reactor Operator Dryer Operator Bagger/Cleaner Labor Pool/Cleaner Plastisol Area Foreman Shift Foreman Tower Operator Laborer Bagger Atomizer Dryer Operator Additive Dryer Operator Laboratory Q.C. Lab. Supv. Analytical Chemist Colorist Q.C. Technician/Days Q.C. Technician/Shift Maintenance Maintenance Foreman Mechanic/Shift i EXHIBIT B-2 (1) USDOL/OSHA MONITORING RESULTS FOR 12 - M - INT. - C Average Exposure (ppm VCM) 8.4 10.0 26.1 5.6 5.0 5.3 16.2 3.7 19.0 7.6 2.5 2.0 2.2 2.5 0.7 16.2 0.8 3.9 3.0 3.7 Number of Data Points 39 79 76 24 59 85 32 27 176 100 71 26 23 6 6 5 46 28 130 Job Classification Warehouse and Miscellaneous Warehouse Supv. Warphouse Shipping Clerk Warehouse Receiving Clerk Warehouseman Effluent Plant Operator Boiler Operator Utility Man Yard Man and Service Man Average Exposure (ppm VCM) 0.5 1.8 1.7 0.7 1.9 0.9 11.0 0.3 EXHIBIT B-2 (2) USDOL/OSHA Number of Data Points 7 6 5 23 22 26 36 9 BOR 0 0 0 8 0 8 Source: Snell summary of industry data 1 Job Description Supervisor Senior Operator Reactor Operator Solutions Operator Utility Recovery Operator Finishing Operator Bulk Operator Bagger Artisan Operator Mechanic Bulk Loader Lab Technician Duties General Supervisory General Roving Duties Reactor Charging, Dumping Reactor Charging, Dumping Reactor Cleaning Number of Employees 8 4 4 4 4 Stripping, Transfer Slurry Drying Bulk Loading Resin Transfer Bagging Monomer Unloading Utilities Maintenance Material Handler Analytical 4 4 5 6 4 5 3 4 EXHIBIT B - 3(1) IJSDOL/OSHA 17 - S - INT. - W Average ^ 8 Hr. TWA PPM Type of Exposure 5 Interm ittant 8 Intermittant 22 Continuous 19 Continuous 16 Intermittant Wear Masks 17 Continuous 7 Intermittant 7 Intermittant * 14 Intermittant 6 Interm ijttant 3 Intermittant 7 Intermittant 1 bor 000809 EXHIBIT B~ 3 (2) USDOL/OSHA Job Description Supervisor 3rd Floor Operator Utility Duties General Supervisory Reactor Charging Reactor Cleaning Number of Employees 8 8 6 2nd Floor Operator Dryer Dryer Bagger Area 5 Operator Maintenance Mechanic Material Handler Lab Technican Stripping Transfer of Slurry Drying Bulk Loading Resin Transfer Bagging Monomer Unloading Utilities Maintenance Warehouse Work Analytical Note: (1) Data collected May 1 - July 15, 1974 Source: Snell summary of industry data 4 4 4 6 4 6 3 8 Average ^ 8 Hr. TWA PPM 5 22 16 17 7 i 7 14 6 3 7 1 Type of Exposure Intermittant Continuous Intermittant Wear Masks Continuous Intermittant Intermittant Intermittant Intermittant Intermittant Intermittbnt Intermittant BOR 0 0 0 8 1 0 Unit Operation VCM Unloading Reactor Operation (1) Current VC, ppm Typical = 40 ppm Ceiling =500 ppm Typical = 25 ppm Ceiling =300 ppm How Measured Gas Chromat ograph Organic Vapor Analyser It Historical VC, ppm N/A (2) N/A EXHIBIT B -4 (1) USDOL/OSHA MONITORING RESULTS FOR 19-L-NEW-W How Measured N/A N/A Drying & Product Transfer Typical = 20 ppm Ceiling = 75 ppm N/A N/A Mechanical Repairs (Flange Breaking, etc.) Typical = 30 ppm Ceiling =1000 ppm N/A N/A BOR 0 0 0 8 1 1 (1) Five minute average (2) None Available BOR 0 0 0 8 1 2 I. VCM UNLOADING AREA Activity Area Under Compressor Shed Guaging VCM Storage Tanks VCM Transfer Pumps VCM Unloading Platforms II. V-ll VINYL BUILDING Activity Area Recovery System Building Exposure At the Dump Strainers Water Blasting Reactor Fresh Air System III. V-12 VINYL BUILDING Activity Area Recovery System Building Exposure At the Dump Strainers Water Blasting Reactor Charging Control Panel EXHIBIT B -4 (2) USDOL/OSHA VCM LEVEL ppm 10 - >200 80 10 - >100 10 - >200 VCM LEVEL ppm 5 ->100 5 - 7100 5 - 7100 40-180 0-10 VCM LEVEL _RM 5 ->100 5 - >100 5-65 40-180 5-65 EXHIBIT B -4 (3) USDOL/OSHA V-ll DRYER BUILDING Activity Area Centrifuge discharge Sifter deck Bird deck Slurry Ilook-up Station Resin Hook-up Station Cleaning Drye^ In Dust Collector Taking Silo Readings Sifter Overflow Resin Bagging Resin Warehouse LARGE REACTORS Activity Area Recovery Sweco VCM Charge Pumps Source: Snell summary of industry data VCM LEVEL DDm 0 ->100 10-100 10-100 10 - >100 6 ->100 125-35 8-80 10-90 10-35 10-100 10-20 VCM LEVEL DDm 5 ->100 5 - >100 0-30 bor oooei3 BOR 0 0 0 8 1 4 Unit OperalInn Current \ V-12 Charge Operation 21 V-12 Recovery Operation 7 V-12 Maintenance Mechanic 12 V-12 Utility 11 V-ll Charge Operation 42 V-ll Recovery Operation 50 V-ll Utility 102 Large Reactor Lead Operator 1 Large Reactor Operation 5 Resin Bagger 13 Vinyl Area Maing. Shop 3 EXHIBIT B - 5 (1) USDOL/OSHA MONITORING RESULTS FOR 40 - L - NEW - W How Measured Historical VC,ppm Gas Bag N/A Gas Chrom atograph How Measured N/A / I EXHIBIT B - 5 (2) USDOL/OSHA Fork Lift Operator 17 Receptionist Office 1 Engineering Offices Maintenance Shop 1 1 Note: 1) Continuous monitoring data shown in attached table. This data is as yet experimental. 2) AJJD & OKC are presented separately because of difference of equipment and technique. Source: Snell summary of industry data f 1 BOR 0 0 0 B 1 5 EXHIBIT B - 6(1) USDOL/OSIIA MONITORING RESULTS FOR 4 - M - NEW - W Table I -- Vinyl Chloride Levels . * (non-respirator areas -- grab samples) May 1 -- June 2b, 1974 Location Operation Vinyl Chloride -- ppm a * Median Low Hijxli Day Tank Area Compressor IK-1 .. Compressor 2K-1 VP Seal Discharge Blower Discharge Popo. .Sampling 109/209 Blind Warehouse (2) Laboratory (3) " O) ^k " * (3, ) Office (3) . , Pumping VC De-gas De-gas ** De-gus During Cleaning Before Discharge Changing Blind Aisle Workbench Office Compositing Samples Center of Area 3.4 0.0 71.6 7.0 0.0 136. . 3.0 0.6 31.4 : 8.4 0.3 ; 159.'; # 7.0 0.9 '34.0 4.5.. 0.0'' 46.5 9.3 0*4 137. rV : i 5.2 0.0 7.7 4.0 1.7 6.4 2.1 Not Applicable it it' it * ` * it ft BOR 0 0 0 8 1 6 n Table XI -- Distribution of Data 110 Grab Samples^') May 1 to June 26, 1974 VC Levels EXHIBIT B - 6(2) USDOL/OSHA v- t Minimum Value 0.0 ppm Maximum Value 159 ppm 10% of samples showed VC levels of 0.5 ppm or less 20% " 30% " MV II 40% " ,,50% It II If it ii 1.1 it tt ii II 10 1.7 tt it ii n 2.9 tt 91 ` * It fi ii it 4,0 ti it * n . -60% " ii ii ti 6.4 n ii V 70% " 80%' " 90% " II II 19 it ti 9.7 ii ii i l 14.9 ti ti i * If 26.2 ii it it > 95% " 97.5% " It If tt it 39.7 19 tt it ti 11 ft it it 71.6 II ii BOR 000817 BOR 0 0 0 8 1 8 Similarly: 3.64% showed VC levels greater than. 50 ppm 4.55% t? II If it 40 II 11.8% it II fl If u 25 91 30.0% 19 II II II it 10 If 42.7 % II 19 U II it 5 If 81.8% II II II II t> 1 f EXHIBIT B - 6(3) USDOL/OSHA *. Table III -- Distribution of 8-HR TWA Levels EXHIBIT B - 6 (4) USDOL/OSHA * * May 15 - June 11, 1974 .r X Median Range 4.9 ppm a -- 27.9 ppm 0 V BOR 0 0 0 8 1 9 10% of employes had TWA values of 1.2 ppm or less . 20% IV 30% 40% u . ,50% If . 60% VI 70% II .80% If 90%. If 95% II ' 57.5% II II V 11 II II II II II ... II 1 II 11 IV 11 M ii If ti VI 11 It 11 IV 11 IV 1 II 11 IV 11 II IV *.w tv * IV II ft It If IV II . VI 1.5 it ii ft 2.3 1 11. II 3.2 < <v II 4.9 n it II 5.9 It 11 II 7.8 t 11 ' 19 10.2 If 11 H 14.0 It i * If 21.1 (1 11 VI 27.9 11 it 1 it it * II II II; II 11 It 11 EXHIBIT B " 6 (5) USDOL/OSIIA 4 Similarly: None had. '1WA values greater tlum 50 ppm 2.2% ft ii ii II II 25 It 22.2% 19 ii it II II 10 19 44.5%-* i ii It U 5 ft 91.1% 90 it it II 19 1 II ' bor 000820 Table IV EXHIBIT B-6(6) USDOL/OSIIA Job Classification rtReactor Cleaner *Poly Area Operator -Outside Operator Finish. Bldg. Operator Loading-Rack Operator Control Room Operator /* *r Supervisor Tech. Supt. (in plant) Number of Values Vinyl Chloride ppm as TWA Median Lov; , IMi 21 6.3 1.4 ' V 27.9 4 11.4 4.2 . 23,7 4 3.4 r 1.9 ' - l4*3 5 . .. 1.6 4 . 3.6 4 0.9 0.4 . 3.2 1.2 9.6 4>.i . 6.0 . 2 3.7 2. 4.9 ,/* J. 6.9 Not Applicable TOTAL .. 45 4.9 CO.! y 27.9 : 0* . *TWA mean for reactor building ** 8.5 ppm -- range 1.4 to 27.9 ppra BOR 0 0 0 8 2 1 EXHIBIT B - 6 (7) USDOL/OSHA Notes: f1) Concentration measurements were obtained from samples taken in 250 ml. glass tubes. Aliquots of these samples were injected directly into a gas chromatograph. Samples absorbed on carbon were desorbed in carbon disulfide prior to injection into the chromatograph. (2) Four samples only (3) One sample only Source: Snell summary of industry data f l BOR 0 0 0 8 2 2 EXHIBIT B -7 (1) USDOL/OSHA MONITORING RESULTS FOR 22-M-OLD-C VINYL CHLORIDE LEVELS TABLE I VCM TEST METERS 1946-1967 1968-1971 1972-1973 1974 MSA Explosimcter' . Lowest reading on scale, 2% of LEL, or 720 ppm - not accurate at this level. Davis Vaportester Lowest reading on a X10 scale was 0.2% of LEL or ' 72 ppm - not accurate at this level. Johnson & Williams SS PK Tester Scale roads 26 ppm per division but not accurate below 50 ppm. Zero drift often in excess of 50 ppm. Century OVA 7/98 Portable FID Testers Not specific for VCM. Reads down to 1 ppm. We calibrate with certified gas at 50 and at 5 ppm. / I BOR 0 0 0 8 2 3 \ ,, TABLE 2 * Vinyl Chloride Levels in Operating; Buildings EXHIBIT B "7(2) USDOL/OSHA fime Span > 1946-1972 TWA C-l C-2 F.-1 E-2 F-l F-3 500 140 500 150 20 K. 1973 Number of Readings 77 73 582 597 222 73 85 TWA (ppm) 50 5 50 25 125 5 175 Maximum reading (ppm) 2800 200 3000 2800 2460 200 2240 Jan; 1974 Number of Readings 9 9 63 *80 27 8 9 TWA (ppm) 64 8 25 17 93 44 17 Maximum Reading (ppm) 300 60 504 168 840 300 100 April 8, 1974 to May 21, 1974 > Number of Readings* TWA (ppm) Maximum Reading (ppm) 306 * 8 131 4 246 35 935 1068 76 43 34 528 328 10 8 50 65 132 7 46 BOR 0 0 0 8 2 4 -Exclusive of Reactor Cleaning. .Jork Functions: C-l - Tank Car Unloading, VC pumping, VCH production until 1967 C-- 2 -- E-01 - Polyme19 rization, MonIoI mer RecoIvI ery E- 1 ~ F-1 - Filter, Apron driers F- 3 - Filter, Rotary drier K - Filter, Spray drier Table 3 -- Area Sampling Results -- . ^ April 8 - June 27, 1974 (Century OVA Meter) EXHIBIT B-7(3) USDOL/OSHA Time Period - 1974 Upwind Reading Building Readings % E-l E-2 F-l . C-l C-2 4 K Average of All Readings (as ppm Vinyl Chloride) F-3 4/8-4/17 4/27-5/7 5/17-5/25 6/5-6/13 6/14-6/27 4.9 14.7 12.6 6.2 11.7, 11.4 4.8 - 9.3 9.2 ;; 3.7 7.0 7.9 3.8 7.6 7.7 38.9 9.1 14.2 14.7 - 10.1 10.6 14.2- 12.8 - 6.7 7.9 10.3 10.9 8.2 5.5 5.7 6.2 10.5 9.2 5.5 6.0 \ 7.3 7.0 4/8-6/27 Number of Readings 4.8 240 .* * 10.5 9.7 13.1 7.2 7.9 10.5 ii.6 1678 1229 398 310 153 154 : 215 BOR 0 0 0 8 2 5 Table 3 (continued) EXHIBIT B -7 (4) USDOL/OSHA Mnximum Reading Recorded (as ppm Vinyl Chloride) 4/8-4/17 * 4/27-5/7 5/17-5/25 6/5-6/13 6/14-6/27 4/8-6/27 7 13 18 6 5 45 28 35 20 27 32 40 40 35 45 - 500 30 *a 24 40 - 21 22 40 10* 10 35 12 11 45 49 27 16 50 ' 42 33 45 55 20 \ 18 50 45 275 500 40 50 55 Note: These data do not cover excursions, but represent routine conditions. / I BOR 0 0 0 8 2 6 ! Tabic-.4 -- Vinyl Chloride Levels I ' April 8 -- June 27, 1974 EXHIBIT B-7 (5) USDOL/OSHA Century OVA Readings as ppm Vinyl Chloride . Time Period - 1974 Average* Maximum* Mimimum* , . E-_l E-2 E-l E-2 E-l: E-2 4/8-4/17 4/18-4/26 4/27-5/7 5/8-5/16 5/17-5/25. 5/26-6/4 6/5-6/13 6/14-6/27 ' 33.0 27.5 29.8 34.2 25.9 20.8 21.8 20.3 27.1 33.1 -- 29.8 31.0 29.7 115 40 % 48 45 46 45 41 40 35 -- 46 * 45 -- 60 48 15 14 15 -- 6 15 10 * 7 10 '* 7 4 15 5 io / BOR 0 0 0 8 2 7 4/8-6/27 26.5 30.6 115 60 4 10 * A total of 193 readings were taken in E-l reactors; 98 reading in E-2 reactors. Table .5 -- Personnel Monitoring Data -- . April-17 -- June 28, 1974 # 'Description of Value 250 ml 10 min Glass Carbon Number of Samples 94 74 Minimum Value -- ppm 0.1 Nil Maximum Value -- ppm . 160 55 EXHIBIT B-7(G) USDOL/OSHA t All ShortTerm Samples 8-HR TWA 168 31 Nil - c 0.04 160 , 100 1` ' / VCM (ppm) -- 107o of samples i 20 It u 30 II * 11 ' 40 It 17 50 17 ft 60 17 It 70 II - - - : 60 ' If o o 90 ft IV o GO to 00 " ,7 95 It It 97. 5 " If 0.6 * - 1 1 <1 ^1 ^1 3* a 21 1.8 .5 2 2 33 2' * : 8. 3 5 3.8 76 '5 ` , 7;7 14 6. . y 16 12 9 .. 1 22 12 15 : 24 42 25 37 28 60 44 55 ,100 to tr-o*0 1 BOR Table 3 Personnel Monitoring Data -- . April 17 -- June 28, 1974 EXHIBIT B -7 (6) USDOL/OSHA Description of Value 250 ml 10 min All ShortGlass Carbon Term Samples 8-HU TWA Number of Samples 94 74 168 31 Minimum Value -- ppm 0.1 Nil Nil 7 . c 0.04 Maximum Value -- ppm . 160 55 160 100 oo BOR 0 0 0 8 2 9 VCM (ppm) -- 10% of samples 20 " 17 ' '' 30 r!; 40 " ii 50 If If '70 " . . : 80 *` " 90 " -7 95 " 97.5 " ff tt ft It If 0.6 1 2 2 3 5 7 12 22 42 60 '1 <1 1 12 3 3,8 6 9 12 25 44 00 '' 1 --1' . ' *' ` ' 3 4 5. 2 *t 3 5` ' 0* * ;* 7 8. 12 14 6 * 1 ' 16 * 10 20 i f *i 715 t . 24 37 28 55 100 Table 5 (continued) EXHIBIT B -7(7) USDOL/OSHA Percentage of values above 50 ppm If 1 if 40 If II II n n 25 ft If II i 91 10 It If IV ii If 5 If II If it If 1 If 4.3 1.4 6.4 2.7 9.6 4.1 20.2 16.2 39.4' *31.6 73.4 66.2 3.0 - 6.5 4.8 . . 6.5 7.1 9.7 18.5 ' 51.7 35.7 67.8 70.2 ,* .V 93.7 BOR 0 0 0 8 3 0 Work Area or Function i Reactor Cleaning Batch Transfer Reactor Area Pump Room Control Room E-Bldg. Supervisor Bagger PfiS Dryer Break Room Locker Room Lunch Room Main Office Warehouse T el ev Laboratory Maintanance Shop Shift Monitor Table 6 -- Distribution of Personnel Monitoring Data By Job Function and/or Area EXHIBIT B-7 (8) USDOL/OSHA Ten Minute-Glass & Carbon Tubes 8-HR TWA - Total Samples No. No. --'40 ppm >25 ppm Vinvl Chloride Total Ava Max Min Samples ppm ppm ppm No. No. Vinvl Chlorid - 25 ppm >1U ppm Ave Max n ppm ppm p 20 23 23 12 : 11 13 9 6 1, O' 0 0 0 1 9 33.1 160 2 6 2 8.3 75 1 3 0 5.0 22 1 5 0 5.8 9 <1 1 0 6.0 12 2 2 3 * 0 4.9 13 c 1 2 1 14.6 60 3 3 0 0 o 0 1 1 0 ,0 5 15.7 1 7.7 2 10/. 0 0 5.0 1 18.0 1 22.0 0 "4.5 3 17.3 22 12 24 nq 51 6 24 ] 7 0 0 . 1.2 2 <1 7 0 0 1.3 2 0.4 --! -- M_ 6 0 0 1.8 7 Nil -- __ -- 7 0 0 1.7 5 Nil 1 0 0 0.04 f 7 0 0 2.0 5 1-< 2 0 0 2.1 3.6 0. 10 0 0 . 1.3 10 ^0.1 -- -- --- ---- 6 0 0 0.6 1 Nil ** * V* -J 7 0 0 0.6 2 0.1 * * -- -- _ -- " 3 1 3 44.0 ' 100 1 Source: Snell summary of Industry data BOR 0 0 0 8 3 2 *\ * Location . Outside, Tank Car Unloading . Outside, Storage Area . Reactor Building . Centrifuge and Dryer Building . Outside, PVC Silos . Bulk Pack Bagging Building . Bagging Warehouse Total Employees 1 1 GO 8 6 6 15 Note: (1) Monitoring performed with Ovameter Source: Snell summary of industry data EXHIBIT B -8 USDOL/OSHA MONITORING RESULTS FOR 31-M-MEW-C Current Olin Estimated VCM Exposure Levels (PPM) ^ 0-5 0-5 25 - 30 (w/excursions to 50 0-5 ~0 - 5 -0-5 -5 \ EXHIBIT B-9 USDOL/OSHA MONITORING RESULTS FOR 45-M-INT-C Unit Operation VC Unloading (1) Polymerization Kettle Cleaning ^ Drying Packaging ^ Shipping Current Range VCM PPM 0 200 10 50 10 175 5 40 5 125 0 70 How Measured - Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph Gas Chromatograph Note: (1) Type C continuous flow air masks required while performing this function. Source: Snell summary of industry data BOR 0 0 0 8 3 3 BOR 0 0 0 8 3 4 Unit Operation 1. VC Unloading 2. Prepolymerizer Charging Opening Cleaning 3. Postpolymerizer Current VC, PPM <50 20 - 40 >100 25 - 100 Charging Opening Cleaning Transfer 4. Bagging <25 50 - 150 <50 >50 <50 Note: (1) Not a reliable measurement Source: Snell summary of industry data EXHIBIT B -10 USDOL/OSIIA MONITORING RESULTS FOR 30-M-NEW- How Measured Historical VC, PPM GC <200 GC GC GC How Measured / Odor (1) GC GC GC GC GC Job Description Maintenance Poly Scrubber Lab Technician Bagger Compounding Operator Dryer Operator HRC Operator Head Operator Poly Head Operator Poly Drop Operator Drop Operator Number of Samples 42 16 13 6 19 34 10 17 21 26 6 Average Worker Exposure to VCM in PPM 1.9 14.4 184.1 2.5 1.7 78.8 3.8 4.9 6.6 5.7 2.5 EXHIBIT B-ll USDOL/OSHA MONITORING RESULTS FOR 41L-OLD-W Range of Worke Exposure to VCM in PPM <0.1 - 26.6 2-49.7 0.2 - 2375 0.1 - 8.4 0.1 - 8.7 0.5 - 915.7 < 1.0 - 18.4 1.0 - 26.4 0.3 - 45.9 0.9 - 52.7 1.0 - 5.6 BOR 0 0 0 8 3 5 Note: Snell average of data for the months of March through June 1974, Source: Snell summary of industry data Unit Operation Current VCM Concentration Since July, 1974 (PPM) . Polymerization and Setting . Centrifugation . VC Recoveryand Unloading . Reactor Entry For Cleaning . Transfer and Loading . Warehousing 5-10 11 - 10 100 - 160 7 - 180 27 4-42 0-3 0-3* 1 EXHIBIT B-12 USDOL/OSHA MONITORING RESULTS FOR 28-L-NEW-C How Measured Historical VCM Concentration Since April, 1974 (PPM) FID (1> Carbon Tube FID FID Carbon Tube Carbon Tube FID FID 7 - 90 20 - 130 100 - 160 Up to 10,000 Up to 10,000 40 - 200 0-3 0-3 How Measured FID Carbon Tube FID/ FID Carbon Tube FID FID FID Note: (1) FID = Flame Ionization Detector Source: Snell summary of industry data I BOR 0 0 0 8 3 7 Job/Location Scrubbing Bagger and Bag Operators Operator and Operator Workmen Control Man/Control Room Sampling and Checking Reclaim Operator Waste Lake Maintenance Washing and Cleaning Perimeters Loading Operators River Discharge Dicer Dropping and Charging Blending and Milling/Mill Intakes, Exhausts, Vents Dust Collectors Office Areas Work Areas and Decks Dryers and Vicinity , Product Collectors . FCM Rotors No. of Data Points 20 17 72 27 26 7 2 17 42 48 16 1 6 23 9 9 10 7 33 7 2 2 EXHIBIT B--13 (1) USDOL/OSHA MONITORING RESULTS FOR 54-M-NKW-C Vinyl Chloride Monomer Concentrations (PPM) Avg. (1) High Low 65 20 24 27 61 55. 2 10 65 2 31 1 3 70 6 22 16 2 8 51 10 1827 199 70 239 343 1021 227 4 ' 34 1389 11 213 X 8 671 36 104 76 4 74 168 16 2141 8 0.4 0.6 0.2 0.3 3 0.8 0.2 0.3 0.5 0.6 X 0.5 0 0.6 0.4 1 0.3 0.7 0.8 3 1512 BOR 0 0 0 8 3 8 Notes: X ~ Not Applicable (1) Snell averaging of Diamond Shamrock data Source: Snell summary of industry data EXHIBIT B~13(2) USDOL/OSHA EXHIBIT B-14(1) USDOL/OSHA MONITORING RESULTS FOR 5-L-OLD-C Atmospheric Concentration Vinyl Chloride During Cleaning of 4,000 Gal. ._______ ____ .._______________________ ____________ Suspension Process Sample Location 1, Operator breathing zone when entering polymerlzer 2. Operator breathing zone while scraping walls of polymerlzer 3. Operator breathing zone while scraping walls of polymerlzer August-September 1967 Air Concentration Vinyl Chloride ppm 19 22 19 Monomer Concentration In Polymerlzer Atmospheres Polymer Type..... Suspension f1 It II II II If II II II II Poly No. 120 130 151 102 124 128 150 150 121 128 136 Poly Size 1100 1100 UOO 1100 1100 1100 1100 1100 1100 1100 1100 Total Evacuation Time 20" 18" 25" 35" 20" 20" 50" 20" 40" 40" 45" VC1 ppm Monomer 10 Min.* 30 Min 84 50 42 99 230 77 20 76 34 104 56 72 46 32 78 123 80 25 80 34 63 62 / l BOR 0 0 0 8 3 9 BOR 0 0 0 8 4 0 VI IV II IV IV 11 VI II VI Dispersion IV It II 11 II II H II II It If ti l| II It 11 II II '130 133 114' 113 117 135 132 136 116 25 32 29 48 28 45 42 43 32 25 6 25 19 34 6 20 9 12 4 1100 1100 1100 1100 1100 UOO 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 UOO 1100 1100 1100 UOO UOO UOO UOO UOO UOO 1100 UOO 90" 25" 25" 30" 25" 25" 40" 40" 60" 22" 20" 30" 25" 55" 55" 60" 25" 30" 35" 25" 30" 25" 25" 40" 30" 25" 25" 30" 93 146 375 147 234 180 147 118 76 74 56 34 417 36 78 100 75 211 55 102 62 94 40 35 165 120 60 271 EXHIBIT B-14 (2) USDOL/OSHA 32 97 250 107 264 185 104 64 59 100 114 84 391 68 100 189 148 279 39 37 41 88 29 44 168 99 78 152 / EXHIBIT B-14(3) USDOL/OSHA I Angust-September 1967 Monomer Concentration In Polymerlzer Atmospheres con't. Polymer JXE____ Poly No. Poly Size Total Evacuation Time VC1 ppm Monomer 10 Min. * 30 Min.** Dispersion II If II 8 12 21 12 17 1100 1100 1100 1100 1100 60" 27 25" 174 18" 102 30" 142 35" 38 80 320 104 168 68 Suspension n ii n H ii 19 II II II II II II II 137 143 137 141 113 127 116 106 146 142 124 142 105 148 3300 3300 3300 3300 1100 1100 1100 1100 3300 3300 1100 3300 1100 3300 20" 45" 25" 35" 15" 10" 4 30" 10" & 5" 30" 30" 35" 30" 35" 30" 45" 374 405 62 138 54 32 440 192 162 147 128 106 52 26 * Sample collected 10 minutes after operator enters poly, operator breathing zone sample. 134 142 112 123 59 498 390 188 200 139 101 113 47 24 **Sample collected 30 minutes after operator enters poly or after cleaning, if cleaning time was less than 30 minutes; operator breathing zone sample. BOR 0 0 0 8 4 1 EXHIBIT B-14 (4) USDOL/OSHA Date 8-29-67 9-5-67 9-7-67 9-11-67 9-12-67 9-25-67 9-26-67 9-28-67 Moncmier Concentration in Room Air ppm VC Dispersion Resin BldK. 451 16 58 450 6 Suspension Resin Bide. 461 53 27 45 26 18 31 48 32 ! BOR 0 0 0 8 4 2 EXHIBIT B~14 (5) USDOL/OSHA Monomer Concentration In Polyroerizer Atmospheres October 1967 Polymer lygg____ SuspensIon II H ft if II II II II II Dispersion II II II II Suspension Poly No. 25 43 33 29 41 25 30 45 34 46 16 18 14 18 2 142 Poly Size 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 1100 3300 Total Evacuation Time . -JgU.JJKS Monomer 10 Min. 30 Min 65" 45" 45" 35" 35" 30" 65" 80" 65" 35" 71 59 48 73 75 73 66 30 35 56 95 50 70 117 38 98 114 23 43 55 50" 115 20" 156 50" 53 35" 58 25" 58 210 114 74 62 56 45" 50 35 BOR 000843 EXHIBIT B-14 (6) USDOL/OSHA Date 10-16-67 10-17-67 10-23-67 10-30-67 Monomer Concentration in Room Air ppm VC1 Dispersion Resin Bldg. 451 Suspension Resin Bldg. 461 142 26 14 28 44 Ambient Concentrations of Vinyl Chloride ppm Year 1967 1968 Date 8-29 9-5 9-7 9-11 9-12 9-25 9-26 v-28 10-16 10-17 10-23 10-30 9-18 9-23 9-30 Dispersion Resin Building 451 16 58 450 6 142 14 28 44 21 21 42 24 59 Suspension Resin Buildti 53 27 45 26 18 31 48 32 26 Suspension Resin Building 464 47 49 30 47 22 68 / 1 BOR 0 0 0 8 4 4 1972 10-8 10-30 11-12 11-13 11-19 6.29 8000 B) % O' Average 72 28 133 72 88 65 76 24 18 62 61 63 29 73 41 41 3 16 <1 41 38 EXHIBIT B-14(7) USDOL/OSHA r J . 14 27 15 7 13 16 I I EXHIBIT B-14(8) USDOL/OSHA Atmospheric Vlnvl Chloride Concentrations In Charging Area Dispersion Resin Building 451 West Side East Side Control Room West Side East Side Control Room Tuesday, 8-22-72; 11 a.m. Tuesday, 8-22-72; 3 p.m. Thursday, 8-24-72; 9 a.m. 82 ppm 155 ppm 8 ppm 89 ppm 378 ppm 64 ppm / BOR 0 0 0 8 4 6 West Side East Side Control Room West Side Center East Side West Side Center East Side Thursday, 8-24-72; 11 a.m. Thursday, 8-24-72; 1 p.m. 78 ppm 13 ppm 5 ppm 73 ppm 104 ppm 30 ppm 97 ppm 72 ppm 10 ppm I ( EXHIBIT B-14-(9) USDOL/OSHA Thursday, 8-24-72; 3 p.m West Side Center East Side 33 ppm 33 ppm 13 ppm Friday, 8-25-72; 9 a.m. West Side Center East Side 135 ppm 22 ppm 148 ppm Friday, 8-25-72; 11 a.m. West Side Center East Side Dispersion Resin Building 451 con't. 24 ppm 24 ppm 131 ppm Friday, 8-25-72; l p.m. West Side East Side Control Room 47 ppm 95 ppm 54 ppm | Thursday, 9-7-72; 1 p.m. West Side East Side 23 ppm 440 ppm BOR 0 0 0 8 4 7 EXHIBIT B -14 (10) USDOL/OSHA Suspension Resin Building 461 Tuesday, 8-22-72; 11 a.m. West Side East Side Control Room Tuesday, 8-22-72; 3 p.m. 531 ppm 131 ppm 49 ppm West Side East Side Control 48 ppm 32 ppm 24 ppm / Thursday, 8-24-72; 9 a.m. West Side East Side Control Room 29 ppm 288 ppm 26 ppm Thursday, 8-24-72; 11 a.m. West Side Center East Side 329 ppm 762 ppm 70 ppm Thursday, 8-24-72; 1 p.m. BOR 0 0 0 8 4 8 West Side East Side 20 ppm 72 ppm Thursday, 8-24-72; 3 p.m. West Side Center East Side 33 ppm 107 ppm 87 ppm 1 EXHIBIT B-14 (11) USDOL/OSHA Friday, 8-25-72; 9 a.m. West Side Center East Side Suspension Resin Building 461 369 ppm 364 ppm 135 ppm West Side Center East Side Frl West Side East Side West Side East Side Friday, 8-25-72; II a.m. Friday, 8-25-72; 1 p.m. Thursday, 9-7-72; 1 p.m. Suspension Resin Building 464 168 ppm 186 ppm 156 ppm 358 ppm 122 ppm 51 ppm 74 ppm BOR 0 0 0 8 4 9 North End North End Center South End Tuesday, 8-22-72; H a.m. Tuesday, 8-22-72; 3 p.m. 82 ppm 5 ppm 32 ppm 32 ppm < EXHIBIT B -14 (12) USDOL/OSHA V Thursday, 8-24-72; 9 a.m. North End Center South End 8 ppm 13 ppm 5 ppm Thursday, 8-24-72; 11 a.m. North End Center South End 5 ppm 7 ppm 7 ppm Thursday, 8-24-72; 1 p.m. North End Center South End 5 ppm 15 ppm 15 ppm Thursday, 8-24-72; 3 p.m. North End Center South End Suspension Resin Buildinjt 464 7 ppm 47 ppm 67 ppm Friday, 8-25-72; 9 a.m. bor ooosso North End Center South End 36 ppm 9 ppm 9 ppm Friday, 8-25-72; 11 a.m. North End Center South End ( 24 ppm 12 ppm 36 ppm North End Center South End Friday, 8-25-72; 1 p.m. 47 ppm 108 ppm 115 ppm Area Measurements Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons by the Flame Ionization Method EXHIBIT B~14(13) USDOL/OSHA Building 451 Product Dispersion Resin Month JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 Average ppm 29.5 23.7 15.3 17.1 17.8 11.3 X Readings Above 50 PPM 3.5 3.9 2.6 4.9 2.7 4.7 X Readings Under 10 PPM 8.7 14.4 23.4 42.9 65.2 72.5 ( 461 464 463 Suspension Resin JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 25.6 17.8 19.1 18.7 15.4 11.9 Suspension Resin JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 31.4 22.7 18.3 12.7 8.8 6.0 PVC Latex JAN, 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 8.1 8.2 7.6 7.6 9.6 8.1 4.7 3.3 2.5 3.4 2.2 4.9 5.1 3.1 1.1 0.0 2.8 2.8 0.0 0.2 0.0 0.7 0.4 1.9 EXHIBIT B-14 (14) USDOL/OSHA 24.1 37.9 21.7 14.6 59.3 57.8 11.1 10.3 34.8 58.9 71.2 82.5 70.9 91.7 97.5 97.6 86.3 82.3 / BOR 0 0 0 8 5 2 i EXHIBIT B -14 (15) USDOL/OSHA Location and Type East Bldg. 464 Suspension Resin PERSONNEL MONITORING DATA - MAY-JULY, 1974 Operation Charging Cleaning Recovery No. of Samples 5 4 6 twa Average 10 12 14 ppm VC1 Maximum 23 23 31 Minimum 3 2 3 West Bldg. 451 Dispersion Resin Oiarging Cleaning Recovery Drying and Bagging 5 7 3 4 8 18 19 42 9 15 12 4 6 3' 1 . West Bldg. 461 Charging 3 10 22 3 Suspension Resin Cleaning 6 22 80 5 Recovery 4 17 26 6 Supervisory 1 12 BOR 0 0 0 8 5 3 West Bldg. 453 Charging 4 14 23 2 Latex Cleaning 3 47 126 4 Recovery 2 80 154 6 Supervisory 1 3 Notes: Everyone wears respiratory equipment where the work atmosphere is greater than 25 ppm or where operations and experience show there is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally 4 hours (some . ,, data repre sents 20 minute samples) to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography. Source: Snell summary of industry data Atmospheric Concentrations of Vinyl Chloride __________ _- Building 731 USDOL/OSHA MONITORING RESULTS FOR 8-L-NEW-C Sample Location Vinyl Chloride Concentration (ppm) Near Manhole, Poly No. 2 - Suspension Resin Near Manhole, Poly No. 7 " " 15 18 Near Manhold, Poly No. 11 " " 24 Near Manhold, Poly No. 21 - Dispersion Resin 34 Atmospheric Concentrations of Vinyl Chloride 2nd Floor Bldg. 731________ .> Tuesday, April 4 12:50 PM VCl ppm Aisleway paste* line proceeding North to South Poly #36 & 35 Aisleway paste line proceeding North to South Poly #29 & 30 Aisleway paste line proceeding North to South Poly #22 & 21 102 98 41 1:05 PM Aisleway pearl* line proceeding North to South Poly #15 & 17 Aisleway pearl line proceeding North to South Poly #9 & 11 Aisleway pearl line proceeding North to South Poly #3 & 5 268 271 124 1:30 PM Aisleway pearl line proceeding North to South Poly #15 & 17 (approx.) Aisleway pearl line proceeding North to South Poly #9 & 11 Aisleway pearl line proceeding North to South Poly #3 & 5 737 76 58 BOR 000854 l EXHIBIT B~15 (2) USDOL/OSHA 2:58 PM to 3:02 PM Aisleway pearl line proceeding North to South Poly #9 & 10 (Approx ) Aisleway pearl line proceeding North to South Poly #2 & 1 Outside control room by metering station 3:53 PM Aisleway pearl line proceeding North to South Poly#15 & 17 Aisleway pearl line proceeding North to South Poly #9 & 11 Aisleway pearl line proceeding North to South Poly #3 & 5 Outside control room by metering station 4:15 PM Aisleway paste line proceeding North to South Poly #36 & 35 Aisleway paste line proceeding North to South Poly #22 & 21 Aisleway paste line proceeding North to South Poly #15 & 17 Outside control room by metering station 4:25 PM Aisleway paste line between Poly #36 & 35 Outside control room by metering station 4:50 PM Aisleway paste Aisleway paste Aisleway paste Aisleway pearl line proceeding North to South Poly #36 line proceeding North to South Poly #29 line proceeding North to South Poly #22 line at South end of Poly #3 & 5* & 35 & 30 & 21 * "Paste" means dispersion resin "Pearl" means suspension resin 550 62 260 40 50 5 30 68 68 58 55 68 35 39 48 39 45 / BOR 0 0 0 8 5 5 Atmospheric Concentrations of Vinyl Chloride 2nd Floor Bldg. 731 Wednesday, April 5 12:13 PM to 12:19 PM Just inside doorway to 2nd floor poly area Aisleway paste* line proceeding North to South Poly #35 & 36 Aisleway paste line proceeding North to South Poly #30 & 29 Aisleway pearl* line proceeding North to South Poly #20 & 19 Aisleway pearl line proceeding North to South Poly #14 Aisleway pearl line proceeding North to South Poly #4 12:42 PM to 12:48 PM Inside control room Outside control room by metering station Aislcway pearl poly line between Polys #9 & 10 Doorway to compound room near freight elevator Aisleway paste poly line by Poly #24 By Bldg, exit door located behind control room 3:00 PM to 3:06 PM Inside control room Outside control room by metering station Aisleway pearl line; North end by Polys $15 & 16 Aisleway pearl line; South end by Polys #1 & 2 Aisleway paste lino; North end by Polys #33 & 34 Aisleway paste line; South end by Polys #21 & 22 EXHIBIT B -15(3) UCDOL/OSHA VC1 ppm 250 318 462 332 474 122 15 130 130 145 ` 133 117 5 45 38 23 90 108 1 BOR 0 0 0 8 5 6 l EXHIBIT B-15 (4) USDOL/OSHA 3:30 PM to 3:40 PM At manhead to pearl Poly #6; just off recovery, fumes seen venting to room (approx.) In aisleway in front of pearl Poly #6 At manhead to pearl Poly #2; exhaust hose had just been removed At manhead to paste poly #34; after HRC cleaning At manhead to paste Poly 7/30; poly filled with cleaning solution In aisleway betweenpaste Polys //27 & 38 5:00 PM to 5:15 PM 550 438 470 400 5 5 Inside control room 10 Outside control room by metering station 45 Aisleway pearl Aisleway pearl line proceeding North to South Polys $15 & 16 line proceeding North to South Polys #5 & < 40 15 / Aisleway paste line proceeding North to South Polys #35 & 36 72 Aisleway paste line proceeding North to South Polys #21 & 22 65 * "Paste" means dispersion resin "Pearl" means suspension resin Atmospheric Concentrations of Vinyl Chloride In Bldg. 731 . Thursday, April 6 9:30 AM to 9:40 AM Inside control room Outside control room by metering station Aisleway pearl* line proceeding North to South Polys #19 & 20 Aisleway pearl line proceeding North to South Polys #1 & 2 Aisleway paste* line proceeding North to South Polys #35 & 36 Aisleway paste line proceeding North to South Polys #21 & 22 VCl ppm 2 8 148 268 25 45 BOR 0 0 0 8 5 7 i CAmoiJ n-15(5) USDOL/OSHA 10:45 AM to 11:0Q AM Inside,control room 15 ' Outside control room by metering station 28 Aisleway pearl line proceeding North To South Polys #19 & 20 25 Aisleway pe.arl line proceeding North to South Polys #14 & 13 28 Aisleway pearl line proceeding North to South Polys #3 & 4 27 At manhead pearl Poly #8; opened for cleaning 300 Aisleway paste line proceeding North to South Polys#35 & 36 30 Aisleway paste line proceeding North to South Polys #31 & 32 30 , Breathing zone of man hose washing #25 paste poly 100 Aisleway by paste premix poly 18 1:45 pm to 2:05 PM Outside control room by metering station By doorway to compounding room; near freight elevator Aisleway pearl line proceeding North to South Polys #15 & 16 Aisleway pearl line proceeding North to South Polys#3 & 4 At manhead of pearl Poly #9 At manhead of pearl Poly#14 Aislcway paste line proceeding North to South Polys #33 & 34 Aisleway paste line proceeding North to South Polys #29 & 30 Aisleway paste line proceeding North to South Polys #23 & 24 At manhead paste Poly #31 At manhead paste Poly #34 By bldg, exit door behind control room On mezzanine level by #9blowdown tank On mezzanine level by #6blowdown tank On Mezzanine level at South end paste blowdown area 32 27 14 30 33 22 30 26 31 163 168 35 20 31 26* / BOR 0 0 0 6 5 8 * "paste" means dispersion resin "pearl" means suspension resin EXHIBIT B-15 (6) USDOL/OSHA Thursday, April 6 -- Con't. 8:AO PM to 8:50 PM Outside control room by metering station At doorway to compound room; near freight elevator Aisleway pearl line proceeding North to South Polys #15 & 16 Aisloway pearl line proceeding North to South Polys#5 & 6 Aisleway paste line proceeding North to South Polys #33 & 34 Aisleway paste line proceeding Nor5h to South Polys #23 & 24 VCl ppm 108 95 43 72 98 91 / BOR 0 0 0 8 5 9 VCL MONITORING DATA Area Measurements Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons by the Flame Ionization Method EXHIBIT B -15 (7) USDOL/OSHA Building 731 Product Suspensi on and Dispersion Kesins Month JAN. FEB. MAR. APR. MAY JUNE 74 74 74 74 74 74 Average ppm 90.7 31.4 18.3 16.8 8.6 8.3 X Readings Above 50 PPM 33.0 10.0 2.0 4.8 2.3 2.9 Z Readings Under 10 PPM 20.3 17.4 27.9 69.1 82.0 79.1 / BOR 0 0 0 8 6 0 PERSONNEL MONITORING DATA \ EXHIBIT B -15(8) USDOL/OSHA May - July. 197 Location and Type Suspension Resin Dispersion Resin Ope ration Charging Cleaning Recovery Charging Cleaning Recovery No. of Samples 7 7 A 5 3 3 TWA Average 6 4 6 5 12 A PPM VC1 Maximum 13 8 9 8 26 5 Minimum 2 ft 4 2 2 3 Everyone wears respiratory equipment where the work atmosphere is greater than 25 ppm or where operations and experience shew there Is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally A hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography. Source: Snell summary of industry data BOR 0 0 0 8 6 1 ( * *. chromatographic ANALYSIS DATA USDOL/OSHA MONITORING RESULTS FOR 49-M-OLD-C Year 1965 1966 Date 10-27 11-10 11-10 11-11 12-8 12-10 1-10 1-12 1-13 1-14 9-2 9-13 Ambient Conce ntrntions Vinyl Chloride, ppm COPOLYMER RESIN BuiIding 15 3rd Floor 24 17 117 51 183 182 99 75 47 30 18 2 38 98 97 68 55 28 111 SUSPENSION RESIN Building 1 SUSPENSION RESIN Building 111 DISPERSION RESIN & LATEX Building 121 3rd Floor / BOR 000862 t Year 1968 C0P0LYMKR RESIN BuiIding 15 Date 3rd Floor "% ^ 2-8 2-14 2-15 2-17 12-9 11-2 12-11 26 32 12 24 28 10 12-12 12-15 12-18 1-9 51 49 42 12-16 12-17 26 2 SUSPENSION RESIN Building 1 41 23 20 SUSPENSION RESIN Building 111 80 36 42 EXHIBIT B-16 (2) USDOL/OSHA DISPERSION RESIN & LATEX Building 121 3rd Floor 231 632 52 374 110 135 130 138 97 85 81 72 114 BOR 0 0 0 8 6 3 i USDOL/OSHA Ambient Concentrations Vinyl Chloride, ppm * Year Date C0P0LYMKK RESIN Building Bui Iding Building 15 15 15 3rd Floor 2nd Floor 1st Floor --SUSPENSION RESIN f Building Building 1 HI 3rd Floor 3rd Floor DISPERSION RESIN & LATEX Building 121 3rd Floor 1969 1-31 2-3 2-14 3-26 9-30 194 52 12 199 77 58 1972 3-21 4 1 3-22 4 1 5 2 2 6 2 1973 3-22 132 57 44 33 28 12 10 19 22 1 1 0.5 7 5 0.5 2 4 4 3 1 4 0.5 0.5 1 7 1 7 3 5 10 9 10 12 11 12 2 4 1 1 6 0.5 6 5 4 3 5 3 3 6 / BOR 000864 EXHIBIT B -16 (4) USDOL/OSHA r Exhaust Time - 15 Min. * Polymerizer Vapor Concentrations Vinyl Chloride, ppm - 30 Min. Year 1964 1965 Date 9-4 9-5 3-1 10-27 11-8 11-9 11-10 12-8 12-10 Copolymer Resin Building 15 93 153 150 120 120 310 145 150 28 31 77 134 29 21 55 48 132 92 32 Suspension Resin Building 1 30 30 30 BOR 0 0 0 8 6 5 Year 1966 1967 Date 1-7 1-10 1-12 1-13 1-14 3-29 9-6 9-13 2-8 2-9 '2-10 2-14 2-15 2-17 2-20 4-14 6-30 4-26 EXHIBIT B -16(5) USDOL/OSHA Copolymer Resin Building 15 26 50 18 23 94 49 164 34 60 42 79 61 45 20 126 129 106 40 20 100 , : Suspension Resin BuiIdin* 1 > / Bor 000866 f EXHIBIT B-16 (6) USDOL/OSHA -Year 1967 Polymerizer Vapor Concentrations: Vinyl Chloride, ppm Date Copolymer Resin Building 15 Suspension Resin Building Building 1 111 Dispersion Resin & Latex Building 121 5-15 5-16 9-8 9-14 9-18 9-27 12-4 10-26 11-1 11-2 12-18 ZOO 120 73 32 ' 12 46 46 14 55 105 75 18 36 32 36 13 20 19 16 77 75 79 34 109 46 122 74 134 34 60 55 70 67 100 58 105 55 30 59 59 628 555 490 219 BOR 0 0 0 8 6 7 ( Year 1969 1973 Date 1-31 2-3 2-14 3-26 9-22 9-29 9-30 3-22 Copolymer Resin Building 15 131 38 11 54 187 101 84 176 143 107 217 2 10 3 -guspeimlon Reatn Building Building ------l---------- --U1 EXHIBIT B-16 (7 USDOL/OSHA Diaper*Ion Rea In & Later Building 121 BOR 0 0 0 6 6 8 i VCL MONITORING DATA Area Measurements Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons by the Flame Ionization Method EXHIBIT B -16 (8 USDOL/OSHA Building 121 111 Product Dispersion Resin and Latex Month JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 Average ppw 34.8 21.8 13,1 12.4 9.5 4,2 X Readings Above 50 PPM 10.9 3.2 0.6 1.7 1.0 0.9 Suspension Resin JAN. 74 FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 . 35.6 20.8 15.6 12.1 8.9 3.4 9.1 2.0 1.5 1.8 1.7 1.5 Z Readings Under 10 PPM 0.2 5.9 40.8 62.0 86.2 88.3 0.2 5.9 36.0 71.0 90.2 90.5 BOR 0 0 0 8 6 9 j EXHIBIT B -16 ( USDOL/OSHA Building 1 Product Month Sus pcns i on Rosin JAN. 7u FEB. 74 MAR. 74 APR. 74 MAY 74 JUNE 74 Average PPm ' 24.9 18.9 16.6 12.1 7.1 5.5 2 Readings Above 50 PPM --------------------- 3.0 0.6 1.3 1.3 1.2 1.1 Z Readings Under 10 PPM 0.4 7.8 21.0 73.8 90.9 91.2 15 Copolymers JAN. 74 30.0 FEB. 74 22.0 MAR. 74 15.7 APR. 74 13.1 MAY 74 15.0 JUNE 74 10.2 6.4 2.2 1.2 2.2 4.6 1.7 0.7 5.1 29.4 64.7 62.9 78.6 115 VC1 Recovery JAN. 74 Purification FEB. 74 27.0 MAR. 74 29.0 APR. 74 15.5 MAY 74 20.2 JUNE 74 17.6 - Data Not Taken 3.0 0.5 5.0 9.3 1.9 34.7 5.4 33.3 0.8 25.2 at 8 000870 EXHIBIT B -16 (10 USDOL/OSHA PERSONNEL MONITORING DATA - MAY-JULY. 1974 - Location and Type Building 121 Latex and Dispersion Resin - Building 111 Suspension Resin Operation Oiarging Cleanlng Recovery Pipefitter No. of Samples 4 2 2 1 Oiarging Cleaning Recovery Bagging and Drying 2 3 2 3 TWA Average 5 4 4 - 1 PPM VC1 Maximum 5 2 6 19 7 3 1 Minimum 2 1 1 7 2 <.5 <.5 / Building 15 Copolymer Resin Oiarging Cleaning fia8Ring Pipefitter 2 42 2 - 11 6 2 - 10 7 1 14 * ** - Building 1 Suspension Resin Oiarging Cleaning Recovery Bagging 2 _32 11 3 15 42 1 1 3-- Notes: Everyone wears respiratory equipment where the work atmosphere Is greater than 25 ppm or where operations and experience shew there Is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted ' average for employee exposure. All samples are collected by absorption on carbon tubes and tested using pas - chromatography. Source: Snell summary of Industry data BOR 0 0 0 8 7 1 EXHIBIT B-17(1) USDOL/OSHA MONITORING RESULTS FOR 44-M-NEW-C * North Area East Middle West Center Area East Middle West South Area East Middle West Atroosphcttc Vinyl Chloride Concentrations Suspension and Dispersion Resins Sample Description Vinyl Chloride Concentration, ________ ppm Wednesday, 7-19-72; 11:20 a.m. g] 44 a. 27, 6> / 000872 iI North Ar.ca East Middle West Center Area East Mlddle West South Area East Mlddle West North Area East Middle Wes t Center Area East Middle South Area Middle We s t Wednesday, 7-19-72; 3:30 p.m. Wednesday, 7-19-72; 9:30 p.m. 4. 6. 6. 4. 4. 4. 2. 4. 6. 96. 19. 55. 78. 29. 110. 78. EXHIBIT B-17 (2) USDOL/OSHA BOR 0 0 0 8 7 3 I EXHIBIT B -17(3) USDOL/OSHA Suspension and Dispersion Resin con 11. North Area East Middle West Center Area Eas t Middle West South Area East Middle West Thursday, 7-20-72; 10:00 a.m. Thursday, 7-20-72; 4:00 p.m. Mass Pclv Building Bottom of Prepoly (Charging VC1) First Level of Prepoly Second Level of Prepoly Third Level of Prepoly Near Vinyl Pumps (Outside) Tank Farm Near Vinyl Pumps Under Vinyl Storage Sphere \ 16. 4. 8. 12. 8. 12. 12. 20. 20. Qy* c. 6* 12* 6. ** (N*D*) BOR 0 0 0 8 7 4 l VCL MONITORING DATA Area Measurements Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons by the Flame Ionization Method EXHIBIT B~17(4? USDOL/OSHA Building Product Month Average ppm . Z Readings Above 6u PPM 512 Mass JAN. 74 23.8 Polymer!ration FEB. 74 15.5 MAR. 74 11.5 APR. 74 10.5 MAY 74 8.7 JUNE 74 8.9 5.1 2.0 1.1 0.6 1.4 0.6 A Readings Under 10 PPM 35.7 46.5 69.3 76.2 79.3 80.7 / 513 Suspension JAN. 74 17.1 3.8 and FEB. 74 14.5 2.4 Dispersion MAR. 74 11.0 1.0 Resins APR. 74 8.8 0.7 MAY 74 9.4 1.2 JUNE 74 8.8 0.5 39.1 66.0 81.3 78.8 75.2 75.9 OOO8 7 5 ( axtUBir ts-17(5) USDOL/OSHA PERSONNEL MONITORING DATA TWA PPM VC1 Location and Type Operation No. of Samples Average Maximum Minimum Mass Resin Charging Cleaning Recovery 4 9 27 2 5 22 46 6 4 11 23 2 / Suspension and Dispersion Resin Charging Cleaning Recovery Drying and Bagging Tank Farm 7 3 3 2 2 11 20 1 33 32 4 785 1-- " - 1 Ni Everyone wears respiratory equipment where the work atmosphere la greater than 25 ppm or where operations and experience show there Is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography. Source: Snell summary of industry data BOR 0 0 0 8 7 6 i EXHIBIT B-18 (1) USDOL/OSHA MONITORING RESULTS FOR 3-M-INT-C Sample Point Number 38 39 40 41 42 43 44 ' 45 46 41 Location SE Corner, Lower Polymer Building SW Corner, Lower Polymer Building SW Lower Polymer Building Center of Lower Polymer Building N'W Lower Polymer Building NE Comer, Lower Polymer Building NW Corner, Lower Polymer Building Outside NE Polymer Building Front of Polymer Pit - Outside Lower Polymer Outside Breathing Zone Facing Toward Center of Building Facing Toward Center of Building Fan Level, in Front of Small Exhaust Fan Breathing Zone Fan Level, in Front of Small Exhaust Fan Facing Toward Center of Building Facing Toward Center of Building Facing Toward Fan In Front of 4 ft. Fan Facing Toward Fan In Front of 4 ft. Fan Facing Toward Fan Fans On 2 Off On 2 Off On 2 Off On 2 Off On 2 Off On 2 Off On 2 Off On On On No. Of Measurements 4 17 4 17 4 17 4 17 4 17 4 17 4 17 21 21 21 VCM Concentration^ PPM Average^ ______ Range Nigh Low 6 19 8 19 11 6 23 6 15 5 28 4` 8 27 325 48 15 175 33 8 38 13 7 31 6 43 1 V 0 0 1 0 1 0 1 0 0 1 1 0 0 10 32 0 12 115 1 BOR 000877 i EXHIBIT B-18 (2) USDOL/OSHA Sample Point Number 48 49 50 51 52 52 53 53 54 55 56 56 57 58 Location Breathing Zone On Slurry Platform By Shack - Wcstsidc Breathing Zone Upstairs Polymer Center of Locker Room Breathing Zone SE Corner, Upstairs Polymer Breathing Zone Across From Locker Room SE Corner Upstairs Polymer By Ice Tank Facing Toward Center SW Corner Upstairs Polymer Facing Toward Center SW Corner Upstairs Polymer Facing Toward Center Center Polymer Control Room Breathing Zone Center Polymer Control Room Breathing Zone Center of Upstairs Polymer By Reactor 307-308 Breathing Zone NE Corner, Upstairs Polymer Facing Toward Center NW Corner, Upstairs Polymer Facing Toward Center NW Corner, Upstairs Polymer Facing 7'oward Center West Center Monomer Pump House Breathing Zone Center of Monomer Pump House Breathing Zone Fans No. Of Measurements 21 On 16 Off 5 On 21 On 21 On 3 18 3 18 21 On 21 On 3 On 18 On 17 Off 4 On 17 Off 4 VCM Concentration^ PPM Average^ Range High Low 28 105 0 5 17 1 3 52 7 25 0 / 16 134 1 16 22 6 17 52 2 2 21 14 101 0 16 100 2 12 45 2 7 11 4 22 326 0 6 24 1 27 52 1 4 16 0 24 62 2 BOR 000878 I EXHIBIT L 18(3) USDOL/OSHA Sample Point Number 59 79 80 Location East Center Monomer Pump House Hose Connect House on Slurry Tank Platform Wind Vector Opposite Side of Property* 1 Breathing Zone Breathing Zone Breathing Zone Facing Toward Wind Note: (1) () Measurements taken by Century Organic Vapor Analyzer Snell average of data submitred Source: Snell summary of industry data Fans On Off No. Of Measurements 17 4 16 5 VCM Concentration^ PPM Average^ Ran^e High Low 9 23 1 37 62 9 46 186 3 1 BOR 0 0 0 8 7 9 BOR 0 0 0 8 8 0 Process VCM Tank Car VCM Storage Measuring Tanks Reactors Blowdown Centrifuge & Drying Bagging Source: Snell summary of industry data i! EXHIBIT 19 USDOL/OSHA MONITORING RESULTS FOR 9-S-INT-C Exposure 0) (ppm - VCM) unloading up to 100 Up to 100 / 25-30 25-30 EXHIBL J-20 (1) USDOL/OSHA MONITORING RESULTS FOR 42-S-INT-C 4 Shifts - Textile Workers Classification Production Reactor Operator (clean reactor) Dryer Operator Lead Operator Service Operator (material handling) Utility Operator (reactor guard) Maintenance Maintenance Workers Instrument Maintenance (part time) Electrical Maintenance Supervisory and Support Q. C. Supervisor Q. C. Technician Engineer Plant Manager Foreman Safety Engineer Lab Technician Analytical Chemist R & D Resin Chemist Number 16 12 8 4 8 5 4 3 1 4 4 1 5 1 2 1 2 % Exposure 100 100 100 100 100 100 50 - 60 10 - 20 30 100 80 - 90 BOR 0 0 0 8 8 1 ( EXHIBIT B-20 C USDOL/OSHA Lpcation Monomer Pump Station (open air) Pump House (open building) Storage Tanks (underground outside) Day Tank (outside) Reactor Room II 1 Reactor Room II2 Open Manhole-reactor (momentary) Open Manhole -exhaust in place Reactor during rinsing Reactor during scraping Screen (open once per shift) Slurry Tanks (open manhead) Slurry Tanks (closed) Slurry Tanks while rinsing Centrifuge Dryers Ragging Storage Area walkway between bags Bulk Storage Transfer Vessels Source: Snell summary of industry data Level ppm 0 0 - 150 0 0 0 - 40 (30 avg. ) 35 avg. 70 - 80 5-6 0-20 600 1000 3000 - 10,000 0 200 0 - 35 less than 20 0 - 100 0 85 10 - 20 BOR 0 0 0 8 8 2 Area Measurement* Using Portable and Fixed Instrumentation, Measuring Total Hydrocar bons by the Plane Ionization Hethod EXHIBIT B -21 IJSDOL/OSHA MONITORING RESULTS FOR 14-M-INT-W . Building 812 Product Suspend' i'r, in Month Average ppm JAN. FEB. MAR. APR. MAT JUNE 74 74 It* 74 74 74' 27.4 14.8 18.1 15.9 12.4 . 11.2 A Readings Above 50 PPM 2.6 1.8 2.4 2.2 0.5 1.3 X Readings Under 10 PPM 25.1 24.4 57.0 49.5 23.1 90.7 BOR 0 0 0 6 8 3 EXHIBIT B-100 USDOL/OSHA MONITORING RESULTS FOR 13 Operatlou No. of Samples Average TWA PPM VC1 Maximum Mini mtim Furnace Operator 13 2 11 Nil EDC Synthesis 5 0.2 0.4 Nil Purification 17 1 4 Nil Tank Farm 10 10 25 1 NOTES: Everyone wears respiratory equipment where the work atmosphere is greater than 25 ppm or where operations and experience show there Is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography. Source: Snell summary of industry data BOR 0 0 0 8 8 4 i Operation VCM Production Tank Car Loading Control Room EXHIBIT B-101 (1) USDOL/OSHA MONITORING RESULTS FOR 24 No . of Employees Exposed 20 2 N.A.*1) VCM Exposure Level (PPM) 10-15 1 6-16 < 0.3 BOR 0 0 0 8 8 5 i EXHIBIT B -101 (2) USDOL/OSHA PERSONNEL MONITORING DATA MAY - JULY, 1974 TWA PPM VCL Location and Type Operation No . of Samples Average Maximum Minimum Suspension Resin Charging Cleaning Recovery* 1 3 3 3 361 34 2 24 1 Notes: N.A. = Not Available i (1) Operations personnel spend 75% of time in control room / Everyone wears respiratory equipment where the work atmosphere is greater than 25 ppm or where operations and experience show there is a risk of exceeding 25 ppm. Personnel monitoring samples are taken over a period of time generally 4 hours to obtain the time weighted average for employee exposure. All samples are collected by absorption on carbon tubes and tested using gas chromatography. Source: Snell summary of industry data BOR 0 0 0 8 8 6 i Area Block I Block II Offsites Control Room Office Maintenance Laboratory Ship Loading TABLE 1 t Current VCM Exposure Levels (TWA) VCM (ppm ave.) VCM (ppm range) 2 .0 .1 to 15 1 .2 .1 to 8.6 3 .5 .1 to 66 0 .7 .1 to 9.5{1> 1,.4 .1 to 29 2,.0 .1 to 50 4..3 .2 to 50 3. 1 1.4 to 5.5 EXHIBIT B-102 (1) USDOL/OSHA MONITORING RESULTS FOR 15 No. of Data Pts. Measuring Device 28 J2) 24 (2) 43 (2) 56 (2) 52 (2) 129 (2) 42 (2) 4 (2) BOR 0 0 0 8 8 7 ( TABLE 2 Current Results of VCM Area Monitoring EXHIBIT B-102 (2) USDOL/OSHA Area VCM (ppm ave.) VCM (ppm range) No. of Data Pts. Block I 8.6 0 - 119 270 Block II 6.9 0 - 124 270 t Offsites 15.3 0 - 898 260 Control Room 1.6 0 - 16.2 18 Office 4.9 0-2.1 25 Maintenance 1.4 0 - 4.9 14 Laboraotry 3.7 0-28 23 Ship Loading 13.7 0 - 278 73 Notes: (1) Employees in these areas are periodically in the process unit. (2) The measuring device used is a Bendix Environmental Science Division Permissible Air Sampling Pump. This device is worn by employees for time periods of 20 minutes to 8 hours. It detects VCM by carbon adsorption and is analyzed by flame ionization GLC. BOB. 0 0 0 8 8 8 Source: Snell summary of industry data t EXHIBIT B-103( USDOL/OSHA MONITORING RESULTS FOR 34 INDUSTRIAL HYGIENE SUR/EYS OF VINYL CHLORIDE JOB CLASSIFICATION levels in raa-ER pla/it no. i ' TM, pph Vinyl Chloridf A Control - Section I C Control - Section I A Control - Section 11 B Control - Section III A Control - Section IV Class I Oerator ' ) No. of s/tf-jPuzs m 3.7 8.2 1.8 1.1 6.9 1.8 1SZ2 J 0.7 6) 1.3 (3) N.D;*(3) 0.6 (3) m 2.1 (2) 3.6 1.0 (3) 0.6 (3) 8.9 (A) -- N.D. = NON DETECTED BOB 0 0 0 8 8 9 ' jmmmmw A Control - Section V C Control - Section V Sr, Asst. Che;i. B Supervision Hmntenance Leading Operator Overall Avlrage ( ) No. OF SWPLES *N,D. - NON DETECTED TWA, pm Vir.'YL Chloride m 19Z2 1973 1.6 3.5 5.1 2.8 3.7 (10) > 0.2 G) J 14 (3) 1.3 6) 1.7 6) ' 45. G) 7.0 (27) 5.2 (2) 3.3 17.6 (2) 1.2 (3) 2.0 (5) ` 1.1 G) 4.2 (29) BOR 0 0 0 8 9 0 i INDUSTRIAL HYGIENE SUWEYS OF VINYL CHLORIDE JOB CLASSIFICATION LEVELS IN moe PLANT NO. 1 TKA, ppm Vinyl Chloride 1979 1st Otr 2nd Ofr A Control - Section I 1.0 9.1 C Control - Section 1 5.9 11,5 A. Control - Section II 1.8 0.6 B Control - Section III 0.9 0.9 A Control - Section IV 0.9 . 5.9 Cuss 1 Operator 10.8 ^0.1 A Cgwwol - Section V C Control - Section V . , 0.7 1.0 1.9 BOR 0 0 0 8 9 1 TM, ppm Vinyl Chloride 1974 1st Otr 2nd Otr Sr, Asst. Chem, B 12.7 Supervision 4 Maintenance 4 2.9 (4) 1.7 (4) Ld/ooimg Operator Dev. Lab Overall Average 16.5 (3) 0.9 (4) 4.4 (24) ( ) No, OF SAMPLES "Peak Exposure measurement were made for this job. # 2.7 (5) 2.5 (4) 6.8" 0.9 6) 1.9 (20) l INDUSTRIAL HYGIENE SURVEY CF VIIfYL CHLORIDE JOB CLASSIFICATION Loading Operator LEVELS II! fOTER PLAITT No. 1 OPERATION - PEAK FXPOSIJRF PPM VO'1 Minnies Disconnecting Lank Car* 20.A 26.9 35.9 30.9 161 A8.1 26.2 22.9 8.0 5.9 26.8 5 10 16 6 8 7 8 5 9 17 13 BOR 0 0 0 8 9 3 JOB CIASSIFICATION OPERATION - PEAK FXPOSURF ppm VCT1Ninnies Sr. Asst De-i B SAMPLING Product Tank 90.2 59.0 70,A 11,7 13.9 7.5 7.6 5.7 9.7 0.5 3.8 : *FrT:SH AIR MASK KORN s* 10 6 10.5 2.5 A 3 A 2 5 5 2 BOR 0 0 0 8 9 4 Source: Snell summary of industry data EXHIBIT B-1MTX) USDOL/OSH/. MONITORING RESULTS FOR 50 LEVELS IN TUTOR PLANT NO. 2 ABELIMMim Sample Period - V25/7N - 6/4/7N No. OF SAMPLES - R99 EACH LOCATION LOCATION VCT1 Concentration, ppm Co.'jtrol Roor-i Laboratory Loading Rack - Ayeraoe ;____ 0.3 0.^ 0A Maximum 7 A 9.1 IL+<1) Product Tanks 0.5 7.2 Furnace Area - 1 ( ) NO. OF SAMPLES 0.3 11+(1) I LEVELS IN im-ER PLANT NO. 2 mmiuom Sample Period - A/25/74 - 6/4/74 No. OF SA'-'PLES - 099 EACH LOCATION VCfl Concentration, ppm Furnace Area - 2 Finishing Area - 1 Finishing Area - 2 Finishing Area - 3 Finishing Area - A Average________ Maxi mm 0,5 11+(1) 0,3 U+Q) 0.7 7.5 0.5 lI+0) 0,6 U+G) ( ) NO, of samples BOR 0 0 0 8 9 6 I unuiOH ) (3) s* JQILdfiSIFICAIlCi LEVELS IN IOTvER PIATfT NO. 2 TWl pm V'iwyi rnn>n " 1973 ______________isa Operations Specialist Sr. Op. Teckjician 1.5 (2) - 1.3 (8) 0.2 01) Op. Technician 1.2 (2) 2.2 (8) Day Operations 1.2 (2) 0.6 (9) Lab Personnel 9.5 0) '1.6 (8) Shift Supervisors Office Personnel Boilermaker Electrician 0.4 (2) 3.5 1.0 (6) o.6 on 201 (5) '1,3 0) BOR 0 0 0 8 9 7 < i JOB classification INSTRUMENT Laborer MILLWRIGHT Pipefitter Loading Operator Marine Operator Tank Car Cleaner Overall Average__ LEVELS IN IDiiae PLAffT NO. 2 ' 1973 1.9 9.5 9.9 9.5 9.2 teL-PlOEIDE. _ _JL979. 1.0 (5) 2.6 6) 1,9 (9) 9.7 (6) 10.2 (5) 1.3 (6) 3.7 (2) .2.2-07) . ______11 (901 Source: Snell summary of industry data BOR 0 0 0 8 9 8 i EXHIBIT B-105 (1) USDOL/OSHA MONITORING RESULTS FOR 38 Loading Techn UlVL'LS IN MOfKI-IER PLANT 3 UxRATIOiT PFAK FXPOSURF PPM VQ1 MINUTES Disconnecting Tank Car B.3 10 Lab Techn Repair Techn * "Fresh air mask worn Sample Analysis Opening LaUlfTEITT 2l, 6 1.1 1.0 10 10 10 BOR 0 0 0 8 9 9 i o o o10 o o ( 4 44M fcA -U J. A XJ *N jsMummm Disttj, Tecim Reactor Teok - 1 LEVELS IN HOTO-ZR PLANT I'D. 3 OPERATION PEAK EXPOSUPE PPM VCH MINUTES Equipment Surveillance ,6 2.3 10 10 .3 10 , EQUIPMENT Surveillance .6 .3 .3 10 10 10 JQB_CL&SS1FICATICN LEVELS IN TONOKER PLATO NO. 3 M/ ppm Vinyl Chloride m. 1st Otr 2nd Otr Reactor Techn - 1 Reactor Tecwm - 2 Reactor Techn - 3 Disttt. Techj Control Ctr Techie ( ) NO. OF SA'IDLES 1.0 N.D.* 0.1 L 0.1 ___ ZO.l 6) 0.1 (2) 0.4 0.8 (2) 0.4 6.4 0.5 (2) 0.1 3.4 (4) *N.D. = NONE DETECTED^ BOR 0 0 0 9 0 1 i cr3 r-H BOR 0 0 0 9 0 2 JPP>, CLASSIFICATION LEVELS IN mU'ER PLAILT NO. 3 -M, ppm Vinyl Chloride m 1st Ofr 2nd Otr Lab Techn Loading Techn Repair Techn Supervision Services Techn OvuR/M-L Average ( ) NO. OF SAMPLES 10,N 6.1 (2) 2.1 12.3 (5) 0.1 AO.l N.D.* -- -- ----------------- 1.7 (8) 1.2 G7) 7 A 6) 6.3 OA (7) 0.3 0.9 1.2 (21) *N.D, = NONE DETECTED Source: Snell summary of industry data i EXHIBIT B-10G(1) USDOL/OSHA MONITORING RESULTS FOR 2 Area _ fchrit- Operation How ^Historical Current VC, ppm Measured VC. ppm *IIow Measured Polymerization 2.8 - IS Quality Control Lab 1. 6 Personal Sampler, Carbon Tube Warehouse 0.9 / EXHIBIT B-106 (2) PVC Area Emulsion Aytoclave Charge Operator Suspension Autoclave Charge Operator Autoclave Cleaner VINYL CHLORIDE EXPOSURE DATA SUMMARY PERSONNEL MONITORING RESULTS Dates 1974 No. Samples Average Exposure (ppm) Range .. ppm 3/14-3/15 2 2. 8 1. 5-4.0 3/14-5/3 3/15-5/2 15 7 3.7 0.1-7.8 5. 2 0. 3-13 Autoclave Cleaner L 3/14-5/3 First Floorman 4/16- 5/3 Ribbon Blender Operator 4/16-5/3 FCM Mill Operator Q. C. Lab Technician 4/16-5/3 4/16- 5/3 Hopper Car Load Operator 4/16-5/3 Bagging Machine Operator 4/29 11 14 14 14 14 1.1 1 75 5. 5-162 15 4. 1 3.7 1. 6 2. 3 0.9 1. 6-44 0. 6-13 0.2-12 0. 1-5. 6 0. 3-4. 4 - Remarks Within temporary standard / Within temporary standard No entry. Within temporary standard Vessel entry with mask. 6 samples above standard but exposure less because of protection. Within temporary standard Within temporary standard Within temporary standard Within temporary standard Within temporary standard Within temporary standard BOR 0 0 0 9 0 4 NOTE: Previous analyses performed are not now regarded as being reliable. Basel on obscrv itions following 50 ppm regulation, one location (autoclaves) was above 50 ppm and two other locations (centrifuge shed and water collection drains in polymerization building) may range above 50 ppm for brief periods. Fresh air masks are now used before entering an autoclave and the centrifuge shed. Measurement means for specific jobs was carbon tube-pump system attached to operators. Area and unit operation surveillance analyses were by Miran I and II infrared instruments and a portable Century OVA flame ionization hydrocarbon analyzer. / BOR 0 0 0 9 0 5 Source: Snell summary of industry data i APPENDIX C ECONOMIC DETAILS. APPENDIX C ECONOMIC DETAILS This appendix presents economic details supporting the findings and conclusions of Chapters IV and V. Exhibit C-l presents typical delivery times for key equipment items. Exhibit C-2 presents Snell's overview of the time requirements in implementing engineered controls for VCM exposure in PVC plants. A case study will be shown in the final report in this appendix for a PVC plant representative of the industry with good exposure data and assumed to be under a 1 0 or I!) ppm TWA compliance limit for VCM . ^ BOR 0 0 0 9 0 7 C-l i Item Pumps(1) Valves C ornpresson.(2) Reactor Vessels L'xmnrr c - ](]> usnoi./osiiA TYPICAL LQUIPMLNT Pn.IVKUY TIMI-S I'OU MID-11)7-1 t)ltl>i;RS Centrifugals Canned Nash Vacuum Viking (positive displacement) Carbon Steel (C, S.) Stainless Steel (S. S,) 1 la:n lloy S. S. to 1 5 hp lb to bt) hp 1,000 ACl'M 28" Vac. All sizes All Types C. S. and S. S. Other (plastic lined) Low hp reciprocating Medium sizes reciprocating Standard sizes centrifugal Large sizes centrifugal Medium sizes screw type to 10 hp 10 to 100 hp 10 to 100 hp over 100 hp Class lined Stainless 5,000 to 18,000 gal. Same sizes Mouths from Order to Shipment Pflivcty rrimc 1 0 11 - 10 12 M - 18 8 5 -G A -0 ti - 8 2-3 A -8 A -8 10 -12 4 -5 1C -2-1 Somewhat less than glass lined bor 000908 l field erected over 10,000 gal. Pump shafts, impellers, casing Valve parts Apilators for reactors Oashcts filter cartridges l/eat cxeliaupcr tubes c. s. s. s. I'm control instruments 1G - 20 10 - 12 0 - -1 3-d 1 -2 1 -2 fl - JO much lonj'er than (J.S. na " ' u l~'OICS: Sources- 1 lo itl'ins of standard construction can be obtained straight off the shelf in many instances (2) based on delivery schedules reported to be subject to substantial upward revisions Interviews with selected major suppliers and Snell estimates I'XllllilTC - 1(2) / 6 0 6 0 0 0 HOS t EXHIBIT C-2 (1) ' ' USDOL/OSHA SNELL'S OVERVIEW OE TIME REQUIREMENTS IN IMPLEMENTING ENGINEERED CONTROLS OF VCM EXPOSURE IN PVC PLANTS 1- TIIE NATURE OF THE ENGINEERING SOLUTION IS A MAJOR FACTOR IN THE DETERMINATION OF Till-: IMPLEMENTATION TIME From Snell's evaluation of the various measures reported by the industry several broad categories of engineering control measures to reduce area VCM concentrations and to forestall excursion have emerged, i Ventilation, including spot ventilation of critical pieces of equipment Modification of the loading/unloading equipment . Modifications to the reactors including automatic cleaning Improvement of the stripping equipment t BOR 0 0 0 9 1 0 w g o o o <0 H* i Others, such us: - ' piping modifications EXHIBIT C-2 (2) USDOL/OSHA pump and compressor replacement provision for adequate, contained venting of criticial pieces ol equipment, sections of piping, etc. (1) Ventilation Of Eii e 1 osqd Arcas And^ Spot Ventilation Of Critical Equipment Has Already ileen Substantially Implemented To Meet The Emergency Temporary Stands rd While indicating that substantial additions are still required to meet more string,cut standards, most of the respondents have installed some form of improved ventilation. In the Northern climates substantial additions to healing equipment will be required to maintain adequate temperatures in the enclosed areas. / The considerable ductwork and additional heating, necessary to implement the 1(1 fold increase in ventilation required in many plants, may require uji to l! months of design work, with another 8 months for procurement and 3 months lor installation. Thus significant venting improvements have a time delay of about 18 months. Comparatively minor work on spot ventilation can usually be accomplished in about 1/2 to 3 months. Necessity for spot welding and such may require a shutdown of at least part of the plant, which, for production reasons, may add a further delay to the implementation. EXHIBIT C-2 (3) USnOL/OSHA (2) Changes To The Loading And Unloading Facilities Arc Required, Somn Of Them May Require.! Substantial Amounts Of 'I'iine s The replacement of tlie present system of gauging the tank cars with more sophisticated equipment may he a major cost element to VCM producers who own and operate fleets of tank cars. A delay of 1 year to 2 years may be expected due to the large num ber of units involved. Immediately required changes to loading and unloading facilities pertain;: to venting of the connect-diseonnect line between tank car (or barge) and product storage. This can be accomplished by venting through a vacuum pump, and/or nitrogen flush and implementation is a matter of weeks, / (3) Leaks Around The Reactor May Be The Most Difficult To Control The problems of the leaks around the reactors have been fully discussed in Appendix A, and in particular Exhibit A-3. time needed in replacing or reconditioning the reactors is estimated at 18 to 24 months time needed in installing solvent washing system . * is estimated at 30 months and 24 months for water wash system BOR 0 0 0 9 1 2 EXHIBIT C-2 (4) URUOh/OSIIA (4) Improvement Of Stripping Would Reduce The Amount Of Free Moiionnir nownstrnam Of The Reactor, Hut hni^hmionlation _May_Bo Subject To Long Delays N I'VC manufacturers recognize lho advantages of improved stripping and sumo slops have already been implemented in many plants. . The problem in the implementation of improved shipping systems is that some manufacturer s are awaiting the completion of engineering development work before installing any interim improvement. A very important element in stripping improvement is the introduction of sparging steam into the stripper. Some plants will have to add steam generating capacity to achieve this, and thus implementation will be dependent on design, pi>inurement and installation of additional steam generating equipment. In this ease a delay ol up to 3 years can be antic ipated . / (5) Implementation Ollier Engineering Control Methods Is More Directly Related To Delays In Equipment Typical of such Engineering Control methods would be, lor instance: Replacement of reciprocating by rotary compressors (estimated delay 18 months) . Replacement of seal pump by seal-less (canned) pumps (estimated delay 1 2 months) . BOR 0 0 0 9 1 3 Repiping (substitute welded lor flanged) . EXHIBIT C-2 (5) USDOE/OSHA Replacement of flexible (or oven open channel) transfer lines with permanently connected piping. . Replacement ol open strainers with moie sophisticated (possibly self-cleaning) equipment. 2 THE NOVEL TECHNOLOGIES WllIC11 MAY HE REQUIRED TO ACHIEVE EXTREMELY LOW LEVEES ARK SEVERAL YEARS AWAY Due to the extremely proprietary nature of any new development, it is not possible to indicate engineering details of new technologies involved. Continuous polymerization has a good potential, but commercialization has not been achieved to date. The main areas of new technologies are: Radical changes in production methods. Cenerali/.aliou of the bulk (or mass) process subsequent to equipment improvements. Improvement of stripping. (1) Radical (Tangos In Production Methods Mav Be Under Development BOR 0 0 0 9 1 4 Continuous polymerization in totally enclosed, remotely controlled trains would obviously contribute to bringing the PVC plant to very low background levels. Appropriate equipment type, with a view to tin: minimization of leakage, could be incoiporated into the de sign at nominal incremental cost. EXHIBIT C-2 (6) USDOL/OSHA The table belcnv summarizes a potential timetable for the implementation ' of such technology . t Hyp(> the lieu! Conlinuous Poly_m erization hnp 1 enient a lion Com[dction Dat Develop Demonstrate Design I'roeure and Install January 107(5 January 1977 January 1978 January 1980 / A val iant may be utilization of part of present equipment. This may lead to a somewhat earlier implementation. Since the implementation of such a technology is a matter of economics, the added burden of severe limitations on VCM emission rnay actually help to spur its development by making it more economically attractive. 11 is to be noted that one respondent indicated the existence of such a technology but described it as "highly uneconomical". BOR 0 0 0 9 1 5 I EXHIBIT C-2 (7) USDOI./OSIIA The Bulk (Mass) Process May Potentially Be More Amenable To Low Area Levels Of VCNl Inherently the bulk process, which lias rio spoilt water stream, nor dryer {pis to be disposed of, should be more environmentally acceptable. At present too few plants exist in the United Stales to permit an evaluation of the specilie economic impact of engineering controls measures without disclosing proprietary data. The values reported by the one respondent using the Bulk Process both for the implementation time and for the costs per pound of capacity tire among the highest in the indusliy. i 9X6000 APPENDIX D PERSONAE PROTECTIVE EQUIPMENT AND HYGIENE / BOR 0 0 0 9 1 7 i APPENDIX D PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE This appendix presents the elements of personal protective equipment and hygiene as related to their purpose, costs, and availabilities. The appendix summarizes the relevant portions of the testimony at the public hearings and details which types of equipment have been purchased by the industry. All exhibits follow the text of the appendix sequentially. 1. REVIEW OF THE REGULATORY REQUIREMENTS PRESENTED BY THE OSHA VINYL CHLORIDE TEMPORARY AND PROPOSED PERMANENT EXPOSURE STANDARDS IN RELATION TO PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE ARE SUMMARIZED BELOW This section summarizes the requirements of employers in the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) producing industries concerning breathing equipment, protective clothing and personal hygiene as they relate to both the temporary and proposed permanent exposure standards. (1) The Emergency Temporary Standard (ETS) For Exposure To VCM^ > BOR 0 0 0 9 1 8 The ETS applies to any area or operation in which VCM is: manufactured reacted handled processed released repacked stored(I) (I) 29 CFR 1910, Occupational Safety and Health Standards Emergency Temporary Standard for Exposure to VCM D-l ( BOR 0 0 0 9 1 9 Wherever any monitoring sample reveals VCM at a concentration in excess of 50 ppm, or whenever any accident, such as rupture of equipment or spillage, indicates the likelihood of a greater than usual release of VCM into the ambient air all employees exposed to such concentrations should be withdrawn to a safe area the employees should not be permitted to re-enter the work area unless they wear either type C continuous flow or pressure demand air-supplied respirators self-contained breathing apparatus Work which may reasonably be expected to release VCM in concentrations in excess of 50 ppm, such as the repair maintenance cleaning of a reactor or other equipment containing VCM, should be accomplished only by employees wearing type C continuous flow or pressure demand air-supplied respirators or self-contained breathing apparatus. (2) The Proposed Permanent Standard (PPS) For Exposure To VCM^ The PPS "states that engineering controls are favored methods of compliance because they tend to avoid contamination of the ambient air in the workplace. However, until these controls are instituted it requires the use of respirators of the continuous flow or pressure demand types only. The PPS requires ' (1) 29 CFR 1910 Occupational Safety and Health Standards, Proposed Standard. D-2 i ( a respiratory protection program in accord with CFR 1910.134 should be established and implemented where respirators are required to be usfed by the PPS respirators should be used only in cases of emergency and where engineering controls or change in work practices have not as yet been instituted respirators or combinations of respirators for protection from VCM should be selected from among the following types: positive pressure full facepiece self-contained breathing apparatus pressure demand full facepiece self-contained breathing apparatus operating in the pressure demand mode combination type C pressure demand full facepiece respirator operating in the pressure demand mode and a pressure demand self-contained breathing apparatus operating in the pressure demand mode combination type C continuous flow respirator and a pressure demand self-contained breathing apparatus operating in the pressure demand mode Employee entering regulated areas should be provided with full-body protective clothing, footwear or shoe cover, at no cost to the employee. The employee should be required to wear this clothing. Where PVC powder contains detectable levels of VCM in handling, employee should also be provided and required to wear head covering required to remove all protective clothing at each exit from the regulated area D-3 / BOR 0 0 0 9 2 0 ( l'P required to shower after the last exit of the day clean protective clothing should be provided whenever contaminated or soiled, but not less frequently than weekly contaminated clothing should be decontaminated before re-use by removal for laundering or disposal Where employees are required by the PPS to wear protective clothing and equip ment, change rooms should be provided in accordance with 1910.141 (e) . Where employees are required by this section to shower, shower facilities should be provided in accordance with 1910.141(d) (3) . The PPS prohibits in regulated areas the storage or consumption of food or beverages the storage or use of smoking or non-food chewing products the storage or application of cosmetics / BOR 0 0 0 9 2 1 2. A SUMMARY WAS DEVELOPED OF THE STATEMENTS OF INDUSTRY AND GOVERNMENT REPRESENTATIVES PRESENTING COMPARISONS OF PROTECTIVE EQUIPMENT TYPES AT THE OSHA HEARINGS ON THE PPS This section presents summaries of selected statements of witnesses at the OSHA public hearings who gave test results on detailed comparisons of respiratory protective devices and protective clothing. These are presented in five exhibits. Exhibit D-l presents the statement of Karl Oelfke, Dow Chemical Company comparing the types of respiratory devices. Exhibit D-2 details the presentation of Dr. Joseph F. Tomashefski of the Cleveland Clinic also comparing various types of respiratory equipment. D-4 i 4. A SUMMARY WAS PREPARED OF SNELL INTERVIEWS WITH VCM AND PVC PRODUCERS TO DETERMINE THE COST OF RESPIRATORY EQUIPMENT AND PROTECTIVE CLOTHING UNDER THE ETS AND THF PROJECTED EXPENDITURES FOR VCM LEVELS BELOW THE ETS In this section of Appendix D the results of Snell's interviews with the VCM and PVC producing industry in relation to present and projected costs of respiratory equipment and protective clothing are presented. The exhibits detail: Purchased equipment and clothing types Capital costs Operating and maintenance costs (08M) / Procurement lead times . Relevant industry comments regarding topics such as human factors The information is arranged in the following manner: Exhibit D-10 summarizes the costs to the industry for protective equipment under the ETS. Exhibit D-11 presents case studies of cost profiles for respiratory equipment as a function of VCM levels and projected covered workers, including expected wearing time. BOR 0 0 0 9 2 2 D-5 Exhibit D-3 is another contribution of Dr. Tomashefski. This exhibit is an in-depth discussion of human factors relating to the use of respirators. Exhibit D-4 is a summary of the statement of Dr. Marcus Key, NIOSH, Cincinnati discussing breakthrough times of VCM in air purifying respiratory equipment. Exhibit D-5 is a general composite statement of several individuals relating to the human factors involved in wearing protective clothing. 3. BASED ON A SURVEY, SNELL COMPILED RESPIRATORY DEVICES AND PROTECTIVE CLOTHING TYPES INCLUDING DESCRIPTIONS , COMPARISONS , THEIR COST AND AVAILABILITY , This portion of the appendix gives detailed description and comparison of the various types of respiratory devices and protective clothing. Also included are their costs and availability to the industries studied by type and manufacturer. As in the previous section, an exhibit format is used for the presentation of the information. Exhibit D-6 is a general presentation detailing the procedure for the selection of the proper type of respiratory protective devices as a function of use. Exhibit D~7 is an in-depth of matrix presentation listing respiratory devices and detailing by type important topics including: function advantage disadvantage v - comparisons with other types - Bureau of Mines approval Exhibit D-8 presents the costs and availability of typical respiratory devices by type and manufacturer. Exhibit D-9 is a comparison to Exhibit D-8 as it describes typical protective clothing types and their cost and availability by manufacturers. D-6 BOR 0 0 0 9 2 3 i EXHIBIT D -1 UStOL/OSHA STATEMENT OF KARL OELFKE COMPARING TYPES OF RESHRATORY DEVICES AT OS1A HEARINGS ftgpbarory Device______ Nose-mouth cartridge or canister respirator (N-Ml Pull face canister type respirator (FF) w/face mounted canister Full face canister type w/chest mutinied canister Continuous flow air supplied hood (Acid Hood) Continuous flow air supplied hood (Acid Hood) Continuous flow air supplied full mash Self-contained breathing apparatus Portable breathing alt cylinders Advantages____________ Easy to don Small size Lightweight Easy to wear and carry Has larger canister than N-M type last longer Eye protection Is an integral parr of mask Longer breakthrough time than above Good head spill protection Good protection Best of air supplied breathing apparatus Mobility , Mobility . Long respiratory protection. Two hours at a demand of S3 L/mtn. _________ Disadvantages_________ . Interferes with certain types of eye protection such as gogglet . Can't lit all faces . Wearing of hard hat becomes difficult . Can't fit all faces . Bulkiness . Can't fit all faces . Foot mobility lot worker due to air hose , Bulkiness . Vision restriction . Lack of head movement . Poor mobility fot worker . Vision restriction , Poor mobility for worker due to air hose . Wearing of hard hat becomes difficult . Poor mobility for worker due lo air hose . Ah supply Is normally limited to 13-20 minutes In the pressure demand mode Breakthrough Time 100 cc canister has breakthrough time of 15 min. at l ppm VCM and flow ntte of 300 Llmltl. Acme canister of 300 cc size had breakthrough time to 1 ppm of 23 min. at 1000 ppm VCM, 1 ppm keaktlwough after 167 min. Same conditions as above. (NA) (NA) (NA) (NA) (NA) BOR 0 0 0 9 2 4 Source: KarlOelfkr. Production Manager for Vinyl Chloride, Texas Dlv.. Dow Chemical Co., Statement presented to USDOl/OSHA Hearings on Vinyl Chloride; Occupational Exposure Standard, (one 2~\ ll^d and Snell assessment. 1 v<* CXHMT H USDOL/OSHA STATEMENT Of D*. KVOTt F, TOMASHEFSKI COUpAMNG TTFB OP SPaATMF tQUPMNT AT OOiA HfAiP<Gl kaatdniocv Device l, Alt Purifying Type Furme Used to remove comaminants from an simi[dttrc that conaafna an adequate cooccnuaiton of {> IGt by volume). Method of Operation Work by chhe* filtration, adsorption, or a chemical reaction to remove contaminants. Advantages PlwAfWmi Ci&liui miika hive attached to dwm 1 unUitr corUSiniiig M adsorbent, Stack mSiki sic at value Ifl p4CCtlon agalntf: Organic vapors . Aciik Amnurda , Carbon dioxide keiftruon imNN to filter pnlciiltiti off* ip (vdikUoo i|ilM |utl dt vSpOn. All purifying respirators poduct hlffa MldiKi to breathing. Adequate lit to the face contour because *4 differences la ilu and *Iiape snd andimpologlcal characteristics Is itfta pobUm. Many times masks must be molded to Individuals--as a result leakage commonly occun. Tkey are very effective and they can The resistance to both impiraUon and a*firstloo causes mmt invUt effective and scUabln potKikt. woiketi to dliciid filter type maaki especially tf ibey can't to* (he du, yet thlt ilm*, qoq-visible dun may be mop harmful, Chemical cartridge type matkt ace usually cd the half mask variety, die chemical adsorbents (charcoal, soda lime, or tlllce gel) have very limited appUcetlcsi and are cf valua when uaod against vapors and gases of tow toxicity. To ptssn ebgglgg at An cullu and to dechim the wriaitrt to imnlik; It la peanlttakio to nhh the llhtt witM* suck uMta thus potsetfoo sgaiH particulates la not reqtdsed. / 3. Ait4>uppUd Usually employed for specific tasks ot foe hazardous cnvUonmenq, This type has a hose connected to an uncontamluatod air Source. They may be equipped ta/wo btowers ot they may have an altUoe attachment for continu ous ot demand flow. They may be used with full face maiiti. hoods, ot with full body suits. Many ah-supplied respuston employ a slight positive prosute in order to prevent inward icakt. They are good for haaordom environments not Immediately dangerous 14 life. When blowers sre employed with such respirators, it Is necessary to have so Individual attending the blower ot a stand-by. Such respirators pvuduce an increased resistance to breathing. They frequently have a long hoi* attached, which, la ksetf, may be a nuisance or a safety liasard. There are limitations on the maximum length <4 hose tkai can be used. Use w/o blower: <50 ft. Use w/blowae ISO ft, o 300 ft. On* mm be sum Am rsrepninf etr nfgiied la fran of CO end CO,. 3. ttlf-Ottalaod PbvUc complete respiratory |*qtoutou for any cMocmrstloo or toxic gar ur oxygen deficiency. rrctrurc^cmand type. The slight negative pressure Initiated by th Individual at the beginning of inspiiattoa triggers the valve so Uui the gas will flow as it is needed at an appropriate rate. They can be used with an alt touts* or an oxygen source. The self-conutoed appnralua Is heavy, bufity and retires highly trained Individuals for use. It U --r--ary wire* one apAoya selfcontained res^tewet to hove warning devices Indicating that the pttaauM eepfty la gmlag low. Source: Jcutpk f. T*m*ihcftltl. Ik-ad gf Pulmonary Disease Department t>f The t'.lcvclstaJ CUnIc, ptesened u UsDOi/OiHA beariitp BOR 0 0 0 9 2 5 I EXHIBIT D-3 (1) USDOL/OSHA STATEMENT OF DR. JOSEPH F. TOMASHEFSKI DISCUSSING HUMAN FACTORS IN RESPIRATOR USE AT THE OSHA HEARINGS - PROPOSED PERMANENT STANDARD GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE Problem Areas 1. Safely In Terms of FIi and Improper Sealing of Mask 2. Perspiration 3. Psychological 4. Respirator and Mask Dead Space Problems If a leak occurs at the mask, especially an inward leak, the toxic materials may be inhaled and a false security will be provided. There is a marked variability in the contour of faces-- therefore it is very important that any mask fit f comfortably, otherwise an individual using it over a long period of time may find a mask to be intolerable. When effort is expended and work is performed requiring increased oxygen demand, perspiration is not adequately evaporated--it remains within the ' ~" mask and produces an unpleasant effect. Toxic substance may become trapped between the skin and the mask causing local irritation. Allergic reactions have been known to occur. ___ Many people find the confinement and sense of * isolation distressing. Otheis are uneasy about the need to work in an . environment that requires the use of such equipment. It is very important that the individual not rebreathe exhaled air, and that the dead space in the mask be kept to <150 cc or that the mask be adequately ventilated to flush out the dead space. Otherwise there would be rebreathing of exhaled CO2 and a deficiency in inspired 0%, BOR 0 0 0 9 2 6 < GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE (Cont'd.) EXHIBIT D-3 (2) Problem Areas___________________ 5. Design Problems Associated With the Eyepiece on Full- Face Masks 6. Speech Transmission 7. People With Respiratory Diseases 8. Personnel Training in the Use of Respirators Problems . They should not distort the vision. . They do decrease the field of vision. . If an individual wears glasses, the glasses can become fogged or the eyepiece itself may become fogged. . The individual with bifocal vision may have difficulty in performing his task. . It may be necessary.to construct the eyepieces by means of special grinding with built-in lenses / , Anti-fogging compounds may have to be employed or a nose clip worn to prevent fogging of the eyepiece. . All of these can decrease efficiency and be uncom fortable and unpleasant for the individual. | . Upon movement of the jaws, the mask may become | distorted and leaks occur. I . It may be necessary to equip the masks with special | diaphragms, microphones, amplifiers, and radios to provide ability for communication. . People who have bronchitis, emphysema or chronic asthma should not be employed in work using res pirator. , This limitation knocks out a large segment of the working population (approx. 32% of all males and females over the age of 35). . Personnel must be trained in respirator use, workings and care. BOR 000927 1 EXHIBIT D-3 (3) GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE rCont'd.) Problem Areas 9. Maintenance of Respirators 10. Storage Problems . Masks must be inspected monthly. . They have to be cleaned and examined after each use. The washing should be done with soap and water or with detergent and allowed to be air or force dried. . Occasionally it may be necessary to sterilize the mask, because it may become a source for bacterial contamination and disease transmission. . Cleaning and repair stations have to be set up wWe masks or respirators are being used. . Storage is another factor that must be considered. Proper facilities must be provided to keep the respirators and their component parts in good condition. BOR 0 0 0 9 2 8 Source: Joseph F. Tomashefski, Head of Pulmonary Disease Department, The Cleveland Clinic, Statement presented to USDOL/OSHA Hearings on Vinyl Chloride; Occupational Exposure Hazard, June 25, 1974 and Snell assessment. % ( EXHIBIT D-4 USDOL/OSHA SUMMARY OF THE STATEMENT OF DR. MARCUS M. KEY AT OSHA HEARINGS - AIR PURIFYING EQUIPMENT TO VINYL CHLORIDE MONOMER BREAKTHROUGH TIMES Respiratory Device Test Conditions Breakthrough ' Comments Organic Vapor Cartridges Canister Gas Masks Gas Mask Facepieces , VCM concentration: 50 ppm . 5070 R. H. , Flow rate consistent with a 1 moderately heavy work rate . VCM concentration: 100 ppm . 50% R. H. . Flow rate consistent with a moderately heavy work rate . VCM concentration: 100 ppm . 50% R. H. . Flow rate consistent with a moderately heavy work rate . 10% breakthrough in 40 to 75 minutes . Service life decreases as R. H. increases . 10% breakthrough in 200-350 minutes . Service life decreases as R. H. increases . 1% leakage . Because the odor threshold of VCM is considerably higher than the breakthrough concentration, it is the position of NIOsfa that the only suitable respiratoiy protective devices for VCM are supplied respiratore or positive mask selfcontained breathing | apparatuses. . . ... Source: Marcus M. Key, M.D., Director, NIOSH Center for Disease Control, Statement presented to USDOL/OSHA Hearings on Vinyl Chloride: Occupational Exposure Standard, June 25, 1974 and Snell assessment. " " 8 626000 t 5 1' \'V bsdurtry Representative K. a OsllW' r.. Ha<# EXHIBIT CHI (1) USDOt/OSHA STATEMENT Of INDUSTRY REPRESENTATIVES CM HUMAN FACTOM HUTING TO PROTECTIVE CLOTHMG AT THE 0A HEANHOt Clothing lypt Full impervious pttaliid Mil Advantages Protective against vinyl cblorlde Full body Impervious air supplied full faventi vinyl chloride gas from contacting body Impervious gloves Rtwnh vinyl vbloftff from cwnciinti hand> Dfridrantages Placet worker In situation of unacceptable heal lUlU Prevents body heat and moisture fiom p*tng io die atmosphere Garment would guarantee longterm exposure to VCM If, by chance, tome of die gat emeicd the garment Gloves will diminish employee's dexterity ftyileMkil ccwKeuHwj A worker, while wearing such a wit In a test after 5 minute* tilting at 85 r ambient temperature, had a skin tempciature of 100,9 f. After five additional minutes of slow walking ihe skin temparature was Id). 8 F and the body tempera ture which had been Ufl,, 4 F at the beginning of the test, ntae to 102 6 F. Human Ficlon Suit tends to be a safety hasaaid because of lu bulkffteu and limited vblbllliy Heating Is difficult Commsnlcatton with otheis Is almost Impoiaible Commanfe The use of dib type mu dwuld be Ifmired so emergency sltuatloua / The hen and discomfort produced will produce fatigue reducing employee alertness fenpl/atlon generated by the wits will cause severe discomfort Reduction of employee efficiency due to cumulative effects of fatigue, tenure footing Reactor cleaners, requited by their Job to be sure looted, will be gieetly Impaired by bulk of suit fttmfum wages will he required so indue* employ*** ti wear Mb Recognizing me fact drat the wife tepicieni a safely haixrd. dte Secretary of Labor did not require tbeii use |* the catdnogeu standioh Employee efficiency will drop es much as 18ft when such suits ete worn Operators will find It difficult to operate controls and keep records, end maintenance men, parilcularly tamniment and electrical repair men, will nor be able ti perform dielr lobs safely and properly Because reactor cleaners ate Menri fled as a group of maximum risk they torrid be supplied with "pmiecbve" rather Man Impervious clothing and glouea la order to protect (hem flora sldn contact * BOR 0 0 0 9 3 0 I lodury >epmtmiilt H. H. Clothing Type Alf supplied win AJvmUgci Onioned for exactly th* kind of 4vntn a* icMUr cleiqliig D1sod ventages BtrdoMglcol conshtoroticnt IXHIlfT D*(t) Human Pictott People could work for longpuM of ilnn wearing air supplied suits tf the air w*i directed throughout die milt. Ifeqsl* 400*1 warn* db rypt ef equipment bocaus* It to trouble bod costs money Equipment can be met tf people Mm educated to use It and know the advantages and necessity for using It / Sanaa, (]) Written mbmUUon by K. H. OeWte. Production Manager It the Teaal DlvUton of Dow. Chemical L'.S A. ptaented ll the USDOl/OSHA Heating On the proponed pemtaneni ttanderd for aeaipotloiul rxpoure , vinyl dilotHn. |H tt. 1174 (1) Statement of r. F Hoy, plant managet. niaitona neitlci Company. feiryvtllc. Maryland pcteniad at USDOU/OOIA Haaikig an dia piopotad petmanant uandaid fot occupational capawn u vinyl cblotlda. My Id, IPM (3) statement of H.H. Fawcett. Chairman of dia Committee on Chemical Safety of the American Chemical Society at the USDOUOSHA Hearing! an die ptopoaed permanent llandard for occupational expaure so vinyl chloride. July 9, 1914. (4) Snell sisnnicfll. w 000931 EXHIBIT D-6 BOR 0 0 0 9 3 2 Note: Source: Numbers in parentheses refer lo llnreau of Mines Scltedules and Revisions thereof. After Bureau of Mines information circular IT.fl ( V Jtojtnwq Dwte I, AU forifyirut Device* 0) Mtdunlul Mw Hnwtium Wiftitwno> Owmlwl Cimkl>i to 8 AttUmtnw Ml AiHfying UcviUI MIIMU COmiMlIHIIItt from die aimoifriieic. Mechanical Filler Respirator* plOvtde respiratory protection agjirui paniculate imiki well a* non-voUulc dusti, nmU, or metal lum{H Selection nf tlte appro priate reipuiloi II iMictf Mil the type. toXiCity. a lid panicle Hie of (he parricuUH. tuaiuc. Chemical Cartridge tfcspimton i|M pnitcileo i^ilmi light cort- ebMraooM w , I',- by volume, depending upon ih* contaminant) of certain acid gases, alkaline gates, organic upon, and mercury vapon by utilising iinvuictiinikal filters >o punfy iIk inhaled ali. Method of Operertoe Umlutiont Venom ciicmtcali remove specific gam and vapon and r<tcrhamcal (Mien remove particulate mailer. Can he wed only in atmospheres containing sufficient oxygen to tuiiain life fit lean lt*> by volume at tea level} and with in specified coacentiitiioa limtUliwU of the specific device. They consist ctfentUlly of a toll resilient ficcpiccc of cither half-mask Or full-face d>;*ii;n, to which It directly attached one o( uvtiil type* of mechanical fillers made up of sonic fihrmu material Which icmovti (he harmful panicles by physical napping n air n mlialcd through tile material. Caieom matter well at alt Itself mi) pass through die filter, but wild or liquid plrtn lit arc napped in much lire amc manner a* ruck* and pebble* as wparattd tn>m wrwl In a screening process. The- filler must be highly efficient however n> tu>p the small harmiul particles. Mechanical filtei TCiptraum fe> not provide against giKt. vapors Or oiygen deficiency. They differ fmm mechanical filler ret* plraion only in lhai they we tr.iali cartridges cwltaliung chemicals io rcitsove harmful gates and vapon. Chemical Cartridge fietpiraaon are mmemergency respiratory protective device* and dwsuM never be wed In immediately dangerow atmosphere*. except far escape PWtJHMCt, However, to clarify this general statement, !l Will be well to list four other mayor negative rules wliirh apply o Chemical Cattndge Ikipnwa, . Ho not use Cbemtial Cartridge cumpitawn for pnxection against gaseous material which is extremely toxic in very small concentration* (carcinogens such ai VCM). Chi meal Cartridge Respirator* should not be used Iw exposures ui harmful guwuus nutter winch caiwmr clearly be detected by odor (tut h as VCM In CiifH.ciiirailt>iis < a.V ppim. tlwfel Hit The wefill life of m aii purifying device I* dependent upon the concentration of the coflumlnanu, the breathing volume of fee wearer, and the capacity of ha air purifying medium. UOUT 0*V 0) UfiDOAtMA compahson or KMMtor rvotvcnon dwku Mlnee Approval firtiedufe si Ofeer than fee differem between i half-maak feceplece end a fell facepiece, which is wod aim fee puticuUte exposurn |i harmful oe Irritating in fee eye* n well u fee rospicatwy tract, fee filter la die mo*i eacndal diuicWi among clawea of respirators, TT* most desirable coitiprosniic must be worked out lot each cl*si with respect to breathing ate* (tus), sestsunce to biuthing, efficiency ut filtering paniculate* of specific rise isoget and time maulrod clog the filter. ffrfcoriuta fifi Moudspucn type chemical crtndne myletm offer protection again*! iMtimiiuo capowit to light concentration* of gates aed vapor* ot m*y be used for seif-rote<x in rimes ef eetxrtic^hc. The mouthpiece design ptomotci compactoeu--such a irpintx can he con veniently carried by the workman durit^ all writing hours or stored coavcfecntly neat the work location for immediate avaltatdlity. * Combination mechanical filter-chemical filter resptiaion utilise dust, mist, or fume filters wife a chemical cartridge lor dual at multiple exposure. Respirators wtih independently replaceable mechanical fllscn are prefened fat tfe, type because the dm* filter normally plugs be fare the chemical cinridge It stkatMfi One combination mcchanical-cbemtcal filser retpiioior employ* e hack mounted filter Clemen* and it ctpecially Well suited fix tpray painting end welding upecationi. where fee air contaminant it concentrated la front of fee worker. 000933 t BOR 0 0 0 9 3 4 <Wap<l*U>fy Device (S) Gw Masks Application Method of Opinion Limitations Chemical Cartridge Aesplreton should not be used against any gaseous material In concentrations which are highly intutlr^ to the eye*. U>ful Ufa >MIm Amroil Obviously, Chemical Cartridge Respire Ion cannot be used for prelection agalost gaseous nuicrlal which It not effectively slopped by chemical hits utilized, regaidless of concentration. Gn matht haw been used effectively feu many yean for respiratory protection against certain gates, vapors and particulate matter which othcrwite ntight bt harmful to life or health. They provide simplicity of operation. compacillcu, ease of maintenance and economy. Use latga eaninett mounted on wcaren Because gas masks arc air purifying devices. rorto, uim principle of operation as designed solely ro remove specific conum- in ih cartridge syitctm. lorn* canisters Inanii hum the air, it is essential dut their located on chin. CaidAen differ from uie be restricted to atmospheres which contain cartridges In that they arc much larger sufficlmi oxygen to support Ufe (at least than the lauex. lOf. by volume ai sea level) and which coniam getwjally no mote than conceuuadotu of toxic gases and vapors by volume. The service llfoof anaupurifyl^ canister type |ti mnak ihpnwti on rht following factors: , The design, Includfi^ the quality and amount ofchemlcal fill, pactoog uniformity ant density, . Variable exposure conditions, In cluding concentration of totusmloenn in the air, bicathlng rate of the wearer, temperature and humidity. Generally, higher concemteiluni, breathing rates and humidify conditions adversely fleet service life. Since the exposure condition! are subject ro wide variation. It is most difficult to cMinute the service life of a gas mask caiuuer. However, for guidance purposes, actual man tutu performed under Bureau of Mines Schedule 14F stipulate the following minimum tervicc requirements at an average breathing rate u| 26 liters per minute In concemraiiotu uf V,, for most gases and vupori of Y% ammonia: TTtlfitiilo 11 - industrial bice ..Canister* 30 minutes Type N. Catdetef ..Acid ,, Organic Vapon ..Ammonia ,, Carbon Momustde IS mirutet 23 minutes IS minutes 30 minutes Super Sice Canlsten, because of their greater volume ofchemlcal All, will last approximately twice is long a( the equi valent Industrial Sic* Canister. Chm Sryle (..Jiuslen, because of their Small sine, dioulJ be ured |n cmicrtittailoiu not in excess of b. 3 DttftMT P-1 (I) Comma-- Csdissr KepUcemeee It la genamlly fct^mmendnd mat pa mam canlsten wed for emergency pwpam mould be replaced aher acb iw. Specific Indicatioos for csqlsut tapUremtu aad/ return to bath air are: If canisters with winds* iruicaioa diow the specified color cheap**. If any leakage is detected by mtll, Uste, eyes, nose oc mioat mtieilon. If lugh breathing mlsuncc mvefopa. If the centner shelf lift is eaccmfod. Warning Signs Specific warring dgm wht<* require Unmcdlaia return to fresh air are. Uncomfortable beat in the inflated air. (A piopvily operating canister will become warm on exposure so curtain gases or vapon, but a canister which hccomci extremely hot indicates dial concentrations above the centner limit have been encountered, > If naurea, dizzlne* or signs of dtures develop. BOR 0 0 0 9 3 5 ftopttamry Devine S. Supplied AitPevtcei 0) All Line fcMlnipii . Cinaro daw typea Awllciiton Provide ill (kid omxldc wuk* fcf torg ptriwli of Him, Method of Operation Umltadom Deliver breathing Hr through a tupply hote connected to the wtiarcn facepiece. Stoll be uied only In mmoapticwi not immediately tormful to life. All mum mun to located in clean uli and monitored frequently. UaMUfc At buy at alt U nyfllri etui rtfirr u mofonehln, tlks ilr* lint lupin (or it connected u> a miuble COrttpreued ill Wuru by tote of limit inner diameter and Hi it delivered to the met coniinnuuily or ipiermltcentiy in itrffirieni volume bi meet the wcarcr'i breathing requiiemenu. All-Line Hetpifuiort dull be ued only In tnwiptorei not immediately harmful m lift or from which the wearer cm eleapt without the uie of the itiptntor. Hii limitation U ArtciOry tocaute ito iiline ntytlitoi li entirely ikpttulent upon in a|r tu^fy which (t not dried by the wearer of the retpireior. If ihe Hr tupply hllit die weetvi u without mpimuiy protection end might not tttipe from the immediately fuSardooi aimotphciE, AhmIm-i limitation of eli-line tvipiteioti It ihM the air tupply tide lim|U die Wcatul M 1 fined dliUnce front (he Hr tupply routte. The bureau of Ml net approves Hi-linc teiptiatuu under Schedule 111 vdililt hat the following tlgoiftcant requirement*. The maximum tot* length for which appruval It granted u 2 SO leet. and the maximum pcrmtttible inlet paeuure li 125 p*tg. Approval it toughl fc tpeciftc forte length* and inlet prcttiuet. With the lungcu lane lengrbi for which approval it toughr auemMed to the reiptiiioi, and the foweti Inlet pretmm introduced to the air supply host, constant flow unlit mull deliver at Idit four cuUc feet pet minute (CFM) measured at the face piece. Hie exhalation retinanee at g& Ui*n per mlnuu than not exceed one (1) inch of water-column height. Wtaeo hehncu ot hoods arc mod, ihc canto requirement* must be met except that (he flow rate mutt be at leatt tlx (b) cubic feet per tnlnutc. For both type* f aisembUca with the lugheu inlet pteuute and shortest bote length, itte maximum flow dial! not exceed fifteen (IS) cubic feet per minute. Corenqt flow erdta am seenrally uted when dkea* la an ample Hr supply such r provided by an au compressor. Constant-Flow Air-Line Rciptrauxi with faceptccei afone are used where (etpluiury protection only n ncrdi-d, A hood can to added to the flccplnc for proieClion againti und or dht bfort Hid frcmrcinl) a ttclmcl k uted foi lint application with a hood or C4|>c HulJ io it. Such v'uo arc rued tiro for fcjJ grtot/mg iNMInei Ahwul Schedule 19 nr dm (> Oteiwiy equipment nek ea pamii-- mgtilems, ypmii rolfef nltw aw air filters mif tan wciatiy to amnia that fit air it at the paopei pacmiro and duality In All-line te^ioBn ere Anltoi la many typer, but then are throe bade c)**u. There ate coiutini flow, demand flow aid prettme dcnwnj fluw. wuh the retpitaioit quipped with toll maths Or full fatcpcca*. If eye protection u tequlml. a full face piece mutt be used. Ito air mppl^it rto leaponiiWbiy of the mar. rod chn tu>n mpuatot ti appouto for ute only when it tuppliM aeqilraht* au t the comet prorauro and flow. Tto eomprowed air thall meet tie muu mcem MMuiicmentt of Compretied Gat AuoctadM SfKdficatlon G7.1 for Type |. Claw D gateout air, Thlt cunently ujuMro that fo carbon monoxide level not titeod 20 jurti per million <rpm), the carton dtuxide conic* Hot exceed 1 OOP ppm, and kondxrued hydrocatbotu nut exceed 1 mtUigromi per itfoic With internally lubricated pUM-typ* tntopreaion, overlieatutg may produce carton nwaailh, routine teaung for carton monoxide or the ixaulU Hon of constant monitoring analyser It <k*jabu Some air compressors an mamifcc lured tpeeffically (o provide respirable alt. They ma Compicialnn teal uqujdt uh aa water or dlaphragmi foe delivedng the ait. ItoltiWlftfj Device , Dnniai lypti demand r/pa* Application__ Dfemud type lit pticnlljr mgj when only (ttnpKiial air cylinders tit lytltiblL KleAod of Operation________ Demand type atr--Une retpiiatnrr wtA half mnla or full faceplcici deliver air flow only during inhalation with cahalation to the atmosphere. fot thoae eondiilona Mien ibe posable invert leib|t nyted by die negative ptewuit Ailing inhalation alwayi present In demand lyricmi |i uoicecpUblc and there can't be Ac relatively high air consumption of die contuni flow unlit. It provide* a positive premise during boA inhalation and exhalation. Umliadon*_________________________________ A wtubk pwanwe regulator u required w enaute that Ac air la ai Ac proper pressure lot breathing. Tlx tame tegulaementf Air appioval apply to the demand type at to Uw constant flow units, except die minimum flow at a maximum resistance of two (*) iikIili of vjlri'ivlumn height mtamnd at the facLpitrce Aa)l be at Icatl four () cuinc feet a minute and not mow than fifteen (IS) cubic (eel a minute VIA all ltoc lengths within Ae inlet pteuutc range for which approval it sought. The cahalation teii.tincc t HS lltcia per minuk AaH u exceed otic (1) inch of water. It moil meet the tame tvuulrcmcnu At demand tytiemi Licept that the static prenurc |n die faecpieCc Aall tut exceed 1, $ inthq of water, the exhalation ruiliUnCc at 8& litcn/mmutc shall exceed tin; Hade prviauM in die facepiece by more Aan 4. 0 Indies of water and Aal Acre be at lean 4 Ct-'M o|r flow during inhalation before a negative pressure It dcveluped In A* facepiece. ______________ uaeftil Ufe (2) Hew lliih W1A btowo , VlAewi tibmcn tine mails with hlowcn may be approved by Bcntlao* foe respiratory protection to any atmosphere tvgatOiett of die degree of conUminilloti o< oxygen deficiency, providing clean* breathable air can l* reached within Ac dlktinte of die permissible how length. lower forces air law math. lloae mask* wlAout blower* arc uied when takconuiMlncted air can be reached vltbln a ihnance of IS feet. Wearer tweet air Into math Arowgb hli own breathing. Mine marks with bluwert can be used wlA up to Aid ft of hose. |lic blower dtould always be used with Ah type of equipment, tbdy band driven blowcn are curretuly approved. The air how mutt have a JaiRc triable diameter* approximately one Inch, to. in cate of blower failure, die Vittel ran breathe through dw Itoic while Lscaping from dw contaminated arc*; and it rutwt be highly rcthiant to peirolcum vapor* * well at he able m withstand crushing Weight. I hit airuuAti for (he heavy wire ftinltitkd oukIiui iron of lion. mask luma. Can only be uwJ op Us a distance of 7j fLel. those unlit, ImwiVit, cany only limited approval and cannot be un-d mi dinmipiicrct iiiMnLillau.ly harmful us life, ftoreau of Mine* Approval. DHUIt 0-1 ft) juMlaaa Appaneal Coiwneoia f tW win has math awefntfy, hcrpirei, hameat, air bat, and blower, la unviliy packaged la a portable trunk. The blower opciaigi serves tie as a wandby or guart, wady us aid the work-' man in cate of mtdiap. BOR 0 0 0 9 3 6 I nHUT D-1 <*) tewtowry Office g. gcif-CoetUd BWaihUw Apparatw * Q) Oxygen Cylinder ftc breath ing and Utf-Cenenttee Xn*i AppUadom Self-eomaioed breathing appnw provide ecmptew nipiuu^ pioiecaon Id mlc |tui io4 when ilwjt ii uyfen deficiency Hie wearer U independent of die wnouMhof aunoiphenr because he ti bmatbing with a tyttem admitting no orntlde at*. the oxygen Bf ill wpply of the ippmaa lUelf ukn can of tv/aneny require menu. Method of Opotteit Self-coninined breathing apparent* ate divided into three bade iypc*--oxygcn cylinder tebreathfog, demand, and ielf*|ciicrating. UmlWUOM Mijm problem or limitation U bnlUien of appaietw. Uwflll Ufa Dependent oo dee of air cylinder* and, in the caw of die icbreathlng rypea, on the COj removal eoOUlatr. Tin oxygon cylinder icbteadtlng type The oxygen cylinder mux be infilled and dm 1b me today U the * lung-governed* caibon dioxide'tenuvfng chemical replaced type which automatically compensate* after each ute. A* la true of au mpirarary for the varying breathing demand of the protective oqulpnteot, training in proper tree liter, Jt contltu of a relatively imall and maintenance U essential fur the mott effl- cylinder of uimprLtied oxygen, nduclng dent operation. and regulating valves, * breathing b^, facepiece or mouthpiece plut note clip, The one hour urvtct life (or the self-generating and a chemical container to itnhirt carbon dioxide from the exhaled breath. type apparatus 1* bated on felt procedure* of Bureau of Mine* Approval Schedule 13 and In we a letter or lunger prelection period may rcsidl The lelf-gtrauung type met ihc bated on the utei and lit* level of exertion. principle of Kbienhing; but It fta* no mctharikal operating component*. Both type* funitluti in the tame ntamei and will be dticinied together. The high-prenure oxygen hum the Cylinder it reduced in preruire to a bre*ildng level by tucaw of a reduc ing and tabulating vlvt. In *une uAiO there i* a i oral*At IV" ptut a lungconiroUed valve wtuth add* any required additional flow. Other appatatui lav* only an adnmdun valve which deliver* the oxygen (torn the breathing bag to the weatet'i fate. Exhaled breath pa>*ct duwu another tube into the conUinei lulding lit* carbon dioxide removing chemical and then through a cooler. finally, die purified exhalation flow* Imu die breathing bag where It miXki with the Incoming oxygen from die cylinder. The nebreailuity principle pcimtu lire Hunt e(fi< kut ulilmailon of tin, *yt;eA uippty. lire cxhJicd fmJih t>nia*w both oxygen and .jfbon ,l|.tide H Hw human ktdy cmai.it i itly a mull part <>( tin "Xy;vn inhaled. Ik type* of cylinder rebreathing redo now maniftanittd an approved by the Bureau of Mine* (h two, dut* Ot four hour duration. Hie sclf-generadog type apparent* U approved by die Bomloe* lot one hour. > BuMinc* Aweml The inlf-|eMre(U| bwxdtiag apfi*w dlrtu* (mii conventional cylinder MbwathUg apparanw In that It aaUi a chemical caniiui idici twltw oxygen and removal the exhaled eaibon tfioitda la accordance with breaihing require menu. Ii ahmtnaici high prcauie cyluidctv. regulating vatrea. and other mechanical ampMnna. The caimer, which contain* potassium upwxtde, evolve* oxygen when comet led by die moliluie and Ciibon dioxide In Ihc exhaled breidl, and retain* foe cartwn dioxide and moisture. V Mining itnaa*rt U important at M aid* tn (xcveniiag lew lugging. In ute, the tell-generating unit cpetaiei a* oil** wbreadnng apparent* except that die wearer, utiog ihecauMct, mxhet hi* owu oxygen tanaad of drawl>i fcnm a compiciicd gai cylinder. Tie ouutaihfing featuie* of dm type ate lu simplicity of cuninxtlui and uic, and Utwr need for inatntenaut-c whnn com pared With hl^i pre hire apparent*. There am wvcral method* for refilling or tecbargiiq high pretkure air or oxygen cylindeo. Compfcuon art tomerime* u*ed, bul the Ample*! ad moat con vemajit mctllud it to CaKadc fium large Wpply In amaii apparaiu* cyliada*. BOR 0 0 0 9 3 7 t  , finfffory PevU ________________ Application `MliIuJoJ Orvraiion A the vltl cilulci lnl lie tomilncr, shq carbon dioxide it nmovti) by lh| chemical and the oxygen which it left it reused. I hat method of operation i|i|)|lti K> all utygcn cylindci Kbrvidl ing type apparatus at will *i 10 the sclfgcneraiing type. Limitations 'Useful Lift " (2) Demand Type Lfcmatid-cypn apparatus are available In differcru model) for specific application*. Of particular application io tome Induatriei it a fiton duration unit known at an * cm. ape ntaik. 4 It ii normally worn by a worker at dmcl wtien be u in an atva whv'lt a puicAlially lode atmosphere. above He eapaury of a gas milk exists, Area* io wiudi high plc-.iuxc ijIki arc piped fall toio iliit category. Another type uf dion duration unit it put on at the time esi|* n necessary, A work n.Jak type nf apparatus Is uied fot planned nuiMenarux work The apparatm U actually a iwo-fclJ unit. , A te)f`Ci>ftiatned apparatus with which the wcater can move freely about by uilng a imall cylinder to enter or leave the Untie atmoiphcre--cither routinely or in die failure of the main breathing VP'!- . There it a piQvtiiun for connecting a bore io tlc demand uyutaiw ,u tliai the wearer can brenhc Jurtnc* itic work pc nod from a large tylruLr winch hai a prctiurc reducing valve atiacheJ to pnhiJt; low preiturc for the connecting hore, Manifold aucmblici can be pre ttified to peitiin nioit than imu worker IO work from a common brcaihing kiuitc. It it imperative dial the imail emergency cylinder be uied w]il| thu type of appara tus oilutvlie, a failure of tire p|>ly from die Urge cylinder wold cxpie die wearer to tire toxic jrmovphcrv. All Coniiit of a high presort cylinder, a demand regulator connected either dire- tiy or by high-pressure tube to the cylinder, a facepiece and tube assembly with an exlialattun valve r valve), and a nikiliud of mourning Uw complt tc apparaiui on Hie body. Inure, the wcarct turns on the Cylinder valve after pulling on die facepiece, inhales at bivJtlniig pressure through the demand regulator to the facepiece and then txh.Het through a valve in the facepiece to the ^unwinding atmoiphene. AH demand apparaiui are relatively inefficient when compared with the rebreathtng iypc( becaute tire exhaled oxygen It releared u> the atmosphere imtead of being re-uicfi. Work nliJi typci are limited by the connecting hore width limits die free movement of the wcAtel to the length of the Irotc, It u nn an emergency type unit a>. fot ole, It requires Miiung up sumc auxiliury equipment. The Juration of the demand type apparent! depends on Mich factor) at. , The degree of physical activity of dm user; 'Die degree to whUh die user's breathing it increased by eacttcmenl, fear ot Ollier emotional factor); Typical demand rype appetaust tuch at the MIA 'Air Cub* art certified by Bummei for 16 mlnutet. Othere tuch at use MSA 'Alt Mask' are ccnffled for do minuter under schedule 13 for entry into and escape from IrrLiptrabk aiinoqdwfvt. There service life ratings arc based on tcita by die bureau of Minus on men per forming moderate to heavy work in each of the different types of work toll or bscathlng machine tests at a talc of 40 liters per minute. The uter should rrei expect to obtain the exact rated service life on each ute. The work being performed may bf more or iera Jtseiuioui. rhe degree of training or experience which (he user liii had wfib thir or Jnilfar equip ment, wiicdicr or not the cylinder il fully ihsrgvd ai tin. slart of die work period; , The fX'ttlblc presence In the comprested alt of carbon dioxide- conccnuailcre greater than (tic ,u4l nurinalky found in Jiumspliehc air. , I'hc aimosplicrlc pressure rhe cimditinn of tire apparatm i refer the current schedule 1JE, alt demand type apparatus mun reiisfy tests conducted at alihougit low temperature components wreh at norecup) w> induce fogging may be added if needed. Source; hade dements of Respiraroty Protection, '(me jftiy Appliances and Mwll leltpfume aurvey -tf Ke-ptremry Lquipment irwlusiry. DIIIT D-1 (f> BuM-i-o-et-Aorenvu-l-------------------Crennreut The term, demand regulator, nream that fir alj flow it on Inhalation tlcmaud, tuiomanuily reguladag itrelf in ihr desired level re compen sate for variations in bmiiii^ nendt. Demand tpparttua depend upon watching a preiaure gauge loic-un when the breathing supply hai dioppud to a point where die uct dium Kium to fresh air. A seir-aciwaung warring device it requited for bureau of Mir*,s ApptuvaL TTw wttnm device can be either audible OS tree increared hreatlting resistance to rttn the wearer to return so ktfi air. BOR 0 0 0 9 3 8 t EXHIBIT D-8(l) USDOl/OSHA COSTS AND AVAILABILITY OF TYPICAL RESPIRATORY DEVICES Respiratory Device/Manufacturer 1. All Purifying Device* (1) Mechanical filter respirators . Bausch and Lomb (B&L) . Mine lafety apparatus (MSA) . Scott . Welsh Catalog Number R 10 R 20 5-15-10 96000 S610G 79983 79984 8201-R 8004-R 8101-R 502-R .7080 7600-8 710G 7500-6B Components Description Lot Size Cost Pet Unit (1974 DoUats) Availability (Weeks To Receive After Order) Provides protection against dusts (single cartridge). Same as above but with dual cartridge. Replacement filters. Dustfoe 77 provides protection from dusts and mists having a TLV of not less than 2.4 million particles/cu, ft. Filters Dustfoe provides protection against finely divided aerosols up to 0.3 microns diametei (99.988b effective). Type "If* cartridge. Duo-seal dual cartridge high efficiency dust fillet (0,3 micron particles). Replacement cartridge. Same as above respirator but single caitrldge. Replacement cartridge. Protex dual cartridge respirator for dusts with TLV more toxic than 0. l mg/m3 full face mask. Replacement cartridge. Protex single cartridge half face mask. Static wool filter replacement. Up to 50 units Pack of 50 24-71 1 7.35 8.90 0,26 7.25 Pack of 50 72-143 144 and up 50-99 0.13 8,35 2.55 9.00 50-99 50-99 1 4 72-143 72-143 packages of 100 si. 8.99 2.80 45.75 1.34 5.50 0,13 Stock item Stock item Stock item Stock Item ^ Stock item Stock Item Stock Item Stock Item Stock item Stock item BOR 0 0 0 9 3 9 (2) Chemical caitrldge respirators . B&L . MSA R 21 5-15-21 8555C 41135 70853 78883 Provides protection against low concentrations of organic vapors. Organic vapor catridgc replacement for R 21, MSA chemical cartridge respirator for protection against organic vapors (0.1%). Replacement cartridge for 85556 , MSA same as 85550 but with single cartridge foT organic vapor. Replacement cartridge for 768*33 . 50-99 50-99 boxes of 6 72-143 100-149 72-143 100-119 I 10.70 1.51 9.70 1,45 9.30 2.65 Stock item Stock Item Stock Item Stock item Stock item Bor oo0940 Respiratory Device/Manufactuitt . Scott . Welsh 0) G*> masks . MSA . Scon Supplied Air Devices (1) All line respirators . Constant flow - MSA - Scott ' Catalog Number 8201 -OV 82004-OV 8101-OV 502-OV 7601 7500-1 457081 77705 457112 8833 8 679-1 184-OV 661-1 282-OV-L 457162 457181 4622-10 Components Description V' ` Duo-seal respirator for organic vapors. Dual cartridge Replacement cartridge fot 8201-OV Same as 820I-OV but with single cartridge Replacement cartridge for 8101-OV Full-face respirator for organic vapors. Dual cartridge Replacement cartridge for 7601 MSA Industrial size for up to 2^5 by volume organic vapors and toxic dusu with full face mask and body mounted canister Replacement canister for 457081 MSA chin type mask for up to 0.57b by volume organic vapors Replacement canister for 457112 Chest style gas mask for up to 2% by volume organic vapor protection with full facepiece Replacement canister for 678-1 (lOOOcc) Chin style gas mask for organic vapor protection (full face) 600cc replacement canister for 656-1 Ultra-Vue facepiece and low pressure control valve (16-1$ prig with 50 foot hose) Same as 457162 box with hyper-flo control valve (40-100 pslg with up to 250 feet of airhose) Zephyralr-complete full vision mask with belt mounted filter body and manual control valve. Adjust air pressures as follows with 3/8" ID hose Hose Length lft' to 50' SO' to U!>U` Pressure at Hose Inlet 8 to 17 psi 17 to ,10 psi Lot Size 50-99 i 100-499 pr. 100-499 100-499 i 72-143 packs with 6 pteces/pick 6-11 12-71 8-11 100 and up 18 and up 12-71 18 and up 50-99 1 1 18and up EXH1NT P-8 (3) Cost Per Unit (1974 Pollan) Availability (Weeks To Receive S 9.00 2.50 8.30 2.30 45.95 1.28 Stock item Stock item Stock Item Stock item 78.05 7.45 53.90 5.85 75.43 6.50 42.16 5.10 itock item Stock Item Stock item Stock item 3 weeks Stock Items Stock item Stock item 82.30 82.30 60.94 Stock Item Stock Item 2 weeks Respiratory Device/Manufacturer ' s Catalog Number . Demand types - MSA 7600A 457157 457165 - Scott 4637-1 . Hose masksA^ISA f' . Accessories for all-line systems - Compression systems/M'A - Pressure regulaton/MSA 457140 457142 32057 81857 46727 79030 66716 66709 68265 68858 - Air-lines and manlfolds/MSA 455020 455021 455022 939\il Components Description Low pressure (10-25 pti) full facepiece. Mask-mounted demand air-line respirator w/ultra-vue facepiece 30-125 psi/15-250 ft. hose lengths. Belt mounted demand flow air-line respirator w/uliravue facepiece 30-125 psi/15-250 ft. hose lengths. Demand type respirator w/full vision mask 50-125 pal/ 15-250 ft* of hose length. One man combination hose mask* with hand operated blow4 (Centrifugal) and 50 ft. of hose. San^e as 457140 but is a two man unit. "Clear air" blower that washes, cools, and humidifies air for 12 masks (Nash Co* compressor) Air-line filter for removal of dusts, mists, fumes at a final. Replacement chemical cartridge for 81851 filter (2 required). Particulate element replacement for 81857 filter. MSA pressure regulator reduces plant -compressor air pressure to the rated valve for the equipment. Pressure relief valve-16 pag. Pressure relief valve-25 pig, Required accessory when air-line respirators are operating from a high pressure cylinder 0-4000 psi hi-pressute gauge 0-200 psi low -pressure gauge . Air hose - 15 ft. long Air hose - 25 ft. long Air hose - 50 ft. long Murufold-4 man (snap-lire) Lot Size 1 1 1 18 and up 1 A 1 1 1 1-71 1 1 1 1 1 1 1 1 1 EXHIBIT D-8 (3) Cost Per Unit (1974 Dollars) Avi liability (Week* To Recet After Order) t 57.BS 95.90 95.90 75.43 668.00 972.00 Stock Item Stock item 3 weeks 60-90 day, 60-90 days 2,586.00 44.55 2.40 4.80 34.90 9.80 14. G& 94.35 16-16 weeks Stock item Stock item Stock Item Stock item Stock item Stoclc item Stock item 16.65 23.95 43.20 59.20 1 Stock Item Stock item Stock item 30 days BOR 0 0 0 9 4 1 I EXHIBIT D-6 (4) * Components Availability Catalog Con Pei Unit (Weeks To Receive Respiratory Devicc/Manufacturer Number Description lot Site (1974 DoUau) After Order) 3. Self Contained Reipiraton (1) Pressure d;m*nd-fuU-faceplece self* contained breathing apparatus 1. 3 MSA 95069 With single lens clear-vue facepiece and audible alarm 1 ISIS.00 Two weeks (3) Combination ptcuuce tknu id full facepiece reiprator and pressure* demand self-contained breathing apparatus 1.2 MSA 96395 Complete In carrying case / 1 699.00 Two weeks (3) Positive pressure full facepiece selfcontained breathing apparatus 1.2 Would be vety wasteful of compressed air Not available (4) Combination continuous flow respirator and a pressure demand self*eontained breaUdng apparatus 1, 2 would be very wasteful of comprised air Not available (5) Demand work mask w/quick-eonnect/ disconnect assembly which can be attached to primary air supply MSA 457159 MSA unit complete with ultra-rue facepiece assembly, speaking diaphragm, demand tcgutatoc, harness, and 12 eu. ft. capacity air cylinder in carrying case 1 496,00 S weeks 4. Cylinder Recharge! Synems MSA 66850 63851 66946 77WJ3 Cascading Sytfem for Cylinder Recharging Air coupler tee Alt pigtail Alt outlet connection, complete with gauge High presiurc airfiUlng hose. 5 ft, long. 1 1 1 1 17.50 22.95 34.93 24.30 Stock Item Stock Item Stock item Stock Item BOR 0 0 0 9 4 2 Notes. (1) Permitted types under the temporary r>0 ppm standard. (2) Permitted types under ihj proposed permanent no detectable standard. (.0 Stock iturns arc delivered in not more than one week. Sources Bauich 1 l.omb Safety Products Division <'arak>g, 1074. Mine Safety Appliances Respiratory Prmei. lion Cats Ini', 1074. Semt/Acine I'ro.iuus Ki_'.pmuny I'mucUuii I'gmpinuni and Accessories Cataki|>, 1971. W .Lit CiuLt 7 jt, ur,. ftt.nlts uf Snell urvey of the tu&jur.u.iry equipment maniifaeturm. i Protective Clothlne/Manu&ciurcr Disable Qothing 1, Coveralls, Hoo<h and Shoe Coverings. Clnes . Purafab . Aiiov Disposable* . Min Inc. , Hotter Rubber 9. One-Piece Pressurized Suits . MSA Penninea nothing 1. Full Imperviou* Pressurized Suits . American Opelcal . KCA Cataloe No. Components__________________ _ Desaiprion Lot Size 700205 520205 V-5 Cowrall made of Dupont TyvekC*) with elastic wrist and ankle for right fit. Shoe cover made of Dupont Tyvek(R) Hlghtop with drawstring for tight fit. Hood made of Dupont Tyvek (R) with drawstring for right fit around face. Coverall made of Dupont Tyvek (R) with elastic wrist and ankle for tight fit. Coverall made of Dupont Tyvek ^ with elastic wrist and ankle for right fit Disposable liquid proof glove*. 91783 Airfed pcaitive Internal presuie suit made cf vinyL Complete with attached hood with clear vinyl face piece. Room f<* respiratory protective equipment Designed for one me only. 100 300 144 1 EXHIBIT P-9 (1) US DOL/OSHA COST AND AVAILABILITY OF WlOTECTJVt CLOTHING 1974 Colt Per Unit (Dollars) Avdltbilin Note: Stock items are delivered in one week or less. } 2 25 0 61 0.40 2.00 2.00 0.21 Stock Ucm Stock Item Stock item / In developmenr 2-3 mottfaa befine available in quantity. Stock item 30 wcel 47 00 Stock item 6111 75096 33406 Vapor chemical suit prcnti/ized with self-contained breathing equipment Chempiuf^ suit complete with case, hood and iii supply system Used with manifold and airline sidi develops positive internal pressure. Rulleiucd Protection Suit can l*e wt*n with MSA air masks mn supplied with unit 1 1 1 298.45 393.45 178 12 0-0 weelo 15-17 weeta 6-8 weeks BOR 0 0 0 9 4 3 t BOR 0 0 0 9 4 4 Protective Ciothlng/Manufacturer Acid Retlmm Suit * MSA . Unlioyal , American Optic*! Cloth Work Clothe* . MSA EXHIBIT D-9 (2) Catalog No. Components Description Lot Stic 37108 31934 M3J-A27 MRO-957 9011 503-1' 512 524 Sun Ra/R) suit, vinyl coated nylon made to be decon taminated after each use. jacket has safety cuffs and is fastened with ball and socket fasteners. Pants have bib front and no fly. Rubber utility suit jacket has stand-up collar with storm fly front. Pants have bib front with no fly. All teams pressure welded. Neoprene coated on nylon jacket with attached hood with drawstring for tight face fit. Closed with storm fly front. Neoprene coated on nylon bib type pants with map nr. Acid resistant coveralls made of neoptene coated on nylon. Acid resistant jacket made of heavy duty vinyl with storm fly front. Acid resistant bib type pants made of heavy duty vinyl. Hood made of heavy duty vinyl with clear vinyl facepiece covering shoulders and upper chest. 1 12 1 1 1 1 1 1 1974 Cost Pet Unit (Dollars) * 47.50 11.50 11.65 0.45 25.00 25.80 22.00 48.70 Av.UiblUtv 2-3 week! t Stock Item Not leas than 2 months No less than 2 months 6-6 t.eek 6-0 week! * 6-0 week* 6-8 week! 39134 Coveralls made of synthetic fiber fabric Dynel* made to cover or replace the worker's street clothes. 72 18.60 3-4 weeks EXHIBIT D-9 (3) Protective Clothine/Manufacturer Catalog No. Component* Description Lot Size 1974 Cost Per Unit (Dollars) GlOVCS . MSA 3G688 Heavy Jury acUi resistant rubber designed with curved fingers and using high quality latex for pliability and chemical resistance over a wide temperature range* 12 * 4.02 2-3 weeks 37643 Flexible, completely coated with vinyl 12" gauntlet type. 12 1.71 Stack item # Pioneer Rubber N-31 Lightweight designed to give liquid tight protection. Glove is not particularly durable. 12 0.91 6*8 weeks / Boon . Uniroyal MB801 MB WO MB %l Knee length acid resistant rubber with steel safety toe. Knee length medium weight acid resistant rubber with safety roc. Knee length imported acid resistant rubber with safety toe. 12 12 12 16.90 1S.SS 12.70 Stock item Stock Item Stock item Sources: Dunfab 1974 sales brochure, Mine Safety Appliances 1974 catalogue. Uniroyal 1974 catalogue, Pioneer Rubber 1974 Catalogue and Snell Survey of Protective Clothing Manufacturers. w O o o <0 ite U1 I EXHIBIT I (1) USDOL/OSHA SUMMARY OF SNELL INTERVIEWS WITH VINYL CHLORIDE/POLYVINYL CHLORIDE MANUFACTURER RELATING TO PROTECTIVE KJUIPMENT PURCHASED VC or PVC Producer^ llM-Int.-c and ns-im.-w 27 20 and 21M-1M. -W Class of Protective Equipment Number of Workers Requiring Protective Equipment Respirators, half face air supplied Respirators Respirators, half lace air supplied 16-20 16-20 57 n.a: Cost of Equipment (1974 Dollars) *200,000 200,000 16, 000 N.A. Operating and Maintenance Costs (1974 Dollars) S 25,000 25, 000 N.A. N.A. Comments Several tripping accidentsbave been attributed to respiratoit and some of the workers are reluctant to wear them. Minute-byminute supervision requited to ensure use. 6 weeks procurement lead time. / 40L-New -K IS 19L-New-W 41L-OU-W 54M-New-C 1. Respirators, airline 2. Protective clothing Disposable coveralls Rubber gloves Respirators Respirators, airline Respirators, airline 88 20 12 16 16 60,000 30 30 4,750 14, 000 13.000 8.000 5.000 300 300 6,300 6. 500 5,000 5.000 MSA type. One Incident of face and scalp tath from use of air mask. Respirators. pressure demand ot continuous flow Same , 6,5 3 10,000 4,000 6,000 2,500 BOR 0 0 0 9 4 6 I EXHIBIT D-lO (2) VC or pvc Producer lOM-Nev M-lnt.-C 5L-01d-C 13 8L-Ncv-C 14M-Int. -1 Class of Protective Equipment Respirators, half face mask Respirators Protective clothing Coveralls Shoe coven Head coven Cloves Number of Worker) Requiring Protective Equipment 36 Cost of Equipment (1074 Dollars) 3 25,000 8 N.A, 40,000 Operating and Maintenance Costs (1974 Dollars) $ 5,000 Comments Worken complain ot dry throat and impaired movement. 12,000 / 1. Respirator Ailline masks Self-contained respirators Cartridge respirators 2. Protective clotltlng Waterproof suits Head covers, dust shields, gloves Resplraton Airline Cartridge 1. Resplraton 2. Protective clothing 1. Respirators, self-contained cartridge 2. Protective clodrlng coveralb Disposable suits 112 N.A. N.A. 81 SO 2 40 N.A. 23,500 7,025 2,312 Disposable clothing listed as operating cost N.A. N.A. 72. 000 2,400 1,500 67,000 15,000 5,000 | 118,000 ) *' 4,503 N.A. N`A. N.A. 36, 030 4,800 Scon type MSA type. Welsh and Scon type. There have been complaints by woiketa on wearing reipfratoa. Scon type. BOR 0 0 0 9 4 7 l EXHIBIT D-10 (3) VC or PVC Producer 49M-01d-C 44M-New-C 22M-01d-C . 9S -Int. -C SOM-New-C 35S-lnt. -C SIM-New-C 42S-Int. -C end 39S-New-C 28L-New C Class of Proiective Equipment 1. Respirators, air tupplied Number of Worker* Requiring Protective Equipment N. A. Cost of Equipment <1974 Dollars) $ 2.500 Cartridge 2. Protective clothing Hard hats Coveralls Waterproof suits 1. Respirators N.A, N. A. N.A. N.A. 37 3,300 1.250 21.188 2. Protective Clothing Respirators, continuous How airline Respirator Respirators, full face mask type C continuous flow Protective clothing Respirators 25 N.A. 76 N.A. N.A. 20,000 500 45,000 5.000 25.000 Respirators Respirators, bottle supplied air masks Self-contained N.A. 20 t IS.000 10,300 1.700 Operating and Maintenance Costs (1974 Dollars) Comments $ 4.800 120, 000 People with heart or lung problems have been advised not to wear reapirarors - have been reassigned to areas not requiring their use. N.A. 72,000 14,400 30,800 56,000 12.000 / One worker with history of asthma became 111 while wearing air line mask. N.A. 3,000 Soon type. Individual cases of workers refusing to wear trapbaton. 2-5 weeks procurement lead time. 26,000 N.A. N.A. 20, 000 N.A. 1-2 months procurement lead time. Problems in fitting masks on personnel with beards and mustaches. Increased absenteeism and refinal of overtime has been attributable to use of respiratory equipment. One complaint of ear problems caused by respirator use. BOR 0 0 0 9 4 8 i EXHIBIT D-10 (4) VC or PVC Producer 36M-Int. -C 46M*01d-C Class of Protective Equipment Number of Worker* Requiring Protective Equipment Cost of Equipment (1974 Dollar*) Protective Clothing Rain suit* Respirator* N.A. 200-300 $ 13,000 41,000 Operating and Maintenance Cost* (1974 Dollars) N.A. ______________________ Comment* $ 18,000 3 month* procurement lead time. Wooten have complained of nasal and throat dehydration. Note: (1) For meaning of producer code, see page II-6. Source: Result* of Snell interview with the VCM/PVC manufacturing Industry. NA = Not applicable. BOR 0 0 0 9 4 9 ( BOR 0 0 0 9 5 0 VCM/PVC Produce*' *<*> tffMl . 2$ 10 -NO DETECTABLE" No, of employee* Wearing totpliHon 2 65 lob CUBlftCidOQ Tank t*t unhiding Maintenance Ship loading Operating (lamplei, etc.) SAME AS ABOVE 9 Operating 12 Maintenance 2 Laboratory 11 Ship loading 40 2 Operating 9 Maintenance Uboiaiory J. Ship loading 11 Operating Maintenance 36 Supcrvliing and ni^ott 19 Ship loading 121 Normal operation Veuel Cleaning Routine maintenance 21 Non-routine maintenance 49 12 Normal opcralloj 12 Veuel cleaning 9 Routine maintenance Non-routine maintenance NOT FEASIBLE 1XHB1T D-ll (1) USDOL/OSMA Samite costs vs. number or covered workers iceding respiratort couirMEKT AS A FUNCTION Of VINYL CHLORIDE MONOMER LEVIU VT fROOUCER Waiting Tim* (frof > Hr. Day) 601b 25 100 a 60 15 ee 100 Inertmen'll Capital Cam (Pollan) *11,050 Opemdon* and MaintenaiKc Com (1014 Pollan) $1,000 ________Cwnnw Total rot B0 ppn Intel. HI.boo 1,300 / With no tnglaflDf impanforiMH. Wbh iiRliaarlin Impeow 100 100 100 100 18 I4t000 0,600 10 10 10 30 20 21 21 BXttBIT D*J| (t) VCM/PVC PiDducer 40L-Netr*V Tnl U TomJ Total Total Total VCU Level -GfL 60 26 No, of Employee* .Wearing Weirtraum 20 4 4 208 4 4 a 12 s 89 20 4 4 0 20 4 4 8 12 _4 88 Job Classification Reactor cleaning Latgt rtctoj operators Urge turtor iced operators Small reactor teed operators Smell reactor operators Rcacior iicpjftmeni ihLh ntptrvimr Dryer leads Dryer operators Dryer utilities Dryer shift tupenlvr Reactor cleaning Large reactoi operators Large reactor lead operate** Smell reactor lead operators Small reat.lor ope/aion Reactor rlnft tupcrvlaor Dryer leads Pryet apetaton Pryet utilities Dryar shift lupervlsor 12 8 _8 28 12 8 _8 20 12 B 8 60 88 186 180 Sampling Loadeo Maintenance Sampling Lnaden Maintenance Sampling Leading Maintenance Others All jobs Wearing Tima (frof8 Hr. Day^ 26% 3 13 26 8 ) 8 3 3 38 16 20b 40 6 3 3 18 S hciamtiial Capita] Coat* (DolLn) <60.000 OpeAdo* and Malmcftaece Cotti (1974 polled) 86*000 Ho laotata KA 10.000 8.60# 713 7 Ho locreaaa fof 7.000 13 80 Plan Level 12 7 HA 100 28 7 HA 100 360. 000 Ha BOR 0 0 0 9 5 1 I IXMBirT O-ll (9) VCWrVCftoAicw 30 Tout Tool tout Tool Tout totol VCWimtl -ffPH) _ 90 IS 10 1 50 29 10 TWA and 29 (Ceiling) I 90 29 10 Mo. or mp)oymo Wearing teiplmon n i2 110102 272 212 lob CMtttflmioa Loader Maintenance loeden Maimounce Loadeei Maintenance Other AU 5 Poly building petaotoel Poly building potonnel 70 Malofcntace, tectaical 70 70 Same as above 70 MOT tASBL 9 Charging polyi 9 Recovery polyt 12 Helper Bulk loading realm tttim Maintenance, pipelining Malnierunce, mechanics Mainit-fUfice, eUctnqlci Maintenance, instruments Pawing, lagging Same n above bur more uie of u ma* NOT fhASmX Wearing Time Ilk of 8 Hr. Day} 109% 11 62 7100 100 iBCHmmal Capital Com (Pollan^ I 4,000 Mo Iikrih MA Operation and Maintenance Com 11074 DulUnf *2,500 Mo iKitaat NA Ma HA 1 tto <60,000 a 10.000 MA to 1164 7,000 NA 11 16 1 91 No fnrraae BOR 0 0 0 9 5 2 ( IXHBfT D-tl (I) VCM/PVC Piofetft efrd-OM'C Tout VCM Level (PPM) SO (Celling) 25 (Celling) No, of Employee* _ Wearing Retpiraion 4 4 4 4 30 20 24 4 29 12 19 4 150 10 2 2 1 933 4 4 4 4 30 20 24 4 29 12 16 4 150 16 2 6 2 1 3J3 __ wt fob CUsalJleatlop Uiu charge operator Plastic latex operator Latex recovery operator Latex helper Charge opemoa Recovery operator* HRC operator! Utility operator* Helpca Dryer Operator! 9*ggcn Tisrufer operaton Maintenance mechanics Tank (arm operaton Foremen Day supenrtiOn Engineer! General foremen Department manager Latex charge operator PUttJe latei operator Latex recovery operator Latex helper Charge operalon Recovery operaton HRC operators Utility operaton Helpers Dryer operaton Ragges Trawler operator* Maintenance mechanics Tank farm operators Foremen Day tupcrvbon Engineer! General foremen Department manager Wearing Time ^oMHr.D.n 56 1 20 5 <1 15 25 20 <1 <1 <1 15 25 10 <1 <1 10 10 5 25 10 5 20 95 20 5 <1 <1 20 95 IS 5 9 9 lucremeiu I 0(41*1 Co*t* (Pollan) 92,950 Opamkn ltd Com (1274 Dollart) 94.000 Giimim n Helpca use bah air-fed m|tiiun and cupldfi type mptiiuo. The air-fed mputum im laed lot opening and cleaning fulymartzea and die cartridge reaptiiion aie u*e4 oa other k*bt where the concentration might be above 25 ppm ba below 60 ppm. / NA HA Whfc a 29 ppm celling the aaa *f cartridge Mi|4ram woeld be ellmUMtcd. The eae f air* fod raptora would be increased aal caaiair masks would be need, Increasingly, hocama d their longer Ufa and better mobility. BOR 0 0 0 9 5 3 tXUBlT D-U (|) VCM/rVC Producer 49M-OU< (cott.) Teal VCM Ural -P*M> 25 (Celling) 10 TWA SO it 10 (Celling) & TWA I of Employe** Weartrtff Rctplraton 4 4 4 4 30 20 24 4 29 12 18 4 ISO 18 2 2 333 61 61 61 lob CUrtflmkw Latex Charge operator Plante latex operator Latex recovery opeiatoi Latex helper Charge operators Recovery operaton HRC opentoq Utility u|eIoq Helpers Dryer operators Batmen Transfer operators Maintenance mechanic* Tank farm operaton Foremen Pay lupcrvlwn Inguteeit Cental foremen Department manager HOT f EASIBLE Sampling Draining equipment Opening equipment Repair* Above, plm taking readings u going Into i while any teak* exut on VCM equipment. Sime At above NOT FEAS16U Hoc*: (I) Ceiling levels antes otherwise Bated. (2) Foe meaning of jnoduccr coda kc page Q-6. Source^ SneU assessment ol rhe_faults of Interviews with VC/PVC ptoducea. Venting Time &#"* DvL 16 1160 3fi 20 10 66 40 6S 16 6 6 30 40 20 6 5 6 cl bmiWil Ctpitil Cfii (Pollan) HA Opsndoa and MiiaaiAM Cow (1974 Pollnn) NA Canmm Pm Alt Iml An wearing of tngniw etgl4 bo incraued u indicated. / f 613,100 fll.OOO IS No taono NA 20 No NA BOR 0 0 0 9 5 5 APPENDIX E MONITORING EQUIPMENT This appendix details the elements of monitoring equipment currently available to industry for the detection of vinyl chloride monomer (VCM) including their costs and availability. The appendix also reviews relevant material from the public hearings and lists the monitoring equipment purchased by VCM and poly vinyl chloride (PVC) producers. All exhibits appear sequentially at the end of the appendix. 1- A REVIEW OF THE TEMPORARY AND PROPOSED REGULATORY REQUIREMENTS FOR THE MONITORINQ OF VCM AND PVC PLANTS FOLLOWS" f This section summarizes the monitoring required under the Emergency Temporary Standard for exposure to VCM (50 ppm) and the monitoring required under the proposed permanent standard (no-detectable limit) . (1) 50 ppm Emergency Temporary Standard (ETS) ^ The ETS required that as soon as possible but not later than April 22, 1974, every employer of an employee working in an area or operation in which VCM is manufactured reacted handled processed released repacked stored should begin monitoring the ambient air of the area to determine whether it contains VCM' in concentrations in excess of 50 ppm.1 (1) 29 CFR 1910, Occupational Safety and Health Standards, Emergency Temporary Standard for Exposure to VCM F. BOR 0 0 0 9 5 6 i . The monitoring should be of the nature that a sufficient number of employees be monitored so that a representative sample of exposure to the gas may be determined. * - monitoring should be accomplished not less frequently than weekly until all results from three consecutive weeks are at a level below 50 ppm after achievement of the 50 ppm level, the monitoring should be conducted not less frequently than monthly as long as the concentration of VCM does not exceed 50 ppm if a monitoring sample reveals VCM in concentrations in excess of 50 ppm, weekly monitoring should be resumed until all monitoring results for three consecutive weeks are at or below 50 ppm f Monitoring should be accomplished through personnel monitoring by collecting samples by suitable device worn by the employee. the samples should be analyzed by gas chromatography or by any other method which is of equivalent sensitivity the analytical procedure shall be sentitive to 5 ppm of VCM in air with an accuracy of + 20% for a ten minute air sample Employees working in an area of operation whose ambient air is monitored, or their representative, should be given a reasonable opportunity to observe the personal monitoring described by the emergency temporary standard. Periodic tests should be conducted for equipment leaks and for emission of VCM which may result from work practices. BOR 0 0 0 9 5 7 E-2 (2) Proposed Permanent "No-Detectable" VCM Level Standard (PPS) ^ A program of monitoring would be required to establish whether there are detectable levels in regulated areas and to permit determination of employee exposures on an individual basis. A regulated area is where VCM is manufactured reacted .. released repackaged stored used PVC capable of releasing detectable levels of VCM is manufactured .. reacted .. released repackaged .. stored used Provision is also made for an employee to observe monitoring by them or their designated representative. The monitoring will assume that any exposure may be determined for each authorized employee with a confidence level of 95%. An authorized employee is one whose duties require him to be in the regulated area and who has been specifically assigned by the employer1 (1) 29 CFR 1910, Occupational Safety and Health Standards, Proposed Standard E-3 856000 any employee who enters such an area as designated representative of employee to exercise an opportunity to observe monitoring and measuring of VCM The PPS requires that monitoring be accomplished by a sampling and analytical method capable of detecting vinyl chloride at concentrations of 1 ppm with an accuracy of 1 ppm + 509d. The PPS is, in part, based on the NIOSH recommended Standard for VCM Exposure as transmitted to OSHA on March 11, 1974. The NIOSH recommendations are presented in their entirety in Appendix H, 2. SNELL PERFORMED AN INDEPENDENT SURVEY OF AVAILABLE MONITORING EQUIPMENT AND DETERMINED AVAILABILITY AND COSTS Exhibit E-l and E-2 present a summary of highlights of the testimony dealing with monitoring systems. Exhibit E-3 presents the proposed NIOSH procedures for VCM monitoring. Exhibit E-4 presents a summary of the Snell survey of VCM monitoring devices currently available; the survey sample included 9 manufacturers. Exhibit E-5 presents a summary of the availability and costs of VCM monitoring devices. Exhibit E-6 presents the results of the Snell interviews of VCM and PVC manufacturers relating to current monitoring procedures and equipment. Exhibit E-7 presents the VCM and PVC industry costs of purchasing monitoring equip ment in compliance with the 50 ppm standard. E-4 BOR 0 0 0 9 5 9 ______ Type of Equipment Gas Chromatographs (GQ Infrared Combustion-Conductivity Total Flame Ionization Detectors (FID) GC - Mass Spectrometry Personal Monitoring Equipment _____ Operating Parameters Flame ionization Gas-cell type Conversion by pyrolysis to HC1 and CO2 Combustion, but not decomposition EXHIBIT E-l USDOL/OSHA STATEMENT OF R. H. STEHL COMPARING METHODS OF VINYL CHLORIDE MONOMER ANALYSIS Advantages Disadvantages Reproducible at constant operating parameters; selective in identifi cation; 0.1-1 ppm sensitivity Cannot be used where explosion hazards exist; 5-15 min./analysis. Little interference; each com pound has characteristic bands; 2 minutes to make energy absorption measurement; 2-5 pprn sensitivity. Water vapor interferes and reduces sensitivity. t 30 seconds for analysis can be computerized. 2 minutes/sample analysis. Interference from other compounds (Freon). Non-specific. Magnetic field. Adsorption - onto media (air pump, sample tube) 1 ppm sensitivity; no Interference. Not applicable to area monitoring; reference method only; requires trained analyst. NA Non-continuous Source; Testimony of Dr. R. H. Stehl, Dow Chemical Co., Midland, Mich., comparing methods of VCM analysis as presented at DOL/OSHA hearings, June 25, 1974 and Snell assessment. NA = Not available. bor ooo96o 1 Type of Equipment Continuous Monitoring Equipment Sequential Monitoring Sequential Monitoring Sequential Monitoring Sequential Monitoring - Personnel Monitors i Operating Parameters Flammable gas detection NA GC, 12 point 15 minute cycle (Monomer plant #1) GC, 10 point 6 minute cycle (Monomer plant #2) GC, 10 point 6 minute cycle (Monomer plant #3) Non-specific analyzer combustion-conductivity type, 18 point, 1/2 minute cycle, alarmsat 25ppm (Copolymer plant) Exposure type NA NA NA NA NA EXHIBIT E-2 USDOL/OSHA STATEMENT OF R.L. DANIEL DETAILING METHODS OF MONITORING AND ANALYSIS OF VINYL CHLORIDE MONOMER Advantages Disadvantages Only alarms at 4000 ppm level. NA NA / NA NA Can only be analyzed after the fact; does not provide on the spot data* does not give min. /max. concentration in employee's work area. Source; Testimony of R. L. Daniel. Dow Chemical Co., Freeport, Texas concerning methods of monitoring and analysis of VCM used at Freeport, Texas as related at DOL/OSHA, June 25, 1974 and Snell assessment. NA = Not available. BOR 0 0 0 9 6 1 < EXHIBIT E-3 (1) USDOL/OSHA 1. SUBSTANCE: RECOMMENDED NI05H PROCEDURE FOR PERSONAL MONITORING OF EMPLOYEES FOR VINYL CHLORIDE MONOMER EXPOSURE Vinyl Chloride Gas 2. SCOPE OF METHOD: Vinyl chloride is a gas boiling at - 13.4 degrees C and having a vapor pressure of 2660 mm of mercury at 25 degrees C. The lower limit of detection for the method is approximately 1 ppm. 3. SAMPLING EQUIPMENT: / (a) Personal sampling pump (b) 250 cc glass gas collecting tubes with teflon stopcocks. 4. SAMPLE SIZE: 250 CC 5. SAMPLING PROCEDURE: Glass Gas Collecting Tubes (a) The gas collecting tube is connected at one end to the personal sampling pump. Both stopcocks are opened and air pulled through at approxi mately one liter per minute. (b) A sampling period of 15 minutes would allow collection of a representative sampling of the worker environment. (c) Stopcocks shall be closed tightly, closing the stopcock nearest the pump first. BOR 0 0 0 9 6 2 i EXHIBIT E-3 (2) .6 ANALYSIS: The gas collecting tube sample is analyzed directly by gas chromatography. 7. SHIPPING INSTRUCTIONS: The gas collecting tube should be wrapped with cushioning material, placed in the shipping case and shipped via Air Mail to the OSHA laboratory Salt Lake City. Source: N10SH Recommended Occupational Health Standard for the Manufacture of Synthetic Polymer from Vinyl Chloride, March 11, 1974. ^ Bor 000963 l Monitoring Device Example of Available Equipment (MafliiD<,tuter/Modtl i) PfctcrtptlOq _____Method of Operation _________ Sentltlvttv ()) Calarlinfirk (i) CIUiciiiI Tub*/ Pump 3yW*m (Autpmitad) Mine Safety Appliance*/ Model 8W2 BetbUx/Model 2a 17554 AnatoleJ. Slptrj Co./ Model SP-i k 7 Halogenatcd Hydrocarbon Detector. Detecting unit consists of two parti - a iuctiv tube and a glaaa detector tube, klnch ne Joined together fot (citing sample. The teacior tube holds two fungible gists ampule* containing them!* call winch ate min'd Immediately failure use and Ktve to oalduc thu halogen' ated hydrocarbon it leasing free C|, Or 8f,,. I he correct detector iiifa. ii elected lot the gai of imereti. The temple it drawn through the detection unit by an aspirator bulb assembly. The released halogen reacts with (lie chemical In the lube u form a length of stain In dication wldch it confuted with die number of atptrationt to give the concentration of the haJoginated hydrocarbon. ~0-350 ppm BenJlx/LijiLO 1'o.t hum Cat ln.itt.ioi system, Syitcm combines iwo proven nvc components (ot die ptctivi sampling a lei detection of ionic gate* and vapon, . Accurate, convenient dlft-it leading detector tubut. , A HKontype vU>- metric pump. Break off the Upa of a fresh tube. Insect into pump and pull handle which auto matically locks at 50 or IQocc sample. The absorbing media will Im mediately react to the gat or vapor being analyzed, and a constant color tuln la produced which will vary in length according to the concentration being measured. *>. 035-Vfb in 2.4 ivefcre Dimension! uf Slpin personal sampler pump. . Depth 1-1/4" . Width '4-1 /r , length 5-1/8" . Weight ' i: oi, fr Jr earned In breait pocket of worker's shirt or coat or In pouch clipped to the worker'! belt. Pump h med to draw a cunlnuouily measured vuIuiik of all llituugh a charcoal tube ftum a wOlka's breathing zone fur the duration of a worldm; stdli. M.tc ilun vi ;ht hours o' ciHiuuuout operation i an he p<utdrd heiun recharge 0> lire h*tWiv. The equipment uuUca a glais Can detect VCM lube packed w/acrlvaivd to <0,1 ppm charcoal through wldch an all sample containing a vapor such at VCM (t pumped. Tlie vapor Is quantitatively adaurbed by the activated Carbon. The VCM collected on the tube Is quantitatively with carton disulfide, and an aUuuot of the resulting mixtute It Introduced into a gas chromatograph. An altainiit to tO'heM tubes It il>L un o' plmk hags i# i olUci sample*, OtfaHT 1-4 n> USDGL/GtHA CSMPAWON OP TYPICAL MOwrTOVMC DgVICB MSD4TLY AVALAfU IDS VMYL CMIDlDI MONOMUl DrTBCTKM Calibration Procedi-- Level of Training Requited for Operator Necessary Support Equipment or Supplies Cfleunsaa Tubes are calibrated for uae at atmospheric premwe betweeo tempeuiute* of bfP and pof and relative humidities of 0 and 80%. Tubes should he wanned fot uk at lower temperature*. ftdudcian or operating foreman. fame Simple In ayusdat, uaoda un maljaenanee* No calibration needed bit tubes should bo refrigerated below 60f. Technician m opentlng foremre. None / Simple l nporarton. nee* no malntEoanca. Pump may be calibrated simply by checking the cc pm roke factor. This l* done by drawing air thra^i charcoal tube preceded by a soap bubble flowmeter: Tedsnlclan ec foreman to collect ruber and check lump. Chemist for calibra tion and uperitloo of gat chromatograph. Total cc't s*moled factor No. of strokes required (Kq The factor hat been initially determined by calibration, end it is shown on site pump cat*. reattach gar dMmnamih w/flD. tump ryiinffl w davelepad for 0EHA and la uand by USDOL far aHA tnapecdoni. BOR 0 0 0 9 6 4 < BUNT 1-4 (*> * Moidtoilng Device Simple of Available Equipment (Manufacture!/Model*) t. Ate* Monitoring (1) ca* Chromaiogra|*ic bynems <AOWFlUtlc. KkjUCfltlJl arufyeen) bcckman Inatrumcima Company/Mode) (-700 Oocripflim Method >f cjpcnn.ou PlKta Ci# Chromatograph Unit 1 designed for Field locilion in luiitiiuui areas tul raiy be separated from (he programmer by distances up io i.ooo u. At# U dnwn into tempting pipe by pump and it filleted. Simple U dtivn Into O.L, nd anilyied (or Vlm by , flame ionliaitcn deiecid. s#(ttp{# up to to positions sequentially. Apparatus hu capability of sounding in alarm U levels gu above f*mm concentration. Results ire displayed oo her* grip*] or on l nmnuKlI bid# vll i nutt|c.ompuief. biiople ijuIyjii ilme ] iwn minutes. Sensitivity 6.1 ppm Calibration Procedure level of Tilling Beguiled for Operator Ntttuty Suppon Equipment or Supplies System la calibrated using gas mUruiei whoac VLM concennaiioni are known, There inliturei ate commercially avail able or can be `made up* in plant laboratory wltfi die. Graduate chemist for tyyteraa Calibration gates operation, H2 gas for FID Technician for maintenance <anhro*n*s I A particular ircl can be moni tored every 20 minuiJes. Hewlea-'Packjud/ Model &SMA Modified research gride M/P gas i liroiuaiogriph vilh lutonuuc Operation. Sinie It above. This system nuy be used to monitor up to 16 different strums in one pUni by add ing a U> pn stream selection valve and pump. 0.1 ppm Same aa above. laseline fezeiolng can be performed with the minicomputer accessory. Same aa above, lame as above, Bendix Similar to (he above instrumentation (2> cu Chromatographic Syuems (Menut) Virtoui. including . Beckman , BciulU . He* letl-Plckird . perkin-Elinei Vinin/Aefogrifti Die of research type gn chromatograph coupled with manually collected sample*. Air samples are manually collected by technician in < Evacuated tubei . Tedlit bigt . Activated charcoal cubes The samples arc brought ce the laboratory and infected into G.C, 0.1 ppm Same ai above. Graduate ebemfe for system* operation. Technician for mainrenanee and sample taking. Calibration gasee Operatic gases > H* - Nt ~ Compreand air Sample collectors such as - Lr lass tubes - Tedlai begi - Activated chaKoat tubes AlrtKargh dlls type of syisem b definikty leu n( a capital tnveicnwm (hen it* automated sequential anilyiea. M nil] would require high operating tom due nr die sechnkian time in obtaining sample*. Abo many (evti area samples coul) ht atialytcd pet day due SO dr* fdivtlnl *trrainsi oi manual opersrun. BOR 0 0 0 9 6 5 BOR 0 0 0 9 6 6 Monitoring l^vice (3) lotfl Hydroezfbcui Anxtyxea Example of Available Edulpmen (MaiajCacmrct/Modcl* ) lendla ________ Pcscctpaon Automated mufti-point analyzer. b capable of monitoring up to 10 temple at tea mi. Method of Operation Senddvity Method of operation It similar to that of the gat chromatographic automated tyitemi. Major dlffrtcncc u that there It no column fui the separation ol die component gaiei in the sample stream. Device. thcMore, Rjvru the concentration of total hydrocarbons. Ulttei than jtut VCM. Pelector Uuiuill) ol the flame ionizailoti variety lot concentration ranges crowd l ppm. 0,1 ppm (4) tohemd SpKQD|fmnMtiie Awdyus . Manual ayaunti ferkln-Clmer/Modcl 21 . Automatic *yatira Wilks Sclentiric/Mlran II AmMeni Air bbmlMi Manually operated system Involving tha Model 261IR equipped with a 20 meter gas cell . similar n> the method lor manually operated gat chromate ^ruilu , Sample collected Iq - ('lunoal tubes - Evacuajud tubea - Tcdlai haj>( , Sample n brought to labwaiuiy and worked up . Introduction of sample Into i. IL ipe* (romeier Syitem utilises the electronic and Jeiection system described below under leak Detection M'ltem- Milan II t-ai Analyzer, lliia ambient Air mviii.v ti capable of aiuly/in^ jj\ or twelve rcliiokly located polftU i|4i<.iUcaUy (ut \'t-M on a ic<.|ucRii*l bam at one iiunuic fer {Vint. fl* dvvuivLe trom the i;tj m-iiiMitrci) tjn be up U> J00 furs. Alarm lyitem can lw included m the lyticm Fur umoiu above the allot.oJ n j ^iiiium. Sampling Hnit He hiou 'iii to a manifold controlled by solenoid velvet. Sailiplo are continuously punijicd from die manifuld to the gai cell, a mudi-joint recorder/i-ori roller sequentially opens the solenoid velvet allowing the air sample u> flow Into ihe analyzir coll. It then ic> usds o Idemlfled puiuf on (he .tiipc iba/i. I ppm 1-100 ppm OCICVT I->4 P) Ccllbcaflog Pmcedute Similar procedure as for Cat Chromatogia|diic apparatus level of Twining ttoqulred ftoe Opcrcw Umtursded operation, however, needs plant |mtru< mentation mao lot main* teiuocc Ncceaaary Support Equipment or Supplica . Calibration gases . Operating gates -* Nh22 (4mpressed alt Commaw> V VCM wwtWMIiu la very low compered to background hydiucsrboo level, changes in VCM level wm nos be defected Calibration la peifoimed In gaa chromatography wing leaa ftta with known concentrations Csadttaie chnmtii fer opeiatlon and result analysis , Technician for mein* tenance and temple collection . Calibration gaaea Semple noUectos Charcoal tubes * Evacuated tubes - Trdlai bags kfcftod la Ida leu Mad' five then F.i. d -C.c. and ilgnlricanily m<e expensive dun a Com parably equipped get chromatograph CalibsaUoQ gates ttchakUn Cattbratiun gates Meidtoflne Device Leak DetefBon {Portable Motion) (1) Cat ChffUTUIO* graphic (?) Catalytic Combintfem Principle Example of Available CqelfMon {Maaufacturcf/Modci ti Ceauiy Sywemt. Inc. /OVA-98 Analytical iwrvroent Development, Inc. OteFunch Imtnunent Co/TLV Portable Shifter Description Method of Operation Semlilvinr Light weight 10 lb*, -box ft 1/3 Ibt. -probe and metor. Portable instrument, flame iooitotloR OC analyzer, specific for VCM onlv. ftirti el'iht tourt on one battery charge. lies 18" column. Flame tanliatlon column work* on <be principle or cold absotptfon-thete h no heater. Completely self contained portable gat cti/omaiogiij* with flaine tuiuzatlon detector. Wctglu 40 lb*. C4n also be wed a* a total hydrocarbon atulytvt . Ilai mic/clunge- ablc. rilJ-C-Tl d(.ictun Manual C.C/F1D operation la described above. ] ppm <1 ppm . Portable untruinent . Clgai bon vizc * x 3 if.' a 6.626* . Weight I) lb. . When mtki'l cadmium battefii-t arc used biitrument t ill drive iccorder up to 8 toon. Inurnment U not i(vc 1/It io V ,M. Audible itarm ti energized If the icailiMt; ciuced* on idjuiUble level. Model TLV operetta on the heat of COmbtnilMi principle, a pamcular phytkal ChatacterUlc of all combustible gave* and vapor*. 3 ppm bated on hciane KXHBIt N (4) Calibration hoctduN Level of TMialnf Necessary fteppoa Same a* fe* stationary C. C. Technician Calibration gam oputting gasea Hew solid nu device putdta--d by over & umpulai and MC6H tad OSHA Same *a for stationery G.C, Technician lap* a* iMw Utei^ ft. x l/i" column packed w/lQ1} chfwnowtfb Instrument l ealtbremd with h*aae la tit ralxruiw OpetuotlacbokUa Hexane la air mixture. . Oust filler* . Nlcad battery . Binery changer Aocted log to manufacture^ malmenance t minimal and it limited to periodic calibration check* and teplacem#ii of die few fUtet. BOR 0 0 0 9 6 7 ( BOR 0 0 0 9 6 8 Monitoring Device (3) Wond Example of Available Equipment (Miimlai Hirer/Model M MI'.i hclcnl|llc/Mi<atl ll IR C* Analyte* Wllkl Scientific/ Milan I IROat Analyzer Lkmlpilon Method of Operation Thl* Inurnment can he readily irfumzeJ and calibrated fot (lie particular cat analyst* ivQiurtJ, 'iTt* Mfiau II ti equipped wUh a varlabk-path-lenglh ga cell aJjuitabk by a nng]e ceriiiol knot1 o\ti a range of O.lu 10 rmtun. Two wavelengths ate tneaeiredand an Output of die tatlot of ifit two energiet n provided, TVii allows one measutement 10 be uken on an analytical absorption bued and the orlict of nearly nonibuubing wavelength to provide a rcfenwe signal. (Vlpul gi ibr unit li linear Tlit iwu uer;y measure- in alnortwntc imiu, Auurning mciin are clntronkatiy a linear Becr` Law rcUtloti- tubtracted after drey have ihlp a readout directly in patted through th vain* perceruagv or ppm concentra analyaet and to ; ( OOvcrtct. tion tan be obtai(h.d. . Weight * 35 lb. Dimension '4`t i 6, 5 12 iikliLi . Time constraint- 1 and d MeonJi Single beam, dual wavelength {diotometet IttttnifnuM deitgned fof portability , Weight - 12,5 iha. , Dimennon 5.5 X a, 5 X 10" |>ltn 3X5" umple platform Similar in opciatlun to Mir an II but can be used to analyze any gaa that absorbs in lie Ik Sensitivity 0-100 ppm 9-100 pfm Source*: Analytical Itutnunerl L Dcvclopncnt, Inc. Catalog, 1924, Bechatach Iramimea Co. J -W Model TLV Catalog, 1924; Beckman Bulletin 41350. Beckman Kmnnneiai. Inc,, Bendvcf'cattcc Catalog, 1924. Century Syitemi, Inc, ouA*9d Catalog, Hewlett Packard Bulletin In ,'>830, r*1 t. Mire 'at#') Appanniv. I. c Model < dialog id'll- |ii -*llit'c' <j*t < IcrOmJrd -tapt (c ftd fci'rarcJ Fwilpuitnt iataloj, l''7f. wilit 'sCleltlMlc MirJIr I ' ll atllO"f V*7 I jnrll survey of cat Jvies. non csriiipiitiht inauwtaciwicn. EXHIBIT t-4 (ft) Calibration Procedure Uk of calibration gates Level of Training Required fot opeistof Operator or technician Necessary Support Commend Itntiuf for a battery operation. Cattteatlon gates. Can be tned on it rob battery power with any inverter acccftafy. Modular cfuuucuon povtdes fov eaay maintenance. / Sam* ai above Same m above Same above Same at above EXHIBIT E-5 (1) USDOL/OSIU AVAILABILITY AND COSTS OF TYPICAL MONITORING DEVICES FOR VINYL CHLORIDE MONOMER DETECTION Monitoring Device 1, Petsooal Monitoring (1) Colorimetric (2) Charcoal Tube/Pump System (Automated) Manufacturer (Inurnment Name) Catalog Number Components Catalog Pcscription/Lot Size Unit Purchase Cost (1974 Pollan) Procurement Lead Time (From Time Messenger Receives Oidcfl Bendlx/Gastec (precision Get Detector) Mine Safety Appliance* (Haloge/ured Hyd/ocarbon Detector) AnatoJc J. Sipln (Slpin Personal Sampler Pump) 24175-34 131 24175-38 85342 85833 Pump kit/6 or more Detector rubci (10/boa, 8 or more bo*ei) Sparc pans kit/1 Halogenaied hydrocarbon detector (Group A)/l Tube* for 8584/p*cfcage of 12 5P-1 or SP-2 Personal air sampler klt/1 Charcoal tubes/packages of 12 112-00 .90 8.00 HO. 28 1.38 300.00 .58 Stock Ucm Stock ttem Stock Item Stock Item Stock Item 8-10 Weeks 2 Week: 696000 2* Area Monitoring (1) Automated, Sequential Gat Chromatographic Syne ms to t (2) Manual Gat Chromatographs For Area Monitoring. Charcoal Tube Analyses, and Residual VCM Determinations Beckman (Procett Gas Chromatograph, FID) Model 6700 Process gas chromatograph including Leeds & Northrop strip Chan Recorder Ten point sampling system Application engineering department final system check-out Byton Instruments, Inc, (FID C,C,) Model 320 VCM monitor 0-10 ppm. fully automated, 10 points, 2 min pet point, w/bar graph or strip chart recorder Hew ten-Packard (FID Automatic Gat Chromatograph W/ Minicomputer) Model 5830 Reporting gat chromatograph w/16 point sequential sampling system (complete)* system also includes built-in digital processor, keyboard control center and printer/plottcr Perk In-Elmer (Industrial Atmospheric Analyzer) Model 3920 Model 2,920 CC with HD. linear temperature programmer, complete automatic data handling as an option Vahan/Acrograph 144010*00 00-9145-01 'J`270 9il0 Single column (18* ) FID, v/linear programmer. G,u Chromatograph Columns/1 Recorder, simple pen Disc ** integrator Diie ^ aiuomitn, printer 6,000.00 3. no. oo 580.00 68.00 10.835.00 3,075.00 -- 50.00 1,1:<0.00 795.00 00 3-0 Month, 2 Month, 8 Week, 2-3 Months Stock Item 2 Montiis 2 Months 2 Month* EXHIBIT E-5 (2) Monitoring Device Manufacturer (Instrument Name) Catalog Number Components Catalog Description/Lot Size Unit Purchase Cost (1974 Dollars) Procurement Lead Time (From Time Messenger Receives Order) (3) Total Hydrocarbon Analyzers Bendlx/THA - . Cost includes 10 point sampling stream $6,600,00 3-6 Months Multipoint System system . FID based (4) Infrared Spectroffiotometer (Automated) Wilks Scientific/ Miran 11 Ambient Air Monitor 206-2120 12-2120 Miran II I-ft System complete including: . 20M variable path cell . Calibration curves for specific analysis LAN Speotlina* H Mo|1i -Point Recorder Six sample inlet parts controlled by nylon solenoid valve. Sample pump capable of pulling samples to) 200 feet through 1/2" I*D. tubing Internal plumbing System housing Particulate filter for each line Same as above but for 12 sampling points 11,250.00 12,500.00 3 Months 3 Months (5) Infrared Spectrophotometers (Manual) for Area Monitoring and Residual VCM Determinations Beckman/Accu Lab. 6 1896 OOU 580248 530249 Accutab Gift Spectrophotometer complete with recorder 20M mulupath cell (sample cell) 2QM multipath cel) (reference cell) 6.130.00 2.310.00 2,310.00 / 3-4 Months Perkin -Elmer 267 Model 267 Infrared spectrometer Single twenty meter cell Closed Loop cttculaiion system Reference beam alternator 8,860.00 2,590.00 275.00 40.00 / 3 Momhi BOR 0 0 0 9 7 0 Leak Detecting (1) Gas Chromatographic Analytical Instrument Development Inc./ Portable CaC. Century Systemj Corp./ Organic Vapor Analyzer Model 511 210-6001 Pott. C.C* equipped w/hydrogen n*i ie ionization detector Reccmler-fcsierllnc Angiis 2 multivofi fixed range completely portable and contains its own rechargeable batteries Six chart spec OVA-93 l lD w /strip dun. teindcx/metcr 3,300.00 810.00 3,500. 00 2 Months 5-4! Weeks Monitoring Device (2) Catalytic Combustion Principle (3) Infrared Spectrophotometric Manufacturer (Instrument Name) Catalog Number Components Catalog Description/Lot Size Bacharach Instrument Co. / 23-7350 TLV Sniffer Wilks Sclentlfic/Miran I 5652 Wilks Sclentlfic/Miran 11 201-2120 TLV portable sniffer, battery powered, linear scale readout Miran Portable Gas Analyzer w/linear absorber readout, spectral range 2.5 to 14.5 micron, variable path gas cell Miran 11 w/20 M variable gas cell Specific for VCM EXHIBIT E-5 (3) Unit Purchase Cost (1974 Dollars) Procurement Lead Time (From Time Messenger Receives Oder) 3 678,00 30-45 Days 4.825.00 4,900.00 / 3 months Sources: Analytical Instrument A Development, Inc. Catalog, 1974; Bacharach Instrument Co. J-W MiKiel TLV Catalog, 1974; . Beckman Bulletin 4135D,Beckman Instruments, Inc,: Bendix/Gattec Catalog, 1974; Century Systems, Inc. OUA-93 Catalog; Hewlett Packard Bulletin 5830, 1774; Mine Safety Apparatus, Inc. Model 85842 Catalog 1974; Perkin-Elmer Gas Chromatographic and Infrared Equipment Catalog, 1974; Wilks Scientific, Miran I A II Catalogs, 1974; q Vartan Associates, Varian Amerograph Catalog, 1974; JJl Snell Survey of Gas Detection Equipment Manufacturers, X.6000 ( VCM/FVC Producer* *> )U14< aid lTS^n. -W ^ *W lfll-Ncv-W Tvm of MoBliodaj Emilpmerg 1. Renewal Cuboa tube t, Leak detection . Organic por luljfur . Cu chromatogtaph X* Leak detection . Oigiaic vapor analyzes 1, Luk detection * Oigalie vapor analyzer k Penonal . Pump and Impinges* C.C. foe analyds of charcoal samples (KID) 2. Leak detection * Organic vapor analyier 1. Personal monitoring tin hap C. Leak detection Name of Equipment Manufacturer TauIlnulM Unit Com (1974 Dollars) Kxmrr USDOL/G6HA SUMMAffT or SNKLL tNTWlEW RESULTS WITH VTKU QflOMDE AND FOtrvtnrL ononoi pkducexs relating to hiidiases or vinyl cniDHDt hCNITOHNG SHIPMENT*1' PEIGGNAL AND UAK DmCTlCW DEVICE* Opuitiag aad Maintenance Com (HU Oollu) TInline PiDcureroeiic Start-Up Commend N.A. Cettury N.A* Century Century 9 20.000 10,000 lo.ort s.ooo Benila (CllS) Sfptn He*lest Packard (Model 6760) Century OVA Calibrated hitratncna he. Century OVA 1.350 1.400 t.m 11.000 3,300 3. tOO * 90,000 3,000 3,000 4,600 N.A. N.A. N.A. N.A. N.A, Short times for delivery. Short time* fo* dettwy. Shon dmci foe delivery. Com ere for die 2 plans. l--miiitehcledsMi f laboratory gat dtomarogtifti and dimli(s)> Assumed so he com for S OVA* and part-time epcraier. dAmnwd be tore for 2 finable wli aad pert* dme operant. N.A. SnH ,iluu OVA con utl.OWpu will. N.A. S3.000 (M oomincais) 3/74 See comrncm for OAM 6/74 9/74 S comment (or OAM N.A, 4/74 9/74 e/i/ie See commem for CAM 0-0/74 Complete 13,000 1.200 t-lKHle 6 veals OAM la total coil for a0 foUnrlng rttrrgftifes. 3 mlu 4 IB1^ Uk4 dm id taimiii VCM imlAul luo. 1 W*1 7 units BOR 0 0 0 9 7 2 I EXHIBIT I'd (I) VCM/TVC Ptodncet Tm of Montioriot Equipment None of tmilpmem Mtmiftetuur Tout (mulled Unli Com (1974 DolUn) Operating and Maintenance Coats (1974 Dollars) Tliitinji Procurement Sun *4)e Cootnuu 1L-OW-V/ MM "New-C 39 M 3M-JK.-C 5L-0ld< 1* Personal monitoring Charcoal adsorption w/ C C. Analysis 1. Pcnons I sampling o 1 flD chromatograph for analysis of personal sampling t. AAlllinns) analytical * PcixODsl monitoring 1. Personal monitoring . G.C. (FP) for analysis of charcoal tubes . Personal samples 2. Leak dciouion . Organic vapor analyzer 1. Persons] monitoring carbon tube pumps C.C. amlytliof samples and VCM residuals Monitoriog G.C. Mlnicom,! jicr to compute and stoic ail m >nitoring data N.A, N.A. N.A, N.A, Perkin-Elmer FtD-GC Century Bendlx Mlcronsir II N.A. N.A, N.A, 40,000 15,000 15.000 10,000 10,300 ft. 000 aoo 13,000 13,000 33, 000 100,000 N.A. 30% complete 1/74 1/TO - Auomed la lodutW can of G. C> md cbunlm. i 10,000 20,000 Net yei known 16.000 2/74 N.A. N.A. N.A. 3/74 12 months after go-ahead N.A. N.A, t min 20,800 20,000 20,000 2,000 N.A, N.A. 2 months 3 months N.A* N.A, 1 mofsh 1 month Netted to comply with . 13 H>m itMdwd. BOB 0 0 0 9 7 3 I EXHIBIT f-6 (9) VCM/PVC Producer SL-New-C 14-M-lnu-W 49M-Oid-C 2IM-OM-C 9S-lr. -C 30M-New-C Type of Monitorltut Equipment 1, Personal rnonitadng equipment t. Leek detection * Organic vapor analyzer 1* Personal monitoring 1. FtnonaI monitoring 2, teak detection Organic vaper analyzer l. Penonal monitoring . Cat chromatograph for charcoal nibe analyzer 2* Leak detection . Organic vapor analyzer 1. Leak detector . Organic vapor aoalyzer Name of Equipment Manufacturer Total Instilled Unit Coru (1974 Pollan) Operating and Maintenance Cons (1974 Dollar) Timing Procurement Set-Up N.A. Century N.A. Bendlx N.A, % 1.200 6,500 2,500 2,500 15,000 9 24.000 3.000 12,000 32,200 06,000 4 months 1 month Complete In opciadm In place Hewlett Packard 0.000 Not yet known In place Century Century 12,000 10.000 60.000 N.A. to place N.A. N,A. 1, Personal monitoring . Dosimeters . O.C. for carbon tube analysis 2. Leak detection . Organic vapor analyzer . Combustion principle Bcndia Slptn Vartan Aerograph Century JAW 6,ooo 0,300 6.000 6,400 1,450 1,000 1,000 1.000 500 250 12 weeks 6 weeks 12 weeks 8 weeks 8 weeks 1 week - 1 week _ . Comments Coe wggest addition of analytical staff. 2 units Coats suggest addition of analytical staff. / Cobb Biggest addition Of analytical tuff. 4 units BOR 0 0 0 9 7 4 i EXHIBIT I-* <4) * VCM/PVC Producer 3lM-+4*v-C Tym of Monitoring EOulpmem Monitoring equipment Name of Equipment Manufacturer N.A. Total totalled Unit Com (1974 DolUn) S 66.000 1. Personal monitoring . Charcoal tube type . G.C. for inalyilr of tubes 2Bl*New<C tfM-Ncw-Cnd 29L-Ncw-W 46M-Old-C 2m Leak detection . Organic vapor analyzer 1, Personal monitoring . Ptiunil simpler 2. Leak detection . Organic vapor analyser . Portable ci.C. 1. Personal monitoring . Lab chromatograph for analyst! cf; * Oagl - Carbon tube* 2* Leak detection . Infrared unit , Organic vapor analyzer K'omi (1) pot meaning of producer cods, ace P*rc M. ranee; Rcmta of Snell Interviews with the VC'M/PVC manufacturing Industry. NA - Mot Available. N.A, Varlan aerograph Century N.A. Century AID N.A. Minn Century 2,100 600 12,000 260 each 2.500 7.500 10,200 6,200 24.000 Operating and Maintenance Cons <1974 Dollars) t 20.000 4-5,000 20-25,000 20,000 N.A. N.A. N.A. 36,000 80,000 70,000 Tlmlns Procurement Set-Up Comments 6 mouths from order Complete Complete QunplU* N.A N.A. for mcb lastimneatt. 1100 ! for rebuilding af C,C, Cotta mggeat addition of akalyrical taff, Three imtnumtm. N.A, N.A. N.A. N.A. la Plata N.A. N.A. 1 writ, la placa 1 ontft Augiui 1P74 4 weala ilcUmy 4 tti Coiti wggest MUftldi of analytical naff, BOR 0 0 0 9 7 5 I VCM/PVC Produce/*1 llM-fau -C and l7S*im.-W SO'.-Nev-W L9L-NO.-W 41L-OM-W SIM-NiW-C 38 34 3-OUJ-C SL-New-C 14M-IM.-W, 49M-OW-C 'TM-Old-C Area Monitoring Device Detcrlptton NA No. of Points 30 EXHnrr e-7<i> USDOL/OSHA SUMMARY OF SNELL INTERVIEW RESULTS WITH VINYL CHLORIDE AND POLYVINYL CHLORIDE PRODUCERS RELATING TO PURCHASES OF VINYL CHLORIDE MONITORING EQUIPMQLTt area MONITORING DEVICE^1* Name of Equipment Manufacturer Total Cost Including Installation (Dollars) Operating and Maintenance Costs (Dollars) NA *200,000 * 45,000 Timing Procurement Start-Up 6 mos. from order Comments Costs ate for 2 plants, 30 pis. pel plant Fixed point continuous system. NA Honeywell 1000 98,000 1.200 8/74 9/74 Fixed point continuous system. Continuous analyzer 20 Honeywell 1000 NA NA 45,000 500.000 2,000 100,000 18 mot. 8*10 wks. 4/76 / Com are fee 2 plants FID chromatograph with sampling systems and computer interface equipment. Sampling point located throughout operations and Loading atea. Same as above. 24 60 Amscoi Amscor Automation total hydrocarbon analyzes. 24 Same as above. NA Same as above. 6 Same as above. NA Mini-Computer fot UcndLx Sequential chromatographic system without computer. 16 Bendlx Bctidix Bcndlz Qcndix NA licndix 60.000 200,000 40,000 10,500 6,000 10,450 49,000 50,000 NA 7/74 Fending 2 unto 20,000 27,300 6,000 6,000 12,000 3,000 NA 18 mot. for project tun-up NA Complete Complete G mot. S mos. NA NA NA 6 untta 4 unlQ NA BOR 000976 VCM/PVC Producer 9S-Int. -C 30M-New-C 42S-lnt.-C 28L-New -C 26M -New-C and 291-New-W 46M-01d*C , EXHIBIT E-1 (S' Area Monitoring Device Description FID gas chromatograph. No, of Points NA Name of Equipment Manufac truer Total Cost Including Installation (Dollars) Operating and Maintenance Costs (Dollars) Perkin-Elmcr $ 18,000 NA Timing Procurement Stait-Up NA NA Comments Fixed point system. FID gas chromatograph. FID system. Automatic chromatograph Kith data system* Sequential monitoring chromatograph 90 NA NA 20 NA NA Hewlett-Packard NA Custom made Bcndix 200,000 NA 70-80,000 30,000 137,000 t 30,000 NA 30*40,000 NA 10,000 26 wks. NA NA NA 6 mos. total 8 wks. NA NA NA ( 2 Instruments Notes: (1) Equipment installed Incompliance with the temporaty standard ot In anticipation of a permanent standard. (2) For meaning of producer code* see page U-6. Source: Results of Snell Interview with the VCM/PVC Manufacturing Industry. NA = Not available. W O W O o o t-oj J 1 APPENDIX F MEDICAL SURVEILLANCE OF EMPLOYEES l BOR 0 0 0 9 7 8 APPENDIX F ` MEDICAL SURVEILLANCE OF EMPLOYEES This appendix details the elements of routine medical surveillance and their attendant costs. All exhibits appear sequentially at the end of the appendix. 1. A REVIEW FOLLOWS OF THE TEMPORARY AND PROPOSED REQUIREMENTS FOR THE MEDICAL SURVEILLANCE OF EMPLOYEES IN VINYL CHLORIDE (VCM) AND POLYVINYL CHLORIDE (PVC) PLANTS This section summarizes the medical surveillance required under the emergency temporary standard for exposure to VCM (50 ppm) and the medical surveillance required under the proposed permanent standard (no detectable limit) . (1) (1) 50 ppm Emergency Temporary Standard (ETS) ( The ETS does not recommend or require any medical surveillance of employees in VCM and PVC plants. It is concerned only with the fixing of exposure levels to 50 ppm value (127.0 ms/cm) . 12) (2) Proposed Permanent "No-detectable11 VCM Standard (PPS) 1 Comprehensive requirements for employee medical examination are proposed, in cluding necessary tests. Some additional guidance is included for the convenience of physicians. The proposed requirements have been recommended to OSHA by NIOSH (see below) as reasonable and appropriate to detect liver dysfunction which may be indicative of, or predisposing to, the development of liver angiosarcomas.1 2 BOR 0 0 0 9 7 9 (1) 29 CFR 1910, Occupational Safety and Health Standards, Emergency Temporary Standard for Exposure to VCM . (2) 29 CFR 1910, Occupational Safety and Health Standards, Proposed Standard. F-l I Records of medical examination are to be kept with provision for access by appro priate OSHA and NIOSH officials. Specific requirements are made to furnish a copy of a medical record to an employee's physician on the employee request. In the event of an "emergency", that is, an unforeseen circumstance or set of circumstances resulting in the release of VCM into areas occupied by employees, a special medical surveillance by a physician shall be instituted within 24 hours for employees present in the affected area at the time of the emergency . (3) NIOSH Recommendations For Medical Surveillance Referred To By The Proposed Permanent Standard The following recommendations are directed primarily at medical screening to de'tect liver disease and/or hepatic tumor. They should be considered in the context of routine health screening for any general employee health problem, including non-hepatic health condition potentially related to VCM exposure. Routine health screening should include at the time of initial employment: . the recording of past medical history the performance of a general physical examination certain basic laboratory procedures including: complete blood count urinalysis chest x-ray Provisions should also be made for routine periodic health follow-up examinations.1 (1) NIOSH, Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974. F-2 i BOR 0 0 0 9 8 0 Employees covered by the following specific recommendations shall encompass all persons engaged in VCM production and polymerization including personnel peripherally involved such as in clerical and management assignments. The recommendations shall be applied both as a pre-employment requirement and as a part of periodic health follow-up. Screening priority should be given to current employees with prolonged and close potential exposure to VCM, whether in present or past work settings. The recommended examination protocol is: At the time of initial employment, or upon institution of screening, a physical examination shall be performed with specific attention to detecting enlargement of liver or spleen by abdominal palpation. . At the time of initial employment, or upon institution of screening and annually thereafter, a medical history check-list shall be completed by the employee. This list shall include questions concerning: alcohol intake past history of hepatitis past exposure to potential hepatotoxic agents including drugs and chemicals past history of blood transfusion past history of hospitalization The completed medical check-list shall be reviewed by a physician and should be acted upon as medically indicated for each individual employee. F-3 t BOR 0 0 0 9 8 1 At the time of initial employment, or upon institution of screening, a serum specimen shall be obtained for screening with respect to the following five bio-chemical determinations of liver function: total bilirubin alkaline phosphatase serum glutamine oxalacetic transaminase (SGOT) serum glutamine pyruvic transaminase (SGPT) gama glutamyl transpeptidase (GGTP) Additional tests that optionally may be considered for use in screening include lactic dehydrogenase (LDH) serum protein determinations serum protein electrophoresis platelet count Laboratory analyses shall be performed in laboratories accredited by the College of American Pathologists, licensed in accordance with the provision of the Clinical Laboratories Improvement Act of 1967. If results or laboratory screening are normal, screening shall be repeated on an annual basis. If the person being screened has been employed directly in vinyl chloride monomer production or polymerization for 10 years or longer, screening shall be repeated every six (6) months. If one or more liver function tests are abnormal, serum testing shall be repeated as soon as possible, preferably within two (2) to four (4) weeks. If no abnormalities are present upon rescreening, testing should be re peated in three (3) months. F-4 i BOR 0 0 0 9 8 2 If abnormalities persist on rescreening, the employee shall be removed from contact with VCM operations and an individualized workup shall be instituted. Suggested as initial steps in medical workup are a complete physical examination various special procedures such as .. hepatitis B antigen determination .. liver scanning If liver function abnormalities are determined to be unrelated to liver disease (e.g. elevated alkaline phosphatase in a young, physically active man or elevated bilirubin in Gilbert's syndrome) or to be transient (e.g. due to recent hepatitis or recent alcohol intake), the employee may be permitted to return to VCM related employment, subject to individual medical evaluation. In view of the preliminary results of animal toxicology studies, it is recom mended that no woman who is pregnant or who expects to become pregnant should be employed directly in VCM operations. F-5 i BOR 0 0 0 9 8 3 2. SNELL ASSESSMENT OF THE COST OF MEDICAL SURVEILLANCE UNDER THE PROPOSED PERMANENT STANDARD U) This section details the cost of medical surveillance needed by the VCM and PVC industries to comply with the requirements of the Proposed Permanent Standard (PPS) . Costs are essentially based on the physical examinations and laboratory tests recommended to OSHA by NIOSH. Exhibit F-l presents a screening flow sheet for the physical examination . and laboratory tests which may be performed. It details the screening steps which are given by the PPS. Exhibit F-2 presents the time required for an average worker to spend on obtaining the needed physical examination and laboratory tests by a physician under contract to the VCM and PVC manufacture. Exhibit F~3 details the types of laboratory tests which may be required as well as their normal values. It is from these tests that a portion of the total cost is based. . Exhibit F-4 summarizes the itemized costs for the various elements of the medical surveillance program from Snell estimates based on the detailed study. The Snell estimate is $160 per worker. Exhibit F-5 shows the costs which were reported by the VCM and PVC industry for their medical surveillance program. Their costs average out to $143 per worker based on sixteen reporting firms.1 (1) 29 CFR, 1910, Occupational Safety and Health Standards, Proposed Standard For Exposure to VCM (2) NIOSH Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974 F-6 < BOR 0 0 0 9 8 4 3. REVIEW WAS COMPLETED OF THE INFORMATION BY NORMAN B. JAVITT, M.D., PH,D. HEAD, DIVISION OF GASTROENTEROLOGY, DEPARTMENT OF MEDICINE, NEW YORK HOSPITAL-CORNELL MEDICAL CENTER According to Dr. Javitt in his letter to Snell, shown in Exhibit F-6, he reviewed the appendix and in his judgment, "the proposed protocol adequately reflects both the recommendations of the appropriate governmental agencies, and considering the constraints of time and expense, is carefully constructed to obtain a sensitive estimate of the existence of liver dysfunction as well as other ancillary data on health status." Dr. Javitt in his letter also suggests modifications or clarifications to the NIOSH recommended protocol as is seen in the Exhibit. F-7 BOR 0 0 0 9 8 5 EXHIBIT F-l USDOL/OSHA SCREENING FLOW SHEET BASED ON NIOSH RECOM MENDATIONS TO OSHA FOR THE PROPOSED PERMANENT STANDARD BOR 0 0 0 9 8 6 EXHIBIT F-2 USDOL/OSHA TIME REQUIRED FOR TRAVEL, PHYSICAL EXAMINATION AND LABORATORY TESTS OUTSIDE OF PLANT Worker Completes Medical History Checklist While Waiting 30 minutes Blood Samples Taken 5 minutes Urine Sample Provided 5 minutes Chest X-ray Taken 10 minutes EKG Taken 10 minutes Physical Examination 30 ipinutes Total Time Required Examination and laboratory tests Travel to and from examination facility Maximum time required Source: Snell estimates 1.5 hours 2.5 hours 4 hours BOR 0 0 0 9 8 7 BOR 0 0 0 9 8 8 Laboratory Test Blood Chemistry Cholesterol ^ Calcium ^ Inorganic Phosphorus (^1 Total Bilirubin ^*2) Total Protein t ^ Albumin f1) Uric Acid BUM Glucose LDH (1-2J Alkaline Phosphatase (1.23 SGOT Creatinine (3) GGTP(2) SGPTf1-2! NPN Purpose Cholesterol metabolism Calcium metabolism Phosphorus absorption Liver function Liver function Kidney and liver function Purine metabolism Kidney function Carbohydrate metabolism Organ damage Liver function Organ damage Kidney function Liver function Organ (part, liver) damage Kidney function EXHIBIT F-3 (1) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS Normal Values 150 to 300 mg/100 ml 9 to 11.5 mg/100 ml 2.5 to 4.5 mg/100 ml 0.2 to 1.0 mg/100 ml 6.0 to 8.0 gm/100 ml 3.5 to 5.0 gm/100 ml 2.5 to 7.5 mg/100 ml 10 to 20 mg/100 ml 65 to 100 mg/100 ml 67 to 122 technicon units 4 to 17 KA units 15 to 45 units 0.9 to 1.7 mg/100 ml 6-28 inp /ml 15 to 56 units 25 to 38 mg/100 ml BOR 0 0 0 9 8 9 Laboratory Test Hematology RBC (2) WBC (2J Hgb Hct(2) Differential (2) Polys Stabs Eosinophils Basophils Lymphocytes Atypical Lymphocytes Monocytes Platelets MCV MCH MCHC Purpose Standard screening for all diseases It I! II II II II II M M II II II II II EXHIBIT F-3 (2) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS Normal Values 4.6 to 6.2 x 106 4.8 to 10.8 x 103 15 to 18 gm 42 - 52% . 60 - 70% 0-1% 1-3% 0.25 - 0.5% 25 - 33% 0-1% 2-6% 2 - 4 x 10s 80 - 94 p 3 273 p p g 32 - 36% EXHIBIT F-3 (3) * Laboratory Test iUt rinailysis (2) Purpose Normal Values Color Appearance Specific Gravity PH Albumin Glucose Acetone Bile Urobilinogen' Standard screening for all diseases II It 11 It II II II Pale straw to amber Clear to slight hazy 1.905 to 1.002 5.5 - 7 Negative Negative Negative Negative Up to 2.1 Ehrlich units Notes: (1) included in automated SMA12 analysis (2) recommended for determination within first screening or initial examination by NIOSH to OSHA specifically for liver function. (3) included to obtain a total laboratory profile of the worker (4) Recommend as a special test by NIOSH to OSHA. Sources: Ivan K. Smith, Diagnostic Services, Inc., 520 Speedwell Ave., Morris Plains, NJ 07950; NIOSH, Recommended Occupational Health Standard for the Manufacture of Synthetic Polymer From Vinyl Chloride, March 11, 1974; Snell assessment of the NIOSH recommendations to OSHA BOR 0 0 0 9 9 0 EXHIBIT F-4 (1) USDOL/OSHA APPROXIMATE COSTS OF PHYSICAL EXAMINATIONS AND LABORATORY TESTS COMPLETED OUTSIDE PLANT BASED ON A MANUFACTURING FACILITY WITH 500 COVERED WORKERS Element Full-time clerical person for typing, filing, coordinating visits to labs and physicians, etc. ($9,000 x 1.25 in fringe) Records, stationary, postage, etc. Overhead^1) 500 examinations by physician (general practioner) @ $20 per examination 500 reviews of physical and laboratory examination results by physician@ $15/review 500 chest x-rays @ $20 per worker 500 laboratory test series @ $24 per series^) 500 EKG's @ $25 per worker 125 repeat laboratory test series (25% of workers) @ $24 per series (21 . 125 repeat medical reviews by physicians @ $15 per review 25 special laboratory tests @ 5% of the workers @ $25 per worker ^ 25 reviews by physician at special laboratory tests @ $15 per worker Total expenditures per annum for 500 covered workers Approximate cost of medical screening per worker Cost (Dollars) $ 11,225 7,500^ 5,000 10,000 7,500 10,000 12,000 12,500 3,000 1,875 625 375 . $ 81,500 160 BOR 0 0 0 9 9 1 ( EXHIBIT F-4 (2) USDOL/OSHA Notes: Sources: (1) overhead includes electricity, telephone, heating, space allocations for clerical activities, etc. (2) initial laboratory screening tests include SMA12, SGPT. GGTP, CBC with platelets and urinalysis (3) special laboratory tests may include: serum hepatitis B determination, serum protein electrophoresis Ivan K. Smith, Diagnostic Sciences, Inc., Morris Plains, NJ 07950; Snell assessment / BOR 0 0 0 9 9 2 EXHIBIT F-5 (1) USDOL/OSHA RESULTS OF SNELL INTERVIEWS TO DETERMINE THE COSTS OF MEDICAL SURVEILLANCE COST PER WORKER PER YEAR Number of Workers Total Cost (Dollars) Cost per Worker per Year ________ (Dollars) 97 173 (NA) 16,000 34,000 (NA) 165 200 (NA) 57 3,000 52 222 (NA) (NA) 1,137 (NA) 200 50 (NA) (NA) 325 (NA) 150 - 200 128 12,000 94 420 12,900 40 (NA) (NA) (NA) 81 10,000 125 150 22,000 to 3,204 224,280 to 146 70 68 (NA) 74 (NA) 135 (NA) 200 200 (NA) / 000993 EXHIBIT F-5 (2) USDOL/OSHA Number of Workers Total Cost (Dollars) Cost per Worker (Dollars) 338 200 693 111 150 700 45,000 (NA) 110,600 (NA) 20,000 (NA) 133 (NA) 160 (NA) 133 200 Average annual cost per employee $ 143fl) Notes: Sources: (1) Cost for examinations assumes tests are based on NIOSH recommendations. Snell review and assessment of interviews with VCM and PVC manufacturers. NA = not available I BOR 0 0 0 9 9 4 EXHIBIT F - 6(1) USDOL/OSHA LETTER OF DR. NORMAN B. JAVITT TO SNELL REVIEWING THE DATA IN APPENDIX F 525 EAST 68th STREET. NEW YORK, N Y, 10021 nil-: i\i:\v yomv hosimtal-counell medical center DEPARTMENT. OF MEDICINE DIVISION OF GASTROENTEROLOGY August 16, 1974 TO: John W. Keating, Ph. D. Director, Biological Sciences Foster D. Snell, Inc. FROM: Norman B. Javitt, M.D., Ph. D. Professor of Medicine and Head, Division of Gastroenterology New York Hospital-Cornell Medical Center SUBJECT: Review of Appendix F (first draft) Technical Feasibility and Economic Impact Study BOR 0 0 0 9 9 5 EXHIBIT F - 6(2) USDOL/OSHA I have reviewed the above appendix with special emphasis on Exhibits F-2 ' through F-5 and have the following comments: 1. In my judgement the proposed protocol adequately reflects both the recommendations of the appropriate governmental agencies, and considering the constraints of time and expense, is carefully con structed to obtain a sensitive estimate of the existence of liver dysfunction as well as other ancillary data on health status. 2. I would suggest consideration of the following modifications: A. Routine tests: 1) Hepatitis B antigenemia (by RIA). A positive test should be an automatic exclusion from working with vinyl chloride because of the possibility of the person being a high risk for developing toxicity. Final judgement would require complete medical evaluation. Expense for this test is probably minimal since now, by state law, every unit of blood obtained for the purpose of transfusion must be tested for the presence of Hepatitis B antigen. B. Special tests in the event of abnormal screening tests: In the event of persistent abnormal test of liver function, the following further studies should be done: *1. Alphaj Fetoprotein (correlateswith hepatoma) *2 . Alpha i Anti-trypsin deficiency (at special risk to develop chronic lung and/or liver disease). BOR 0 0 0 9 9 6 EXHIBIT F - 6(3) USDOL/OSIIA *3. 2-hour post-prandial serum bile acid. (The most specific sensitive test for hepatobiliary disease - not as yet activated-cost per test on contract basis, $20 test). * Probably can be cost-accounted through Bio-Science Laboratories and other similar laboratories. NBj/bq BOR 0 0 0 9 9 7