Document gDknMeRO7ZX88LKJpdBvVQ87Q

** * i Interoffice Communication To Jerald Uptain From Date Owen Tubb January 20, 1976 * Subject Proposal for Reduction of VCM Regulated Areas and Modification of VCM Personnel Monitoring This letter is being written as a proposal for reducing the VCM regulated areas in the plant and also as a proposal to modify the present VCM personnel monitoring program. I. BACKGROUND A. OSHA VCM Regulation Requirements 1. Regulated Areas The OSHA VCM regulation states that; (1.) a regulated area shall be established where: (a) vinyl chloride is manufactured, reacted, repackaged, stored, han dled or used; and (b) vinyl chloride concentrations are in excess of the permissable limit. (2) Access to regulated areas shall be limited to authorized per sons. A daily roster shall be made of authorized persons who enter. 2. Signs and Labels The OSHA VCM regulations states that, (1) entrances to regulated areas shall be posted with legible signs bearing the legend: "Cancer-Suspect Agent In This Area Authorized Personnel Only". (2) Areas containing hazardous operations or where an emergency currently exists shall be posted with legible signs bearing the legend: "Cancer-Suspect Agent In This Area Protective Equipment Required Authorized Personnel Only." 3. Monitoring The OSHA VCM regulation states that, (1) monitoring shall be repeated monthly where any employee is exposed, without regard to respirators, in excess of the permissable limit - (1 ppm VCM) (2) shall be repeated not less than quarterly where any employee is exposed, without regard to respirators, in excess of the action level (0.5 ppm VCM). (3) may be discontinued for any employee only when at least two con secutive monitoring determinations, made not less than five (5) days apart, show exposures for that employee at or below the action level. VAB.0001215870 B. Aberdeen Compliance To Date 1. Regulated Areas Since April 1, 1975, the entire plant, with the exceptions of the old main offices, the purchasing/accounting offices, and the two off-site warehouses at Prairie, has been desig nated as a regulated area. 4 t 2. Signs a. Regulated area signs are presently located at all entrances to the plant: 1. Front gate 2. Shipping gate (east) 3. Railroad gate 4. James Creek gate 5. Boiler House gate 6. Exit from ''old" main office 7. Exit from "new" main office 8. Compress Warehouse 9. Receiving office 10. VCM Tank Farm b. Hazardous operations signs are located in the following locations: 1. VCM Tank Farm 2.* V-ll Reactor Building (which includes large reactor area) 3. V-12 Reactor Building 4. V-ll Dryer Building 5. Compound Line I 6. Compound Line III 7. V-10 Dryer Area 3. Personnel Monitoring m Since April 1, 1975, approximately two thousand, five hundred personnel monitoring samples for VCM have been taken. The monitoring method used was to monitor each plant employee once a month for eight hours using seven-liter "gas bags" and Sipin air sampling pumps. BASIS FOR PROPOSAL The attached table indicates the personnel monitoring results by plant area. The monitoring recorded in the table was conducted from September 1, 1975 through December 31, 1975. This time period is believed to be the most representative of current exposure since the steam stripping process was not in full use prior to September. The table also indicates the Honeywell continuous monitoring results taken from November 1, 1975 through December 31, 1975. This time period is believed to be the most representative of current exposure due to the fact that prior to November the monitoring units were set to operate on a .0-50.0 ppm range. The units were adjusted to read on a .0 - 10.0 ppm range in the latter part of October. Areas proposed for de-regulation (see table) are those areas for which: A. Average exposures have been shown to be at or below the action level (0.5 ppm). VAB.0001215871 * B. the upper confidence limits (95%). have been shown to be at or below the permissable limit (1 ppm). There are certain exceptions which are noted in Section III A. III. PROPOSED ACTION A. VCM Area De-Regulation 1. De-regulate areas so noted in the table by the target dates, except as noted below: a. Laboratory - This area is used in the testing of liquid VCM and will continue to be designated as a regulated area. b. Large Reactor Area - The VCM monitoring results indicate that this area should remain a regulated area. c. VCM Tank Farm - Due to the large amount of liquid VCM stored in this area, it will remain as a regulated area. d. "Compress" Warehouse - This is an off-site warehouse. The monitoring results indicate that this area should remain as a regulated area. e. East Warehouse (Transportation) - The VCM monitoring results indicate that this area remain a regulated area. However, this area should be re-evaluated in approximately three (3) months to determine if de-regulation is feasible. 'r m f. Purchasing-Accounting Offices - This area presently exceeds the limits as stated in Section II. However, if the monitoring results for a time period starting in January for a three (3) month period, are at or below action level, the area shall continue to be a de-regulated area. a. Regulated area signs will be placed in the following locations by the dates as stated in the table. 1. At all entrances to the laboratory. 2. On all four sides of the Large Reactor area, along walkways and roadways. 3. At all walkways and roadways to the VCM tank farm. 4. Signs are presently posted at the entrances to the Com press. 5. At all entrances to the East Warehouse. b. Hazardous operation signs will be placed at all entrances to the laboratory and East warehouse by 2-15-76. These signs are presently in place at the Large Reactor area, VCM tank farm, and the compress. The signs located in the compound and vinyl dryer area will remain. c. All other regulated area and hazardous operation signs will be removed by 2-15-76. k- VAB.0001215872 .3 Regulated Area Logs Regulated area logs will be placed in the following areas by the dates as stated in the table. a. Large Reactor Control Room b. Laboratory c. Rail Scale House d. Yard Supervisor's Office e. Compress Warehouse (currently in place) f. Shipping Supervisor's Office (east warehouse) B. VCM Personnel Monitoring Reduce the level of personnel monitoring as noted in Section (F-2) by the dates as stated in the table, except as follows: 1. Large Reactor Area - Personnel dosimetry will continue on a monthly basis for each employee. 2. Yard - Personnel dosimetry will continue on a monthly basis for each employee. * 3. "Compress" warehouse - Area dosimetry will continue in this area on a monthly basis. 4. East Warehouse - Personnel dosimetry will continue in this area on a monthly basis. C. Recordkeeping There will be no change in recordkeeping procedures. D. Reports 1. There will he no changes in reporting procedures. 2. The safety director will be responsible for advising the OSHA Area Director of the regulated area changes. This information must be reported within 15 days after the change. E. Responsibilities 1. Regulated Areas a. It will be each regulated area department's responsibility to see that all personnel entering the reguTated area sign the log on a daily basis2 Each^log must be dated andPiden tified by area. " ^ It will be the regulated area department's responsibility department a dailybasis Tt will be department's repsonsibility to file ogs for permanent retention. Supervision of sign re-location will be the safety depart ment's responsibility. The maintenance department will place the signs. A 4 h VAB.0001215873 } * ft F. Summary * 4 V 1. Area De-Regulation All areas of the plant, with the exception of the Compress warehouse, laboratory, VCM tank farm. East warehouse, large reactor area, and the purchasing/accounting office area will be de-regulated by the dates as noted on the table. 2. Personnel Monitoring a. Large Reactor Area - Personnel dosimetry for each employee once a month. b. Vinyl Dryer Area - Personnel dosimetry for each job clas sification once a month. c. Laboratory 1. One area sample per month. 2. Personnel dosimetry for each hourly job clas sification in Quality Control lab once a month. d. East Warehouse - Personnel dosimetry for each employee once a month. e. Receiving warehouse - an eight hour area sample once a month. f. Office Areas1. "New" main offices- an eight hour area sample once a month. 2. "Old" main offices " an eight hour sample once a month. 3. Purchasing/Accounting offices - an eight hour area sample once a month. 4. Maintenance/Safety offices - an eight hour area sample once a month. g. "Compress" Warehouse - an eight hour area sample once a month. h. Plasticizer - an eight hour area sample once a month. i. Yard - Personnel dosimetry monthly for all yard employees. j. Compound - an eight hour area sample for each of the three (3) operating areas; Line I, Line III, and Dry Blend. k. Maintenance 1. Maintenance shop - an eight hour area sample once a month. 2. Instrument technicians/electricians - Personnel dosimetry for one employee, monthly. % 3. Utility group - Personnel dosimetry for one employee, monthly. 4. Mechanical group - Personnel dosimetry once a week for one employee working in regulated areas. Owen Tubb Industrial Hygienist C: RAD VAB.0001215874 m) SUMMARY OF ABERDEEN PLANT VCM EXPOSURE MEASUREMENTS FOR SEPTEMBER - DECEMBER 1975 PERIOD A PLANT AREA Vinyl Dryer Area PERSONNEL DOSIMETRY NO. OF NO. OF AVG. 95 EMPLOYEES SAMPLES EXPOSURE UCL (PPM VCM) CONTINUOUS MONITORING DE-REG- % OF READINGS IN RANGE ULATE? PPM (NOV.-DEC) YES NO 0-0.5 0.5-1.0 1.0-5.0 5.0 DE-REGULATION TIMING 25 94 0.3 1.0 96.7 1.0 1.7 0.6 X ? Vinyl Reactor Area 17 64 3.0 18. ll92.3 3.4 3,8 0.5 X Compound Area: 1. Line I 2. Line III 3. Dry Blend 4. Scrap Blender Area 5. Plasticizer Area 9 31 6 4 28 0.3 0.8 | 94.8 3.1 1.9 0.2 X 12-15-76 101 0.2 0.8 | 98.2 1.3 0.4 0.1 X -15-76 17 0.2 0.8 193.8 4.1 2.1 .0 X -15-76 .94.8 4.1 1.0 0.1 X -15-76 10 0.1 0.1 X -15-76 East Warehouse 9 36 0.3 1.2 188.8 6.6 4.6 .0 X Vinyl Bagging Area 91.0 5.4 3,4 0.2 X -15-76 Purchasing/Accounting Offices "New" Office Area 15 31 Transportation Traile : 3 4 0.8 3.4 4 0.1 0.1 4 0.2 0.4 X -15-76 X -15-76 X -15-76 Yard Area 6 24 0,2 0.5 X Receiving Warehouse 3 11 0.3 0.8 X -15-76 Compress Warehouse 3 4 1.0 4.0 X Laboratory Safety Offices Maintenance Area: L. Main Shop 2. Stockroom 5. Electrical Shop f. Office Area Maintenance Groups** L. Btimlding Attendant 2. Vinyl Maintenance 5. Compound Maint. 1. Utilities 27 9 4 98 0.3 1.3 23 0.2 0.7 15 0.2 0.7 0.1 0.5 0.3 1.3 0.4 1.6 0.2 0.6 0.4 2.8 0.2 0.5 0.2 0.7 X X -15-76 X X X X ** Not Plant Areas * Based on 8 hour (TWa) area sampling and personnel dosimetry using the "gas" bag method. .0D01215875