Document gbm1pZbJwOvg663j9VdB1NeGV

ORGANIZATION CORRESPONDENCE THE GENERAL TiRE -& RUBBER COMPANY CHEMICAL DIVSSiON TO M. G. Glexm ATTEf^TION R. W. laundrie cc: M. C. Bentley R. L. Jachson E. S. Kierctead FROM DATE SUBJECT H, E. 0ewett March 18, 1976 VCSA Meeting February 28 Atlanta, Gfi. NOTES FROM VCSA IN ATLANTA The main format of the meeting was a statement by each company where they stood on OSHA with regards to work levels VCM, RVCIl in resin, medical surveillance, monitoring equipment and procedures, productivity loss, OSHA. Rather than list in detail each ?VC producer, a summary of what is being done will be presented. I have a complete table by producer if you want any specifics. Per cents are rounded to nearest 10 because voting was not always accurate. 1. Monitoring systems --* $ by type of thos$ commenting: Bendix Areas Honeywell Miran Self 10 units 10 units 1 unit 5 units (Uhion Carbide and Pantaeote) Only two of 23 companies have a single system as General Tire does. Some plants have three or four systems. Based on VCSA group dis cussions, we should consider ordering a second Areas, using some of the points for EPA monitoring. Eight plants have computer data tabulation on readings. 2. VCM Levels Area Polymer Resin Finishing Warehouse Tank Farm Average Level 60 ho 50 50 0 0 GENC 20986 VCHA Meeting - February 28, 1976 Page 2 Mechanics tend to be a problem on personnel exposure. Several high exposures. All plants reported excursions over 100 occur periodically. 3. KVCM in Resins See separate meins issueito M. G. Glenn. 4. Medical Surveillance General Tire program is equal to best, and better than most programs for medical surveillance. Goodyear and General Tire are the only two companies to use the advanced blood work SMA-22. All the rest are using SMA-12. We are providing an equivalent medical program for much less per employee than the majority of those commenting. On refusal to take medical work, most are obtaining an affidavit that the testing was offered but refused. Vast majority are not furnishing medical surveillance for outside con tractors but are presenting training on VCM to long term contractors in plant. 5* Leak Patrol The majority of the EPA discussion centered around the leak patrol criteria in the Standard. All companies agreed that leak patrol was a necessary and useful tool, but there was no unanimity on the frequency and details of this patrol. Goodyear is the only plant with 24 hours a day, 7 day a week leak patrol coverage. Most plants agreed that there was a need for at least a minimum of 8 hours leak patrol per week day and 3ome spot checks on the weekend. One plant started a program of numbering all valves and flanges, pmnp seals, etc., but when they hit 900 and some numbered parts, they ' abandoned the program. It was a general consensus that a leak patrol should have area sheets, for example, a sheet for each reactor, a sheet for the recovery area, a sheet for the MVC transfer pumps, etc. Some plants indicated a need to put a very small bird cage around .the probe' of the Century to prevent over-zealous leak patrol people from sticking it, for example, down in a valve stem cavity. They will always get a high reading doing this. There was an agreement that 25 ppm detected by the permanent monitoring system on two consecutive readings^indicated a leak and would require a leak patrol to Investigate and correct. There was a general agreement that the EPA would allow the collection of high KVCM waters and put them to a central system for stripping. GENC 20987 VCSK Meeting - February 28, 1976 Page 3 6. True Confessions The only item covered under true confessions was an incident involving mischarging of catalyst into the reactor due to a communication break down between two operators. The catalyst was charged into a hot reactor causing auto ignition and flames from the reactor. The main breakdown in the procedure was the failure to follow a required check list for charging reactors. 7. General Comments a. Most companies are sending only one representative to future meetings. b. Most companies arc going to video slide presentation for presenting the CSHA Standard. c. M03t companies are alarming at +5 and +25. We are alarming at +1, +5; and flOGO, d,, Meet people with Mirans find they do not work adequately. 8. Conclusions It is my firm opinion that we should not approach the EPA Standard with the same crash type programs as ve did OSEA. I firmly believe we should request variances in all areas and do an organized detailed completion of each project. This would prevent many of the fiascos that we encountered in the OSHA program, such as using the wrong piping for our plant breathing air system. May I have your thoughts on this approach. HEJ:sm H.vdS. Jewett Plant Manager QENC 20988