Document jBbaRdpvO9GqZgGkkw77MNkdk

EZZZZ3; UNIRDYAL UNIROYAL CHEMICAL Division of UNJROYAL, Inc. Painesville, Ohio 44077 216-357-7574 January 4, 1978 Mr. Kenneth Bowman Area Director Occupational Safety and Health Administration 1240 Last Ninth St., Room 847 Cleveland, OH 44139 Dear Mr. Bowman: Re: Regulated Area - Vinyl Chloride UHIR0YAL is currently maintaining a regulated area for vinyl chloride at it's Painesville, Ohio plant in Building 420-421 where polyvinyl chloride latex is processed with nitrile rub ber latex to produce our nitrile vinyl blend. Changes in our operations have reduced the vinyl chloride levels below.the permissible exposure limits of 1 ppm averaged over any 8 hour period and 5 ppm averaged over any period not exceeding 15 minutes. The most significant change is that.the polyvinyl chloride latex presently being used has a vinyl chloride re sidual of less than 100 ppm compared with levels of over 5000 ppm in the latex used prior to 1977. . The air monitoring data enclosed, which was developed from our fixed point monitoring system indicates that we are continual ly below the permissible exposure limits. Since we now have a situation which no longer requires the establishment of a regulated area for vinyl chloride as speci fied in 29 CFR 1910.1017, we plan to deregulate Building 420 421 effective December 31, 1977. With deregulation of these facilities the UNIROYAL Painesville location will have no VCM regulated areas. . I would appreciate receiving your written concurrence with this action prior to January 31, 1978. Factory Manager'....... ........... UNIROYAL Chemical Division of UNIROYAL, Inc UNIR0000965