Document jgoDz86VBrJk42GYvbYm5RoRy
Revised: October 20, 1983
VINYL CHLORIDE AND AREA MONITORING MONOMER ALARM SYSTEM, PVC RESIN DEPARTMENT
The VCM alarm system at PVC monitors up to l6 points while providing a two-level alarm system in the manufacturing plant and storage areas. It is made up of Bendix sampling boards which continuously draw air samples from the test points giving a low time span between the time which the sample was tested and the time which the sample was taken.
The samples are tested in a gas chromatograph from Bendix, Model 007 Analyzer.
Data gathering, comparison, input, and output is handled by a Hewlett Packard 2108a mini-computer with 2^*K of memory and a Texas Instruments Silent 700 print er/tape cassette recorder.
The vinyl chloride alarm system is based on two-leves, low-level, currently set at l.Oppm VCM, and high level, currently set at 25ppm VCM. Alarm operation is as follows:
1. Low Level
- Initiating rotating blue alarm lights in specific plant areas, indicating the need for operating personnel to wear approved respiratory protection.
2. High Level
- Initiating a horn in the appropriate area, which requires the wearing of airline or self-contained respiratory prot ection.
The alarm set points are entered into the computer which then compares all tests to these set points. Once exceeded, the appropriate alarm(s) for the correspond ing area(s) are initiated. The alarm(s) are designed to remain on until another test of the area through the sample system and a chromatograph produces a VCM con centration under the set point. The low level alarm is automatically activated when the high level set point is exceeded.
EPA monitoring points are annunciated on a panel in the MAC Room if the alarm set points are exceeded. This will alert personnel to leaking equipment that re quires investigation and correction.
The control center, housing the above equipment, is located in the PVC area, close to the main personnel entrance. It also has an annunciator which displays all alarms at PVC and their level, low or high. This can be seen from outside the center and gives an indication at a glance of the alarm situation in the many areas at PVC
PORTABLE ANALYZERS
Century OVA 98 total hydorcarbon analyzers and/or Hnu photoionizers are used to back-up the Bendix Monitoring System and to locate random VCM leaks.
Update
- February, 1982. Ecolyzer L00 LFL, Oxygen Analyzer, Monitor has been purchased for monitoring in remote areas.
BOR 012204
Revised: October 20, 1983
VINYL CHLORIDE MONOMER ALARM SYSTEM, PVC RESIN DEPARTMENT
Specific alarm locations are as follows:
ALARM
AREA/ACTUAL LOCATION
Light
Bldg. 1-E Upper, at control panelboard, above main walkway.
Light
Bldg. 1-W Upper, at south control panelboard, above walkway.
Horn
Bldg. 1 Upper, between Bldgs. 1-E & W, where main walkways from Bldgs. 1-E & W and 7 intersect.
Light
BLdg. 7-E Upper, at control panelboard, above walkway.
Light
Bldg. 7-W Upper, at control panelboard, above walkway.
Horn
Bldg. 7 Upper, above operator's desk, near Bldg. 7-E Panelboard.
Light
Bldg. 1 Lower, lane between Bldgs. 1-E & 1-W Lower, south side, where main walkways and sight lines from Bldgs. 1-E, W, and 7 Lower intersect.
Horn
Bldg. 1 Lower, next to light. Bldg. 1- Lower.
Light
Bldg.. 7 Lower, north side of large support post, near blend tanks, along main walkway.
Horn
Bldg. 7 Lower, next to light. Bldg. 7 Lower.
Light
Pilot Plant, stairway, main reactor level, near main walkway.
Horn
Pilot Plant, stairway, main reactor level, near main walkway.
Light
Dryer Area, above main walkway/line of sight between 9' and 12' dryers.
Horn Light
Dryer Area, next to light, dryer area. Control Lab., above main walkway.
Horn
Control Lab., above main walkway.
Light
Force Flow Packer, adjacent to fire alarm location indicators.
Horn
Force Flow Packer, adjacent to fire alarm location indicators.
Light
Bldg. 8 Whse., at entrance, above main passageway and sight line.
Horn
Bldg. 8 Whse., at entrance, above main passageway and sight line.
Light
Bldg, k Whse., at entrance, above main passageway and sight line.
Horn Light
Bldg. ^ Whse., at entrance, above main passageway and sight line. Bldg. U --A Whse., at entrance, above main passageway and sight line,
BOR 012205
Leominster Site Vinyl Chloride Monomer Alarm System PVC Resin Department Alarm Locations Page 2
ALARM Light Horn Light Horn
AREA/ACTUAL LOCATION Bldg. 10, Semi-Pilot Plant Bldg. 10, Semi-Pilot Plant New Recovery Building. New Recovery Building.
Revised: October 20, 1985
BOR 012206
VCM EMERGENCY PLAN
Revised: June 1, 1982 September 1, 1983
PVC DEPARTMENT
DEFINITION: An emerr ^ncy is defined as the existence of a concentration exceed ing lOOppm Vinyl Chloride in air resulting from a massive release from an uncontrolled source.
EQUIPMENT: The only respiratory equipment approved for use in dealing with an
emergency is the Scott Air Pak. These units are located as follows:
2 - MCC #3-A emergency center 1 - Bldg. 7 East Wall Upstairs 1 - Bldg. 7 Lower near stairway 1 - Bldg. 1-W at west stairwell
1 - Bldg. 1-E outside fire door - downstairs 1 - Bldg. 1-E upstairs near maintenance supply room 1 - Safety Equipment Room 1 - Supervisor's Office (Outside - opposite 6' dryer) 1 - Bldg. 31 office (Reserve Center) 1 -Bldg. 10 - Semi-Pilot Plant hallway
Any Scott Pak used for an emergency must be taken to the Mask Room so that empty tanks can be replaced with full ones, and the face pieces can be cleafied as soon as possible.
The Safety Department should be notified any time Scott Paks are used during hours other than Monday through Friday, 0800-1700 hours except holidays, by contacting Steve Shaw (S34-0546) or Ken Macy, Jr. (874-2013). During regular office hours, call 241, 297, or 322.
Take any used Scott Pak to the Mask Room immediately following any emergency for tank replacement. The EPA Technician will be in the
Mask Room during emergencies for tank replacement if necessary.
Used Scott Paks must be returned to their designated location as soon as the tank has been replaced.
ALERT:
The Bendix monitor will sound the area alarm at 25ppm. This is a warning that a higher concentration may exist. If the cause of this alarm is judged as an emergency or indication of a massive VCM release, the local alarm will be sounded.
EVACUATION PROCEDURE - PVC DEPARTMENT 1. All personnel except the Action Team must evacuate operating
areas at the sounding of the local or fire alarm.
A. Operating personnel reporting to Reserve Center - Bldg. 31
B. Maintenance personnel report to Maintenance Dept. - Bldg. 6
C. Control Lab Technicians report to Bldg. 31
bor 012207
1-6-1-1
VCM EMERGENCY PLAN - PVC DEPARTMENT
PAGE: 2
EVACUATION PROCEDURE - PVC DEPARTMENT - continued D"! Shipping personnel report to Bldg. 31
E. PVC Plant Office personnel report to Bldg. 31
G. All others (visitors, engineers, etc.) report to Bldg. 31
2. Action Team - Personnel who are required to remain the operating area.
PERSONNEL
RESPONSIBILITIES
A. Shift Supervisors
Overall control of emergency
B. Procedures Supervisor
Monitor report VCM levels. Monitor unattended reactors. Monitor evacuation of personne Provide assistance to Shift Supervisor.
C. Utility Kettle Operator
VCM source control. Shutdown equipment as required
D. Kettle Operator or Pilot Plant Operator In Affected Area
VCM source control. Shutdown equipment as required
E. Kettle Operator in building not affected
1. If emergency is in Bldg. #1, Kettle Operator in Bldg. 7 East will remain
Monitor all reactors in that
building.
r
Shutdown equipment as required
2. If emergency is in Bldg. #7, Kettle Operator in Bldg. 1 East (D305-D310) will remain.
F. Production Helper (Transferring in Bldg. 7)
Obtain key for Elm Hill Ave. Gate from Supervisor ' s,,. Office in Bldg. #7. Close railroad gates and Elm Hill Ave. vehicle gate. Have train engine shut down. Remain at Elm Hill Ave. Gate and wait for instructions from Supervisor.
G. Shift Mechanic
Standby at Shift Maintenance Supply Room in Bldg. 1-East.
H. EPA Technician
Mask Room - Change Scott Pak Tanks .
BOR 012208
1-6- 1- l
'VCM 'EMERGENCY PLAN - PVC DEPARTMENT
PAGE: 3
EVACUATION PROCEDURE - PVC DEPARTMENT - continued Action Team - continued
PERSONNEL
RESPONSIBILITIES
I- Shipping Dept. Supervisors
Have vehicles that would
obstruct Fire Dept, relocated and vehicles shut down.
J. Guard (Polyco)
Shutdown vehicles. Gate to be unlocked but closed to control "unwanted" emergency vehicles. Proceed to guard shack and stop to relocate all incoming traffi to Polyco Parking lot. Coordinate communications at extension 279.
3. Shutdown
A. Kettle Operators/Pilot Plant* Operators Stop charging reactors and close charge valves. Stop reactor degassing but do not enter building to stop. Isolate all reactors. -
B. Helpers Stop transfers. Shut off transfer pump(2) and close reactor discharge valves.
C. Helper Shutdown rail car unloading operation. Stop compressors or pump(s).
D. Dryer Operator Ensure that Fire Doors between reactor and dryer areas are closed.
E. If equipment shutdown is required involving additional people, they will be directed to do so by their Shift Supervisor
(including mask requirements) using the plant phone system (extension 214) to Bldg. 31.
4. Reserve Center
BOR 012209
Control Lab Technician will be a communicator for the Reserve Center. He will be informed (extension 214) by the Shift
Supervisor above special needs such as Fire Department Per sonnel, ambulance or additional Supervisors.
Control Lab Technician will inform personnel at the Boiler House that an emergency condition exists in the PVC Dept.
C. Control Lab Technician will record names of ail personnel who report to the Reserve Centei, Bldg. 31.
"VCM'EMERGENCY PLAN - PVC DEPARTMENT
PAGE: 4
5. "All-Clear"
A. The VCM concentration will be checked in adjacent operating areas by the Supervisor before sounding the "All-Clear" signal.
B. The "All-Clear" signal is the same for all alarms (4-4-4).
C. The Supervisor shall determine that the VCM concentration is under 25ppm before sounding the "All-Clear" signal.
D. All evacuated personnel will report to their normal job station using necessary respiratory equipment.
6. Medical Attention
A. Anyone exposed to emergency conditions involving VCM exposure will receive medical attention as soon as practical (Report to medical unit as assigned by Supervisor if during normal 0800-1700 hours, Monday-Friday work week or beginning or end of next shift.)
' *'1 B. Anyone coming into skin contact with liquid VCM will receive
immediate medical attention either at the Medical Center or Leominster Hospital.
BOR 012210 1-6-1-1
RCRA CONTINGENCY PLAN NOTIFICATION OF EMERGENCY COORDINATOR
The following people should be contacted in case of an emergency
EMERGENCY COORDINATOR
M.R. Thorsen
IT ant Manager
Home Phone 554-6554
ALTERNATE D.L. Young R.R. Underwood K. Macy, Jr. A.C. Mendelsohn
PVC Prod. Mgr. Polyco Prod. Supt Safety Supervisor Chief Maint. Eng.
554-9433 422-7212 874-2013 537-0480
There is no clear definition of just what constitutes an emergency under RCRA. Therefore, the following will be used:
Emergency for RCRA contingency plan:
1. "A massive uncontrolled release of hazardous material into the air, soil, or surface water thr*eatening the environment or human health."
2. A fire
3. An explosion
In the event M.R. Thorsen is not contacted, the alternate is to contact one of the following individuals and notify Operation Alert, 614-457-5200, if appropriate:
' H. R. Jep sen, Jr W. F . Gabel N. M. B1ac kman
S29-5582 779-5106 5 34 - 4 ''6 6
BOR 012211
WASTE HANDLING PROCEDURE
RAS/3-1-83
Objective:
To define steps to be used while accumulating waste material in each department and while transporting the material to the stag ing area south of Bldg. 31.
Scope:
This procedure applies to all waste that cannot be placed in trash dumpsters.
Personnel: A. RCRA Site Staff Members are required to monitor waste gen erated in their departments until such time as it leaves the site for legal disposal.
K. L. Macy, Jr. K. L. Macy, Sr. D. L. Young R. R. Underwood A. C. Mendelsohn J. E. Phillips
S. Farrington G. Martin
- RCRA Site Coordinator - RCRA Site Functional Supervisor - RCRA Site Staff Member - PVC - RCRA Site Staff Member - Polyco - RCRA Site Staff Member - Maintenance - RCRA Site Staff Member - Control Lab,
Shipping - RCRA Site Staff Member - Bldg. 10 - RCRA Site Staff Member - Pilot Plant,
Semi-Pilot
Plant
B. The following individuals are functionally responsible for any movement of waste generated in their departments to the hazardous waste storage area:
J. Michaels S. Foster H. Conklin R. Caron L. DiRusso G. Martin
I. General Guidelines - All
Shift Supervisor - PVC - Shipping
Polyco Maintenance Q. C. Labs. Development
te Substances
A. Trash suitable for placing in trash dumpsters will not be mixed
with other waste materials and will not be brought to the staging area.
B. Waste materials will be accumulated in sound metal drums only, preferably in an original shipping container for that material.
C. While waste is being accumulated in each department, drums will be maintained so as to prevent the introduction of water into the container.
D. Different types of waste material will not be mixed in individual drums.
E. Individual drums of waste will not be accumulated or stored for longer than 70 days in the department. The date of start of accumu lative will be marked on each drum. BOR 012212
0-1-9-0
Waste Handling Procedure Page 2
I. General Guidelines - All Waste Substances (continued)
F. Prior to transport to the staging area, all bungs and/or lids will be secure on all drums.
G. Intraplant Transport Control Card (See Attachment #1)
1. All waste material transported to the staging area will be accompanied by an Intraplant Transport Control Card, colorcoded by department.
2. The card will be completely filled in (except for the bottom tear-off portion) and signed by the individual functionally responsible for the movement of waste in the department.
Particular attention should be given in identifying the con tent of the container. For example, a drum of "Unstripped PVC Resin" should be identified as such and not just "PVC Resin" or "Waste Material".
3. The number on the card will be placed on the metal drum with a marking kit which will be provided.
4. When material is transported to the staging area, the control card will either be given to the person responsible for that area or placed in a receptacle which will be provided for that purpose.
5. The person responsible for the staging area will acknowledge receipt by signing the bottom tear-off section which will be returned to the individuals in each department as listed be low :
PVC Department Polyco Department Maintenance Q. C. Labs. Development Pilot Plant
D. Young R. Underwood C. Mendelsohn J. Phillips S. Farrington G. Martin
6. The stub will be attached to the bottom portion of the Gen erator File Sheet (see Attachment #2) and maintained in a fi le.
7. Personal protective equipment requirements while handling waste materials will be the same as those used in the plants when handling the material prior to its becoming a waste.
J BOR 012213
0-1-9-0
Waste Handling Procedure Page 3
11. Specific Waste Handling Procedures
A. PVC Product Waste
1. The following materials will be accumulated in separate con tainers whenever possible.
a. PVC chips and chunks b. Unstripped resin c. Stripped resin
2. If unstripped material is mixed with stripped material, the entire container must be considered as unstripped PVC waste.
B. Polyco Product Waste
1. The following material will be kept separate whenever possible.
a. Reactor or other vessel scapings b. PVC Latex c. All other Polyco product waste
C. Waste Chemicals or Waste Oil
1. Chemicals will not be mixed in individual drums.
2. Different types of waste oil will not be mixed in individual drums.
3. A minimum of 4" head space will be maintained in each drum.
4. Chemicals or oil spills absorbed with Speedy-Dry or other absorbents will be placed in metal drums and identified as such.
III. Empty Metal/Rubber Drums
A. Supplier returnable drums in the Polyco Department will be stored on pallets south of Bldg. 24 until picked up by the supplier.
B. All other metal drums will be transported to the staging area for disposition.
C. Lids and/or bungs will be secure. D. An "EMPTY" tag will be attached to each drum
BOR 012214
NOTE:
Any questionable situation encountered concerning the movement, and/or disposal of any substance, material, chemical, oil, etc. on the site will be brought to the attention of the RCRA Site Coordinator (Safety Supervisor) for clarification and assignment.
INTRA-PLANT TRANSPORT CONTROL CARD
BORDEN, INC. LEOMINSTER. MA
N?
00500
date__________________ DEPARTMENT-------------DISPATCHER ---------------SUBSTANCE ___________ DATE, STORAGE BEGAN
SIGNATURE
TRANSPORT DATE________ RECEIVED AT STAGING BY
00500
The control cards will be issued with departmental color coding and prefix letter.
Gold Red Green Blue White
-M
= Maintenance
- PVC = PVC
- PM = Polyco
- PP = Pilot Plants
- SPP = Semi-Pilot Plant
BOR 012215
The prefix will be followed by a serial number in ascending sequence.
DATE _________________ DEPARTMENT __________ DISPATCHER __________ SUBSTANCE ___________ CONTAINER NUMBER __ DATE, STORAGE BEGAN COMMENTS
GENERATOR FILE SHEET
SIGNATURE
ATTACH STUB HERE
0-1-9-0
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TRAINING - I'VC DEPARTMENT
^ <ei
I. Shift/Procedures Supervisors
A. Initial Training
1. Initial safety indoctrination. 2. Review of Vinyl Chloride Standard as required by OSHA
regulations. 3. Initial over-view of plant operations and responsibility
by Production Manager and/or day supervisor. 4. On-the-job training in area of responsibility by an ex
perienced supervisor currently working the position un til qualified as determined by Production Manager.
B. Refreshers
1. Annual review of OSHA Vinyl Chloride Standard. 2. Periodic supervisor meetings to cover various facets of
plant operation. 3. Supervisors attend or present monthly safety meetings
held for hourly personnel in their department. 4. Supervisors attend or present routine process training
sessions held for hourly personnel in their department.
C. Special Training *
1. Sessions presented by Production Manager or day super visor following a VCM emission to review circumstances leading up to the emission and steps to be taken to pre vent future emissions.
11. Kettle Operator* 1 2
Kettle Operators are not normally hired externally but are sel ected through a bidding process from existing plant employees, normally from the Production Helper classification. These per sonnel are familiar with the purpose and location of reactor equipment through exposure in the Production Helper, classifica tion.
A. Initial Training
1. Initial training in reactor operation and control by area supervisor in accordance with established train ing guidelines (4-8 weeks).
2. On-the-job training under the guidance of Procedures Supervisor for 4-8 weeks or until qualified as deter mined by shift and area supervisor and a test covering reactor operations.
BOR 012223
Training - PVC Department Page 2
II. Kettle Operator (continued)
B. Refresher Training
1. Scheduled routine process training sessions covering all phases of reactor operation with emphasis on batch con trol and emission prevention.
2. Scheduled monthly safety meetings. 3. Quarterly audit of each Kettle Operator by a production
supervisor to determine if operators are following stand ard operating procedures. This audit is performed in accordance with a predetermined checklist.
C. Special Training
1. Training sessions held after a VCM emission to review the circumstances leading up to the emission and steps to be taken to prevent future emissions.
2. Sessions on a "needs" basis as changes to equipment or procedures occur.
III. PVC Production Helper
A. Initial Training
1. Initial safety indoctrination. 2. Review of OSHA Vinyl Chloride Standard. 3. Initial over-view of job requirements and responsibilities
by area supervisor and shift supervisor. 4. On-the-job training with an experienced Production Helper
until qualified as determined by shift supervisor.
B. Refresher Training
1. Scheduled monthly safety meetings. 2. Scheduled process training sessions to review operations
in their area of responsibility.
C. Special Training
1. Sessions held on a "needs" basis as changes to equipment or procedures occur.
IV. Maintenance Mechanics
A. Initial Training
1. Initial safety indoctrination. 2. Review of OSHA Vinyl Chloride Standard. 3. Initial over-view of job requirements and responsibilities
by Maintenance Superintendent. 4. On-the-job training with an experienced mechanic until
qualified to perform the duties of a shift mechanic as determined by a Maintenance Supervisor.
BOR 012224
Training - PVC Department Page 3
IV. Maintenance Mechanics (continued)
B. Refresher Training
1. Scheduled monthly safety meetings. 2. Routine on-the-job training to gain experience in new
areas. 3. Training programs in off-duty hours at trade schools or
seminars in skills such as welding. 4. Presentations by vendor representatives in the repairs
of their equipment.
C. Special Training
1. Sessions held after VCM emissions that were in any way attributable to equipment malfunctions to review the circumstances leading up to the emission and steps to be taken to prevent future emissions.
V. EPA Technicians
A. Initial Training
1. Initial"safety indoctrination. 2. Review of OSHA Vinyl Chloride Standard. 3. Over-view of job requirements and responsibilities and
EPA regulations subject to compliance by this location by EPA Coordinator. 4. Operation of equipment that will be used in compliance effort~-portable detectors and fixed monitor--by EPA Coordinator. 5. Reports required as a result of compliance requirements. 6. On-the-job training with an experienced EPA Technician until qualified as determined by EPA Coordinator.
B. Refresher Training
1. Monthly safety meetings. 2. Attendance at monthly process training sessions. 3. Scheduled sessions to upgrade the technicians knowledge
in plant equipment and operations.
NOTE:
Training for personnel in the Polyco Department is essentially the same as listed for the PVC Department but is not itemized in this report.
BOR 012225
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