Document k9Kwja94vqYDL2VybERnZVoXD

PQ42I049 To: 4.18.16 UNIROYAL CHEMICAL Dlvislan ( UHIROYAL, kc. January 6, 1978 cc w/Att: RMH, VHI, CEK, RTS, IZB, EBB. CES, 4.20.03*01, 4.28.01.298, B. R. Leach - Naugatuck E. J. Sowinski - Naugatuck E. Turk ADtX "1230" From: R. V. Kenney Subject: Painesville Plant Ylnyl Chloride Deregulation A meeting van held on January 4, 1978 in the Cleveland office of QSHA to discu deregulation of vinyl chloride in the Paracril facilities at Painesville. Present were R. K. Ball, V. M. Xliff, R. V. Kenney and Robert L. Knarr, an Industrial Hygienist for OSHA. The attached letter and data vere presented to QSHA for their review. Mr. Knarr questioned the one result of 2.2 PPM and was advised that this result ) was recorded on December 23, 1977 when the plant was totally shutdown and therefore in our opinion is not a valid result. Mr. Knarr's interpretation of 1910.1017(a)(2) is that PVC latex would fall into the category of a fabricated product and that there should be no need for a regulated area for VCM at Painesville. He considers that we are in the same class as some body processing polyvinyl chloride. Mr. Knarr will draft a letter for the Area Director indicating there is no further need for our nitrile rubber plant to be regulated for VCM; however, he is not sure if the Area Director will be able to sign such a letter or whether a variance must be issued from Washington or a letter issued from their legal people as onr ease had been transferred from QSHA to the So licitor's Office after the citation in 1974. In any case, we are planning to deregulate immediately with formal notice being given to the Union. Mr. Knarr indicated that as long as no major process changes are made the area should remain unregulated with regard to VCM. However, any major change should precipitate monitoring and contact with QSHA. Process changes that obviously would result in reduced exposure would not fall in this category. For example, a significant reduction in finishing temperatures obviously w uld reduce exposure, and it would not be necessary to bring this to OSHA's attention but it would be worth file documentation. Although not discussed with OSHA, this obviously will be the ease for suepensi PVC replacing PVC latex. v CO oto 2 Attachment R. V. Kenney PRODUCED PURSUANT TO PROTECTIVE ORDER INTRACOMPANY CORRESPONDENCE