Document kmGz4Oy9V4oEmjwJL2ompaLvD

Vista Chamicot Company 15990 N. Barker's Landing Rd. Post Office Box 19029 HoustonJexos 77224 Phone (713) 531-3200 October 15, 1984 XF: Ms. Margaret Samaways Gulf Oil Corporation P.0. Box 1166 Gulf Bldg. - Room 358 Pittsburgh, PA 15230 Dear Margaret: Enclosed is a copy of my speech (please excuse extraneous markings), a copy of ray slide text, and the Marnie comparison summary. Good luck with the chapter. Sincerely, Thomas G. Grumbles.`'C.I.H. Director, Industrial Hygiene ajo 004 Enclosures VVV 000016241 Vuto Chemical Company 15990 N. Barker's Landing Rd. Post Office Box 19029 Houston,Texas 77224 Phone (713} 531-3200 October 12* 1984 Carol Stack Chemical Manufacturers Association 2501 M Street, NW Suite 200 Washington, DC 20037 Dear Carol: Vista Chemical's comments on the STEL issue are below. We have identified the following operations where potential peak or short-term exposures to Eto may occur during operations at our Ethoxylation Unit. 1. Unloading Eto cars 2. Loading product cars 3. Eto product sampling 4. Eto analytical procedures in the laboratory 5. Maintenance operations including vessel entry 6. Emergencies Of those operations listed above 1,2, and 6 are specifically cited in the standard as operations for which respirator use is acceptable. For number three we have designed a closed-loop sampling system which controls peak exposures during those operations. For number 4, exposures are controlled by restricting all Eto operations to chemical fume hoods. Where maintenance operations may result in exposures, our procedures require the use of respirators until atmospheric levels of Eto are determined. Exposures during these operations could not be reduced by feasible engineering controls at this time. Respirator use would be required for these jobs. Based on the information above, we would not see a need to do a significant amount of short-term sampling for compliance with a STEL. However, if required we are not confident that we could monitor within the accuracy limits of the standard. We feel our lower detectable limit is right at 0.5 ppm with a 2-hour sample and a 15-minute sample would result in questionable accuracy. We do not, however, have quantitative data to confirm this. The costs for short-term monitoring would increase directly, due to more samples, and indirectly, due to the additional man-hours needed to collect 15-minute samples versus longer term samples. VVV 000016242 Carol Stack Page 2 October 12, 1984 In general, we feel the EOIC should reemphasize their comments regarding the lack of scientific evidence regarding the need for a STEL, and the fact that the controls required to meet a 1.0 ppm PEL would control most exposures to below 10 ppm. Sj,nr^i*plv. \ Th . . Director, Industrial Hygiene ajo VVV 000016243