Document mmrjjGK1jgLdJ1QdKJOEpEqaO

IPGoodrieh Chemical Division Inter-Organization Correspondence To u>CBtlon Department ____ From Location Chuck McCann Pedricktown Department Subject VCM PERSONNEL MONITORING DATA 1979 - 1981 >i ! . / The following is a summary of the personnel monitoring data gathered for Mass Resin. YEAR #READINGS 0.0-0.5 0.5-1..0 T-l-O RANGE ARITH. AVG. LOG AVG. 1979 Respirator worn No respirator worn Total 91 83 174 52 81 13 3 16 1 17 23 .01-21.82 1 .01-4.22 24 1.39 .16 .80 0.39 0.08 0.18 1980 Respirator worn No respirator worn Total 34 119 153 15 114 125 6 5 11 13 .00-12.85 0 .00-.87 13 1-63 0.11 0.45 0.34 0.04 0.06 1981 Respirator worn No respirator worn Total 45 107 152 29 95 122 9 8 17 9 .01-3.09 4 .00-12.58 13 0.61 0.36 0.43 0.27 0.09 0.12 1979-1981 Respirator worn 170 No respirator worn 309 Total 479 94 290 384 31 14 45 45 .00-21.82 5 .00-12.58 50 1.23 0.21 0.57 0.34 0-06 0.11 If we can assume that the actual exposure on a shift where a respirator was used was < 1.0, we can state that actual exposure was less than l.Oppm 99% of the time: (474/479 = 98.96%) ? Logrithmic averages are included as they are felt to be more representative of "typical" employee exposure. __________/ If you have need of any more information on this, please let me know. Thanks, C'fu+J<- fit Chuck McCann CEM/re cc: B.A. Prusinoski/M. Dunn I.A. Kiel NGC 14846 r>- 'yd.f C. i, Q April 30. 1975 Mr. William Dreeland Area Director - Region 11 U.S, Department of Labor Occupational Safety 6 Health Administration 970 Broad Street Newark. New Jersey 07102 Dear Sir: In accordance with the requirements of 29 C.F.R, I910.93q (n) (1) (1) and (11), the B.F.Goodrlch Chemical Company, P.0, Box 400, Pedricktown. New Jersey 06067 is reporting the following information regarding regulated areas at this location. Plant Location: U.S. Route 130 and Porcupine Road Salem County Pedricktown, New Jersey Number of Regulated Areas: Two (2) i Building 512 - Mass Resin Polymerisation Building Building 513 - Suspension and Dispersion Resins Polymerization Building Number of employees In each regulated area at any given time during normal operations: Building 512 - 3 Assigned 1 to 4 on intermittent basis Building 513 - 5 Assigned 1 to 6 on Intermittent basis Any changes to the above information will be reported within 15 days of the effective date. Respectfully, The B.F.Goodrich Company ARW:DlJOjC: jle A. R, Webber Plant Manager NGC 14847 March 12, 1981 Tot J-M. Fletcher Re: MASS RESIN VCM MONITORING I have been requested to review the Mass Resin VCM monitoring results for consideration of deregulating this process. Dave Winstead In hts December 22, 1980 letter to Dr. Oietz Included a January, 1978-June, 1980 summary of VCM Personnel Monitoring. This summary Is Insufficient to make a recommenda tion. Please provide me with the individual data by year for the five classifications shown in this summary. Also the data should be for the complete year of 1980 and any new data available In 1981. I wi11 review this Information with the appropriate individuals and make a recommendation on deregulating this process. Please call me if clarification is needed. H. Waltemate HW cc: H. J. Lanese/E. W. Harrington N. R. Aquino R. M. Montgomery NGC 14848 ^HFGoodrich Chemical Division Inter-Organization Correspondence To D.L. Winstead Lotion Pedricktown From Chuck McCann Location Pedricktown 29 WB1 DeportmentPer s onnel Department Environmental REGULATORY STATUS RECLASSIFICATION FOR MASS RESIN Subject POLYMERIZATION AND ACRYLIC LATEX REACTOR CLEANING Date 5/15/81 On April 30, 1975, the BFGoodrich Company notified the Occupational Safety and Health Administration (OSHA) , that the Mass Resin Polymerization Area, housed in Bldg. 512 at the Pedricktown, N.J. facility, was designated as a regulated area under the OSHA Vinyl Chloride Standard 29CFR1910.1017. The OSHA Vinyl Chloride Standard established a permissible exposure limit of l.Oppm and an action level of 0.5ppm of vinyl chloride for an 8 hr. time weighted average (TWA) . On December 1, 1978, the BFGoodrich Company notified OSHA that the task of entering and cleaning polymerization vessels in the Pedricktown facility's Acrylic Latex area, housed in Bldg. 502, was a regulated task under the guidelines set forth in the OSHA Standard for Acrylontrile 29CFR1910.1045. The OSHA Acrylonitrile Standard establishes a permissible exposure limit of 2.Oppm and an action level of l.Oppm for an 8 hr. TWA. Based on personnel monitoring information compiled in conformance to these OSHA standards , it is proposed that the Mass Resin area and the function of cleaning Acrylic Latex reactors should be reclassified per their respective OSHA standards. In support of this proposal, many factors were taken into consideration when questions of time frame and data analysis were encountered. The Mass Resin area, due to process improvements and a continued emphasis in fugitive emissions, has experienced a reduction in the level of Vinyl Chloride monomer in the general workplace atmosphere. The monitoring results from 1980, therefore, are indicative of how the Mass Resin area can be expected to perform. The task of reactor cleaning in the Acrylic Latex area, on the other hand, was essentially the same in 1978 as it is currently, and personnel monitoring results gathered during this period of 1978 thru 1980 are presented to indicate the exposure monitoring history for this position. It should be noted that the automatic reactor cleaning system, being brought on -iline in the second quarter 1981, is expected to further improve the .levels of exposure related to this position as both frequency and extent of manual reactor cleaning may be re due ed. It should be noted that without regard to OSHA classification both Mass Resin and Acrylic Latex have defined tasks where personnel protective equipment is mandatory. These tasks are defined in Pedricktown Safety procedures SA 30B and SA 31C and are incorporated into specific operational or manufacturing procedures as warranted. NGC 14849 * r-+ Page 2: r The tables below summarize the data that have been compiled in support of the deregulation of the Mass Resin Bldg. 512 and the task of cleaning reactors in the Acrylic Latex Bldg. 502. If you have any questions, please feel free to contact me. VINYL CHLORIDE MASS RESIN PERSONNEL MONITORING DATA - 1980 POSITION NO. OF SAMPLES WITHOUT RESPIRATOR NO. %<-5 %<1.0 AVG. WITH RESPIRATOR NO. 7o<.5 %<1.0 RANGE Lead Technician Technician Utility Professional TOTAL 56 52 20 20 148 46 31 17 20 114 97.8 93.5 94.1 100. 100. 100. 100. 100. 96.5 100. 0.09 0.11 0.18 0.06 .10 10 30 40 .01-8.46 21 42.9 66.7.00-12.8 3 100. 10.0. .15-.33 0- - 34 44.1 61.8.00-12.8. POSITION ACRYLONITRILE ACRYLIC LATEX PERSONNEL MONITORING RESULTS - 1978 -1980 NO. OF SAMPLES WITHOUT RESPIRATOR WITH RESPIRATOR NO. 1.0 7o< 2.0 AVG. NO. 7e<1.0 7o<2.0 RANGE Utility 91 42 97.6 100. 0 0.07 49 75.5 83.7 .00-14.* Chuck McCann CEM/re cc: C.J. Nosal/J.M. Fletcher/J.A. Kiel B.A. Prusinoski/R.J. Purtell R.R. Szmerda/D.R. Erbe D.P. O'Keefe/W.R. Myers File - VCM Personnel Monitoring - VCN Personnel Monitoring i KGC 14850