Document moMbLzEOY1QpjekdeRDj6yXJ

BURLINGTON SOUTH 1976 - 1990 PROPERTY LOSS PREVENTION REPORT OCCIDENTAL PETROLEUM CORPORATION OCCIDENTAL CHEMICAL CORPORATION BURLINGTON SOUTH P.O. BOX 116 BEVERLY ROAD BURLINGTON, NJ 08016 Insp. Date: June 17-18, 1987 Issued Date: July 8, 1987 Report by: E. Roy (233L) Conf. With: R. Newgold, Plant Manager C.F. Wunder, Safety Supv. Attention: Mr. J. DiPasquale, Insurance Manager Summary This is a well maintained and protected poly vinylchloride (PVC) production facility producing both suspension and dispersion PVC resin. Suspension resin is produced using Scientific Design batch technology in 9 reactors, 8-5000 gal and 1-3750 gal. Dispersion resin is produced in 8-40 ft. high, 3 ft. diameter and 6-60 ft., 3 ft. diameter reactors using Warker technology from West Germany. This updated loss prevention report supersedes all previous reports. Occidental Petroleum procedures require a written response to Loss Prevention recommendations within 45 days of receipt. Elmslie engineers are available for clarification and assistance. R commendations: Changes Since the Last Inspection: New Recommendations: 87-6-1 (Revised), 87-6-2 Completed/Removed Recommendations: 86-9-2 OCC 8505 I ONDON LIVERPOOL HONG KONG SINGAPORE MANILA TAIPL1 PIRAFUS PROVIDFNCE LOS ANGELES CALGARY LOSS PREVENTION REPORT Page 2 87-6-1 (Revised) (Previous 86-9-1) To prevent weakening of steel structure supports due to fire exposure in the VCM Recovery Area, the existing sprinkler system should be supplemented by attachment of the existing portable monitor to the fire hydrant to the north of the VCM Recovery Area. Reason: Due to location of equipment and steel supports not all support steel is completely wetted by the existing water spray deluge system. Positioning of the monitor nozzle in the area will allow fire fighters to put additional water spray on equipment and support, greatly reducing possible serious fire damage. Cost to complete the recommendation is minimal since the monitor nozzle is already on site. Without the additional protection recommended a vessel containing VCM may collapse breaking pipe flanges releasing more fuel to the fire, resulting in a property loss up to $750,000. Completion of the recommendation will reduce the loss to the normal loss expectancy for this type plant, approximately $100,000. 87-6-2 To minimize fire exposure to VCM unloading facilities and VCM railcars the four unloading racks should be protected by providing four permanently mounted remotely operated, 750 gpm monitor nozzles within 50 ft. of each unloading spot. Reason: A fire at a railcar unloading VCM could expose the car involved, as well as, the cars to either side to overheating and possible failure due to flame impingement resulting in the loss of one or two railcars and associated unloading rack and property damage estimated at $1,000,000. Completion of the recommendation will reduce the property loss to the normal loss expectancy of approximately $100,000. Attachment Sketch to follow Water Supply Form cc: C. Elam/Occidental Petroleum Corp. B. McNally/Occidental Petroleum Corp. J. Wilkenfeld/Occidental Petroleum Corp. W. Driscoll/Occidental Chemical Corp., Niagara Falls TPZ/GSN ER:pw (233L) OCC 8506 SOURCES 1 {EXCEPT PUMPS) I TAN RES1 s- i1 fLMSLlt Consultancy Services WATER SUPPLY SOURCES (DESCRIBE) ns.. PRESSURE AT YARD -- PSI ZQ /> (</o> CAPACITY GAUONS CITY STATE 'bot-LttiG-to ri -South 1/fT CONDITION fid NO SATIS X UNSATISFACTORY (DESCRIBE) FIRE PUMPS suqnoNRATING FWW (-) mGPM0PSI CAPACITY GAUONS HEAD(+) DRIVE LIFT pi) DRIVE RELIABLE NO AUTO. ^3START PRES. YfS NO GPM PSI PRIMING ACCESSIBLE JOCKEY RELIABLE DURING FIRE PUMP PSI YES NO YES NO ON OFF SATIS CONDITION UNSATISFACTORY (DESCRIBE) NO. 1 Z^oopot Us. NO. 2 TZSdfm U NO. 3 r u NO. 4 /.<XX,QO0 t iV 2 JD It Li- *_ y jL z h IP x _>c m m A 90 a /- u X loo X X U U X NO. S NO. 6 0 - tmstl i1 C cucimc G - GASCXINI NO - NATURAL GAS $ . SHAM 0 - OtHCR WATER TEST DATA DATE TEST BY SUPPLY FROM ft M 7 H fuu/r K GPM ol&dO 1000 FLOW PITO FLOW LOCATION p/ Mousems. "tuny It l ** PRESSURE PSI STAT. RESID. GAUGE LOCATION WHERE STAT. & RESID. WERE READ FIRE PUMP SUCT. PRES. DSCH. PRES. SPEED RPM RATING z /tfr m /(?<? /.-To? J) * it M io00 It It *t ~x toi *Soo & % OCC 8507 __________________1 1 1 INTER-OFFICE M E,M O TENNECO CHEMICALS, INC. to P.R, Scarito at Burlington Date May 18, 1976 from yF.W. Kanzler/W.W. Heal subject OSHA Inspection at Burlington Summary copvtoW.F. Gabel P M, Reed F.X. Ritter G.I. Rozand A.C. Siegel F. Toea File bcc R.A. Lojewski The Burlington Plant site has undergone an OSHA industrial hygiene inspection since April 26, 1976 with one more inspection in the Compound Plant - for carbon black particulate testing - outstanding. Inspection dates for the Resin Plant were April 27, 1976, May ,3, 1976, May 6, 1976 and May 10, 1976 at which time personal VCM monitoring, dust monitoring and area VCM monitoring were performed. Inspection dates for the Compound Plant were May 27, 1976 and May 29, 1976 at which time personal particu late measurements were taken to characterize lead, cadmium and barium exposures of operating personnel. In addition, an initial meeting with the two OSHA inspectors (OSHA CSHOs) and plant management as well as Com pound Union representatives was held on April 26, 1976 and an interim meeting with plant management and Union representatives from the Resin Plant was held on May 7, 197 6. Listed below is an outline of the meetings and inspections for the above dates: I. Initial Meeting and Plant Tour On April 26, 1976 Messrs F. Lewis and R. Hanlon, OSHA CSHOs from the United States Department of Labor, Camden Office, visited at the Burl ington Plant requesting an industrial hygiene inspection. As a preliminary to the actual inspection, the CSHOs requested a meet ing with Tenneco representatives in the Compound Plant. Messrs W.W. Heal, P.N. Thomas, P.R. Scarito and F.W. Kanzler were present to meet with the CSHOs. The discussion centered primarily around the Tenneco biological testing programs including frequency of testing, type of testing and actions to be taken if an overexposure should occur. Also discussed were respirators and their mandated use by the various plant personnel, general housekeeping practices and safety meetings conducted; the latter item in particular, as related to an instruction on safe handling practices of lead and other powdered stabilizers, Mr. Hanlon requested and was provided with the OSHA log 100 for 1975 and 1976 to date. Formulation recipes were requested by Mr. Hanlon for the comppounds run during the time of the expected particulate monitoring. Following a meeting with a Compound Union representative - R, Horvath the CSHOs requested a plant tour of the Compound Plant. Both lines, all levels and the exhaust area on the plant roof was inspected. OCC 8508 Page 2 After the plant tour, the CSHOs were given the opportunity to meet with the plant physician, Dr. M.C. Venditti, to further discuss the biological testing program and test data, A second meeting was requested for the Resin Plant with Messrs W.W. Heal, P.R. Scarito, A.C. Siegel and F.W. Kanzler representing Tenneco. Topics covered were (1) a review of deregulated areas including data generated, (2) mode, type and frequency of personal monitoring samples, (3) reviewed in detail the status of the Engineering program at which time Mr. Lewis requested a monthly status report for this program to be sent to the Camden office, and (4) the personal VCM results as listed in the alphabetical personnel roster were reviewed in detail by Mr. Han lon. Mr. Lewis was provided with copies of AOPs M-5, M-6, M-7 and M-8. In addition, a copy of EOP 11, the OSHA log 100 for 1975 and 1976 and a copy of the OSHA summary 102 for 1976 was given to the CSHO. A detailed review of the standard was conducted by Mr. Lewis to clarify possible areas of misinterpretation. The only differences of opinion, as Mr. Lewis pointed out, were found to be in the area of fifteen-minute ceiling samples, which should be taken on a regular basis along with the eight-hour TWA samples; personal exposure samples exceeding 1 ppm should be retaken on the same employee and not for the same job classification with a different employee. There was no request made by the CSHOs to meet with Resin Plant Union representatives. II. Hygiene Inspection - Resin Plant A. Copolymer - VCM On April 27, 1976 a personal VCM monitoring survey was conducted by Mr. Lewis in the Copolymer Plant. Mr. F.W. Kanzler took parallel samples for Tenneco. The CSHO used Sipin pumps at a flow rate of about 50 ml/minute. SKC pumps with the same flow rates were used for the Tenneco samples. Eight-hour TWA, as well as fifteen-minute ceiling samples, were taken. The following is a listing of the personnel mon itored : Number of Samples Fifteen-Minute Eight-Hour TWA Ceiling Name Job Classification OSHA Tenneco OSHA Tenneco J. Webster I. Raymond H. Wallace reactor oper - chg reactor oper - dmp bagger - cleaner 11 11 11 33 44 44 (Tenneco results are summarized in the attached Table I.) No other type of inspection was made, neither was any attempt made to establish work patterns for the people monitored. OCC 8509 Page 3 * The Union representative present all day was Mr. W. Comegno who had very animated conversations with Mr. Lewis throughout the day. B. Homopolymer - VCM On May 3, 1976 a personal VCM monitoring survey was conducted by Mr. Lewis in the Homopoly.mer Plant. Mr. Kanzler took parallel samples for Tenneco. The CSHO used new DuPont pumps at a flow rate of about 50 ml/minute, while SKC pumps were used by Tenneco. Again, eight-hour TWA, as well as fifteen-minute ceiling samples were taken. Due to a pump malfunction, only a limited amount of fifteen-minute ceiling parallel samples could be taken. All Tenneco pumps were in use for the Homopolymer Plant survey and the "A" Plant survey - see below. The following is a listing of the per sonnel monitored: Number of Samples Eight-Hour TWA Fifteen-Minute Ceiling Name R. McFadden R. Espenschied A. Anicic Job Classification reactor oper - chg reactor oper - dmp bagger - cleaner OSHA Tenneco 11 11 11 OSHA Tenneco 43 41 42 (Tenneco results are summarized in the attached Table II.) No other type of inspection was made. No work pattern was established by the CSHO. The Union representative present for all day was Mr. F. Roessler. C. Dispersion - TtATt Plant Also on May 3, 1976 a personal VCM monitoring survey was conducted by Mr. Hanlon in the Dispersion "A" Plant. Mr, W.W. Heal was present as the company liaison and Mr. R. Laws to take the parallel samples. Mr. Hanlon used Sipin pumps at a 50 ml/minute flow rate and SKC pumps were used by Tenneco to conduct the survey. A shortage of pumps al lowed only a limited amount of fifteen-minute ceiling parallel samples to be taken. The following is a listing of the personnel monitored: Number of Samples Name Job Classification Eight-Hour TWA OSHA Tenneco Fifteen-Minutf Ceiling OSHA Tenneco J. Canterbury W. Simpkins W. Navarro tower oper - chg tower oper - dmp tower clnr - jet clnr 1 1 1 1 1 1 32 43 32 (Tenneco results are summarized in the attached table III. ) OCC 8510 While no work patterns were established by Mr. Hanlon, he re quested information on the types of chemicals charged to the batch mix tank including the catalyst types. The Union representative present for all day was Mr. F. Roessler alternating between the Copolymer and Dispersion Plants. It may be of interest to note that prior to proceding to the plant, Mr. W. Comegno accused both CSHOs of failing to have an opening meet ing with the Union. Mr. Lewis pointed out that an opening meet ing was held with the Union at the inspection on December 24, 1975. Bagging, Dryer, Warehouse and Atomizer - Dust On May 6, 1976 a personal dust monitoring survey was performed by Mr. Lewis covering operating personnel in the bagging, dryer, ware house and atomizer areas. Representing Tenneco were Dr. F. Toca and Mr. W.W. Heal. OSHA took respirable dust samples utilizing MSA pumps at a flow rate of 1.8 l/minute fitted with a 0.5 micro filter and a cyclone attachment. Due to a lack of availability of a cyclone attachment, parallel samples taken by Tenneco represent total dust samples using a Bendix pump set at a flow rate of 1.5 l/minute fitted with a 0.8 micron open-face filter. The CSHO used four pumps, while only three pumps were available for Tenneco. The following is a listing of the personnel monitored: Number of Samples Eight-Hour TWA Name Job Classification OSHA Tenneco R. Paxton E. Dever J. York D. Motta plastisol bagger atomizer operator suspension dryer operator warehouseman 11 11 11 1 (Tenneco results are summarized in the attached table IV.) A general inspection was conducted by Mr. Lewis in all the above areas The following pictures (attached) were taken during this inspection tour: 1. plastisol bagging area 2. plastisol bagging machine 3. plastisol bagger wearing sampling pump 4. two pictures of the general warehouse area 5. suspension dryer panelboard with operator wearing sampling pump 6. plastisol bagging machine, east view ^ 7. plastisol bagger wearing dust mask OCC 8511 The Union was represented by Mr. F. Roessler for the whole day. Page 5 E, Atomizer Room - VCM On Hay 10, 1976 Mr. Lewis made an area VCM monitoring survey of the atomizer room to confirm justification of deregulation of this area. Eight-hour area TWA samples were taken at the north and south ends of the atomizer room. In addition, three fifteenminute ceiling samples were taken at the south end and one at the north end of the atomizer room. Mr. Kanzler took parallel samples for Tenneco which are summarized in Table V. In addition, the CSHO used a Gastec grab sampler. Both the OSHA sample and the Tenneco sample taken with the same type of sampler showed a VCM level of 0,2 ppm. The Union representative for the day was Mr. W. Mayer. An apparent complaint by the Union, using asbestos insulation on blend tanks, was investigated. A picture was taken of blend tank #3 (attached), showing exposed asbestos insulation at the outside bottom of the blend tank. Additional pictures were taken of the sample pump loca tions at the north and south areas of the atomizer room. Also, the "A" fine products bin and the primary screw areas were photographed. III. Hygiene Inspection - Compound Plant A. Compound Plant - Airborne Particulates On April 27, 1976 Messrs F. Lewis and R. Hanlon (0SHA-CSH0) with Messrs F.W. Kanzler and W.W. Heal proceded to sample the following personnel for lead: Sampled for Lead Eight-Hour TWA Name Job Classification OSHA Tenneco K. Elberson R. Tomaszewski B. Cunningham F. Anstey R. Lessard J. Fate mixer - line #1 mixer - line #2 mill operator - line #1 line operator - line #1 utility services operator short weight operator 11 1-- 1-- 111 1- (Tenneco results are summarized in the attached table VI.) The equipment used by OSHA was MSA pumps set at 1.5 liters per minute using 0.8 micron filters. Tenneco used Bendix pumps set at 1.5 liters per minute using 0.8 micron filters. Both OSHA and Tenneco used closedface filter cartridges (button sample). Messrs Lewis and Hanlon introduced themselves to the Union representa tive, Mr. Anstey and explained to him what they would be doing. He chose not to stay with the group. Once the initial pumps were placed on the personnel, CSHO Lewis and Mr. Kanzler returned to the Resin Plant to monitor for vinyl chloride. OCC 8512 While the personnel monitoring was taking place, CSHO Hanlon took the following pictures (Tenneco was unable to take parallel pictures): 1. three pictures of mixer on line #1 dumping bags of resin into blender 2. lead weighing booth - line #1 3. #2 blender, south view - line #1 4. short weights setting on pallet 5. blenders, north view - line $1 6. clean room, from door 7. blenders, east view - line #2 8. blenders, northeast view - line #2 The lunchroom, shower room and locker room were inspected. CSHO Hanlon's comment during this inspection was he felt that the employ ees should not travel through the lunchroom to get to the locker room and shower area with contaminated clothing on. He also stated that the washing up facilities should be separate from the lunchroom. CSHO Hanlon also indicated that these facilities should be cleaned up on a per-shift basis, rather than once.every twenty-four hours. Compound Plant - Airborne Particulates On April 29, 1976 Messrs F. Lewis and R. Hanlon returned and indica ted they would be sampling for the following: lead, barium and cadmium. W.W. Heal was present representing Tenneco. The following personnel were sampled: Eight-Hour TWA Name Job Classification OSHA Tenneco K. Elberson R. Tomaszewski B. Cunningham K. Jenkins F. Anstey R. Lessard mixer - line l mixer - line #2 mill operator - line #1 mill operator - line #2 line operator - line #1 utility services operator 11 11 1-- 1-- 11- (Tenneco results are summarized in the attached Table VI. ) Equipment used by OSHA was MSA pumps set at 1.5 liters per minute, using 0.8 micron filters. Tenneco used Bendix pumps set at 1.5 liters per minute using 0.8 micron filters. Both OSHA and Tenneco used closedface filters (button samples). OCC 8513 Page 7 Wipe samples were taken using Whatman #41 filter paper, ash less 11.0 cm diameter. This paper was moistened with deionized water before sampling. The following areas were sampled: 1. Lunchroom a. top of lunch tables b. catch tray in cigarette machine 2.2.^ c. catch tray in snack machine ^ ^ d. catch tray in bottled soda machine e. shelving in refrigerator, plus crisper and meat drawers f. shelves in refrigerator door g. faucets on bottled water fountain and inside cup dispenser h. can opener, wiped cutting edges it-o i. top of bottled water on fountain j. top of refrigerator UtOO 2. Clean Room a. top of operator's desk 6^3 b. telephone mouth piece A'cr` Aa a a c. 76 c, bottled drinking fountain, faucet and bottle top - also in side cup dispenser 3 3 S' d. dispensing unit for salt tablets The CSHOs were given the opportunity to listen to the taped talk Dr. Venditti had given to all Compound personnel as related to personal hygiene while working with lead. The effectiveness of the ventilation was checked for the following exhaust ducts with smoke tubes. 1. lead weighing booth - line #1. 2. #1 and #2 blender exhaust ducts - line #2 3. lead weighing facility at line #2 Checked ventilation of the following exhaust systems with a velometer: 1. lead booth - line #1 OCC 8514 Page 8 * 2. exhaust duct, #1 blender - line #1 3. #1 blender at fill grate - line #1 4. lead scale - line #2 A drawing was made of each scoop, sections were drawn in and velometer readings were entered for that given area. The CSHO took pictures during the time of the velometer readings from the following areas: 1. clean room through the door, two pictures 2. lead weighing facilities, line #2 3. storage of raw materials on line #2 mixing floor 4. lead weighing facility including lead shortweights at line #2 5. air conditioner intake for clean room inrelationto exhaust dis charge from #1 mill line at roof area 6. line operator and mill - line l 7. mill operator and mill - line #1 8. mill operator on forklift at line #2 The following pictures were taken at the lunchroom: 1. vending machines and refrigerator 2. soda machine 3. line operator at lunch table 4. general picture of lunchroom including both lunch tables Tenneco was unable to take pictures at that time. IV. Interim Meeting and Inspection of Hygiene and Analytical Facilities On May 7, 1976 Messrs Hanlon and Lewis met with Messrs P.R. Scarito and W.W. Heal to give a status report on the inspection to that date. No comments were made whether any citations will be issued. With the ex ception of the dust data taken on May 6, 1976 in the Resin Plant, no an alytical data was available from OSIIA. In the case of the dust, no numbers were released to Tenneco, however, the CSHO indicated the dust readings were well below the standard. The CSIIOs then met with representatives from the Union - Messrs H. Stellwag and F. Roessler. OCC 8515 Page 9 Following the meeting, the CSHOs requested a tour of the mask washing facility and the Analytical Laboratory, Hr. Lewis reques ted to be provided with the following forms: daily respirator inspection record, weekly mask cleaning record and monthly char coal tube report form. In addition, a copy of the analytical charcoal tube method was requested. Attachments FWK-WWH/jst F.W. Kanzler/W.W. Heal OCC 8516 TABLE I OSHA INSPECTION PARALLEL SAMPLES COPOLYMER PLANT Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Eight-Hour TWA - VCM Date Sampled 4/27/76 4/27/76 4/27/76 Time in Air, min 0 1 120 TWA, ppm VCM Standard, ppm VCM 0.65 l 1.0 0.63 r- 1.0 ii.i 36. r oSma Data S ci wfi C. 6 P 6 At e q 1.0 Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Fifteen-Minute Ceiling Date Sampled 4/27/76 4/27/76 4/27/76 Time in Air, min 0 0 0 0 0 0 0 15 15 0 0 ppm VCM 1.9 0.4 0.5 1.2 0.9 0,5 0.6 64.0 38.0 0.5 0.8 Standard, ppm VCM 5.0 5.0. 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 OCC 8517 TABLE II OSHA INSPECTION PARALLEL SAMPLES HOMOPOLYMER PLANT Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Job Classification Reactor Oper - chg Reactor Oper - dmp Bagger - Cleaner Eight-Hour TWA - VCM Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air; min 14 16 20 TWA, VCM ppm Standard, ppm VCM 0.54 .a 1.0 0.31 i.H-s 3.1 .6V nA OiMft DATA post ,^t_e i AhPtiJ H i < i/P 1.0 1.0 Fifteen-Minute Ceiling Date Sampled Time in Air, min 5/3/76 0 0 0 5/3/76 2 5/3/76 15 0 ppm VCM 0.9 0.7 1.0 0.5 46.0 0.4 Standard, ppm VCM 5.0 5.0 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 OCC 8518 TABLE III OSHA INSPECTION PARALLEL SAMPLES DISPERSION - "A" PLANT Job Classification Tower Oper - chg Toiler Oper - dmp Tower Cln - jet cln Eight-Hour TWA - VCM Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 24 40 210 TWA, ppm VCM Standard, ppm VCM 0.29 1.0 0.45 ,t`Z 1.0 0.73 /. IL -t 0 A O AT A 1.0 Job Classification Tower Oper - chg Tower Oper - dmp Tower Cln - jet cln Fifteen-Minute Ceiling Date Sampled 5/3/76 5/3/76 5/3/76 Time in Air, min 0 12 10 0 0 15 15 \ ppm VCM 0.3 0.5 1.0 1.7 1.3 0.5 0.3 Standard, ppm VCM 5.0 5.0 5.0 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 OCC 8519 ,, s TABLE IV OSHA INSPECTION PARALLEL SAMPLES RESIN PLANT Eight-Hour TWA - Inert or Nuisance Dust (Total Dust) Job Classification Plastisol Bagger Atomizer Operator Dryer Operator Date Sampled 5/6/76 5/6/76 5/6/76 TWA, mg/m3 (l&p. 0.126 2.799 0.208 .OH' iH< Standard, 15.0 15.0 15.0 W.W. Heal 5/17/76 OCC 8520 TABLE V 05HA INSPECTION PAALLEL SAMPLES RESIN PLANT - ATOMIZER ROOM Area Atomizer Room - N Atomizer Room - S Eight-Hour TWA - VCM Date Pampled 5/lC,/76 5/1 C'76 TWA, ppm VCM 0.05 -t.tW 0.12 4, OS HA p<V~A Standard, ppm VCM 1.0 1.0 Area Atomizer Room - N Atomizer Room - S Fifteen-Minute Ceiling Date Sampled 5/10 76 5/10.76 ppm VCM 0.5 0.4 0.4 .1* 0.1 -MS/ 4 OIhA _P A7A Standard, i 5.0 5.0 5.0 5.0 F.W. Kanzler 5/17/76 occ 8521 TABLE VI OSHA INSPECTION PARALLEL SAMPLES COMPOUND PLANT Job Classification Mixer - line #1 Utility Services Mixer - line #1 Mixer - line #2 Job Classification Mixer - line #2 Job Classification Mixer - line #2 Eight-Hour TWA - Lead Date Sampled 4/27/76 4/29/76 TWA, mg/m3 0.543 0.159 0.342 0.286 Eight-Hour TWA - Barium Date Sampled 4/29/76 TWA, mg/m3 0.061 Eight-Hour TWA - Cadmium Date Sampled 4/29/76 TWA, mg/m3 0.016 Q Standard, mg/m 0.2 0.2 0.2 0.2 q Standard, mg/m 0.5 Q Standard, mg/m 0.2 W.W. Heal 5/17/76 OCC 8522 PICTURES TO II.D. Plastisol Bagging Area Plastisol Bagging Machine Plastisol Bagger Wearing Sampling Pump OCC 8523 yk "-.i a >-.. if * i General Warehouse Areas OCC 8524 ( Plastisol Bagging Machine and Plastisol Bagger Wearing Dust Mask OCC 8525 r l PICTURES TO II.E Blend Tank #3 North End Atomizer Room Personal Monitoring Pump Location South End Atomizer Room Personal Monitoring Pump Location OCC 8526 Fine Product Bin Screw Feeder Area "A" Plant OCC 8527 iz n n/u/j f>, 4' I. a./C^i- /%- i, Cl 2, a. X, i/cpI c/6, - */s^u' , ,, / \rc+t,* /W -J&( S~^ - , C-<~ - fj>. - S, o. * 'CW/^ <* +c. Co^JCr. 3. / ?. o y ^ j` /2. */-Vf^ &*-*(-"S / /B^ aS.__-<C 5" ^ ji^45). <s^cJA^/~z* /C/1 $> / 2, 6, ' /, o/*~^/ U^ 2, *f /Ce*vt^. eyi*^ ] / 0asM~ ^ / ^*4 ~1 gAst*** 2S'2* c y^r) ^/ fc ii/(/.~-< O^*- J*6 A"*- /" s4*-t^Z*Ag t).d> "'j G-S&^ j\JZ**Csi***-S --------- * (t tJ/ s^**c^ j2, CC&/*-' --' ^ cAjc**/ r y&. OCC 8528 ? /5r ), . / o--X c^/ 2. fird-A**''w ,, 7, >^( 6 /, - '/. /. 2-c 7, * I r* ^ 7, j, .- % /A < > 1. ,_ fi4***^ a'1^ *-4. _-l K ft**. A ** U~tx,. t<J #-. eJ^'-y/u~-*^- i 7 7 *"*7' 7 OCC 8529 J, ~ /*** J? i i/ -- * ,. / csd~A.^?o^ 2-* c^c^ - xjJ7pr 'Ct~?. 3j 77/ 7/ *h ^ "' ^-*--_^^ =u^o t, C-c~-<f t 2_j 7<r-^r Ht'-u-n r7` tf ^ '/f/90 &/HsU. )1W Hi *r- J> 7 X J,* 1^ jA*--^ V /*\fC. ti-,L^ L$, e~yjl 3. JjLaps >. /. "< /. -t-"--'- 3. ^ SJT. ^7 zMip . /, *7< X ^/< -3. <*7? /? . jt V<52> y c&Z'4^. /"^^- OCC 8530 r /, ^ 2. 2. ^ UvJT t' /: /, 2, J. # *2. 7 7 , / @$s.us * OCC 8531 4 cj. SJ-UimP (PfSC+j ^\_ OCC 8532 TENNECO POLYMERS, INC. AUTHORIZED OPERATING PROCEDURES DISPERSION PRODUCTION AOP No: M-l Date: 4/25/85 OPERATION: AUTHORIZED BY: PURPOSE: RESPIRATORY EQUIPMENT Supt. - Dispersion Resins - R. H. Mathis, Jr. Production Manager - W. Miringoff /J/i/ - Plant Manager - R. R. Neugold _______ 1. To establish the use of respiratory equipment. 2. To Establish a maintenance program for respiratory equipment. 3. To establish a cleaning program for respiratory equipment. HEALTH HAZARD: DEFINITION OF A RESPIRATOR: VINYL CHLORIDE (VCM) IS A CANCER-SUSPECT AGENT. The OSHA standard sets an exposure limit of 1 ppm averaged over any 8-hour period, and a ceiling of 5 ppm averaged over any period not exceeding 15 minutes. Type "C" airline respirator or self-contained breathing apparatus must be worn in areas where VCM concentrations are greater than 5ppm. A monomer detection system located throughout the plant will be utilized to warn all employees when the VCM concentrations reach the OSHA limit. All employees are alerted to the need to avoid contamination of the environment, person, or clothing by monomer from such sources as slurry or latex spills, accumulations of any monomer contain ing resinous material, or monomer releases. Protective clothing is available In addition to all other protective equipment where its use is indicated. If additional information is desired, refer to the Material Safety Data Sheet (MSDS) Book located in the Production Foreman's office. A device worn over the nose and the mouth for protection of the respiratory tract. OCC 8533 AOP #M-1 4/25/85 Page 2 SAFETY PROCEDURES ARE INCLUDED IN THE STEPS BELOW: PROCEDURE: 1. Until vinyl chloride levels throughout the regulated area are brought to less than lppm, it will be necessary for personnel to make use of one of the various types of respiratory equipment as follows: a. 1 - 1,OOOppm A type "C" air supplied respirator must be worn in concentrations of 1 1,OOOppm; the maximum length of air line hose that can be worn on a breath ing air line respirator is 350 ft. b. 1,000 - 36,OOOppm Open circuit, self-contained breathing apparatus (air paks) must be worn in concentrations of 1,000 - 36,OOOppm. c. 36,000 - Unknown ppm Entry into unknown concentrations or concentrations greater than 36,000 ppm may be made with the use of self-contained breathing apparatus strictly for the purpose of life rescue or to secure equipment as to prevent a greater hazard from the release of vinyl chloride. 2. Breathing Air Supplied Respirators a. Areas that breathing air supplied respirators must be worn: Any area that has airborne contamination of 5ppm or more of vinyl chloride vapor. b. Operations where breathing air supplied respirators are required. 1) Suspension Reactor Building a) Opening any manway cover which had contained vinyl chloride until the 8" coppus hose has been installed. b) While 02 content of a blend tank is being checked or when maintenance is being performed on top of the blend tank while any port or connect ing pipe line is open. c) Entering any vessel that had contained vinyl chloride. d) Production or Maintenance personnel disconnecting any line that had contained vinyl chloride. OCC 8534 AOP #M-1 4/25/85 Page 3 e) Maintenance personnel performing repairs on any line that had contained vinyl chloride until such time by either the Bendix or HNU the VCM drops below lppm. 2) Dispersion Process Building a) Opening homogenizing systems for maintenance or cleaning orifice plates, b) While any maintenance is being performed on top of latex blend tanks when any port or connecting pipe line is open, c) Entering any stripper, batch mix tank, wet cake bin, or tower. d) Maintenance or Production personnel disconnecting any line that had contained vinyl chloride. e) Washing out and rodding out wet cake bins through an open manway. f) Maintenance personnel performing repairs on any piece of equipment that had contained vinyl chloride until such time by either the Bendix or HNU the VCM drops below lppm. g) Opening cake breakers and maintenance on same. h) While flushing exhaust system or dump header through an open line. Maintenance of Breathing Air Respirators a. It will be the responsibility of the wearer to inspect his own respirator. This inspections must be done each time a mask respirator is worn. b. The respirator will be inspected by each employee for the following: 1) Tightness of connections, rubber parts to be checked for wear and deterioration, such as breathing tube, face mask, and head bands, and lenses in place. c. When a malfunction is discovered in a breathing air supplied respirator, it will be the wearer's responsibility to turn in same for replacement or repair. d. Defective respirators will be repaired by qualified personnel. Any respirator that cannot be repaired on site will be sent to the manufacturer for repair or replacement. Cleaning and Inspection of Breathing Air Respirators a. At the end of the day, the soiled respirators will be dropped into the receptacles provided in the process buildings and Foremen's office. OCC 8535 AOP //M-l 4/25/85 Page 4 b. The soiled respirators will be washed in a dishwasher using detergent soap, sanitized and rinsed for removal of dirt with water temperature of no more than 120F. d. Air dry in a dust-free room. e. Inspect valves, headstraps, face piece and hose for defects. Defective parts will be replaced. f. Placed in a plastic bag and sealed to keep clean. g. Air paks used for emergencies shall be .inspected, washed and sanitized after they have been used. It shall be the Company's responsibility to keep records of repairs and inspections. Particulate Respirators (Dust) a. Areas the dust respirators must be worn in. MSA Comfo II with F type filter. 1) At the bagging machines for: a) Dispersion b) Copolymer c) Homopolymer 2) Checking or replacing collector bags. 3) Loading bulk truck and hopper cars. 4) Any area where dust might be created. b. Maintenance: 1) It will be the responsibility of the wearer to inspect his own respirator each time it is put into use. 2) If a malfunction is discovered, it will be turned in for repair or replacement. 3) Cleaning of particulate respirators: a) Respirators used shall be collected, cleaned and disinfected to insure proper protection is provided for the wearer (See Section D.). b) The procedure for cleaning shall be the same as used for breathing air supplied respirators (See Section D.) OCC 8536 TENNECO POLYMERS, INC. AUTHORIZED OPERATING PROCEDURES DISPERSION PRODUCTION AOP No: M-3 Date: 4/25/85 OPERATION: AUTHORIZED BY: PURPOSE: EMPLOYEE PROTECTION FOR VCM ATMOSPHERE Production Manager - W. Miringoff Plant Manager - R. R. Neugold Implementation of Federal VCM Standards (1910.1017) HEALTH HAZARD: INTRODUCTION: VINYL CHLORIDE (VCM) IS A CANCER-SUSPECT AGENT. The OSHA standard sets an exposure limit of 1 ppm averaged over any 8-hour period, and a ceiling of 5 ppm averaged over any period not exceeding 15 minutes. Type "C" airline respirator or self-contained breathing apparatus must be worn in areas where VCM concentrations are greater than 5ppm. A monomer detection system located throughout the plant will be utilized to warn all employees when the VCM concentrations reach the OSHA limit. All employees are alerted to the need to avoid contamination of the environment, person, or clothing by monomer from such sources as slurry or latex spills, accumulations of any monomer contain ing resinous material, or monomer releases. Protective clothing is available in addition to all other protective equipment where its use is indicated. If additional Information is desired, refer to the Material Safety Data Sheet (MSDS) Book located in the Production Foreman's office. In order to effectively provide for the implementation of the Federal Standards on April 1, 1976, Tenneco installed a very sophisticated and sensitive system to detect very low levels of VCM in the atmosphere. However, in order to obtain the greatest employee protection, each employee must utilize this equipment to the fullest extent. To accomplish this task, the following operating procedure has been developed. By law, adherence is mandatory. OCC 8537 AOP M-3 4/25/85 Page 2 SAFETY PROCEDURES ARE INCLUDED IN THE STEPS BELOW: PROCEDURE: 1. Constant flow airline respirators are available in cabinets on the 2nd floor of the Copolymer reactor building, 3rd floor of Dispersion"B" Plant, and at the Foremen's office. Each employee has been issued a control valve for this respirator. 2. Upon entering any monitored area, all employees are to first check the rotating beacon and the Bendix panel board. a. If no alarm condition exists, enter your work area. b. If an alarm condition does exist, you must protect yourself upon entry with the proper respiratory equipment, as per A.O.P. #M-1. 3. After entry and the alarm comes on, determine where the alarm is by using the following procedure: a. Immediately check the Bendix panel to determine if the alarm condition exists at your work station. If the alarm condition does exist at your work station, it will be necessary to put on your airline respirator with the attached length of hose to reach your area (maximum 350 ft.) in order to continue your operation. b. When check the Bendix panel and the alarm condition does not exist at your work station, continue your operation and avoid the alarm area. 4. Should four (4) or more adjacent alarm points light up simultaneously and the readings are 100 ppm, you should don a self-contained breathing apparatus (air pak) if necessary to enter the area until extent of excursions has been de termined and corrected. NOTE: ALL EMPLOYEES HAVE THE RESPONSIBILITY UPON SEEING A BENDIX ALARM LIGHT OR HEARING THE BENDIX ALARM HORN OF NOTIFYING ANYONE IN THE EFFECTED AREA OF THE EXCURSION SO THAT ANYONE EXPOSED CAN PROPERLY PROTECT HIMSELF/HERSELF OR LEAVE THE AREA. NOTE: While cleaning reactors or towers, the Buddy will not leave during an alarm condition. He/She will put on his airline respirator and continue acting as a Buddy until he/she is notified that the area is safe to remove his/her airline respirator or until the situation calls for other action. NOTE: THE ABOVE PROCEDURE IN NO WAY SUPERSEDES E.O.P. #11 WHICH INVOLVES A MAJOR RELEASE OF VINYL CHLORIDE MONOMER. OCC 8538 AOP M-3 4/25/85 Page 3 5. Location of the alarm panels and lights are as follows: a. PLA-1 Located next to the operator's desk in "A" Plant, Dispersion. Indicates 9 points in "A" Plant, 1 point in the Nash Building. b. PLB-1 Located next to the tower panel board in "B" Plant, Dispersion. Indicates 5 points in "A" Plant and 5 points in "B" Plant. c. PLB-2 Located next to the tower panel board in "B" Plant, Dispersion. Indicates 9 points in "B" Plant, 1 point in the Nash Building. d. CO-1 Located near the operator's desk in Copolymer. Indicates 5 points in Copolymer and 5 points in the outside areas. e. CO-2 Located near the operator's desk in Copolymer. Indicates 8 points in Copolymer, 2 points outside the Copolymer recovery area. f. HO-1 Located near the operator's desk in Homopolymer. Indicates 10 points in Homopolymer. g. LA-1 Located in the Copolymer Lab. Indicates 10 points, 4 points in Lab area, the 3 dragout pits, ARDO building, and 12 points at the Effluent Plant. h. B/V-G Local panel located outside the lunchroom. Indicates 10 points, including the Tank Farm, Maintenance Shop, bulk bins, east and west fence line and lunchroom. i. G Local panel located near Suspension dryer panel board. Indicates for 5 points, bagging areas, panel board, and atomizer room. 6. There are rotating beacons located on the operating floors of the Suspension reactor building and the Dispersion building. These beacons operate when a 5 ppm alarm condition exists in that building. Visitors and/or non-operating personnel are not to enter while this condition exists. Operating personnel must follow the Procedure Items #1 thru #5 as outlined in this A.O.P. M-3. OCC 8539 V MM * * ' INTEROFFICE MEMO TENNECO CHEMICALS, INC To P.M. Reed At Piscataway From J F.W. Kanzler At Burlington Subject OSHA Inspection - Resin Plant date June 3, 1976 Copy to W. F. Gabel F.X. Ritter G.I. Rozand P.R. Scarito A. C. Siegel File A second VCH personal monitoring inspection was conducted by OSHA F. Lewis - on 5/26/76 in the Burlington Copolymer Plant. Only two classifications, reactor operator - charging and reactor operator - dumping, were monitored. The attached table lists the TWA samples and the 15-minute ceiling samples taken by Tenneco as parallel samples. Attachment FWK/jst 'Sfrtd )V. F.W, Kanzler OCC 8540 V TABLE I OSHA INSPECTION PARALLEL SAMPLES Job Classification reactor oper - chg - copolymer reactor oper - dmp - copolymer 8-Hour TWA Individual Data (Time in Air, min) 0.3 (0), 0.3 (0), 0.4 (0), 0.2 (0), 0.5 (0) 0.6 (0), ND (0), 0.1 (0), 0.1 (0) 15-Minute Ceiling - 5 ppm Max. Job Classification reactor oper - chg -- copolymer reactor oper -- dmp - copolymer Individual Data (Time in Air, min) 0.6 (0), 0.4 (0), 0.1 (0), 0.6 (0) 0.2 (0), 0.6 (0), 0.5 (0), 0.6 (0) TWA 0.36,i'A' 0.21 J* F.W. Kanzler 6/3/76 OCC 8541 Occidental Chemical Corp. Attn: Personnel Dear Sir: 1 have conducted a physical examination of enOccidental Chemical Corp. employee at Burlington, N.J. on as required pursuant to the standard issued by the Occupational Safety and Health Administration, U. S. Department of Labor, 29CFR 1910.1017, Paragraph <K) and have concluded that, as of the date thereof, the said .employee is suitable for exposure to Vinyl Chloride Monomer or Poly vinyl Chloride Resin, including the use of protective equipment and respirators, in accordance with the Standard. The employee has been informed of any medical condition which may require further examination or treatment. Michael C. Venditti, M.D. Date OCC 8542 CHARCOAL TUBE 8-HOUR TWA READINGS GREATER THAN 1.0 PPM VCM Name Job Classification Date Sampled Date Analyzed Results Mask Time Notification Date Employee signature Notifying Supervisor Remarks /Date OCC 8543 Revised 3/11/83 OXY Occidental Chemical Corporation PVC Resins/PVC Fabricated Products To____ From__ Subject Distribution A.L. Dickerson Personal Monitoring Charcoal Tube 8-Hour TWA MEMO Date CC: C.C, Cattell R.S. Cole F.W. Kanzler R.A. Lojewski R.H. Mathis C.F. Wunder File The following is a summary of personal monitoring results showing levels greater than 1.0 ppm for the month of _________________________ Name Job Classification Date Sampled Date Results Analyzed VCM ppm ALD/jst A.L. Dickerson OCC 8544