Document oMR2GEVQN6EJaRZGZaYk9V9g8

(conoco) Interoffice Communication To VCM Plant Employees From J. A. DeBernardi Date February 9, 1981 subject Deregulation of Area #4 - Tanjc Car Loading Pumps I am pleased to report that based on analysis of data generated by the Honeywell fixed point monitor, personnel dosimeter sampling results, and normal time intervals employees are in the tank car loading pump area, this area has been deregulated effective February 9', 1981. The data analyzed indicates during normal operation that potential employee ex posure over the OSHA permissible limit for VCM has been eliminated in this regulated area. These results can be attributed to engineering changes and improved work practice controls that have reduced or eliminated such exposures in the tank car loading pump area during normal operations. 1. A closed sampling system for VCM has been installed which vents to the incinerator system. 2. Tandum pump seals have been installed on the loading pumps with seal oil pots vented to the incinerator system. 3. Rupture disks have been installed under relief valves in this area to protect the valves from premature discharge. The fixed point monitoring point located in the tank car loading pump area will continue to function as an exposure warning system. Notification of excess VCM concentrations will be made from the control room to personnel in the area should they occur. Appropriate respiratory protection equip ment will be used by personnel should this occur until the problem causing the excess concentration is found and eliminated. Deregulation of this area does not alter our established procedures related to use of respiratory protection equipment when breaking into process lines or vessels, or the necessity to seek out and repair leaks that may occur in the area or in other areas of the general plant. CC: JWW-GLF-JRH-CWT-WRH-JHB-PLF Safety Bulletin Boards Supervisors CCR 000080965 CO ro tH CO rH CO e % RECEIPT FOR CERTIFIED MAIL--30^ (plus postage) r"*TT Attn: joe Amsley, Area DirectHoOrT pPOoSsTtMmAaRskK U-St,Dept. of Labor - QSHA J nOR"nD,ATTeE STNEET AND NO. 2156 Mooddalp Blyd, Hoover Arnj P.O., STATE AND ZIP CODE Baton Rouge, LA 70806 OPTIONAL SERVICES PPM ADDITIOMAL~pQf RETURN ^ * tt vtwm and data dtlimM RECEIPT ^ "**> RdHwtry to address** only vsiivien JERVTCCS * is wtooi, iili ml vktit mu with delivery to andreue. n" DELIVER TO ADDRESSEE OUrT------------------------------------- SPECIAL DELIVERY (result PS Pone Apr. 1D71 3600 NO INSURANCE COVERAGE PROVIDEDHOT FOR INTERNATIONAL RIAIL (See etfeer tidu) * GPO : 1974 O - SSl-454 000080966 CCR Lk Chart** VCM Plant CERTIFIED MAIL #316138 RETURN RECEIPT REQUESTED Conoco Chemical* Company A Division of Conoco Inc. P.0. Box 605 Westlake. Louisiana 70669 <318] 491-5211 February 10, 1981 U. S. Department of Labor Occupational Safety & Health Administration 2156 Wooddale Boulevard Hoover Annex, Suite 200 Baton Rouge, LA 70806 Attention: Mr. Joe Amsley, Area Director Gentlemen: Pursuant to Title 29, Chapter XVII, Part 1910.T017(n)(1) of the Occupational Safety and Health Standards for Vinyl Chloride, this letter is to inform you that portions of this plant were deregulated on February 9, 1981. One area that is now regulated and the average number of employees in this area per day during normal operations, including maintenance is: Regulated Area No. of Employees 24 Sincerely Plant Manager Conoco VCM Plant is BCC: T. G. Grumbles - Houston RDG-GLF-OWW-JRH-CWT CCR 000030967