Document oOGee8z1M3NB99pJVOMMjwNr

DOT Interoffice Communication To R. E. Lehmkuhl - Houston '"O O <r o o * T3 0 V From Date Subject J. E. Cearley - Lake Charles January 5, 1976 Proposed Schedule for 1976-1977 Chemical _p -J V <r Exposure Abatement Program P p" \ (_. S The initial comprehensive monitoring of the first group of chemicals (Table 1) considered as "high risk" has been completed, and we now know which of these chemicals have the greatest potential for employee exposure to unacceptable levels. Additional chemicals have been added to the monitoring list as the sampling program progressed. The results of the sampling program for the period of June through November, 1975, are presented in Table 2. The results of the sampling and analyses for the chemicals monitored thus far indicate time-weighted employee exposures are below the action level. The primary exposure problems encountered have been the short-term high level exposures that exceed the ceiling and/or maximum peak concentrations; i.e., methyl chloride, hydrogen chloride, benzene, and ammonia. Corrective measures to reduce these short-term high level exposures to acceptable concentrations are either in the planning stages or are being carried out (Table 3). The proposed schedule for monitoring of chemicals in the plant for the next two years (1976-1977) is presented in Table 4. We will attempt to adhere to this schedule, although proposed and finalized standards for various chemicals by OSHA may change the priority of our sampling schedule. Our existing man power prevents us from moving ahead any faster than what is proposed. The general format that will be followed in our sampling program is as follows: 1. In all monitoring, samples reoresentative of each job classifica tion for all shifts will be collected. We will attempt to monitor at least 50% of the employees in each operation or process. In addition to Operations personnel, Maintenance employees will be monitored, particularly during turnaround and major repair work where the potential for high level exposures is greatest. 2. Monitoring of an operation or process will be repeated at least monthly when the concentration has been found to exceed the action level. 3. If the concentrations exceed the recommended TLV standards, monitoring will be conducted at biweekly intervals until two consecutive surveys indicate the adequacy of the control measures taken. MCI; 00005 7 MCI) 00001788a R. E. Lehmkuhl Page 2 January 5, 1976 4. Samples will be collected semi-annually for those chemicals below the action level and considered as "high risk;" i.e., methyl chloride, hydrogen chloride, ethylene oxide, and benzene. Other chemicals below the action level will be monitored every 12 to 18 months, depending on the chemical's toxicity and the potential that exists for employee exposure. 5. For those chemicals that have relatively high established TLV values, and we are assured exposures do not approach the action levels, written determinations will be made and placed in our files. Some of the chemicals currently believed to fit this category are butadiene, pentane, LPA solvent, propane-propylene, and various raw materials and supplies, such as various Nalco products. We currently are considering placing phosgene in this category, since a phosgene analyzer has been installed on the HC1 feed line and 01 in Chemical is in the process of installing an analyzer at their facility. In addition, we analyze the methyl chloride product four to five times daily, and we know how much phosgene must be present in the product for the potential of exposure to unacceptable levels to exist. 6. As time permits, training programs will be developed for the various chemicals. We realize the importance of training programs, but our manpower is such that we are unable to develop this area as rapidly as we would like. 7. Routine plant inspections (one to two times per month) will be made to evaluate housekeeping activities and work habits in the various units. 8. Where feasible, engineering design changes will be made to reduce employee exposures to acceptable levels. Where engineering controls are not feasible, personal protective equipment will be utilized. The Chemical Plant will adhere to this format as much as possible, although proposed and finalized OSHA regulations for various chemicals may require changes in our current schedule. In addition, there are no established sampling and analytical procedures for some of the chemicals to be monitored, and we may run into difficulties here. % (LJ> J. E. Cearley mbr Enclosures cc: RDG RAC RHG DDZ DDP TABLE 1 Chemical Methyl Chloride Methanol C Hydrogen Chloride C Phosgene Ethylene Oxide Benzene Sulfuric Acid Butanol Hexanol Ethanol Acetic Acid C Ammonia Carbon Monoxide Vinyl Chloride Chlorine Calcium Hydroxide Asbestos 8-Hour Time Weighted Average Action Level Acceptable Ceilirg Concentration Acceptable Maximum Peak Above the Acceptable Ceiling Concentration for an 8-Hcur Shift 100 ppn 200 ppm - 50 ppm 100 ppm 2.5 ppm 0.025 ppm 200 pom (5 minutes in every 3 hrs.) - 5 ppm 0.05 ppm 300 ppm - - 50 ppm 10 ppm 25 ppm 5 ppm 1 mg/m^ 0.5 mg/n^ 50 ppm 25 ppm No Establi shed TLV 1000 ppn 500 ppm 10 ppm 5 ppm - 25 ppm 50 ppm 1 ppm 25 ppm 0.5 ppm 1 ppm 2 mg/m^ 0.5 ppm 1 mg/m^ - 25 ppm (10 minutes) - - 50 ppm (5 minutes) - 5 ppm (15 minutes) - - - 50 ppm - - - - - - Two Fibers (s* 5 micron >ters)/cc of air hrr> J0o^s8, Monitoring handled by au.^ty TABLE 1 (CONT'D.) NOTE: 1. Acceptable Ceiling Concentration (C) - Those chemicals preceded by a *0" shall at no tire exceed tne ceiling value given for that material in the table, unless a maximum peak value is designated. 2. 8-Hour Tine Weighted Average - An employee's exposure to a designated chemical shall net exceed tne 8-hour time weighted average in any 8hour work shift of a 40-hour work week. 3. Action-Level - The action level is one-half the TLV; if exposures are below this level, then no further action is required, other than monitoring every 5 months. However, if exposures are greater than the action level, then more frequent monitoring is required (generally monthly), medical surveillance must be implemented, control measures must be improved, and various other requirements are necessary. 4. Maximum Peak Above Acceptable Ceilino Concentration - The ceiling standard may oe exceecec for sr.ort psriocs (.generally 5 to 30 minutes) up to a concentration defined as "acceptable maximum peak above the acceptable ceiling concentration for an 8-hour shift." AfCft 0OOl 7ses Chemical ZActlon TABLE 2 .^Action Level< Knx Permissible Level _>Knx Permissible Level Method Methyl Chloride Methanol }*9?l 12 50 65^0 11 101 Hydrogen Chloride Sulfuric Acid Ammonia Acetic Acid Censeno Ethylcno Oxide Chlorine Carbon Monoxide {[exonol Ethnnol Butanol 120 k 6 9 32 10 13 soar 11(3 u 2393 12 6 127 72 *4539 12 5290 12 J*l*YO 12 Vinyl Chloride phosgene ` .11 99b Coixplca avcrogcJ 1.0 ppm b~All oo.-nplca Icfid thou .15 pi<a *(l) Multl-So.nple Point Environmental GO ' TWA - Tiir.c WeiIgl.lcd Averago Greb - Crab Cui-.plco 823 0 8 228 0 1 0 q 0 0 6 * 2 3^a 3 0 5 0 2 0 1 . 0 . 0 0 Mrt. 0 0 *0 T,,n y y y a l u u u u (IDW 165 (D 0 TWA 12(8 above max peek) Grab 175 (1) 0 TWA 0 Droger 1 Droger 1 TWA 0 0 7 l* 3 1058 A. 0 TWA TWA Droger Area-Monitoring Droger Droger TWA 9 ID , 0 TWA 2 Grub 0 Droger 0 Droger - (D 0 WA 0 (1) 0 TWA 379 <1> 0 TWA 0 TiptA $ 0 Droger , .* TABLE 3 CORRECTIVE MEASURES FOR REDUCING CHEMICAL EXPOSURES Z88ZT0000 aow CHEMICAL Ammonia HC1 Ethylene Oxide UNIT Waste Water Holding Pond (Nutrient Addition) Alcohol Methyl Chloride Ethoxylation MAJOR SOURCE(S) OF EXPOSURE Filling of Ammonium Hydroxide Storage and Day Tank; Discharge for Day Tank Filling of Ammonium Hydroxide Storage Tank - Vents to Atmosphere Sampling MCI Feedstock Vent used to Blowdown ETO Reactor at Grade Level CORRECTIVE ACTION Discharge and vent lines extended to below the water level of the influent waste water Vent line rerouted to Acid Hold ing Pit and extended to below the water level Redesign sampling system enclosed loop Install knockout pot and vent to atmosphere COMPLETION DATE 2-1-76 4-1-76 2-1-76 Methyl Chlpride Methyl Chloride Benzene Ethylene Ethylene Offsites Loading of Tank Cars - Venting to Atmosphere Bleeding of Knockout Drums Sample Bomb Collections Additions of Caustic to T 112(1 'various Vents, Pel ief Valves, and Bleeclors Quench Water Settler Vent off of Light Aromatics Distillate Tower API Separator at Waste Water Holding Pond Manholes along Ethylene Oily Water Sewer Line Designs currently underway to provide engineering changes for reduction of emissions Monitoring for benzene has recently been completed and the data is being evaluated. Recommendation as to corrective measures needed are being pre pared Design to be complete by February 1, 1976 Recommenda tions by 1-31-76 STATUS Complete Work rescheduled due to priori ty Design issued 12-30-75 Original cost estimate was hieh; project mL.-sign*. ci work rescheduled Assigned to Process Engineering for design work Recommendations to corrective action needed being pre pared TABLE 4 MCD 0 0 0 0 1 7 8 8 8 CHEMICAL Methyl Chloride Methanol Hydrogen Chloride Sulfuric Acid Ethylene Oxide Benzene Vinyl Chloride Ammonia Hydrogen Sulfide Butanol Ethanol Hexanol Carbon Monoxide Chlorine Calcium Hydroxide Acetic Acid Chromate Mercury Hexane Phosphoric Acid Caustic Sulfur Dioxide Methyl Chloride Hydrogen Chloride Ethylene Oxide Benzene Sulfur Dioxide TBC TPT Nalco Products Methyl Chloride Methanol Ethylene Oxide Benzene Vinyl Chloride UNIT January 1 - February 15, 1976 Methyl Chloride Methyl Chloride, Ethylene Methyl Chloride Methyl Chloride, Alcohol, Cooling Towers Ethoxylation February 15 - Mav 1, 1975 Ethylene, Ethylene Offsites Ethylene Alcohol, Ethvlene Offsites Normal Paraffin Alcohol Alcohol Alcohol May 1 - June 1, 1976 Alcohol Ethylene and Alcohol Cooling Towers Steam Plant Ethoxylation Alcohol Cooling Tower East and West Shops June 1 - Auoust 1, 1976 Alcohol Ethylene Offsites, Ethoxylation Ethylene, Methyl Chloride Steam Plant Methyl Chloride Methyl Chloride Ethoxylation Ethylene, Ethylene Offsites August 1 - October 31, 1976 Normal Paraffin, Methyl Chloride Ethylene Alcohol Ethvlene, Ethylene Offsites, Normal Paraffin Methyl Chloride Methyl Chloride Ethoxylation Ethylene, Ethylene Offsites Ethylene METHC'O 1 1 } 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 n i 2 2 2 TABLE 4 CONT'D.l CHEMICAL Butanol Ethanol Hexanol Total Hydrocarbons Merox Methyl Chloride Methanol Hydrogen Chloride Sulfuric Acid Ethylene Oxide Benzene Vinyl Chloride % Sulfur Dioxide o o o CP CP 'S> Ammonia Hydrogen Sulfide Butanol Ethanol Hexanol Sulfur Dioxide Carbon Monoxide A1 umina Methyl Chloride Ethylene Oxide Benzene Vinyl Chloride Chlorine Caustic Phosphoric Acid Hexane Sulfur Dioxide Calcium Hydroxide Acetic Acid _______________ UNIT November 1 - December 31, 1976 Alcohol Alcohol Alcohol ATE Quench, Waste Water Holding Pond Ethylene, Ethylene Offsites January 1 - March 31, 1977 Methyl Chloride Methyl Chloride Methyl Chloride Methyl Chloride, Cooling Towers Ethoxylaticn Ethylene, Ethylene Offsites Ethylene Ethylene April 1 - June 30, 1977 Alcohol, Ethylene Offsites Normal Paraffin A1coho! Alcohol Alcohol Alcohol Alcohol Alcohol July 1 - September 30, 1977 Methyl Chloride Ethoxy!ation Ethylene, Ethylene Offsites Ethylene Ethylene and Alcohol Cooling Towers October 1 - December 31, 1977 Methyl Chloride, Ethylene, Ethylene Offsites Ethoxylaticn, Ethylene Offsites Alcohol Normal Paraffin, Methyl Chloride Steam Plant Ethoxy!ation METHOD .1. 2 12 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 TABLE 4 {CONI'D.) NOTE: Monitoring for asbestos will be conducted whenever employees come in contact with the material, which is only when old Insulation is removed. Monitoring is handled by Safety. 1. Personal Dosimetry 2. Mobile Multi-Point GC mod 000017890