Document oeQo0OYYDZZk32yg2N7YJg6Rr

PVC AT PAINESVILLE rwmpHanca Effort a to Data In 1965 new Federal legislation was enacted which made many new requirements of industry. As a result, we were required to install water pollution control equipment and to begin planning for air pollution control equipment. Soon afterward the OSHA Act of 1970 required that we survey and begin to up grade to new federal standards all aspects of the workplace. By the end of 1973 we were operating a primary water waste treatment plant, had made estimates for several alternative schemes for compliance with boiler emission regulations, had conducted a detailed plant survey for compliance with the OSHA Act of 1970 and had made considerable progress toward correcting the deficiencies determined by this survey. In January 1974 the vinyl chloride problem gave a new set of concerns which we had to add to a continued effort to satisfy those items mentioned previously, we quickly became expert in the terminology and equipment for monitoring levels of VC in our work areas and in the breathing zone of each of our employees. Preliminary equipment and process modifications were made and protective equipment ordered to reduce employee exposure. An educational program was begun to convince our employees that precautions were necessary for protection against both VC monomer and PVC dust. We attempted to gain a rational perspective in the discussions involving NIOSH, OSHA and our own people regarding the true nature of the hazards of these materials. The OSHA hearings provided very little additional insight into the technical nature of the problem. We tried, at this point, to guess where the permanent standard would be set and made engineering studies on what we would do to bring the plant into compliance. It was quickly apparent that major capital expenditures would be necessary. At thie^point, we decided we must conduct our compliance program on two levels. First, we should do those things which could be done within the scope of the plant technical, production and engineering departments capabilities to reduce high exposures in the quickest way possible. The other level Is full compliance to the standard, which requires con siderable capital commitment and, therefore, should be treated as a long range rather than short range consideration. PLAINTIFFS EXHIBIT < * Y * r7* b. 1975 to provide for th health, w 11-being and employment of all of our plant employees as best we could with available ioreSsOoUuirWceofsl,. He feel that this vsuwhaowrt term" pro^g"rav"m" was wswuvcwcwewwssfful In light of the marry problems. The long terra program to maintain a viable operation for the future is a separate subject T/ma Range Prelects &: . i-e' , ' While fixing leaks, installing exhaust systems at key areas and providing air breathing respirators attack the random high exposure levels, significant reductions to a consistent low level in operating areas require major changes to our facilities. A list of these major projects is included as Table B. Briefly, the major areas are reduction in the frequency of opening vessels, stripping of the slurry before it leaves the process areas, highly sophisticated monitoring systems, greatly increased ventilation, and major expenditures to reduce losses of VCM to ambient air URL 2 2 5 8 4 With the exception of a minor benefit from reductions in VC losses, none of these installations will contribute anything to operating effectiveness or production economies. In fact, we must anticipate productivity losses from these installations as well as major increases in energy related and maintenance related operating costs. He have employed the resources of UNIROYAL engineering personnel at all levels as well as several outside engineering firms in estimating the facilities required for compliance. To the extent possible, we have participated in information exchange within the PVC industry. The answers available through this last source indicate that there are no easy, cheap solutions. They confirm that effective answers can be had only by major capital expenditures. r C. Capital Hot Related to VC Many capital projects are estimated for the foreseeable future which are either indirectly related to VC or unrelated to VC usage in this plant. These are shown in Table c. The additional steam requirements for operation of the equip ment required for compliance to OSHA and EPA regulations for VC will necessitate the addition of a third coal fired boiler. This is above and beyond the operation of the two coal fired and one oil fired boiler presently in use. This, in turn, will require better coal handling facilities for the in creased volume of coal. Our insurance carrier has proposed numerous changes which must be made to the PVC plants in order to obtain future coverage. These changes will provide no operating economies; ,s* Much of the glass lined equipment In the Area 1 plant is near the end of lte useful life. If we are to continue that oper ation, this equipment must be replaced within the next 5-7 years. S. Suwnarv 1. Prior to October 1, 1975, the Painesville plant had spent about 11.1 million in capital and operating expense specifically for compliance with the VC standard. (Sum of "to date* columns from Table A and Table B.) 2. Additional capital of $3.2 million is estimated for * OSHA compliance along with $3.1 million for EFA com ' ' pliance. These are minimum figures since the results from the changes can only be estimated.' These changes will add at least $2.1 million to the annual operating cost of pvc manufacturing. (These sums are from the appropriate columns of Tables A A B.) *: -. ip/' ~ Sfe- 3. If a commitment is made to bring the plant into com pliance and continue to make PVC, an additional increment of $6.0 million will be needed to sustain this operation. Within about 5 years, major process equipment must be re placed at a cost of nearly $15.0 million. 4. The estimate of capital needs for the Painesville plant, if PVC manufacturing continues, is $12.3 million for compliance with known requirements and an additional $15.Q million for equipment replacement. <> 5. Postponing any of the above will only add to the cost of doing it since costs will continue to rise. 6. An estimate was made that a new plant to replace the Area 1 plant could be built for $35-40 million. tot... jit. 7. In view of these estimates as well as'the demand for capital money for other commodities, it was decided to tentatively announce the shutdown of the PVC plant. It is our conclusion that had the OSHA permanent standard been set at a maximum of 10 ppm rather than 1 ppm we might have provided the necessary plant changes to con tinue operation. However, with the evaluations that have~since been made regarding alternative uses of available capital, we conclude that even a 10 ppm maximum does not now present a viable condition for UNIROYAL to continue the manufacture of PVC resins. N> F07 r10/30/75 * --V . i . . - * X - - ?J1. Jf "" 1 * - ii i/ y` - ** ' T ' i` ' * ' .it. t * *- . t' ^ 7. 1 ~ ''i . ' /. ; TABLE A STATUS OF PROJECTS ANOTCTlVlTIES AS OF OCTOBER. 1975 PROJECT NUPEER A -1 -2 -3 -4 DESCRIPTION '* Respirators, Air Purification A Distribution Leak Detection and Leak Correction Personnel Monitoring and Record Keeping Monitoring and Warning Systems for 107*117*414 EXPENDED TO Date sn CAPITAL EXPENSE - 52.3 22.0 61.4 - 56.3 - 23.5 ADDITIONAL REOUmiD' SR CAPITKl ANNUAL EXPt 26.4 91.0 75.0 - -S Operator Enclosure* Bldg.414 (AR-5222) 15.9 - - .6 Exhaust System for 3 Screeners (AR-5339) 11.6 - - - -7 Exhaust System for W M Centrifuge A Hopper 7.2 - - -8 ' Extend A-l Air Compressor Intake Stack - 5.8 - -9 VC Medical Testing - 22.1 20.5 -10 Breathable Air Compressor (AR-5317) 31.1 - 93.7 . -n Portable Reactor Evacuation (AR-5343) 3.8 18.8 - -12 Remove Bldg. Siding - Ventilation Improvement - 29.5 14.7 -13 Revisions to Seals-VCM Compressors 414 - 37.3 - -14 Reactor Modifications 107 A 117 - 33.3 - 91.6 340.3 93.7 227.6 { Nji. 9qszz tan TABLE B t HAJOR PROJECTnWPnfWAT PLAHHED PROJECT UMBER- DESCRIPTION * B-l Solvent Cleaning of Reactors (AR-5195) -2 Ventilation of Bldg. 414 (AR-5319) -3 Recovery Compressor Seal Improvements (A-l) -4 Ventilation of Bldgs. 107,117,108 -5 Tank for Hi-Boller Disposal Compliance Program OSIIA (AR-P-5357) -6 Item I Experimental Stripper -7 * Item 2 Ventilation of 107 S 117 Control Rooms -8 " Item 3 Ventilation at Baggfng Stations -9 * Item 4 Replace Recovered Monomer Pump -10 * Item S Fetterolf Valves for 414 Reactors -11 * Item 6 Reactor Evacuation -12 * Item 7 Transfer Piping - 414 -13 Item B Better Breathing Air -14 * Item 9 Additional Area Monitoring IS Canister Program for 5-25 ppm Range -16 Purge VC Unloading Lines -17 Control VC Release 9 Unit Operations IB Paracrll 020 Finishing Ventilation -19 ltarehouse Ventilation -20 PVC Slurry Stripping EPA -21 Gas Holder and Collection Systems (2) " -22 Stripping of Hater from Process Area " -23 Auxiliary Power for Process Area * -24 High Pressure Alarms for Pressure Vessels* -25 Activated Carbon for all Vents * -26 Required Sampling Program " 10/27/75 i&zz inn CAPITAL $M TO DATE 604.5 24.9 - * - m 11.5 S.4 - - 4.2 25.0 - - 7.1 - - - - 682.6 CAPITAL |H ANNUAL ADDITIONAL OPER. EXPEHS 560.0 175.0 88.0 848.0 7.0 45.0 140.0 206.0 13.2 45.0 1.2 50.2 157.0 100.0 685.0 127.9 - 66.0 74.0 80.0 63.0 1245.0 1200.0 200.0 167.0 119.0 100.0 15.0 210.0 80.0 784.0 200.0 150.0 55.0 6173.3 1883.2 . PROJECT NUMBER C-I -2 -3 -4 ' -5 -6 -7 TABLE C ' 11 ADDITIONAL CAPITAL FOR FUTURE OPERATIONS HOT DIRECTLY RELATED TO VC DESCRIPTION Remove Particulate, Boiler 2 (w/PVC Operation) Install 3rd Coal Fired Boiler (w/PVC Operation) Upgrade Coal Handling Facilities Insurance Requirements for PVC Plants Replace A-1 Poly Area (5 Year Project) Secondary Hater Haste Treatment Tertiary Hater Haste Treatment (by 1983) CAPITAL JH 495.0 1500.0 480.0 3500.0 15000.0 1 7 20975.0+ ^ * * .* '"i- > t TABLE D 'd SUMMARY OF FUTURE MEEDS ITEMS 1. 2. 3. DESCRIPTION Projects from Table A Projects fron Table B Projects froa Table C CAPITAL NEEDED ________$M ANNUAL OPERATING COSTS. <M 93.7 227.6 6,173.3 1,883.2 20,975.0 27,242.0 2,110.8 i ? J WEEK BECiriHIHG 5-5-74 BLOG. 107 PROCESS 22 117 PROCESS 18 108 FIHISHIHG 14 414 PROCESS 22 415.FINISHING 14 10/28/75 AVERAGE WTtAnBnLnErVECH LEVELS 4-20-75 12 14 12 10 9 10-19-75 7 7 7 8 1