Document pBp1bxrgrnNpGyOJpeym1Ee0B

J UNIROYAL CHEMICAL DIVISION OF UNIROYAL, INC. PAINESVILLE, OHIO, PLANT NIOSH VISIT MARCH 5, 1974 Kenneth Coss - President, United Rubber Workers Local 553 J. Robert Douglas - Industrial Relations Manager J. Dexter Forbes, MD. - Corporate Medical Director Arthur Frltinger - Maintenance and Construction Engineer Walter 0. Harris, PHD - Corporate Industrial Toxicologist Robert Holman - Production Superintendent Chang Ho Kim - Technical Superintendent Benton R; Leach - Factory Manager Don Rhlnehart - Sr. Process Methods Engineer Richard Shearer - Employee Relations Supervisor C. B. Westerhoff - Chief Chemist /}. 9 f M.l, t)(vJ / CwnioL*) UNIR0003344 r-B04 REV. 2*t UNIROYAL CHEMICAL Division of UNIROYAL, Inc. March 5, 1974 cc: DED - Oxford TO 0. E. Crim Naugatuck FROM B. R. Leach Painesville SUBJECT: URW Activity Associated with NIOSH Visit Louis Beltczky spent all morning, today, at the Paines ville plant. He and Ken Coss sat In on the preliminary presentations made to the NIOSH investigating team. When this meeting was completed he said he would like to make a tour of the plant. I accompanied Lou Beliczky and Ken Coss on a tour of all of our production facilities Area I and Area IV. - Beliczky asked me questions both In the NIOSH presentations and during our plant tour. I feel they were all answered satisfactorily and that we left the impression that we did not feel that we had anything to hide. Beliczky and Coss had lunch then with Dr. Forbes and Dr. Harris and then returned to Akron. INTERCOMPANY CORRESPONDENCE UNIR0003345 FOR204 UNIROYAL CHEMICAL Division oi UNIROYAL, Inc. TO: FROM: I Mankowich Naugatuck C. H. Kim March ht 197k cc: (BKpYMI REH JRD SUBJECT: B. F. Goodrich Chemical13 Hydraulic Reactor Cleaning System With the mounting scientific evidence indicating that vinyl chloride causes cancer in workers exposed to it, we would like to reinvestigate the BFG's hydraulic reactor cleaning system for the purpose of minimizing VCM exposure to our employees* It is hoped that revisions planned for the THF solvent cleaning system will eventually replace present manual cleaning operation* However, as you know, the S.D. plant suspension resin reactors require flushing and high pressure jetting every batch to control "fish eyes" and particle size control* We hope that BFG's system will replace this operation thus completely .eliminating the need for opening of polys for the purpose of cleaning. I have been in contact with Mr. Arthur L. Hastings of B.F. Goodrich Chemical Company to reopen the case, .which we have undertaken in 1970 and 1971* Mr. Hastings informs me that the Secrecy Agreement signed in September, 1970 has expired. Your assistance is requested to secure a Secrecy Agreement with B.F* Goodrich Chemical as soon as possible to begin our investigation of its feasibility and applicability to our process as well as economics. CHKshew Attachments ) CTITHS INTERCOMPANY correspondence UNIR0003346 memorandum ; DATE: MARCH 1, 1974 B&L c//< tEti JR.X) SUBJECT: PHONE CALL WITH NIOSH, ROCKVILLE, MARYLAND 3-1-74 TO: J. E. ERTEL cc: E. R. Bardgett J, McDaniel A* Dorko Jy'c. Pal insky On Thursday, 2-28-74, the writer called Mr, Vernon Rose of NIOSH in the Washington area in an attempt to determine what medical screening,protocol, and medical testing may result from the task force committee; in addition to determine what work practice standards may be formulated for the industry. Mr, Rose, being unable to talk with me on Thursday, returned my call oh Friday morning. I discussed our situation, that we are not members of the MCA, that we lack the recourse to get information directly from MCA as can most of the rest of the industry. I requested of Mr. Rose what information he may be in the position to give me at this .time, NIOSH will meet on Saturday, March 2, with .certain members of the medical profession that have been called together to set up medical protocol, testing and screening. He feels that after they discuss the medical aspects there will be a lapse of at least a week while these members digest what is discussed before they re-meet to formulate medical plans. They will, as part of this medical screen ing and protocol group, probably have a set -of medical tests suggested as a basis for initial screening and reference for further and continued testing. Mr. Rose informs me that just this week he has received from various members of his task force, drafts of suggested work practices. He is formulating a proposal from these drafts as a recommendation for OSHA. This he expects may be presented by the middle of next week. He is not sure whether the Department of Labor will, or will not accept the draft as an immediate and temporary standard or whether they will modify the draft and propose this draft in the Federal Register. This would probably then involve a 30 day period for the public rebuttal, after which OSHA could hold another public hearing. In all, it appears that nothing factual or formal will be available for approximately 2 months time. UNIR0003347 -2- He did suggest that as in interim measure that we continue our program of monitoring for VCM and continued good work practices to reduce exposure to VCM wherever possible. Mr. Rose recommends that the purchase of an OVA unit is a good start for equipment to monitor VCM concentrations. He suggests that we contact our. plant physician to enlist his aid to find a medical liver expert. I -reques'fced . `<Ros e '*fefrat ^he i*S'end^o- ^our 'Parnesvi l-le~address, future information that may be passed on by or through NIOSH to the MCA since we are not currently members and would be unable to obtain this information except by the generosity of other processors in our local area. His secretary recorded us on their.mailing list. V NES:sp UNIR0003348 TELEPHONE CALL REPORT TOf A. C. Werner Bis C. H. Kim SUBJECT: frequency of S. D Poly Cleaning DATE: torch 1, 197U In view of high VCM exposure measurement in the S.D. plant processing area:, a call was made to A.C. Werner to obtain torvinol R&D's approval for reduction of frequency of poly opening. It was agreed that the S.D. plant polys will be opened for jetting and cleaning purposes every other batch instead of the current practice of jetting after eveiy batch. No permanent gel specification change is contemplated at this time; however, special approval will be obtained for those lots having- high gels so that the Plant will not be penal ized unduly. 1 The changes in poly cleaning procedure will become effective immediately. Oi Monday, torch It, 197U, we will attempt to make new measurement of 7CM concentration in the S.D. processing area to measure the effectiveness in this procedural change. CHKthew cc: CBRL) REH CJIT GMB CBW ESP jis mcj wmi ACWerner - Naug. UNIR0003349 ' VINYL CHLORIDE PROBISM - SUMMARY TO DATE 1. On January 23* 197**, B. F. Goodrich made a public announcement that they had informed health authorities in the State of Kentucky and the Federal Government that three of their employees had died of a rare form of liver cancer. They were concerned that these deaths might relate to the fact that these men had" worked in the Louisville PVC plant for many years. Additional search of medical records indicated that two other B. F. Goodrich Louisville employees had died from the same cause. Angiosarcoma of the liver. (Plus one at Goodyear, Niagara gal*Sa?je)at Eal011 Carbide, S. Charlestown, V. Va*; and one at ICI in 2. The Kentucky Department of labor and representatives of the Federal Agencies OSHA and NIOSH began an immediate investigation. NIOSH issued, Ch February 1, 1974, a set of recommended precautionary procedures for use in PVC plants. These procedures recommended protective measures for workers against, both VCM and PVC dust. 5- o 4. Within the last month, representatives of both the Painesville plant and Corpor ate Health and Safety have participated in numerous conferences on this subject. We have issued recommendations to everyone in Marvinol manufacturing and all maintenance men associated with these operations for personal protection against both VCM and PVC exposure. Some equipment and procedural changes have been made to reduce exposure. We have borrowed an instrument for monitoring VCM levels in the air in our buildings. Instruments are on order for our continued use. We are studying additional process and procedural changes to be made as soon as possible. A review of the medical histories of our employees, both living and dead and both present employees and former employees, has not revealed any occurrence of Angiosarcoma. 5. The National Institute for Occupational Safety and Health (NIOSH) will visit a number of PVC manufacturing facilities to study both the operation of the facility and the medical history of the employees with the facility. The object is to determine whether the problem which has surfaced at the Goodrich, Louis ville plant is unique to that plant or a general problem in PVC facilities. A team from NIOSH will visit the Painesville plant on Tuesday, March 5- We will cooperate fully with them during their visit. 6. Various industrial groups are pooling their operating experience in order to set up minimum acceptable operating procedures for the PVC industry. This information will be available so that when NIOSH completes their investigation as to the probable factors related to the B. F Goodrich experience, recom mendations can be made to be applied uniformly to the PVC industry. 7. At this point in time we cannot say, with certainty, the degree of hazard which VC and PVC represent. We want all of our employees to be aware of this problem and to- help safeguard them against unnecessary exposure to these materials. It seems unlikely that products made from PVC offer any hazard even if there is a hazard during the manufacture of PVC resins such as Earvino!. BRL 2-28-74 UNIR00033S1 VINYL CHLORIDE PROBLEM - SUMMARY TO DATE 1. On January 23* 1974, B. F. Goodrich made a public announcement that they had informed health authorities in the State of Kentucky and the Federal Government that three of their employees had died of a rare form of liver cancer. They were concerned that these deaths might relate to the fact that these men had worked in the Louisville PVC plant for many years. Additional search of medical records indicated that two other B. F. Goodrich Louisville employees had died from the same cause. Angiosarcoma of the liver. (Plus one at Goodyear, Niagara MglaAd^to#3a?ee)a^ Un*on Carbide, S. Charlestown, W. Va*; and one at ICI in 2. The Kentucky Department of labor and representatives of the Federal Agencies OSHA and NIOSH began an immediate investigation. NXGSH issued, On February 1, 197^9 a set of recommended precautionary procedures for use in PVC plants. These procedures recommended protective measures for workers against, both VCH and PVC dust. 3* O 4. Within the last month, representatives of both the Painesville plant and Corpor ate Health and Safety have participated in numerous conferences on this subject. We have issued recommendations to everyone in Marvino1 manufacturing and all maintenance men associated with these operations for personal protection against both VCM and PVC exposure. Some equipment and procedural changes have been made to reduce exposure. We have borrowed an instrument for monitoring VCM levels in the air in our buildings. Instruments are on order for our continued use. We are studying additional process and procedural changes to be made as soon as possible A review of the medical histories of our employees, both living and dead and both present employees and former employees, has not revealed any occurrence of Angiosarcoma. 5. The National Institute for Occupational Safety and Health (NIOSH) will visit a number of PVC manufacturing facilities to study both the operation of the facility and the medical history of the employees with the facility. The object is to determine whether the problem which has surfaced at the Goodrich, Louis ville plant is unique to that plant or a general problem in PVC facilities. A team from NIOSH will visit the Painesville plant on Tuesday, March 5- We will cooperate fully with them during their visit. 6. Various industrial groups are pooling their operating experience in order to set up minimum acceptable operating procedures for the PVC industry. This information will be available so that when NIOSH completes their investigation as to the probable factors related to the B. F. Goodrich experience, recom mendations can be made to be applied uniformly to the PVC industry. 7. At this point in time we cannot say, with certainty, the degree of hazard which VC and PVC represent. We want all of our employees to be aware of this problem and to help safeguard them against unnecessary exposure to these materials. It seems unlikely that products made from PVC offer any hazard even if there is a hazard during the manufacture of PVC resins such as Marvinol. BRL 2-28-74 UNIR0003351 F-C04B *V. 2.7 ; \fC flvdA " f^ifA >q5j . }H> TO: MEMO UNIROYAL CHEMICAL Division of UNIROYAL, Inc. February 26, 1974 cc: GAA - Naug. JEC - Naug.. DEO - Naug. FROM: B. R. Leach SUBJECT: NIOSH Visit I received a telephone call on Monday, February 25, 1974 from Mr. Phil Bierbaum of NIOSH. NIOSH plans to visit Uniroyal, General Tire and Avon Lake PVC plants during the first week of March for a preliminary survey. We chose Tuesday, March 5 for this plant. They will plan to arrive between 8:30 and 9:00 a.m. There will be two MD`s, two Industrial Hygienists and a Statis tician. The planned sequence of events will be: 1. Discussion of the plan for the day. 2. A walk-through of the PVC manufacturing facility. 3. Split up for individual talks as follows: a. The MD's for discussion with Plant Medical Department. b.- Industrial Hygienist with Process people.' c. Statistician to Personnel for work record review. It will be desirable to have our Corporate Medical Department present so I have arranged that both Dr. Forbes, Corporate Medical Director, and Dr. Harris, Corporate Safety and Plant Protection, will be here. Dr. Fletcher had already planned to be here from 8:00-10:00 a.m. for his regular visit but we may want him here for a longer period that day. As indicated from our information on the Pottstown visit, the following information is needed for this visit: List of raw materials. . This should include both a listing of all chemicals that have been used in this operation as well as a quantitative estimate of the chemicals presently being used. A process flow sheet. . Access to medical records. Brief, summary of now operations have changed during the plant's history. . Any results from In-plant air sampling. Pictures showing steps of the process. In addition to the visit of Tuesday, March 5, there will probably be one man who will visit on Friday, March 8,for a more detailed discussion of process operations. j&jQ P P (\I&ydy I , MUrfak CcT WMI REH CHK JRD 8. R. Leach V^li^MEAtiXJZQRRESEOJ&ENCE^ not 0 Qofiyf IP* UNIR0003352 TELEPHONE GALL REPORT TO: Dr* R* S.Brookman Technical Director . Firestone. Chemical Plant Pottstown, Pennsylvania DATE: February 2$, 197l BT: 0. tt. ESa ' SUBJECT: NIOSH Visit , . DATE: February 26, 197U ____ i. cc: CBRV WMI REH RJD MCJ GEB CBW WFB ~ A telephone call was made as a follow-up to my memo of February 22, 197h regarding NIOSH's visit to Firestone Chemical Plant in Pottstown, Pa. On February 21, 197U, NIOSH's inspection team consisting of three medical doctors (Dr. Falk, Dr. Mallov, and one name unknown), one epidemologist (Mr. Stringer), and two industrial hygienists (Mr. James Jones and Mr. Phil Blerbaum) have visited the Firestone plant. One of the industrial hygienists stayed an additional day to conduct an in-depth process study. According to Dr. Brookman, NIOSH intends to visit approximately 15 PVC manufacturing plants that have a manufacturing history of more then 15 years. From the 15 plants, NIOSH will select 2-3 plants for in-depth study. It seems to Dr. Brookman that since no angiosarcoma is found in other FTC manufacturing ^ite$ other than B.F. Goodrich's Louisville, Ky. plant, NIOSH is looking for the differences that may exist between the Goodrich .Site and other PVC manufacturing operations to verify whether angiosarcoma is indeed caused by VCM, or related to a particular operation. NIOSH personnel were very cordial and made no demands whatsoever, and left any information on a voluntary basis. After a quick walk through of the plant by the NIOSH team, each professional team started to conduct their own investigation with Firestone personnel. NIOSH's medical team spent the whole day with Plant and Corporate medical staff to review employees' medical records, especially records on deceased personnel. It was Dr. Brookman's understanding that NIOSH's medical team will review the death certificate and possibly the autopsy with the State Health Department of each case. When a suspicious death is found, they intend to conduct an investigation with hospital and employee's personal physician. The NIOSH epidemologist reviewed personnel work and VCM ex posure records with Firestone's Industrial Relations Department. The two industrial hygienists spent the entire visiting time with plant personnel to review processes and make VCM analyses of the plant environment. Dr. Brookman informs me that based on their questions, NIOSH is more inter ested in what the past work practices and VCM exposure have been that could be related to employees health records. They were very much concerned with air borne PTC dust for reason of VCM carried by dust and ingestion of VCM with inhalation of PVC dust. UNIR0003353 NIOSH Visit (cont'd) 2 February26> 197U NIOSH has borrowed Firestone*s'Century hydro-carbon analyzer unit and made extensive spot analyses including: 1. Reactor/during cleaning operation - they have detected very' high 'con centration3 when the reactor was opened, for cleaning and just prior to venting (exact concentration .not known).' During the cleaning opera tion) air sample exhibited less' than 66 PPM of VCM, mostly 30-1:0 PIM range. 2. Warehouse Area - they have detected reasonably high concentration of VdM "between bags as'well as the warehouse in general. Since they have gas driven lift trucks, Dr. Brookman expects that Century unit will detect high concentration of hydro-carbon concentration as the . . unit is not discriminative. 3. Hydro-Carbon (other than VCM but used as additives to their processes) Storage-Warehouse Area - NIOSH detected total hydro-carbon concentra tion of 150 PPM, but Dr. Brookman was sure that it was not VCM but . caused by other hydro-carbons. NIOSH personnel did ask permission to take photographs of the operation} however, instead. Firestone showed slides that were available for their personnel training, NIOSH accepted the slides rather than taking their own photographs. Firestone is in the process of editing those slides for submission to NIOSH. A complete list of chemicals were given to NIOSH personnel also. Dr. Brookman further informs me that NIOSH's industrial hygienists asked many many questions but the answers were strictly voluntary-at Firestone's discretion and not forced. I have informed Dr. Brookman that I would reciprocate his favor if and when NIOSH makes a visit to our plant. CHK:hew. UNIR0003354 F-S04* ev. 2-7 i/VMl PRIVATE UNIROYAL CHEMICAL Division of UNIROYAL, lne. ; February 22, 1974 Report of Telephone Conversatfon Dr. Dexter Forbes - Oxford Dr. Forbes called today to relay the latest Information regarding the vinyl chloride problem. He wanted to acquaint me with these facts and see what we might do to get additional background Information on those former employees who are deceased. 1. Tabershaw-Cooper have tabulated data on 131 deaths so far (not Including the B. F. Goodrich five). At least two of the cancer deaths are from the Palnesvllle plant. These are Herbert Nelson, died 1969 and Sten Gergley, died December 1972. Dr. Forbes would like us to verify the work history of these men such as, what job did they, do here? How long did they work here? What exposure did they have? What other employment history other than Uniroyal can we determine? Dr. Forbes asked me to consult with Dr. Fletcher as to what medical data might be available on these and the others that we might be aware of who are now deceased such as, did death occur In a hospital? What hospital? Autopsy performed? Anything noted regarding liver, O kidney, or lungs? Any record of laboratory work during last illness? 2. Dr. Forbes asked what we do in our annual physicals of our employees. It is probable that one result of this VC problem is that a good annual physical examination will be required of all employees. This would include, medical history, occupation history, lung function test, xrays of chest, hands and abdomen, blood count, platens?)'' count, SMA-12, and urinalysis. The cost of such ae examination is likely to be in the neighborhood of $200 soyfctlwf.are talking about 200 people, this is $40,000 annually. Even $40,000 Is optimistic.since. If any sort of problem Is found there will be additional work required. cWi""VL Dr. Forbes, asked me to determine when It would be convenient for him to visit Painesvllle for discussion with Dr. Fletcher regarding some more of the medical details which he has learned. I told Dr. Forbes I would determine this and I would like to have it as soon as possible since I want to review our Infplant plans with Dr. Harris and himself. " 4. Dr. Forbes has a meeting this afternoon from 2:00 to 4:00 pmm. I promised tha'L either Dr. Fletcher or myself would call him after 4:00 to see If anything can be arranged for next week. BRL:nak INTERCOMPANY CORRESPONDENCE UNIR0003355 F-I04I REV. 2.07 ; ' UNIROYAL CHEMICAL Division of UNIROYAL, Inc. February 22, 1974 cc: GAA - Naug. OEC - Naug. TO: D. Ei--frudrow Oxford FROM: B. R. Leach Painesville SUBJECT: NIOSH According to a conversation I had on Tuesday, February 19 with the Cincinnati office of NIOSH, the Painesville plant is high on the priority list of PVC facilities to be visited. ~ I was told that we would be Informed well ahead of any NIOSH visit if we were selected. The attached memo from C. H. Kim Indicates the kind of information that is likely to be required if we are visited. He are preparing this now. If some sort of higher level approval is required for any of this infor mation, please begin to get It now since I rate the probability of a NIOSH visit to be high. B. R. Leach ) INTERCOMPANY CORRESPONDENCE UNIR0003356 . No vinylchloride monomer has been manufactured at the Uniroyal Painesville facility since 1954. 2. No vinylchloride resin has been manufactured at the Uniroyal Painesville facility since 1976* 3. The Uniroyal Painesville facility has had a viable health monitoring and surveillance program in place since 1974, including a hands-on annual physical examination, com prehensive blood analysis, hemoccult blood tests, pulmonary function and chest X-ray. 4. The Painesville facility has had on-line area monitoring systems since 1974. 5. In 1974 a personnel monitoring program was initiated including employee notification of monitoring results* 6. An epidemiologic study by the University of North Carolina in 1978 revealed the co hort of the Painesville Uniroyal facility to have a better health profile than the general population. 7. When the temporary standard for vinylchloride was issued (1974) all employees and retirees were notified of the concerns regarding vinylchloride exposure. 8. The Uniroyal Painesville facility is in full compliance with all of the requirements ot the federal standards and regulations regarding employee exposure to hazardous i materials, including the annual requirement for employee orientation and training. 9. The Uniroyal Painesville facility maintains a comprehensive in-house auditing pro cedure to Insure that all programs relative to employee exposure are in compliance. 10. The Painesville Uniroyal facility in 38 years of manufacturing operations has never had health-related problems that have been identified with employee exposure in the workplace. URL-P 3356 C 0)V PIDEr^nA?, DOC CMEI\T PHOO'JCr-. '> ;V T'J FOM2SOSO TO: ,/b. r. Leach FROM: C. H. Kim SUBJECT: NIOSH Visits UNIROYAL CHEMICAL Division of UNIROYAL, Inc. February 22, 197U cc: REH WMI RJD During the MCA meeting last Wednesday, February 20, 197It, Mr. R. S. Broolanan, Technical Director of Firestone Chemical Plant in Pottstown, Pennsylvania, has made an announcement that they were notified by NXOSH (Mr. J. Jones, 2-11-7U) of their in tention to visit the Pottstown plant. They have asked how much time Firestone would need to prepare for the visit. NIOSH*s visit is tentatively scheduled for February 21 and 22, 197U upon mutual agreement. The NIOSH visiting team will consist of two medical doctors, two epidemiologists, and two industrial hygienists. NIOSH requests Firestone to be prepared to present the following information: 1* A complete list of; chemicals used in connection with the manufacture of FVC from year one. i 2. A complete current chemical list detailing monthly usage. 3. Flow sheets in schematic form. I U. Medical records of all employees. 5>. VCM measurement data, if available. 6. Walk-thru inspection. 7. NIOSH intends to take photographs of the operation but they will leave the negatives with the Company for udittoa. w- I made arrangements with Mr. Brookmah so thatl may make telephone contact with him in regard to NIOSH*s visit on February 2$, 197U. o /v^v- - C. H. Kim CHK:hew 0 INTERCOMPANY CORRESPONDENCE UNIR0003357 F-0O4B 4 EV. 2-57 UNIROYAL CHEMICAL Division of UNIROYAL, Inc. February 19, 1974 cc: JEC - Maug. TO Dr. W. D. Harris 0*-fo*pd FROM: B. R. Leach Painesville SUBJECT: Chemicals Used in PVC Manufacture The president of our URW Local, Ken Coss, received a telephone call from Louis Beliczky requesting a list of all chemicals used in the Painesville plant in the manu facture of PVC. We have prepared the attached list by takinq the list of ) all the chemicals we use and deleting those specifically limited to the manufacture of Paracril. This produces a list of chemicals used in the Boiler House, water treat ment and waste treatment as well as in the PVC manufacturina buildings. I concur that it is best to have this information conveyed from your office to the URW International. When you have provided the information to them I want to qive a copy of your letter to our local president to satisfy him that we have done the job completely. BRL:nak cc: RJD CHK Att: INTERCOMPANY CORRESPONDENCE UNIR0003358 VCM CONCENTRA!ION 24 HOUR SAMHES'-MIftAH RESULTS ) DATE BLDG. LOCATION RANGE,ppm AVE. ,ppm 2/12/74 2/13/74 2/14/74 2/15/74 2/18/74 2/19/74 2/20/74 2/20/74 2/20/74 2/20/74 2/20/74 2/21/74 2/21/74 2/22/74 2/23/74 2/24/74 2/25/74 2/26/74 2/27/74 2/27/74 2/27/74 2/-2J/74 20/74 3/1/74 3/1/74 3/1/74 3/1/74 3/2/74 3/4/74 3/4/74 3/4/74 3/5/74 3/5/74 3/5/74 3/6/74 3/6/74 3/7/74 3/7/74 3/8/74 3/8/74 3/9/74 3/10/74 3/11/74 3/11/74 117 117 117 117 107 107 107 107 107 * 107 107 107 107 414 414 414 414 ! 415 117 117 117 117 108 108 108 107 107 108 414 414 414 414 414 108 117 107 107 107. 108 117 100 108 108 108 2nd Floor @ Charge Station 1st Floor.@ Stripper H 1st Floor @ #7 Compressor 2nd Floor @ Exhaust Fan 2nd Floor Q Weighing Bench 2nd Floor Between A&B Strippers Air Above Manhole During Jetting Poly Cleaner Entered @26 -ppm PoIlIy CleanII out MaII tl.lnII DruII m{2I/I3 fuIIll) 1st Floor Catwalk Under #17 2nd Floor Exhaust Fan With Poly Cleaner In #15 2nd Floor Exhaust Fan 2nd Floor Zl East of Poly #11 1st Floor Exhaust Fan . 1st Floor Between Strainers Bagger Station Poly 10 Jetting Poly 6 Jetting" Poly 6 Jetting-next shift SE Exhuast Fan-2nd Floor Centrifuge Catwalk Swenson Bagger Bowen #1 Poly 22 with Poly cleaner Poly 22 with increased air Catwalk @ Bowen #2 Derrick 1st Floor Exhaust Fan Poly 5 Jetting Poly Cleaner in #5 1st Floor Exhaust Fan Jetting #4 Feed Chute to. Wins. Mills Between Compressors 7.&8 2nd Floor Exhuast Fan Poly Cleaner in #16 2nd Floor Exhaust Fan Locker Room 2nd Floor Exhaust Fan Break Room Locker Room Sock Change-Bowen #2 Pilot Plant 52 36 528 148 52 25 32-230 90 (40 min.) -26 6"abv.drum 40 6"into drum 75 2-1100 120 (22 hrs.) 26-1000 120 (4 hrs.) 1630 (chromatoap 20-1050 88 0-1640 88 3-1600 100 0-1600 160 20-160 26 70-745 265 (30 min.) 50-1095 260 (24 min.) 160-1600+ 380 (17 min.) 80-530 160 (16 hrs.) 0-950 65 30 (30 min.) 15 (6 hrs.) 120-580 185 (75 min.) 25 35-800+ 250 8-360 60 (2.5 hrs.) 100-320 160 (8 min.) 10-25 15 (23 min.) 10-380 40 (4.hrs.) 1600+ ( 7 min.) 5-100 25 (11 hrs.) 160-550 270 50-1040 120 (19 hrs.) 50-150 80 (70 min.) 50-160 70 (2 hrs.) 0 25-800 0(3.5 hrs.) 90 (18 hrs.) 4-14 8 2-190 5 15-26 20 (15 min.) 0-700 14 (10 hrs.) UNIR0003359 t EtGoodrich B. F. Go o d r ieb Chemical Company A DIVISION OF til 0.1. 6 0 0 0 RICH COMPANY 1ft TER NATIONAL DEPARTMENT February 19, 197^ . VIA AIN MAIL. Mr, C* H. Kim Unirqyal Chemical PainesviUe, Ohio 4407T { Dear Mr* Kim: '. This letter and the enclosed brochure are for the purpose of intro ducing you to the B.F.Goodrich Chemical Company Hydraulic Reactor Cleaning System, The system has been developed and perfected .by B.F .Goodrich over the last several years, and many systems are now in operation in various Goodrich Chemical and licensee FVC plants. The hydraulic reactor cleaner has been used on large and small reac tors, including glass-lined and stainless steel, with very good cleaning obtained on all vessels during a total cleaning cycle of onehalf hour. A small amount of polymer buildup occurs in difficult to clean spots, after a considerable number of charges. This buildup may be removed physically in a very short time, this being the only time it is necessary for personnel to enter the reactor. B.F.Goodrich Chemical Company is willing to license this reactor clean ing system. The hydraulic reactor cleaner, or the complete system if desired, would be available from a reputable engineering firm which has worked closely with Goodrich in the development of this device. If you have an interest in the system, we would be very happy to demon- . strate it at our Louisville, Kentucky plant upon execution of a simple secrecy agreement. Should there be any questions regarding this system, we would be pleased to meet with you at your convenience, to discuss licensing and operation of this hydraulic reactor cleaning system. Sincerely, .1 1 ALH:rh Enclosure \ i CABLE ADDRESS GQQOCHEM IQPC. CODE ABC SIXTH EDITION -- 7E1EX NO. 88*0427 UNIR0003360 B. . GO 6D R I C H CHEMICAL . COMPANY HYDRAULIC REACTOR CLEANING SYSTEM Economic Data March 1971 ^BrcMxifichy B. F. Goodrich Chemical Company r Division or r * f t * ( n m i c > : 3 * > n i UNIR0003361 TABLE OF CONTENTS I. DESCRIPTION OF SYSTEM II. ' OPERATING AND SAFETY ADVANTAGES III. ECONOMIC ADVANTAGE IV. LICENSING SITUATION UNIR0003362 I. ; DESCRIPTION OF SYSTEM f The B.F.GoodrichChemical Company has developed a unique system for cleaning FVC reactors.' Actual cleaning of the reactor is accomplished with high-pressure water in a fraction of the time required for cleaning reactors by hand. Operation of the system is'quite simple, and is operated by one man. .Very little training is required to operate the equipment, as cleaning is essentially automatic. The hydraulic cleaning unit is supplied with a special cart so that it can be moved ftiom reactor to reactor. Approxi mately five minutes are required to mount the hydraulic reactor cleaner . unit on the reactor and make the necessary hose connections. Cleaning is then accomplished in 15 to 20 minutes. The reactor manway is completely sealed by the unit so the personnel on the operating floor are not exposed to high pressure water and resin particles. After cleaning, the unit is removed, which requires about five minutes, for a total cleaning cycle of approximately 30 minutes. Use of this system results in noticeably cleaner reactor surfaces then are normally obtained by manual cleaning. .II. OPERATING AND SAHSTY ADVANTAGES . In addition to the economic advantage of using the E.F.Goodrich Chemical Company hydraulic reactor cleaner system, there are several additional important benefits to be gained. These are as follows: 1. Normally personnel do not enter the reactor, and therefore they are not exposed to possible suffocation by VCl fumes, or injuries caused by someone mistakenly starting the reactor agitator. UNIR0003363 II. OPERATING ACT) SAFETY ADVANTAGES 2. The hydraulic reactor cleaner operates pneumatically, and uses water as the cleaning agent. Therefore,, the danger of fire is not present as it is with solvent cleaning of reactors, or mechanical cleaning with. Inherent spark producing potential. 3. The reactor is significantly cleaner using the hydraulic reactor cleaner. . as compared to hand cleaning methods. This results in reduced product contamination, and better heat transfer through the reactor.walls. 4. The chipped glass, nicks, and gouges normally associated with mechanical cleaning of reactors is eliminated when using the hydraulic cleaning system. m. ECONOMIC ADVANTAGE * The economic advantage gained from using this system is derived from two parts. First, the actual cleaning cost per pound of resin is substantially reduced. Second, reactor productivity is increased. Example: Following is an example of possible savings for a hypothetical 100,000,000 pound per year PVC plant. The cost of the hydraulic reactor cleaning system shown can be higher or lower depending on the options chosen,' but it is felt that the figures shown provide for a more than adequate system. Assumptions 1. 25 reactors producing 6,000 pounds PVC per charge. 2. Onstream time, 333 days per year. 3. Total cycle time using H.R.C. system, 12 hours. UNIR0003364 ECONOMIC ADVANTAGE (continued)^ - . With Manual Cleaning . .V:'v 3. Operating Cost a. -Manpower (3 men/shift at $10,000 $120,000 per man per year) b. Utilities, tools, and safety equipment ' 5,000 TOTAL COST % $125,000 per year Reactor cleaning cost per pound of PVC $125,000 = .136^/lb. $2,000,000 m Productivity gain using hydraulic 100,000,000 lbs. PVC Reactor Cleaning System $2,000,000 8,000,000 lbs. PVC/yr. Assuming net profit of.5^ per pound PVC ($.005) (8,000,000 lb. PVC) = $40,000 per year $125,000 cost for manual cleaning 61,330 cost for H.R.C System $ 73,670 Saving per year $73*670 40,000 Savings using H.R.C. Savings dueto increasedproductivity $113,670 total savings per year UNIR0003365 LICENSING SITUATION '' ; . . J ;; B.F.Goodrich Chemical Company is willing to license this reactor-, cleaning technique for .a nominal lump- sum royalty. Licensee will be given all the information in the possession of .BFG and will also be placed in contact with a machine design company who can work with Licensee to design units for specific vessels. Upon signing a simple secrecy agreement, prospective Licensee will be allowed to see this unit in operation at the Louisville, Kentucky plant of BFG Chemical. One patent has already been filed in the United States, and it is expected that additional-patents will be filed in the future. Foreign filings based on the Ubited States application will be extensive. Mr. L. M. Puckett, Manager of Licensing, or Mr. A. L. Hastings, Licensing Engineer, will, be happy to discuss this reactor cleaning technique at your convenience. UNIR0003366 Co ill.' ECONOMIC ADVANTAGE (continued) ; With Hydraulic Reactor Cleaner System 1. Capital Investment Complete system including pump, controls, electrical, installed piping, and two hydraulic reactor cleaning units 2* Operating Costs* a* Maintenance and utilities tu Manpower (1 man per shift at $10, (XX per man per year) 3* Ten year depreciation of equipment and. 8$ compound interest per year TOTAL CC6T $ 83j 000 $1A ,700/year 40,000/year $51,700/year $ 9,630/year $61,330/year Reactor Cleaning Cost per pound of FVC $ 61,330 .06l^/lb. 100,000,000 It. With Manual Cleaning 1. Total cleaning time, 1.5 hours per charge.. 2. Charges per day (24 hr.) (25 reactors) (13 hr./chg.) ' = 46 (46 chgs.) (1.5 hours cleaning time) = 8.6men/day = 3 men/shift r (o hrs./man day) " (46 chgs./day) (333 days) (6,000 lbs./chg.) ,,92,000,000 lbs. PVC/yr. UNIR0003367 CONFIDENTIAL TRIP REPORT B. F. Goodrich Company Niagara Falls, . New York Attended: UNIROYAL Personnel B. F. Goodrich Personnel V. M. Iliff P. E. Phillips G, J. Higgins . Messrs. Lennox Aquina Nolan Hastings A visit was made January lit, 1971 to the B. F. Goodrich Plant in Niagara Falls, Not York to witness a demonstration of a high-pressure water cleaning device that B. F.. Goodrich is interested in licensing to other FVC manufacturers. The device is water and air driven and is similar to many of the avail able whirling nozzle spray devices except that it has a rather sophisti cated programming system allowing it to clean from four different positions. The reactor used for the demonstration was a 1,100 gallon stainless: steel vessel that was very lightly fouled. In a matter of a half an hour, the machine was installed, worked through its program and was re moved. The vessel was completely cleaned except for a knot or two on the agitator shaft coupling. The spray machine was handled by one man using a four-wheeled dolly and chainfall. This was, of course, a small piece of equipment in comparison with that which we would need at . Painesville. A device of this sort would be useless to us in Area I where all of the vessels have heat exchangers, but might prove to be highly satisfactory in S-D, and for Area I Strippers. The economies are being prepared and will be reported in the near future.- For maximum effectiveness, it would appear at present that two machines and a 5,000 pound, 60 GPK pump would be required. A firm in Cleveland, Polytechniques, 3hc., has built these units for Goodrich and is recom mended as a reliable source- of manufacture. GJHshew 1-18-71 Copies: Fiji RkH W5I PEP . .r UNIR0003368 V / December 23#. 1970 Hr. A. L. Hastings B. F. Goodrich Chemical Company 313S Euclid Avenue Cleveland, Ohio Iit|115 Bear Hr. Hastings* Enclosed is a fully executed copy of the secrecy agreement concerning your hydraulic reactor cleaning system. X am interested in meeting vlth you at an early date for further discussions, and whsn possible, a demonstration of tbeysystem in actual operation. O Sincerely, tltlXBOXAL, INC. PEP/jea Attach. bcc* P. E. Phillips, Methods Engineering Supervisor UNIR0003369 3135 EUCLID AVENUE B. P> Go odr ich Chemical Company k DIVISION OF THE B. F.GOODRICH COMPANY C L E V E L A N T , OHIO 44115 * PHONE 2 1 3 -B 8 1- 6 2 0 0 R, P; ICENNET ltl MC 0I Mt'llllf / " September 30, l$70 XJniroyal Chemical Division of Uniroyal, Inc. Painesville, Ohio iikOj'l ~ Gentlemen: SECMEY AGREE-EKT BE: H3C '' It is understood that representatives of your company (hereinafter UC) desire to receive further information concerning high pressure hydraulic devices and systems for reactor cleaning (hereinafter KRC) developed by our company (hereinafter B?G) to detcraine possible interest in licensing the same. To this end, BEG will permit its JIEC operations at its . Niagara Falls, I!ew York plant to be observed by representatives of UC and will also authorize representatives of POLYI'ZCHIi'IC.lBS, INC. of 17100 Miles Avenue, Cleveland, Ohio (hereinafter Pi) which has performed services relative to HRC for B?G to discuss the possibi lity of PI performing services and supplying HRC devices to UC, . provided that UC agrees to the following conditions: ik (1) It is understood that the engineering details and drawings of HRC devices will not be revealed or disclosed pursuant to this letter and that UC by virtue of this letter will have no license express or inplied under any patent rights .of BFG including certain pending U.S* patent applications directed to HRC devices and their method of operation* (2) UC agrees that information revealed to or acquired by it as a result of the visit to the aforesaid Niagara Falls Plant, or as a result of discussions with representatives of BFG and/or PI, will be maintained in confidence and not revealed to any third party and will be used by UC . solely for the purpose of determining whether UC wishes to acquire a license relative to KRC frera BFG. UNIR0003370 September 30f 1970 Page 2 (3) The obligation of UC a3* set forth in .paragraph1 (2) shall not apply to any item of information which (a) is published 01* available to the public on the date hereof or. hereafter . becomes published or available to the publ5.c through no fault of UC or (b) can be shown to have been in the- posse- . ssion of UC prior to acquisition from B?G or PI, or (e) is acquired by UC without binder of secrecy ficra a third party who has no obligation of secrecy to BFG with respect thereto, it being understood that PI is. not such a third party. ' J (4) The obligations of UC as set forth in Paragraph (2) shall terminate three (3) years from the date hereof. If the above conditions are satisfactory to UC, please so signify by countersigning the enclosed copy of this letter and returning it to us. : Very truly yours, B,F.GOODRICH CHEMICAL COMPAQ COUHTERSIGEED: UHIP.OYAL CHEMICAL .VICE PRESIDENT R. P. Kenney' -JVice President International UNIR0003371 UNIROYAL CHEMICAL Division of UNIROYAL, Inc. February 15, 1.974 cc: JEC - Naug. } ' . . '.. . . ` WDH - Oxford . . ;.. '. . *. f .- .. ' ' *' . TO: 6. A. Anderson Naugatuck ,:.^,,iL.JjeAC.h . > PalnesvilTe SUBJECT: Palnesvllle Application of NIOSH VC/PVC Reconimendatlons : As you know,we held a meeting.on Wednesday to review with most Interested staff people the NIOSH recommendations of .1-31-74. Attached are the Minutes of that meeting as put together by C. J. Urbanski. Yesterday, Thursday, we had a review session with the union -committee to go over the highlights of this list. They were given a copy of the NIOSH recommendations and we went throuah those recommendations,Item by Item, to tell them the action we planned to take. Ih some cases this was an immediate action and in others- a study of alternatives to determine . what would be done In the near future. The primary principles Involved were that use of Individual protective equipment and operating procedures presently provided,as well as individual personal hygiene,would be required of everyone. Certain process changes,such.as no longer having the S. D. manhole open during batch dumping,will be made. This presentation was received calmly. The concern was expressed that process and equipment changes be made to reduce exposure and that we don't try to do It all by changing established operating procedures. A similar presentation was made to PYC Production and Mainte nance foremen later on Thursday. A follow up staff review Is scheduled for 2-25-74` to check' . progress on'the assignments of 2-13 and to consider any new information available -from.MCA or NIOSH. UNIR0003372 -tv ITEM I-A-2 . I-A-13 ACTION TO .BE TAKEN BY Good Housekeeping procedures will have-to be maintained. All * ' ' * T *4 ' . I' * . All>dried PVC containers to be .kept closed*- r* , 1 v* ! / ' -All , Drums used for.jpoly cleanout must-have lids. \b Poly cleanout to be-removed from inside buildings . ABF/et al # . ABF/et.al each shift;, and ;duraped. into Dumpsters {NOTE:''- Involves * .' BTS change in jdb'ddtieS in Area 'Iv; `: Collection of- Poly . cleanout .In drums for sale to b discontinued. ' Sale of Poly cleanout in' dumpster containers to be investigated. " 618 Present poly' cleanout stored-in drums in Bldg. 1.02 to GMB be removed from inside building. I-B (Determination of Yields and Efficiencies- to be increased ,/wto wrom once/month .to once/week. CHK Will need to concentrate on identifying sources and mag- . .CHK nitude of unaccountable losses.- I-C. SD - Active program underway to clean off ledgestops .GMB of tanks, equipment, .etc., utilizing .built-in vacuvnn cleaning system. .Need to finalize and .maintain. ' Bldg./108 - Major Cleanup to-be contracted, out to capable - ABF/CES UNIR0003373 UNIR0003374 ITEM ACTION TO BE TAKEN ;. f BT II-D (cont'd) B, F. Goodrich to be contacted on how they, are imple- ; ,. WMI meriting this requirement and as to what is'nature of "Slicker type" suits, '' vY i . Possible counter-effects of wearing impend.crus -type ' .( suits needs-to, be' investigated. . ^ . HCK; ` ~ Is , . H 1 ni: Bequirements for taking showers''and;practicercf i-l personal .hygiene deemed to be. one of mostimportant '.. aspects of1 program. . ` Vessel, cleaners to be required to .take showers during ABF allotted washup time. Other personnel to be encouraged to. take showers on own RTS time while Industrial Relations investigate ways to implement'program without Jeopardising need for contin uous operations, ' .' . - I ' * . " IV-A-l thru It /. . *. In-Plant environmental monitoring programs, are actively, - ' underway by Technical -Department. .. .A Wilks-Miran continuous Infra-red analyser is-currently, being used to monitor VC concentrations oyer a 2lt-hour : periodidbach^ of, t^ee;fixed .positidns.; in Bldg, il7-; ; . . ; - ; , <- ^ ' . ' .*/*V* ,.* .vCi'*'' - a -v ; , '* :V - -T' *... *---T , ^ * ,, . - Same procedure will;be'used..;bo monitor Bldgs'? 107', 108,".-.v'-.r UNIR0003375 FOA29041 TO* JROKs C. H. Kim D. E. Rhinehart UNIROYAL CHEMICAL Division of UNIROYAL, Inc. DATE: January 22, 1974 BRj/GEB CJU CCS SUBJECT? Improved Foam Knockout Tanks for the S.D. PTC Plant The knockout tanks as originally installed are too small, resulting in frequent plugging of the recovery system. Poorer recovery of the unreacted vinyl chloride is the result as well as lost time and extra expense for filters that are necessary to keep polymer out of the Hash recovery system. In addition, for the more foamy types such as Marvinol 19 and 2ii, one of the 12 polys (8.3?) must be used as a foam knockout vessel,. For the past year (1973) 2285 poly hours (2.2%) wad lost using a poly for stripping. At the same time, finishing lost 5,1# production time for lack of slurry. Larger 6* diameter foam traps equipped with water sprays and liquid level control such as i& being used successfully for Building 107 debottlenecked plastisol and were to be used for the plastisol expansion, should be provided (see Fig. 1). Using 2% increase in poly usage of a possiblo 2.2% used as a stripper and for a 1973 production of 93.65 million packaged pounds, the installation of an improved foam control system would increase the production by 630,000 pounds per year. The installed equipment cost is estimated at $30,000. (Table 2) The increment increase in income would be $37,970. per year or 127? return before taxes (Table 1). The equipment cost is firm to June 197k with 30-32 week delivery (DSS). N ote? With increased selling price effective February 15, and escalating costs, return would be approximately 136? (see Table 1). In addition to increasing production, other benefits would include? (1) Improve yield by returning carry-over material to A-grade, (2) reduced filter costs. (3) reduce pluggage and downtime for maintenance on the recovery system, and (It) insure better vacuum to improve VCM recovery stripping. DER/ard 2-22-74 Attachments? 6 Pages UNIR0003386 Copies Toi BRIXWW*MI 'W'T&ur RFH MSJ JXS cbv; vi- L/v% Routi wiMii' ' yr * \mi | K OW-Up *''/// 6^ File Telephone Call Report SUBJECT: Air Sanpling Within Plant Working Arens From : C P Hesterhoff X advised Dr, Harris that our air sampling program rinri rvi+. To: . Dr, W, H, Harris Day Monday Date November 27. 197? include the testing in which he was interested, namely the concentration of vinylchloride monomer in the working areas. He asked "what our capability was for testing low conccntra-- -tions of vinvlchloridp and Mrs- Stoll p-rruriripd Vnw t.ri f V, th<=> .that..we..can tp.ilil.part jer..ml2ifln in,a samplfi. rf ai>. Dr. Harris Plans to visit Painesville on December 11th and 12th, arriving late on the 11th arid possibly stay- ,ing over until the 13tn so that he wight examine .the opera ting areas of the Marvinol production facilities and decide where it would be appropriate to sample the air and analyze for vinyichloride monomer. He will oversee the sampling and analysis and discuss with us the possible necessity of a regular program of sampling for this purpose0 UNIR0003387 JH .jlSL H-R -OK *JLa> (l>iP ^~-v -Z^o Afa ~i*. *J) i~Qcy-% ld^Jls=^tJll^ _ rL^Ai~c j^a^3r^-i^*~y --------------------------------^J/S-g-AA---4--dUo-----O*__ !^fcfe<lsA-__/ fV^flfjioJL , . -tx>_ <4^<^vfccS. j(L<^A^Ta--fl^a.AjuaJLffo , (jut %Jaj LjtJLcO^X - *t^5 -co. C3----- . -CL- _^2^4=suol. ~i4--itJst^n^. __ Cl^a-^L ___<^lA. fV2- OTM-S--___ __ -asiS^_^L___<&>'$o$t\j ., UNIR0003388 j)#lLi'kQ ?Jidy IB, 1973 MEMORANDUM File-2 REK GJU E SBF HUK NOT CKi JDP Oxford: HDHarris IDieringer Report on. Plant Trial of Hiran Oas Analyzer Mr. Harry Jacobs of the Wilks Scientific Corporation brought a portable infra-red gas analyzer to the Painesville plant on June 28, 1973, for a brief daaonstration* The instrument had no self contained power source although this is available. It is not explosioo^prbpf, but can pull vapors through a hose from the area to be tested to the analyzer up to 100 feet away. Mr. I*. Dieringer was present for the demonstration. Sampling was carried out in the Paracril finishing area, process area, and the S.D, process area. At the same time, sampling was carried out using the TLV Sniffer meter. In all cases, readings on both meters rose and fell together. Since neither instrument had been accurately calibrated for the vapors being sampled at that time?, so qx antithtive results were obtained. It appeared that hydrocarbon concentrations in the air were quite low. however. Air samples taken at the discharge end of the P&S dryer showed aegligable meter readings. The air in the building was also quite clear at this time, Paracril 3300 (alum floe) was being produced. Small readings at the wavelength where acrylonitrile absorbs were obtained at the second dewatering screen, but the air sample had to be taken within 12 inches of the crumb bed to get a reading. Air samples in the latex blend banks gave significant levels of acrylonitrile, bat the air around the operating area wan quite clean in both the finishing and process areas of Paracril. The process area in S.D. indicated some vinyl chloride content in the air. Several reactors were open. In order to obtain a more complete and quantitative idea of the air corapoTM sition throughout the factory, the Miran gas analyzer should be rented for about three months with a recorder and a calibration systemc. This would cost slightly over 0500,00 per month, 75% of which would apply against purchase price. Calibrating and Interpreting data could take 2$% to 50% of a man's tine in order to get maximum effectiveness from this instrument. After Painesville has characterized its major problem areas, it is possible that Dr* Harris might want to consider purchase of the instrument for use in other plants. CBW/jem UNIR0003389 <rF-233 RlSV.^2-67 cf ft. TO: FROM: DATE: C. B. Westerhof Painesville Plant W. D. Harris, Ph. D. May 29, 1973 Enclosed is the information on the MIRAN Infra-red Analyzer, which I mentioned on the phone. My understanding is that data used in this instrument is acceptable to OSHA. Larry Dieringerand I saw it at the Boston AIHA meeting last week. We think that it looks like a very-useful instrument. You can use it for scanning to find where- the highest > concentration is located. In this application you w>uld get a contin uous reading on the dial. On the other hand, you could set it up with a chart at a fixed location and measure the fluctuation with time. I think there should be at least one of these instruments in the com pany and we will be discussing this with Mr. Dudrow to see whether we could get one here. If you should decide to get one at Painesville, we would like to be kept in close contact, both to get acquainted with the instrument and to get firsthand knowledge of the concentrations. WDH: Enclosure cc: G. A. Anderson - EMIC D. E. Dudrow - Oxford u). 3 W. D. Harris, Ph. D. irporate industrial Toxicologist r&d fis. /& s ^aro^vJS- Ulfes xfe; Vvwk- pSc>s.^ <Zcre>A 4. 'C2> y t C0uj&e.j- 1-^=6, fb*_ OsMtf-, INTERCOMPANY CORRESPONDENCE UNIR0003391