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IHS File OOC-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Paga2 INTRODUCTION The following programs are included In your current Occupational Health Program. The programs are scheduled to be reviewed annually and updated on a two year basis. Industrial Hygiene Monitoring Program Hearing Conservation Asbestos Ventilation Ergonomics Heat Stress Medical Surveillance Hazard Communication Industrial Hygiene Education Program Respiratory Protection Protective Equipment Radiation Hazwoper Department Activities Roster and Job Descriptions (updated on a yearly basis) Chemical and Physical Agent inventory (updated on a yearly basis) These programs should be placed behind the appropriate tab in the Department Industrial Hygiene Manual. C O N F ID E N T IA L IHS Fite #00-4905 199S05 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE. OC-101 Paga3 OCCUPATIONAL HEALTH GOALS AND PLANS 1993-95 Industrial Hygiene Monitoring: Comprehensive Chemical (8-hr TWA & Excursion) Noise (Area & Personal) Hearing Conservation Training: Asbestos AwarenessTraining: Ventilation: Ventilation Survey Manometer Check Ergonomics: Team Training Heat Stress Training: Hazard Communication: Review written Hazoom program Review Industrial Hygiene Manual/Protocol Update CPAI Review MSDS's compared to CPAI Health hazards training (annually) New chemicals training Respiratory Protection: Fit Testing for MSA Ultravue, 3M Half faceScottovista full face air purifying Training Protective Equipment Training (biannually) Radiation Inspections Visual (location, labels, sign) VVipe test, survey DATE LAST COMPLETED 1989 1991 1993 1993 1992 quarterly - 1993 1992 1993 1993 1993 1993 as needed DATE DUE 1993 1994 1995 1995 1995 1993 1995 1994 1995 1994/95" 1994/95 1994/95 1993 1992 1992 1995 1993/94 1994 Biannually (Feb7August) Biannually (May/Nov.) C O N F ID E N T IA L R&S154068 IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, 00101 Page 1 MONITORING PROGRAM 1. RATIONALE Industrial Hygiene monitoring in 1990-92 at Unit 1 was focused on specific areas instead of a comprehensive survey as originally planned in the 1990-92 Occupational Health Program (IHS File 0C1-3700-90). Area and personnel monitoring was conducted at the Unit 1 tank car off-loading area as part of an OSHA quarterly monitoring requirement and to evaluate modifications to the duct work and fans associated with the off-loading area laboratory hoods. Modifications included rebuilding and rewiring of the fans associated with the hoods and redesigning and raising of the exhaust stacks. Followup area monitoring for vinyl chloride in the laboratory has shown a significant decrease from an average of 0.84 ppm to non-detectable. Personnel monitoring for vinyl chloride has shown average exposures have decreased but the average of 0.62 ppm continues to exceed the OSHA Action Level of 0.5 ppm. A new laboratory hood has been installed in the loading area laboratory and followup monitoring will be conducted. In addition, quarterly monitoring of Loading Technicians will be continued and engineering controls will continue to be investigated. A comprehensive chemical survey has not been conducted at Unit 1 since 1989; therefore, a survey will be conducted as part of the 1993-95 Occupational Health Program to insure exposures remain within acceptable guidelines. Chemicals evaluated will include vinyl chloride, ethylene dichloride, benzene, 1,1,2-trichloroethane, 1,1,2,2-tetrachloroethane, and 1,1,1,2-tetrachloroethane. The tetrachloroethanes have not previously been evaluated at Unit I. Monitoring for benzene was conducted as part of the 1989-90 protocol year; however, the data was inconclusive and the monitoring needs to be repeated. A few samples were collected in 1992 to evaluate exposures to benzene; however, the study will be completed as part of the 1993-95 Occupational Health Program. Both 8-hour time-weighted average (TWA) and short-term monitoring will be conducted. Texas Operations Hearing Conservation Guidelines requires that a noise survey be conducted every three years. The previous noise survey at Unit I was conducted in 1991. A comprehensive area and personal noise survey will be conducted in 1994. 2. SAMPLING STRATEGY A. 8-Hour TWA Chemical Monitoring Job Classification'1 Chemical2 Number of Samples Process Technician-OXY, BPR, VF, l&E Process Technician-DC, VD Process Technician-LD Process Technician-R Process Technician-Lab Mech. Tech. Specialist Pipefitter/Contractor Machinist/Contractor VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2; 1,1,2,2; 1,1,1.2, Benzene VI VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 6/area 6 Quarterly 6 3 3 4 3 1 OXY-oxychlorination, DC-direct chlorination, 8PRby-product recovery, VD=vinyl distillation, VFvinyl furnace, l&E-instrument & electrical, LD-loading, R-repair. 2 VI - vinyl chloride; EDC = ethylene dichloride; 1,1,2 - 1,1,2-trichloroethane; 1,1,2,2 = 1,1,2,2-tetrachloroethane; 1,1,1,2 = 1,1,1,2-tetrachloroethane. C O N F ID E N T IA L R&S 154069 IHS Fite #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Paga2 MONITORING PROGRAM (CONT.) B. Job Task Monitoring Job Task Area Chemical Number of Samples Process Sampling Process Sampling Filter Changing Waste T/T T/C Sampling T/C Hookup T/C Disconnect C. Noise Monitoring All areas DC DC BPR Loading Loading Loading VI; EDC; 1,1,2; 1,1,2,2; 1,1,1,2 Benzene EDC VI; EDC VI VI VI 3/area 3 3 3 quarterly quarterly quarterly Job Classification Number of Samples Process Technician-OXY.DC BPR, VD, VF, l&E Process Technician-LD Process Technician-R Process Technician-Lab Mech. Tech. Specialist Pipefitter/Contractor Machinist/Contractor Painter/Contractor 6/area 4 8 3 4 4 4 4 3. SAMPLING METHODS Sampling tor vinyl chloride, ethylene dichloride, 1,1,2-trichloroethane, 1,1,2,2-tetrachloroethane, 1,1,1,2-tetrachloroethane, and benzene will be conducted using 1 gram charcoal tubes and air sampling pumps. Pumps will be calibrated both before and after use at 50 cc/min for 8-hour TWA samples and 200 cc/min for excursion samples (as outlined in DLI-IHM-83-25A). Analysis will be performed by the Industrial Hygiene Laboratory. Personal noise levels will be measured using Quest noise dosimeters (Model M-7B) and area noise levels will be measured using a Quest noise level meter (Model 215). All dosimeters and meters will be calibrated both before and after use. 4. QUALITY CONTROL AND EQUIPMENT Routine quality control procedures shall be an integral part of the sampling and analysis procedures and functions. These shall include: a. Routinely introduced sampling of blanks and spikes (known content) along with other samples for analysis b. Routine checking, calibrating, and maintaining in good working order all equipment and instruments. Air sampling pumps will be calibrated both before and after use. c. Routine checking of procedures and results. d. Participation in Dow's Analytical Proficiency Testing (APT) Program. &u> CD o o C O N F ID E N T IA L IHS Fite #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 MONITORING PROGRAM (CONT.) Page3 5. EVALUATION CRITERIA Aoani Exposure Excursion Guideline___________GuMfi______________ Source* Vinyl Chloride Ethylene Dichloride 1.1.2-trichloroethane 1.1.2.2-tetrachloroethane 1.1.1.2-tetrachloroethane Benzene Noise 1 ppm 10 ppm 1 ppm 10 ppm, Skin 0.1 ppm, Skin 0.1 ppm 1 ppm 90 dBA (8-hr TWA) 85 dBA (8-hr TWA 5 ppm-STEL 2 ppm 5 ppm-STEL 90 dBA-Ceiling OSHA-PEL ACGIH-TLV Proposed OSHA-PEL ACGIH-TLV DowlHG DowlHG OSHA-PEL DowlHG OSHA-PEL OSHA-Actidn Level * OSHA-PEL = Occupational Safety and Health Administration-Permissible Exposure Limit ACGIH-TLV = American Conference of Governmental Hygienists-Threshold Limit Value Dow IHG = Dow Industrial Hygiene Guideline C O N F ID E N T IA L B&S154071 IHS Rla #00*4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 REVIEW OF PAST MONITORING DATA Page 4 A. CHEMICAL REPORTS: TABLE 1 SUMMARY OF 8-HOUR TIME WEIGHTED AVERAGE EXPOSURES, 19891 JOB CLASS/CODE #0f SAMPLES Process Technician: Oxychlorination/ 127005800X 4 Direct Chlorination/ 12700580DC 7 Vinyl Distillation/ 12700580/VD 7 Vinyl Furnace/ 12700580VF 4 By-Product Recovery/ 12700580BPR Loading/ 12700580LO 4 10 Repair/ 12700580R 4 Contractor/Utility Man 2 Acceptable Guideline (8-hour TWA): CONCENTRATION (PPM)*--* VINYL CHLORIDE ETHYLENE DICHLORIDE RANGE AVE RANGE _ AVE_____ ND ND-0.19 ND-1.1 ND-0.16 ND-0.14 0.47-1.6 ND-0.24 0.07-0.10 ND ND-0.07 0.06 0.10 ND-0.44 0.25 0.40 0.05-0.24 0.11 0.09 ND-0.31 0.18 0.09 0.04-0.30 0.14 0.94 ND ND 0.17 ND-0.54 0.36 0.09 0.26-3.2 1.7 1 1** Reference: Blue, M. A, Evaluation of Employee Exposures to Chlorinated Hydrocarbons at the Unit 1/ Vinvl Chloride Plant. Ovster Creek- 1989. IHS Rle OC-3138-89C. Ethyl chloride, 1,1,1-trichloroethane, 1,1,2-trichloroethane, and carbon tetrachloride were also monitored however all samples were less than 5% of their respective IHG's 3- ND non-detectable; detection limits are as follows: vinyl chloride = 0.07 ppm; ethylene dichloride = 0.04 ppm 4- The guideline for ethylene dchloride (EDC), an OSHA PEL when the study was completed, is now considered a proposed PEL The current ACGIH-TLV for EDC is 10 ppm . Quarterly personnel monitoring was conducted in 1990-92 to evaluate Loading Technician exposures to vinyl chloride during tank car off-loading activities (IHS File OC-3652 and OC-3951). In 1990, the average 8-hour TWA exposure for Loading Technicians was 1.7 ppm. In 1991, due to adjustments to the laboratory hood and purge times, the average exposure was reduced to 0.69 ppm. In 1992, exposures averaged 0.62 ppm. As average exposures continue to exceed the OSHA Action Level of 0.5 ppm, quarterly personnel monitoring will continue to be conducted. Exposures are considered potential as full-face air-purifying respirators with canisters approved for use with vinyl chloride are used during tasks with a significant potential for exposure above the guidelines. C O N F ID E N T IA L r&s i 54072 IHS File #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT IA/INYL CHLORIDE, OC-101 Pages REVIEW OF PAST MONITORING (CONT.) In 1990 and 1991, short-term personnel exposures to hydrogen chloride, vinyl chloride, and ethylene dichloride (EDC) were monitored during furnace maintenance activities (IHS File OC-3702). Average personnel exposures were less than the acceptable guidelines with the exception of EDC. Average exposures to EDC at 7.4 ppm during top 90 removal and 5.7 ppm during let down valve removal exceeded the Short-term Exposure Limit for EDC of 2 ppm. Respiratory protection was used during top 90 removals. In October, 1991,8-hour TWA exposures to vinyl chloride and ethylene dichloride were evaluated during plant shut-down activities (IHS File OC-3866). Exposures were within acceptable limits the exception of EDC for a Process Technician in the Direct Chlorination area, two contractors in the furnace area, and one contractor working on the chilled EDC unit. Exposures were considered potential as fullface airline respirators were used whenever there was a significant potential for exposures above the guidelines. Employee exposures to sulfer dioxide during sodium bisulfite tank truck unloading were evaluated in 1991. Area samples collected after opening the dome ranged from 50 to 100 ppm which exceeds the short-term exposure limit for S02 of 5 ppm. As a result of this data, a nitrogen regulator was installed and the sodium bisulfite trucks are now padded with nitrogen which eliminated the need to open the dome. Hexachlorobenzene (HCB) wipe testing was performed in selected office and process areas in Unit 1. Areas of the plant that were identified as having higher levels of HCB were cleaned by hydroblasting and followup monitoring was conducted. HCB wipe testing will be conducted periodically to insure levels stay within acceptable limits. C O N F ID E N T IA L R&s 154073 IHS File #004905 B. NOISE REPORTS: 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, 00101 REVIEW OF PAST MONITORING (CONT.) Page 6 TABLE 2A SUMMARY OF 12-HOUR TWA NOISE EXPOSURES, 19911 JOB CLASS/ JOB CODE # OF SAMPES % OF OSHA ALLOWABLE RANGE AVE. Process Technician: Direct Chlorination/ 12700580DC 6 7.0-52 26 Byproduct Recovery/ 12700580BP 6 17-93 44 Oxychlorination/ 127005800X 6 27-52 39 Vinyl Furnaces/ 12700580VIF 6 18-130 44 Vinyl Distillation/ 12700580VD 6 18-78 47 OSHA PEL OSHA Action Level 100 50 ^ Reference: Blue, M. A.^1991 Personal and Area Noise Levels at Unit 1/Vinvl Chloride. Ovster Creek. QC-101 IHS File OC-3700-90N. C O N F ID E N T IA L R&S154074 IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, 00101 Page7 REVIEW OF PAST MONITORING (CONT.) TABLE 2B SUMMARY OF 8-HOUR TWA NOISE EXPOSURES, 19911 JOB CLASS/ JOB CODE Process Technician: l&E 12700580VD Repair/ 12700580R Loading/ 12700580LO Sr. Technician/12700004: Unit Technician-Training/ 12700780: Process Technologist/12600580 Mechanical Technologis/12606980t Mechanical Supervisor/01203800 Supervisor/02400580 Service Technician/12903410 Contractors: Pipefitter/ 20910120C2 # OF SAMPES 6 7 4 7 3 4 5 1 1 3 4 % OF OSHA ALLOWABLE RANGE AVE. 0.4-39 1.5-61 1.7-12 13-69 4.0-67 7.0-16 4.7-17 6 5 9.7-68 20-54 20 28 4.8 23 30 13 12 6 5 32 36 OSHA PEL OSHA Action Level 100 50 1. Reference: Blue. M. A.. 1991 Personal and Area Noise Levels at Unit 1/Vinvl Chloride. Oyster Creek. QC-101 IHS File OC-3700-90N. CO NFIDENTIAL R&S154075 IHS File #OC-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Page 1 HEARING CONSERVATION PROGRAM 1 . JOB CLASSIFICATIONS IN A HEARING CONSERVATION PROGRAM The date of the last noise survey was June - July, 1991. The survey included both area noise levels and personal job exposure evaluations. Average equivalent noise exposures for all monitored job classifications were less than the OSHA Action Level of 50%. Therefore, these job classifications are not required to be in the Hearing Conservation Program. 2. TRAINING Training should be conducted at least every 2 years. 3. HEARING PROTECTION AREAS The following areas are designated as required hearing protection areas since they are at or above 90 dBA. These areas are posted with signs requiring hearing protection. 1. Compressors throughout the plant including PC-300, DC-300, C-350, C-300, C-204, C-103, C-104, C-30, and C-402 2. Fin fans in the Direct Chlorination area 3. Control valves near T-260 and D-28 4. Pumps throughout the plant including P-270B, P-267B, P-200B/C, P-311, P-313, P-350B, P-500, P-7A/B 5. Re-heater blowers between F-202 & F-203 6. Between R-100 & R-101 7. Generator G-12 8. D-301 9. Shop tool (grinders, drill press, air arcing, pipe threader) 10. Tow motors, cherry picker, trackmobile 11. Steam release The following areas are designated as hearing protection areas for both plug and muffs since they are at or above 105 dBA. These areas are posted with signs requiring both plugs and muffs. P-500 hurricane pump, when operating 4. HEARING PROTECTION TYPES Hearing protection devices utilized at this department need to have a NRR rating over 19 dBA. Some of the devices available in the plant are: DEVICE E-A-R plugs Bilsom Viking Ear Muffs #2314 Wilson Sound Ban #20 Howard Leight Max-1 Foam Ear Plugs Howard Leight Max-1 Foam Ear Plugs w/cord E-A-R Caboflex #600 NOISE REDUCTION RATING (dBA 29 25 19-22 33 33 22 Other devices are available through plant supervision or the Occupational Health Department. C O N F ID E N T IA L CJ1 o -045 IHS Fils #OC-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE. OC-101 Page 2 HEARING CONSERVATION PROGRAM (Continued) 5. NOISE ABATEMENT PLAN There are currently no noise abatement plans at this time. Any new equipment or changes to the process, will be evaluated for noise and when feasible, engineered to keep noise levels below 85 dBA. Temporary jobs that have equipment with noise levels at or above 90 dBA require temporary signs and mandatory use of hearing protection anytime the equipment is in operation. This includes such areas as sandblasting, hydroblasting, use of portable air compressors and hand tools. 6. NEXT REVIEW DATE: April, 1995 C O N F ID E N T IA L ID 9C/3 cn o IHS Hie #00-4906 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Page 1 REDACTED ASBESTOS PROGRAM 1. INVENTORY Asbestos is contained in this block in the following forms : insulation gaskets transite pump packing An inventory of all asbestos containing materials and their respective locations is attached. The inventory must be maintained until the materials have been removed. Labeling of asbestos is by block signs located at entrances to the block. 2. INSPECTION SCHEDULE Asbestos containing materials will be inspected annually by ^,Senior Technician/Repair) for signs of deterioration. If deterioration Is found the material will be repaired or removed. In th.e event removal is required insulation services will be contacted for assistance. Removal and disposal will be according to appropriate procedures as outlined in the Texas Operations Asbestos Handbook (TOAH). Questions may arise at the time of removal of insulation or at the time of the annual inspection as to whether a particular piece of equipment contains asbestos or not. If this situation arises, the material will be sampled and sent to analytical services to be analyzed. 3. TRAINING The following job classifications are identified as having potential to handle asbestos containing materials and should be trained according to Section VII of the TOAH. Process Technician Unit Technician Senior Technician All individuals in the above job classifications will be trained before initial assignment and annually thereafter. Training will be documented and forwarded to Industrial Hygiene Services for inclusion in the plant's Industrial Hygiene files. 4. RESPIRATOR CERTIFICATION ~ For those jobs that require a respirator, an approved respirator will be chosen and mandatory medical certification and fit tests completed before initiation of the job. If exposure exceeds the Action Level (0.1 f/oc), the employee must be fit tested semi-annually and have annual medical examinations. Currently there are no employees at Unit I that require medical surveillance for asbestos. 5. PROCEDURES Written procedures have been developed for the handling of asbestos materials during the performance of maintenance, demolition, and renovation activities to be conducted at the facility. The procedures are located in the Repair Office. 6. ASBESTOS ABATEMENT PLANS All forms of asbestos containing materials are being phased out as replacemant is warranted. 7. NEXT REVIEW DATE: April, 1995 C O N F ID E N T IA L IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT t/VINYL CHLORIDE, OC-101 VENTILATION PROGRAM 1 . PROGRAM DESCRIPTION The Unit I ventilation system includes as follows: ID Nurrber Location Last Survey Next Survey Average Velocity OCIOIOI (Env) OC-101 OC10102 (Vinyl) OC-101 OC10103 (BPR) OC-101 OC10104 (Main) OC-101 OC10107A(DC) OC-101 OC10107B (Dev) OC-101 OC90101 OC-901 6/92 6/92 6/92 6/92 6/92 7/92 4/93 6/95 6/95 6/95 6/95 6/95 7/95 4/96 94 131 111 90 93 129 113 The hoods in are equipped with make-up air and are separately ducted to the outside. 2. OPERATING CRITERIA A. Periodic Performanca Evaluation and Maintenance Programs -Administered by Industrial Hygiene Services and lab personnel at Unit I. B. Laboratory Fume Hood Performance Criteria -Utilize marked static pressure manometers to provide direct readouts and fall under the quarterly inspection guidelines. 3. DOCUMENTATION The Industrial Hygiene Contact for Unit I is responsible for maintaining documentation on hood surveys and inspections. 5. NEXT REVIEW DATE: April, 1995 C O N F ID E N T IA L c93n3 c-pnt o CO IHS Rle #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Page 1 ERGONOMICS PROGRAM 1. INTRODUCTION The plant ergonomics program is dependent on the work situation and other specific factors which contribute to musculoskeletal injuries. At this time, ergonomic concerns will be handled on a case by case basis by plant personnel with assistance from the department's Industrial Hygienist. 2. MANUAL LIFTING ACTIVITIES Job Activity 1. Recharging W-261 caustic pots 2. Repacking/recharging W-2's & W-7's 3. Adding iron chloride to D-8 Frequency Biennally Biennally Quarterly Weight 50 lb 501b 35 Ibfiberpacks REPETITIVE MOTION/FORCEFUL EXERTIONS none identified 4. POWER TOOL USE Power tools used in Unit I include hand drills, portable grinders, impact wrenches, a drill press, and pipe threaders. The frequency and duration of use for each varies depending on the nature of the job. 5. TRAINING Basic training on the identification of ergonomics factors is recommended for all block employees on a periodic basis.6 6. NEXT REVIEW DATE: April, 1995 C O N F ID E N T IA L r &SI 54080 IUS Fite #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE. OC-101 Page 1 HEAT STRESS PROGRAM 1 . HEAT STRESS INVENTORY The plant heat stress program is dependent upon the work situation and other specific factors which would generate excessive heat for the employee. The two factors to be considered are environmental temperatures and heat build-up due to the activity level of the employee. Based on previous heat stress studies, work/task evaluations, hot process operations and/or use of personal protective equipment such as impermeable suits, the following are identified as potential heat stress problems: Outside manual labor with or without chemical protective clothing 2. TRAINING The following job classifications are identified as having potential for heat stress and should be trained in the recognition, prevention and treatment of heat stress: 1. Process Technician 2. Unit Technician 3. Senior Technician Heat stress training should be conducted every 2 years at a minimum. 3. HEAT STRESS ABATEMENT The following drinking fluids are available for fluid replacement: 1. Water 2.Gatorade The following checked personal protective equipment for the prevention of heat stress is available at this plant: 1. Ice vests Recommended work practices for reduction of heat stress include: 1. Fluid replacement 2. Seif-paced work 3. Scheduling 4. Acclimation 4. WORK REST SCHEDULE The heat stress prevention work/rest schedule for jobs requiring impermeable clothing is as follows:5 Temperature (F) 72-79 80-87 88-? Maximum Stay Time fmin.t 40 30 20 5. NEXT REVIEW DATE: April, 1995 Minimum Rest Time fmin.i 20 30 40 C O N F ID E N T IA L P&S154081 IHS File #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE, OC-101 Pagel HEALTH SURVEILLANCE PLAN 1. HEALTH SURVEILLANCE All employees are offered core examinations every two years. 2. MEDICAL SURVEILLANCE REQUIREMENTS The following job classifications are included in the MSR programs as identified below: Job Classification MSR Tests Test Frequency Process Technician, Unit Technician, Proc. Tech. Trainee Vinyl Chloride Health history, physical measurements, blood chemistries, (hepatic), hands on physical Annual Vinyl Chloride (10 +years) same as above Semi-annual 3. DOCUMENTATION Results are reported individually and in group format to area supervision. C O N F ID E N T IA L n aAocot ro IKS File #004905 1993-05 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE. OC-101 REDACTED INDUSTRIAL HYGIENE EDUCATION PROGRAM 1. INTRODUCTION Training will be documented using the forms located in the Training Guidelines" section of the facility's Industrial Hygiene Manual. The original documentation will be sent to Industrial Hygiene Services at B-101 for filing in the plant compliance files. 2. TRAINING PLANS - CHEMICALS The Industrial Hygiene Education Program will focus on the following key agents for 1993/94: 1993 Vinyl Chloride Benzene Ethylene Dichloride Ethylene Oxide Betz Additives Refractory Ceramic Ffoer 1994 Vinyl Chloride 1.1,2,2-Tetrachloroethane Benzene Chlorine Carbon Tetrachloride 3. RESPIRATORY PROTECTION TRAINING Unit I will follow the guidelines defined in the Plant's written respirator program (located in the Industrial Hygiene Manual). Annual training is required. 4. CHEMICAL SURVEY RESULTS A report of the results of sampling conducted in accordance with this protocol will be written and communicated individually and in a group session. ~ 5. HAZARD COMMUNICATION TRAINING All new employees shall review and document with signatures: a. hazard communication videos (2) -- b. the facility's hazard communication program c. health hazard information for all materials with Priority Rating of 1,2, or 3 (see CPAI) d. health hazard information for OSHA regulated chemicals with a Priority Rating of 1.2,3" or 4 e. health hazard information for the key agents listed above See the plant's written Hazard Communication program in the Hazard Communication section (Section 10) of the facility's Industrial Hygiene manual for other training requirements. Any temporary employees shall review and document: b, c, d, e. 6. ASBESTOS TRAINING All personnel whose only potential for exposure to asbestos is accidental disturbance including but not limited to office personnel, engineers, supervisors, and some operations/maintenance personnel must receive Asbestos Awareness training on initial assignment and at least every 2 years thereafter. Employees involved in general maintenance and repair tasks where asbestos may be handled on a smallscale short-duration basis as an occasional or routine part of their Jobs (ie., removal of asbestos gaskets with mechanical methods) must receive Asbestos Operations and Maintenance training initially and annually thereafter. Consult the Texas Operations Asbestos Handbook for training requirements. C O N F ID E N T IA L R&S154083 IHS Fite #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Page 2 INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.) 7. NOISE TRAINING Noise training (or Unit I is required every 2 years at a minimum. Refer to the Hearing Conservation Manual for training requirements. 8. NEW CHEMICAL TRAINING Per HAZCOM all employees to be potentially exposed to a new chemical must be trained on the hazards of that chemical and the approved protective equipment. Signatured documentation is required at the time of this training, to include MSDS, TIME sheet, or hazard data used. 9. RADIATION TRAINING Per the Radioactive Material license issued to Texas Operations, all persons working in areas with radioactive sources are to be trained on: a the hazards of radiation b. signs and labelling requirements c. emergency procedures d. inspection requirements e. personnel monitoring (if required) f. approved procedures (use, close-out, transport, etc.) 10. HEAT STRESS TRAINING Personnel performing jobs (eg. chemical suit in the summer) that may lead to heat stress are to be trained on heat stress avoidance procedures. This training is recommended for new employees and a minimum of every 2 years for experienced employees. 11. PROTECTIVE EQUIPMENT TRAINING Per 29 CFR 1910.132 protective equipment shall be provided, used and maintained for employees with potential for exposure to environmental or process hazards. Personnel are to be trained on the proper use and limitations of protective equipment upon initial assignment, after major job changes, and periodically. Consult the Texas Operations Personal Protective Equipment Program Manual for training guidelines. 12. VENTILATION SYSTEM TRAINING Personnel that use ventilation systems (incl. hoods, dust and chemical ventilators) are to be trained in the use, maintenance and documentation requirements. Hood requirements are covered in the Texas Operations Ventilation Manual. 13. HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE Training must enable the employees to perform their job in a safe and healthful manner so as not to endanger themselves or others. Training topics include respiratory protection, hazard communication, health hazards training, protective equipment, safety standards/references, job procedures, RCRA, hearing conservation, eye protection, emergency procedures and unit specific rules. 33 C/3 oi -fc* C O N F ID E N T IA L IHS File #OC~4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101 Page 1 RESPIRATORY PROTECTION PROGRAM 1. INTRODUCTION Information regarding Dow respiratory protection programs is located in the Texas Operations Respiratory Protection Manual (RPM). The RPM addresses selection, use, fit testing, medical approval, training, maintenance, records, administration and recommended respirators. Responsibilities for employees, supervisors, industrial hygiene, authorized repair/maintenance facility, central purchasing department and medical department are detailed in the RPM. 2. TYPES OF RESPIRATORS USED Respirator Type AOR9722 Mouthpiece1 Scott 90-AG Mouthpiece Scottovista #801548-04 full face airline Scottoramlc full face airline Scottovista full face air-purifYinq 3M half-face ELSA 5 min. Pack Survivalr 30 min. SCBA XL 301 Scott Air Pack 2.2 Survivair 5 min. SCBA Pack 9881 -221 Scottovista Ska-Pak 3M 8710 Dust Mask MSA Ultravue Cartridges, Filters, Canisters OVAG (R722)2 Acid Gas Cylinder Cylinder HEPA/OVAG3 HEPA 5 min. air tank 30 min. air tank 30 min. air tank 5 min. air tank 5 min. air tank NA Canister (461480)4 Filter Change-Out Policy After use or every 6 months After use or expiration date NA NA After each use After each use Fire Dept, refill Fire Dept, refill Fire Dept, refill Fire Dept, refill Fire Dept, refill After each use End of shift C O N F ID E N T IA L 1 These respirators are gradually being phased out. 2 The OVAG is NIOSH approved for Organic Vapors and Acid Gases. 3 HEPA - High Efficiency Particulate Air-Purifying. 4 This canister is approved for use with vinyl chloride. 3. RESPIRATOR USE CATEGORIES Job Classification Office Personnel Process Personnel, Lab Personnel User Category Escape Only Routine/Emergency& Escape Resp. Types Used MP, ELSA All available in Unit Individually Issued MP MP MP = AOR9722 or Scott 90-AG Mouthpiece respirator Routine/Emergency users are medically approved and fit tested every two years. Training for all respirators is conducted annually by a plant representative. Visitors, contractors and employees are required to carry an escape respirator on their person while in Unit 1 process areas. The escape respirator is an AOR 9722 MP or Scott 90 AG. IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101 RESPIRATORY PROTECTION PROGRAM (CONT.) Page 2 4. USE SITUATIONS Respirator Tvoe/Fllter Airline ELSA 30 min. SCBA 5 min. SCBA MSA Ultravue Air Durifvino/HEPA (Half or full) Air purifvino/OVAG (Full face) Dust mask Chemical of Concern Use Situation All chemicals Line or equipment opening that cannot be cleared < acceptable auidelines All chemicals Escape All chemicals Emergency response All chemicals Escape Vinyl Chloride Tank car samplinq/hook-up Refractory Ceramic fiber Furnace maintenance EDC. HCL Sampling in Oxy area Silica, alumina-copper chloride, Sandblasting, catalyst addition Gunite dust 5. RESPIRATOR CLEANING STATIONS The cleaning station is located in the Safety Supply room. After each use respirators are cleaned with soap and water and disinfected with a spray antiseptic or by wiping with antiseptic towelette. Before storage, respirators are dried with paper towels or allowed to air dry. SCBA's are sent to the authorized repair/maintenance agent for cleaning after each use. Contaminated respirators and cartridges which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.6 6. RESPIRATOR STORAGE Respirator MP ELSA SCBA (30 min.) SCBA (5 min.) Airline masks Air purifyinq MSA Ultravue Dust masks Storage Location Offices or personal lockers Cabinets in process area and computer room; racks in offices Cabinets throughout plant Cabinets in control room Storaqe cabinet in supply room or personal lockers Respirator cleaninq room cabinets Cabinets in off-loading control center Safety supply room All respirators must be stored in secondary containers such as a plastic bag or storage box. Spare parts for the disposable MP are stored in the safety supply room. All other equipment must be sent to the Fire Department for repair. C O N F ID E N T IA L DcO C/3 CJ1 o 00 IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101 Page 3 RESPIRATORY PROTECTION PROGRAM (CONT.) 7. INSPECTION SCHEDULE Respirator Airline Full face air-purifying Half face air-purifvina ELSA SCBA MP Frequency Before each use Annually Before each use Annually Before each use Before each use Weekly Annually Before each use Weekly Annually Before each use Annually Inspected By User Fire Department User Fire Department User Owner Plant Rep Fire Department Owner Plant Rep Fire Department Owner Owner Documentation Retained Bv none Fire Dept. none Fire Dept. none none Plant Rep Fire Dept. none Plant Rep Fire Dept. none none 8. BREATHING AIR COMPRESSOR This block has no breathing air compressors, the only source is from bottles which have been pre checked for oxygen content and markings. 9. DOCUMENTATION Documentation of annual SCBA and ELSA inspections are maintained by the fire department. Documentation of all other formal inspections, fit testing, and training are maintained by the area supervisors. Training documentation with original signatures are sent to the plant industrial hygienist at B-101 for placement in the plant's 75 year compliance file. The Unit Manager and the Occupational Health Department maintain the medical approval list on file. .10 NEXT REVIEW DATE: April, 1995 C O N F ID E N T IA L 33 to OCAJ1 CnDI IHS File *004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101 Page 1 PERSONAL PROTECTIVE EQUIPMENT PROGRAM 1. INTRODUCTION: Information regarding the Texas Operations personal protective equipment (PPE) program is located in the Texas Operations PPE Program Manual. The manual addresses program administration, approval procedures, testing requirements, selection, use and maintenance, decontamination, laundering, training, records, and program evaluation. Responsibilities for employees, supervisors, industrial hygiene, safety, purchasing, the Texas Operations Protective Equipment Team, and the Texas Operations Protective Equipment Supplier Partnership Team are detailed in the manual. 2. SELECTION: See Table 1 for a listing of approved PPE for the Unit I/Vinyl Chloride plant. PPE selection was based upon the health and safety hazards associated with the site or job tasks. All PPE has been reviewed by the Unit I Industrial Hygienist and Safety Director and has been approved for use by the Texas Operations Protective Equipment Team. 3. TRAINING: Training on user responsibilities, PPE inspection, use, donning, doffing, decontamination, limitations and the location of the Unit I/Vinyl Chloride PPE program is conducted for Dow employees and long-term contractors upon initial assignment and biennially thereafter. This training is documented. Visitors are informed of and provided the minimum PPE required in the Unit I/Vinyl Chloride plant. 4. INSPECTION: All PPE items must be inspected visually before, during and after use for signs of deterioration, defects, damage, etc. However, the PPE items listed below shall be inspected according to the following minimum frequency and specific test protocol: EPE Item Test Method Ereauencv Totally encapsulated suits (emergency response) Visual Inspection/Pressure Test Monthly Dept. Rep. Chemical protective gloves (high hazard operations) Electrical rubber gloves Electrical rubber blankets Dielectric rubber boots Air test method High voltage test Air test method High voltage test High Voltage test Each use Semi-annual Each use Biannually Each use User Elec Shop User Elec Shop User C O N F ID E N T IA L n9U> cn OOS CD IHS Rle #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101 Page 2 PERSONAL PROTECTIVE EQUIPMENT PROGRAM (CONT.) 5. DECONTAMINATION AND DISPOSAL: The Unit I/Vinyl Chloride decontamination stations are located in the following locations: Safety shower tail hoses throughout the process area 2 shower nozzles in the D-36 and oxy-analyzer building area After each use where PPE has been contaminated by hazardous substances, users of the contaminated PPE shall use one of the above listed decontamination stations and clean their PPE by rinsing with copious quantities of potable water. Before storage, the PPE is air dried. Contaminated PPE which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards. 6. MAINTENANCE: No clothing or chemical protective suits are repaired in this department. Defective or damaged equipment is discarded. 7. LAUNDERING: A washer and dryer is located in the boiler room. Cotton gloves and Nomex suits are cleaned by ARA laundry services. Material Safety Data Sheets are sent to ARA when it is suspected that the clothing items sent may be contaminated. 8. STORAGE: The following lists where PPE is stored when not in use: a. OC-101 change room b. Loading area control center c. Lockers in OC-101 repair area d. New PPE is stored in the Safety Supply room in OC-101 9. PROGRAM EVALUATION: This program shall be evaluated biennally or whenever there are major job or process changes that require a re-evaluation of the PPE currently in use. NEXT REVIEW DATE; April, 1995 C O N F ID E N T IA L 33 C/3 0A1 o 0(O3 IHS File #004905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101 Page 3 TABLE 1 UNIT l/VINYL CHLORIDE PPE INVENTORY, 1993 The following lists the approved PPE for the Unit l/Vinyl Chloride plant. Unit I written job procedures indicate when and which PPE items must be worn for specific job tasks. A. HAND PROTECTION 1. Edmont #29-865 neoprene rubber gloves 2. Pioneer AF-18 nitrile butadiene rubber gloves 3. North #E214B dielectric natural rubber gloves 4. Scooba #JPS 10B cotton gloves 5. Stringer/Norton Leather gloves 6. Rsher Scientific vinyl disposable 7. PVC Dot, Cotton general purpose (Take Two) B. FOOT AND LEG PROTECTION 1. Servus 22114 and 21629 natural rubber boots 2. Lehigh #1149 dielectric natural rubber boots C. EYE, FACE AND HEAD PROTECTION 1. Jackson 24-40 Faceshield for welders 2. MSA Hard Hat 3. Sideshields - American Optical 4. Chemical goggles -Allsafe #211-1 OR D. BODY PROTECTION 1. Nomex III coverall 2. Nomex III Switchman Flash Suits E. RESPIRATORY PROTECTION 1. Self-Contained Breathing Apparatus - Survivair30 min, SCBA XL-30, Model 9838-9 or Mark I Model 9845-2 (being phased out) - Survivair 5 min. SCBA Pack 9881-22 (being phased out) - Scott Air Pack 2.2 2. Airline Respirators - Scottoramic full face - Scottovista full face 3. Air-Purifying Respirator - 3M 6000 series half face - Scottovista full face - MSA Ultraview - 3M8710 4. Escape Respirator - AO Mouthpiece R9722 with organic vapor/acid gas cartridge (being phased out) - ELSA 5 min. Pack - Scott 90 AG - Scottovista Ska Pak F. HEARING PROTECTION 1. Caboflex # 600 Sound Ban (NRR=22) 2. E-A-R Foam Ear Plugs (NRR=29) 3. Bilsom Viking Ear Muffs #2314 (NRR=25) 4. Wilson Sound Ban #20 (NRR=19-22) 5. Howard Leight Max-1 Foam Ear Plugs with or without cord (NRR=33) G. FALL/RESCUE PROTECTION 1. RTC 430 Body Harness 2. RTC 252 Lanyard C O N F ID E N T IA L R & S 154090 IHS File #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 1A/INYL CHLORIDE, OC-101 RADIATION PROGRAM 1 . RADIOACTIVE SOURCES Radioactive sources currently in use at Unit I are as follows: Source Number 0743 0744 0745 0746 0747 0748 0749 0792 0793 2. TRAINING: Isotope Cesium 137 Cesium 137 Cesium 137 Cesium 137 Cesium 137 Cesium 137 Nickel 63 Cesium 137 Cesium 137 Activity (mCi) 200 100 100 100 200 200 8 100 100 Location Acid to V-60 Acid to Unit II T-111 bottoms T-400 bottoms T-116 bottoms T-110 bottoms Varian 3700 GC D-35 D-35 In accordance with the Texas Radiation Control Act and Texas Department of Health, only trained personnel are allowed to handle or operate devices with radioactive material. Training should be done by a qualified person and documented, with the original documentation forwarded to the radiation compliance files. At Unit I the following personnel have been trained: ' 3. INSPECTIONS: -- A semi-annual inventory check is required in February and August in which the location, labels, sign, and condition are inspected. In May and November, in addition to the above, the posting, a wipe test, leak test, shutter check, shielding and source condition are also inspected and documented, or I ' is responsible for conducting the inspections. The GM radiation meter used for surveys at Unit I is located in I annual meter calibration program. office and is in the -- 4. SOURCE REMOVAL: Sources are not to be removed from the work area or worked on without notifying the Radiation Safety Officer. 5. EMERGENCY NOTIFICATION: In case of emergency, the Radiation Safety Officer or his back-up should be notified as soon as possible. 6. NEXT REVIEW DATE: April, 1995 REDACTED C O N F ID E N T IA L 393 C_c/kn3. Old IHS File #004905 Direct Chlorination: 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE, 00101 DEPARTMENT ACTIVITIES Oxvchlorlnatlon: Vlnvl Furnaces: Bv-Product Recovery: C O N F ID E N T IA L g n H M O u8 CO cn o<roo IHS Rle #004905 Vlnvl Distillation: 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE, 00101 DEPARTMENT ACTIVITIES (CONT.) Page 2 Repair: I Lab: Loading: O > R&S154093 IHS File #OC-49Q5 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT IA/INYL CHLORIDE. OC-101 JOB DESCRIPTIONS Unit Manager. Unit Secretary. Sr. Clerk Typist: The probability of personnel in these job classifications of experiencing a significant exposure to chemical and physical stresses in the plant is low as the majority of their time is spent in office areas. Process Technician - oxvchlorlnatlon. vlnvl distillation, vlnvl furnaces, direct chlorination: Technicians in these areas are responsible for operating and maintaining the process streams in their respective areas. Duties include field and control center operation of these systems, minor maintenance when needed, and the collection and processing of routine lab samples from their respective areas. Estimated time distribution while in process is 10% labwork, 30% in the control center, and 60% in the field. Twenty percent annually of the Technician's time (2 weeks out of every ten) is spent as a Maintenance Technician in Repair. Senior Technician: The Senior Technician is responsible for control center operations and communications from within the control room. He assists other Process Technicians in controlling, troubleshooting, and emergency operation of respective areas. 100% of the Senior Technicians time is spent in the control room. Process Technician - Loadlnn: The Loading Technicians are responsible off-loading vinyl chloride tank cars, maintaining appropriate VCM supplies to customers, and minor maintenance as required. All VCM samples from the storage spheres and tank cars are caught and analyzed by the Loading Technicians. Estimated time distribution is 10% lab work, 25% on the laoding racks, 50% on other field activities, and 15% in offices. Process Technician - Bv-Product Recovery: The BPR Technician operates and maintains the plant's waste disposal systems. These include a thermal oxidizer, a waste incinerator, waste water, and ethyl chloride systems. Responsibilities include field and control center operation of these systems, minor maintenance, and sampling/analysis of lab samples from the BPR area. 20% annually of the BPR Technicians time is spent as a maintenance technician in repair. Estimated time distribution while in process is 10% lab work, 25% in the control center, and 45% in the field. Process Technician - Laboratory; The Lab Technician operates and maintains all of the plant's on-stream analytical equipment, manual sample collection loops, and in-house lab equipment. Lab Technicians also provide production support by way of special analysis for process development, trains operations personnel on lab procedures, and maintains the lab inventory. Estimated time distribution is 65% lab work, 15% in the office, and 20% in the field. Process Technician - Instrument & Electrical. I&E Technician: The l&E Technician installs, calibrates, maintains and repairs the plant's process instrumentation and electrical equipment. Estimated time distribution is difficult due to the varying natures of particular tasks, but an average would be 40% in the field, 20% in the control center and electrical panel rooms, and 40% in the l&E shops and offices. Process Technician - Training: These job classifications are responsible for coordinating and updating all phases of the plant's employee training program, both on the job and classroom sessions. Estimated time distribution is 50% in the field and 50% in the office. Process Technician - Repair: The Repair Technician participates in all phases of the plant's maintenance activities including pipefitting, exchanger work, mechanical and rotational equipment, vessel and tower repair, and general plant maintenance. Estimated time distribution is 50% in the shop and 50% in the field for rotational equipment personnel. For other functions the time distribution is approximately 90% field and 10% in the shop. C O N F ID E N T IA L R&s 154094 IHS Fite #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 Page 2 JOB DESCRIPTIONS (CONT.) Service Technician: The Service Technician is responsible for maintenance of Unit I's motorized equipment including vehicles, disposing of hazardous wastes, and occasionally works in the repair group. Estimated time distribution is 80% of the time in the shop and process areas and 20% as a repair technician. Process Supervisor, Manufacturing Supervisor, Environmental Supervisor, Instrument and Electrical Supervisor, Mod V Specialist, Manufacturing Representative, Project Supervisor. Process Engineer. Process Specialist. Sr. Computer Engineer. Engineer: The potential for exposure to chemicals in the process area is minimal for these job classifications. Estimated time distribution is 10% in the process areas and 90% in office areas/control room. Lab Supervisor. Analytical Technologist: These job classifications are involved in all aspects of the Unit I laboratories including on-stream analytical instrumentation, process development, analytical methodology, and supervision. Estimated time distribution is 5% in the field, 45% in the lab, and 50% In the office. Mechanical-Supervisor. Mechanical Technologist: These job classifications are involved in the coordination of maintenance activities and construction projects Estimated time distribution is 30% in the field and 70% in the shop and office areas. Mechanical Tech. Specialist: Supervises the repair and preventative maintenance of all pumps at Unit I, orders new mechanical equipment, and manages the EPIC equipment system. Estimated time distribution is 40% of the time in the field and 60% of the time in the office. Contractors: A significant amount of maintenance activities in the plant are performed by contractors in various capacities including welding, pipefitting, carpentry, insulation, painting, and electrical work. Estimated time distributions vary depending on the nature of the work. C O N F ID E N T IA L R&S154095 IKS File #00-4905 1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT l/VINYL CHLORIDE, OC-101 OSHA SPECIAL REGULATIONS Unit I Is directly affected by OSHA special regulations 29 CFR 1910.1017: Vinyl Chloride, 29 CFR 1910.1028: Benzene, 29 CFR 1910.1001: Asbestos, 20 CFR 1910.95: Occupation Noise Exposure and 29 CFR 1910.120: Hazardous Waste Operations and Emergency Response (HA2WOPER). A copy of each of these standards is located in the plant's Industrial Hygiene Manual. Key elements of the standards include: A. Vinyl Chloride, Benzene, and Asbestos 1. exposure monitoring requirements 2. respiratory protection and personal protective equipment 3. medical surveillance 4. information and training A review of the past monitoring data, the plant's respiratory protection and protective equipment policies, and Hazard Communication and training program, has confirmed Unit I to be in compliance with the requirements outlined in the Vinyl Chloride, Asbestos and Benzene standards. B. Noise 1. exposure monitoring requirements 2. audiometric testing requirements 3. hearing protection requirements 4. training requirements A review of the hearing conservation program at Unit I has confirmed the plant to be in compliance with the requirements outlined in the Noise standard. C. HAZWOPER There are eight key elements to this standard: 1. provide a written safety and health program 2 provide and hazard communication program 3. implement a medical surveillance program 4. implement a protective equipment decontamination program 5. implement new technology as it becomes available 6. provide procedures for container handling 7. conduct employee training 8. provide emergency response plans -- This protocol, Unit I's written job procedures, Dow Safety Standards, the written hazard communication program, Dow medical (health surveillance) programs, RCRA permit and Dow shipping procedures, training programs, and emergency response plans effectively meet the above requirements. O n> H ma C O N F ID E N T IA L 33 9W c4on* t<oT> CONFIDENTIAL UNIT I BLOCK FLOUI DIAGRAM REDACTED R&S154097 IMS FILE #OC-4905 t, / JUu^^cAA^jL UNIT I/VINYL CHLORIDE OC-101 NOTIFICATION OF VINYL CHLORIDE EXPOSURE MONITORING RESULTS. The OSHA vinyl chloride standard, 29 CFR 1910.1017, requires that any employee that has been monitored for exposures to vinyl chloride and found to have been exposed , without regard to the use of respirators, in excess of the permissible exposure limit, be notified in writing of the results of the exposure measurement and the steps being taken to reduce the exposure. This must be done within 10 working days following the monitoring. The following employee was exposed in excess of the Permissible Exposure Limit of 1.0 PPM for vinyl chloride: NAME MASTER NUMBER DATE MONITORED a-s#- 3a 8-HOUR TWA (PPM) 47 CONFIDENTIAL SIGNATURE OF MONITORED EMPLOYEE: DATE OF NOTIFICATION: , ^3,3. U PLEASE FORWARD THE COMPLETED FORM TO 2, INDUSTRIAL HYGIENE SERVICES, B-101 FOR INCLUSION IN THE 75 YEAR FILES.