Document qmDvxJwoy5Eqz8DegJd8GBax5

fjttJer?- arganizatian Correspondence TO A.W. Clements MLD MINT OR AKRON OOUfTTMUfT k BLDG. MO. Long Beach - from F.C. Dilley FISX-iJ POINT Off AKRON OCPAKTMKNT * RLPO. NO. Long Beach /'/ DATE YOUR LETTER ! OATS THIS letter June 11,1974 OSHA INSPECTION Mr. Lee- L. Pitchforth, Jr., Industrial Hygienist, U.S. Department of Labor, Occupational Safety and Health Administration visited the Long Beach Plant on 6-10-74. The length of Mr. Pitchforth's visit was approximately 5 hours. A meeting was held in the Plant ManagerTs office attended by Production Manager, Technical Manager, Industrial Relations Manager, and Safety Engineer. Mr. Pitchforth stated his visit was to complete the Questionnaire and for a quick walk-thru of our plant. The questionnaire is the 18 page form entitled " Vinyl Chloride, (VC) and Poly-Vinyl Chloride (PVC) Facilities. To complete this form is quite time consuming and took approximately 3 hours. After completion of the questionnaire I escorted Mr. Pitchforth through the plant. We visited the Poly building main floor and control room. In the control room he asked to talk to an employee for only about 5 minutes. We selected Recovery Operator, to talk to Mr. Pitchforth. He merely explained to the employee the role of OSHA in the Vinyl Chloride situation. He was interested in determ ining if our employees were actually informed on all aspects of the vinyl problems. After being satisfied in the Poly area we proceeded to the Bendix unit and this operation was explained in detail. At this time we made a quick walk thru of the Compound, Warehouse, and new Vinyl storage areas. On the summation Mr. Pitchforth made 2 recommendations. He suggested I follow more closly the ANSI Standard on Respiratory Protection pertaining to the fitting of respirators. Also, He suggested either deducting the background figures on OVA reporting or noting the background differential on the report itself. A weekly summary is posted in our Poly building for employee information and on this report he suggested the changes. Also, he mentioned our housekeeping as being excellent and stated that this one item helped cut his time in half in our plant. This official was aware of our recent Cal/OSHA and State Health Department inspections. Also, he was acquainted with the Health Department official that took air samples in our plant and also of the findings. Mr. Pitchforth gave no indication that he would return at a later date. KED.ACTKI) F.C. Dilley M,C 05605 NGC 05606 Attachment 4 QUESTIONNAIRE: VINYL CHLORIDE (VC) AND POLYVINYL CHLORIDE (PVC) FACILITIES 1 General Plant Layout: * Is it an outdoor facility? es except 2nd floor reactor building enclosed. b. How long has the plant been in operation? Since i960 ig c la the equipment corroded? wo *4 f d. Is the equipment in need of maintenance? No maintenance program in force. Specify: Freventive e. la the housekeeping good? Yes aspects?__ Poor? In which Where is the control room located? West side. 2nd floor-of reactor building. Other pertinent details re general plant layout: Close proximity to American Chemical Company plant. \GC 05609 COPY 2. Raw Materials a. Indicate the raw materials; Basically all VCM (Homopolymer plant) bv How are these handled? Closed system of tanks, pumps, and pipeline. c. What provisions is made for their storage? . Silo? _________ Tank? _________ Car? Bags? __________ Pressure area? Other? VCM Stored in sphere and small pressure tanks at process area. (Cars presently unloaded at American Chemical Co. and transferred via pipeline to BFG) d. What controls are enforced while these materials are in storage? Closed storage system with normal .fire and safety protection. Daily routine leak detection checks with OVA e. Is entry to storage facilities accomplished with an air supplied mask? Yes If not, how? . . How are withdrawals of raw materials controlled? Via pipeline and pumps Yes Closed system? '____________ Exhaust system? __________________________ Out of doors? Other?___ ___________________ NGC 05610 3. Manufacturing Process What process is.used? Suspension polymerization VC* Direct chlorination? Qxrchlorination? Other? ,1 PVCj Polymerization? See 3a* Wet? Yes Drv? % Other? j... b* What is the method of recycle for the unreacted vinyl chloride? Unreacted VC removed as vapor, then- compressed and condensed to liquid. c* In what form Is the finished product? Powder? Yes (resin) Pellets? Yes (compound) Gas? Other? d. Bov is it shipped? 50 lb* baes* boxes, hopper trucks, hopper cars. ' e. What are the container sizes? 50 ib. bag to 180,000 lb. hopper cars. NGC 05611 advance copy | 4 Controls for the Containment of VC and/or Control of Reaction a. What controls are utilized? Polymerization in pressure vessel, temperature Describe: Polymer**6^ jacketed, water cooled. Additional cooling controlled, source considered proprietary information. Are. the controls arranged to fall-safe^ Yes , b. Are two sources of supply provided for? __________________________ Cooling water? Tower supply; fire water back up. Electricity? Twin loop supply from outside power source. No in-plant emergency power source. Compressed air? Dual compressors. Refrigeration? '. Are they automatic? Cooling water - manual valve; Electrical- automatic; compressed air - manual valve. c* Where is the control room/area located? building. West side, 2nd floor of reactor Is it at positive pressure with respect to contaminated areas? Yes Ie it at least 200 feet from major VC storage or processing? Approx.200ft. d Are written control/startup/shutdown procedures available to Batch process - covered by routine procedures. operating personnel? ._______________________________________ NGC 05612 - ADVANCE COPY ' ; 1,11 5 Ventilation *. What is Che type of ventilation system? Pressured control room. Louver intake and powered exhaust blowers for enclosed area of reactor butlding. Is It adequate? Control room pressure maintained at 0.20 inches H2P. Reactor building-one air change per 2.5 minutes at normal blower speed and one change per 1.6 minutes at high speed. * , bk Where is the air exhausted? Control room exhaustswithin reactor area. -Reactor area exhaust to atmosphere at roof level. Is the air treated before exhaustion? No How? c Is makeup air introduced in sufficient volume to maintain correct operation? see 5 (a) above. Where does the makeup 30ft. NW of building. * Is it treated? air come from? How? Control Passes room intake approximately through furnace type filter. Is it heated in the winter? Yes (control room) d. Is the entry air to the control room treated? How? _____ *________________ NGC 05613 6. Waste Materials a. What Is the disposition of waste materials? Solid waste to public landfill. Waste water to sanitary sewer. Burled? Where? Burned? How? Cltv dump? Other? Public landfill Describe* Waste polymer and waste compound Treated? No _ ._ Estimated amount Specify* How7 1,000 to 1,500 pounds per day. * Other pertinent specifics relative waste materials! k < ' - NGC 05614 7. Sanitation a Vhat sanitation facilities are provided? Shower? Change room? Yes Yes Vashroom? Yes Individual lockers? Lunchroom? Yes Yes Drinking fountains? Yes Toilets? Yes b* Comment on location, accessibility, adequacy, utilization, condition, etc. of pertinent sanitation facilities: (Inspector made no comment prior to plant tour). I NGC 05615 X Exposure to VC < a. In which activities is there a potential for exposure to VC? vc pynnWp. potential in polymerization and drying area jobs. PVC exposure potential in resin bagging and loading area and in certain compounding jobs. How many employees are involved in each activity? 8 people per shift in poly/drying area: 2 charge operators, 2 recovery operators, 3 helpers, 1 dryer operator, (continued below) .t ^ What is the length of the potential exposure time? Per shift: Charge operators - 4 hrs; recovery operators 5 hrs; helpers 5 hrs. dryer operator 1 hr. b. . Are the activity areas regulated? Not posted, but only regular Indicate which- employees and authorized visitors permitted. Give the rationale for establishing these: . c. Are all employees generally aware of the hazards presented by VC or PVC? Yes. Employees informed at hiring and on a continuous basis through safety meetings, bulletin board notices, etc. To what extent is labeling or posting of signs used to appropriately X Inform or warn employees? No posting. (a) Continued: Potential PVC exposure: 3 operators per shift involved. Resin bagger/loader - 5 to 6 hours per shift:; Compound Henschel operator 7 hours per shift; Compound relief operator - L hour per shift. NGC 05616 - - . ADVANCE COPY 9* Protective Clothing and Equipment*. a. What articles of protective clothing and equipment are the employees provided? Coveralls, impervious suits for vessel entry, safety glasses, gloves, hard hats, rubber footwear for vessel entry. ear plugs and faceshields yhere needed. Are they required to wear or use these? Yes * Do they wear or use these? Specify Yes b. Do employees change into work clothes upon arrival at the plant and back into street clothes before departing? Yes c. .. Do they shower at the end of the day? d. Do they wash hands and face before eating lunch? Where do they eat lunch? Lunch room ( remote from process area) f. How are clothing and equipment articles cared for? Clean coveralls provided daily - separate lockers for clean and dirty garments. (1) How often cleaned? Daily change provided. How? Garments laundered once per week Where? Rental garments; contract supplier. (2) Are they decontaminated after use? see f. (1) above Which use? When? ___ Where? 056/7 ________] I~ """----r advance copy 9m Protective Clothing and Equipment*--Continued g. How often are the articles replaced? As necessary by contract supplier. What determines replacement? Normal wear_____________________________ * Respiratory protection devices are covered In question 10--omit here, NGC 05618 10. Respiratory Protection * a. What kind of respiratory protection devices are provided? Self- contained breathing apparatus; air supplied respirators; organic cartridge respirators with particulant filter. Huisance dust respirator provided in dusty areas. Are the respirators provided specific for protection from VC or PTC? ______________________________________________________________________________________ . * Explain* Self-contained and/or air supplied respirator used in con- centrations above 50 ppm; organic cartridge respirator used in areas for vessel entry. What respirators are utilized by the employees? All of above as dictated by job requirement arid individual situations. b. *Tb there a training program for employees which Includes the K proper wearing of respiratory protection devices? Yes c. How often are the respiratory protection devices checked for efficiency and effectiveness? All respirators monthly. , If applicable, how often are cartridges or cannisters replaced? Cartridges replaced daily. Cannisters replaced as dated or used. d. Other comments: NGC 0561`> 11, Maintenance and Decontamination Activities a What procedures are established for maintenance and decontamination? Any equipment which has contained VC Is exhausted prior to any entry by either production or maintenance personnel. Written procedure and safety, check list employed. Are there periodic inspections for the:' Ventilation system? Visual- Process equipment? Yes ` Piping and fittings? Yes Other? What transpires when leakage occurs? Personnel alerted. breathing apparatus obtained if necessary, problem area isolated and repair made as soon as possible. c. What provisions are there for the protection of employees in cleanup of leaks or spills, maintenance or repair operations on contaminated systems or equipment? Protective clothing, footwear, gloves, eye' protection, respirators. What protective clothing and equipment are utilized? See above Air supplied suits? No Gloves? ______________________________Yes ___________ Yes Respirators? , Others? ______________________________________________________ Clothing d How are employees decontaminated after work is completed? change, -shower. \GC * ** -i . ** - ADVANCE COPY! i " _______ i -- - -- i ' j .r . II* Maintenance and Decontamination Actlvltlesr-Contlnucd a* Are maintenance repair cleanup crews available during all shifts? Maintenance crew available on day shift and on Call-out basis at night. Production personnel handle minor, maintenance during night sfiifte, . i NGC 05621 ADVANCE COPY J '' r j 12. Fire Protection a. What provisions are made for fire protection? All buildings sprinkled and equipped with fire hoses and hand extinguishers. All buildings connected to a common fire' alarm system. Who Approves the fire protection plan? 1 FIA Insurance, Divisional Engineering. L. A. County Fire Department. b. Who conducts fire Inspections? FlA Insurance. L.A. County Fire Department. Plant Safety Personnel What is the frequency of the Inspections? monthly, Bi-annually - quarterly and c. ' Are there fire Insurance engineers? Yes Give particulars: FIA Insurance personnel are fire ^protection engineers. ngc o?62 Kovmcz COPY Employer Monitoring . What Is the. method of sampling? Stationary Bendix total hydrocarbon continuous analyzer in polymerization area. Portable organic vapor analyzer for specific leak detection. Are grab samples taken? Yes Bendix Micronalr II. , How? Permissible air sampling pump. Are continuous samples taken? Yes How? See above If sensors are used, where are they located? Bendix sample points: 1 on roof,-3 on reactor floor, 2 at pad level in reactor building. b. Are personal samples taken? Yes , How? Carbon absorption For.how long? Z| __ , , * 1 liter/minute What Is the sampling rate? __________________________________ What areas of activity are the employees in when monitored? work areas. Normal What percentage of employees are monitored in each area? in polymerization area. What is the frequency of monitoring? 3 "Platers per week. c* What method is used to analyze the samples collected in the OVA - total carbon hydrogen flame GC. monitoring program? Bendix total carbon hydrogen flame GC Carbon absorption - extraction and GC. What is the sensitivity? ova t-s PrTM t-s PPPicr. .S. ppm. What is the accuracy? QVA - 207., Bendix _ 20%. GC - 10% d. What Is the disposition of the results of sample analyses? ____ Data tabulated and maintained on file. NGC 05623 13. Employer Monitoring--Continued Are the employees informed? Yes (Weekly posting of ambient average concentration, Are .the results recorded? .Yes_____________________ _ Where are the records kept? Bendix ~ strlP chart in control room. Other records kept in Lab and in Technical Department office. How long are records of the results maintained? Plan to help as ' long as required by Standard. Are the results available at all times to the employees? Yes i \ NGC 05624 Medical Program a* What does the in-house medical program consist of? Audiometric, visual, fland X-rays, Bloou and Urine specimen for lead -(Compound employees annually) O..L..i.v.er fui nction blood test.(Chem-12 and GGTP) 1..1 . --. ----- . Are physical examinations of employees required? Xes Preplacement? Yes -- Ypr Periodical? ___________;_________________________________________ f What does the physical examination Include? Mr` Pitchforth asked for a copy of Blank Physical examination form. See attachment. Is there a medical surveillance program in effect? xes What does It consist of? See (a.) above,._______________________ * Does the employee have access to his medical records? Yes Is there a physician and nurse on duty at all times? N * - If not, when? Nurse on day shift only ; doctor one day per week and on call. - How many employees are trained in first aid? f 4 per shift. b.. What satellite-support medical facilities are readily available? St. Francis Hospital What is the distance to the nearest hospital which would be . 6 miles to St. Francis Hospital readily available at any time? ________________________________________________ Would adequate, appropriate, medical services be available there? Yes Is there a contract or working agreement in force with this facility? Yes (Pjant doctor -is- on-hospital staff) - Other comments* _________________________' ' '_____________________________________ 15 Emergency In the event an emergency should occur for any reason within the. operation whereby employees are Involved, what plan would be Implemented? Plant has established emergency procedures. t a. Is there an evacuation plan? Yps b* Are there definite emergency procedures established to include authorization for Individual control of assigned personnel? Polymerization area foremen control- polymerization. c. Is there a mutual support plan for outside assistance in the event of a catastrophic Incident such as fire, explosion, massive eplll? *$fes. Carson Community Inaustry Emergency System. A Explain: Communication system established among area industries end L. A. County .Fire Department t.o inform of any major emergency and place each . company in best possibles.position to help each other. NGC' 05626 NGC 0562**