Document vVO1bwa65oBYo3EROE4dLp5dm

Top of the news some differences with the rest of industry on the exposure level standards that would be manageable. Industry generally supports the Society of the Plastics Indus try's proposal, that the present temporary emergency standard of 50 ppm. be low ered in several stages to 25 ppm. for PVC plants by Oct. 5, 1975, with further impo sition of a time-weighted average limit of 10 ppm. Standards for VCM production, says SPl. could be more restrictive--10 ppm. by October 1975, and a timeweighted average (twa.) of 5 ppm. T.C. Walker, president of Firestone Plastics, says that a "safe and medically sound--as well as technologically and ec onomically feasible--standard'' is 40 ppm. maximum exposure and 25-ppm. twa. Snell's analysis offers data on several alternatives, maintaining the SPI distinc tion between VCM and PVC plants (table, p. J5). Cost data indicate that VCM makers can manage with a 10-ppm. limit and a 2-5-ppm. twa. without closing any plants. Meeting such a standard would increase their average unit manu facturing cost by an estimated 0.32c/lb., which is about 4-5% of the present range (7-10e/lb.) of list prices for various grades of VCM. For polymer producers, however, some plant closings may be necessary when the present emergency standard is tightened. According to the Snell study, at an expo sure limit of 25-40 ppm, and a 15-25 twa., 4% of the existing PVC plants may have to be shut down. This might not be too disastrous, considering that 58% of the in dustry's plants are more than 10 years old, and only 8% are less than five years old. But for an exposure limit of 15-25 ppm. and a twa. of 10-15 ppm., 26% of the PVC plants could face the axe. Snell's survey indicates that with this standard, unit costs of PVC would increase 1.6c/lb., or about 4-8%, at those plants that can take the needed engineering changes. At some older, smaller batch op erations, the companies say it would be impossible to reach such a low exposure level without building a new plant. At certain plants, Snell believes, the addi tional cost might be 50% more or less than the 1.6/lb. average. Schedule Makers: Snell estimates it will take VCM plants up to three years to achieve what it considers the lowest achievable level. For PVC plants, the es timate is two and a half years. This is based on engineering estimates of installation time for various kinds of apparatus to reduce exposure levels at 16 CHEMICAL WEEK September 25. 1974 PVC plants. Examples: major ventilation system improvement, 18 months; replace ment or reconditioning of reactors, 18-24 months. Overly Optimistic? Some companies contend that these estimates are overly optimistic in light of today's materials shortages and delivery delays. Observes a Firestone executive: "Individual com pany confidence in being able to attain compliance with even the SPI recommen dations has been eroding as lead times for obtaining equipment expand, as capi tal costs rise rapidly, and as the prospect for financing these projects becomes dim mer." VINYL SIDING costs will rise as makers meet new in-plant and emission standards. Industry criticism has also centered on Snell's projection of cost data to meet projected standards. The figures are said to be heavily weighted in favor of newer plants and suspension homopolymeriza tion units in wanner climates. Such plants could probably be most readily adapted to meet a more stringent exposure stan dard. Separate Standards: The proposed nodetectable-level standards would be ap plicable to VCM and PVC plants as well as fabricators. But the Snell study follows the SPI proposal of separate standards for VCM and PVC plants. Reasoning is based on relative ease of controlling emissions at VCM plants, which are generally closed systems, oper ating in the open air. Leaks may occur around pump packings, during samplings or maintenance operation, or at tank-car loadings. The batch operation of PVC plants involves continuous, emptying and recharging of autoclaves and frequent in spections and cleaning out of these reac tors. Chance of VCM exposure in these plants is high even in the packing areas. While separate standards would seem reasonable to manufacturers, the prac ticality of this approach is limited. It's un likely that labor groups, strongly in favor of the no-detectable level and opposed to the concept of a threshold level for any carcinogen, could accept different expo sures for workers in various plants. Outside Plant: If the vinyl producers solve their in-plant exposure problems, they will still have to deal with monomer gas escaping from the plant. EPA Admin istrator Russell Train said last week that his agency will set standards for vinyl chloride, plant emissions by next June. And without firm data on health effects of VCM at various levels in the atmo sphere, Train is proposing that the stan dards be based on "best available tech nology." EPA's survey of air and water around 10 PVC plants indicated VCM air levels of 1 to 2 ppm. Through those emissions, the agency estimates, PVC plants are los ing monomer at the rate of 200 million lbs./year. With controls, EPA says emissions from PVC and VCM plants could be cut 75% and 90%, respectively. Capital out lays for these controls are put at 580 mil lion for the industry as a whole, with op erating expenses estimated at some S40 million/year. John Nelson, vice-president for manu facturing at B.F. Goodrich Chemical, ap proves of Train's analysis, especially the statement that there is "no imminent haz ard" from VCM exposure in the atmo sphere. But if OSHA's no-detectable-level pro posal becomes the law, the vinyl chloride industry might have to re-evaluate its do mestic production. Although industry spokesmen have warned of extensive shutdowns if such a standard is adopted. OSHA's environmental impact statement merely suggests that the costs will be high but will be passed on to the consumer, and that the time needed to reach the standards would be long. But this report also suggests that "in the long run U.S. companies might find it profitable to build plants abroad.' Clearly, this will depend not only on tra ditional market and raw-material logis tics but also on whatever in-plant am emission standards are put in force in th< U.S. and other nations. BOR 007086 Top of the news Vs? Showdown on vinyl plant rule presages shutdowns Newly issued advisory reports hint at compromise in fight to curb vinyl chloride fumes, but battle may continue in court. Industry insists OSHA's proposal would be ruinous The bitter controversy over worker ex fects of the proposed standard. This re els; and there are no technology transfer posure to vinyl chloride gas may climax port does not discount the possibility of a opportunities to permit development of on Oct. 5 when the U.S. Dept, of Labor is level higher than the 1 ppm. implicit in design for no detectable levels in new expected to set permanent standards for "no detectable level." But it concludes plants. Moreover. Snell says that because the 17 U.S. plants that produce the mono that anything higher is a risk to workers. PVC manufacture is a batch operation, mer, the 37 that polymerize it to make "Despite significant cost increases that emissions couldn't be completely elimi polyvinyl chloride resins, and the thou may occur, the high demand for PVC nated. sands of plants that mold, extrude and resins is likely to continue," the report Something to Live With: Those conclu otherwise shape those PVC resins into states. sions would seem to support a compro plastic pipe, vinyl flooring, house siding The Environmental Protection mise regulation that the vinyl makers and phonograph records. Agency's notification that within nine could live with--perhaps not too happily. The controversy has raged since last months it will set VCM plant emission But probably because of the imminence January, when medical data apparently standards that could add 4% to the cost of of the Labor Dept.'s new regulations, in established a link between workers' expo PVC. This would seem to preclude the dustry representatives were reluctant to sure to vinyl chloride monomer (VCM) engineering possibility of venting all the discuss Snell's final report, noting that and angiosarcoma, a rare liver cancer. in-plant VCM leaks to the atmosphere. they haven't had time to examine it. And last week the scores of chemical Double Negative: OSHA's proposed Nor did they have much time to react and plastic companies that have a stake goal of operating monomer and polymer to Snell's preliminary report, which con in this $3-bitlion/year business were plants at no detectable level of vinyl chlo tained pretty much the same data used in given some inkling of whether the gov ride exposure is "not feasible," according the final report but did not contain any ernment will stay with the 50-ppm. emer to Snell. Moreover, the firm's analysis in conclusions. OSHA issued the prelimi gency standard, adopt the proposed "no dicates that the U.S. industry would com nary report Aug. 28, called for response detectable level" by Sept. 6. Never limit or move to theless, industry some compromise position. Whatever OSHA's vinyl standards impact: higher costs, fewer plants leaders submitted comments, and these standards are set could determine the profitability of pro ducing and process ing vinyl compounds Proposed VCM exposure standard* (ppm.) Timeweighted Maximum averege Increese in averege unit costs (cents/lb.) Loss of Direct productivity Total1 Time needed to comply (months) Proportion of industry endangered* were generally nega tive and caustic. One point of con tention in the prelim inary report was the in the U.S. for many years and are likely to be attacked in the federal courts, either by the companies or the labor unions in Monomer plants 50 15 25 15 10 2-5 "No detoctable amount" 0.04 0.09 0.17 - 0.03 0.03 0.15 - 0.07 110% 0.12 40% 0.32 40% 0 24 36 Not feasibla 0% 0% 0% 100% use of Firestone data for bringing a PVC plant into com pliance with a no-detectable-level stan dard. Firestone, Snell volved. Conflict: As to exactly what stan dards will be promulaated next week, various indications-- Polymer plants 50 = 25-40 15-25 15-25 10-15 "No detectable amounf 0.19 0.36 0.90 4.01' 0.35 0.49 0.70 3.07* 0.54 t 20% 0.S5 35% 1.60 50% 7.08 * 75%' 0-6 30 30 30-48* Negligible 4% 26% 100% reported, was the only company that said it could meet such a standard. Firestone replied that studies of its poly sometimes contra dictory-can be found in three newly issued reports: Vinyl chloride monomer (VCM) content, expressed as parts per million, In the sir to which employees are exposed. 1 With estimated range of variance for Individual plants, basad on partial statistical analyslatof data. 1 Percentage of capacity that managamant would sarloualy consider shutting down. * Based on Flrastona's estimates; actual compliance 1s not considered feasible. Source: Foitar D. Snail, Inc. merization plants in Pottstown, Pa., and Penyville, Md., ac tually indicated a Foster D. Snell's contrary judgment. final report to the Occupational Safety pletely collapse under that restrictive Declares a Firestone executive; "Inde and Health Administration on the eco standard, with all producers indicating pendent of economic considerations and nomic impact of the agency's proposed they would have to close their plants. despite enormous equipment, engineer VCM exposure standards. A principal The study offers several reasons for ing and process changes at both facilities, conclusion: "achieving no detectable lev els .. . is judged not feasible, both in PVC and VCM sectors." reaching these conclusions: technology to eliminate VCM leaks and fugitive losses is not available; existing plants have not costing in excess of $50 million, it is not possible to achieve the drastic exposure levels required by the proposed standard, The Occupational Health and Safety been designed for total VCM contain based on engineering controls and tech Administration's final environmental im ment; there has been no operating expe nology that now exist." pact statement on the physiological ef rience in maintaining very low VCM lev Firestone, No. 5 in PVC output, has SaptMKw on 1974 CHEMICAL WEEK 15 BOR 007087