Document xzRLB2N7waxBbkEoOVorbZxJ
to MR. C. J. KLEINERT
SUBJECT
INTEROFFICE
DATE
FROM F. F. HOY/E. H. GARNER
REFERRING TO LETTER OF
APPENDIX
This section outlines in brief notes the comments made by the representatives of the various companies.
AIR PRODUCTS - JOHN BARR (Open Air Plant)
Average VCM Readings:1
c\ to >2. In one month, 400 excursions over 10 PPM out of 50,000 readings.
Number of Points:
20 to JO points per plant
Sampling Methods:
Bendix GC and computer, picks out averages and high points, carbon tubes for personnel monitoring, dissolve in THF
Masks:
Half face, continuous flow, will wear all the time after April 1, few canisters, to expensive for regular use
Physicals:
Mandatory - no objections
Contractors:
10 to 15 regulars for each plant, company handles these. Non-regulars--their re sponsibility. Below 5 PPM outsiders can stay 45 minutes ner day without effect (telephone, etc.")
Residual VCM:
Homopolymer regular MV/ to 50 PPM, spec 50 PPM Copoly ^50 --100 PPM
ALLIED CHEMICAL (Open Monomer Plant)
Average VCM Readings: Number of Points:
0.5 - 0*7 PPM Many excursions above 5 PPM, especially in pump area, personnel
0.05 average for 5 months, 0.19 high, down from 2.85 PPM a year ago, no one over action level since September, 1975 2 - 10 pt. systems
Sampling Methods:
Bendix GC with flame ionization, comput erizing now
OCC 5311
ALLIED CHEMICAL (cont.)
2- -
Masks:
Canisters and Scott Air Paks, tank car loaders - air line from cylinders
Physicals:
Net yet requiring?
Contractors:
None in regulated areas
Miscellaneous:
Have converted 80% of tank cars from slip gauges to magnetic gauges. Slip gauge emissions are run to incinerator
AMERICAN CHEMICAL, CALIFORNIA (Now Stauffer) HERB LINGER
Average VCM Readings:
Personnel 70% below 1.0 PPM, 30% 1.03-5 PPM, plus excursions
Number of Points:
Installing 90 points, feels it is too many
Sampling Methods:
Sipin pump and bag for personnel
Masks:
Air
Physicals:
Removed one person from regulated area, went as far as biopsy - not VCM related not in regulated areas, have contract maintenance, treat as regular employees
Residual VCM:
^10 PPM in Homopolymer, 50-100 PPM in copolymer
ATLANTIC TUBING (New Plant, On Stream One Month)
Average VCM Readings:
None taken
Number of Points:
No area monitoring
Sampling Methods:
No samples taken
Management has taken the position they will spend no money on this until need is shown. In the meantime, state OSKA people have approved plant operation on the basis that the company has checked with portable monitors and said they have no leaks. Ed Biehl as he reported this said he expects the roof to fall in any day.
Masks:
Scott Air Paks
Physicals:
Mandatory
Contractors:
None in regulated areas
Residual VCM:
No test data yet
OCC 5312
-3-
ATIANTIC TUBING (cont.)
Miscellaneous:
Had major problem with state air quality people. Had consulting company spend three months gathering data to satisfy them. Extensive off-site monitoring at Atlantic Tubing expense.
BORDEN
Average VCM Headings:
1-5 PPM, expect soon to be at 1-5 PPM
Sampling Methods:
Now Bendix hydrocarbon detector, installing Bendix GC with computer Personnel - Sipin pump and tube with Bendix flasher system
Masks:
Air line or canister - issue daily
Physicals:
Mandatory - complete physicals, well re ceived have detected several cancers not related to VCM and have saved at least
one life, possibly a second.
Residual VCM:
Not measured
CEHTATNTEED
Average VCM Readings: Number of Points:
0.5 to 1.5 PPM above background reading of 2-5 PPM hydrocarbon
50 points
Sampling Methods:
Miran but adding GC system - Check 200 points/day with Century, Personnel carbon tubes and head space with Perkin Elmer (not sold in carbon tubes)
Masks: Physicals:
Pull and half face continuous flow Mandatory - well received
Contractors: Residual VCM:
Not many used but burden is entirely on the contractors
Pipe grade Avg. 25 PPM. maximum 50 PPM
CONTINENTAL OIL
(Comments on PVC Plants')
Average VCM Readings:
Have 242 employees, 17 in reactor area with 8 hour TWA over 1 PPM, average 5 PPM 95% confidence level of 18.1 PPM, this was not clear - What he was trying to indicate was that exposures are variable.
OCC 5313
4- ~
CONTINENTAL OIL (cont)
Number of Points:
30 points
Sampling Methods:
Honeywell with range of 0-10 PPM Personnel 8 hour sample each month with Sipin 3P2P pump and bag
Masks:
Canisters and Scott Air Pak 25-1000 PPM - half face continuous with Nash Actively seeking a half face piece transfer mask and will seek variance to avoid full face piece masks for some jobs where they consider them a safety hazard
Physicals:
Mandatory - no objections yet Considering a medical van
Contractors:
Using many contractors on construction, require compliance but burden is on con tractors. Offer medical surveillance as option
Residual VCM:
Test eac& shipment, January summary for largest volume resin was 2.9% k.1.0 PPM,
45.7% 1-10 PPM, 57*1% 10-25 PPM, 14.3% >25 PPM
DIAMOND SHAMROCK (2 PVC Plants - Delaware City and Gulf Coast)
Average VCM Readings:
Gulf Coast - open air -- poly area 0.52.0 PPM average less excursions then Dela ware City
Delaware City - 1-3 PPM, January very bad for excursions, illustrates benefit of open air plants
Number of Points:
48 points and 80 points
Sampling Methods:
Areas and computer Personnel - carbon tubes
Masks:
Canister and half and full face air masks Some jobs will always require air line masks - Held a week of full dress test at Delaware City, many canisters used 90% of employees had to use a mask at
least once during each day. In this older
plant they expect continuing problems, would like a transfer mask'
Physicals:
Mandatory, emphasized sensitivity of SMA to alcohol intake
OCC 5314
DIAMOND SHAMROCK (coat)
5- -
Contractors:
Using large crews on construction, for semi permanent outside contractor employees same program as for their own employees, for short termers it is contractors burden.
Residual VCM:
Sometimes zlO PPM, always z50 PPM, depends on storage and temperature
DOW CHEMICAL (J monomer plants, 2 copolymer plants - monomer plants open air)
Average VCM Readings:
Monomer Plants zl.O PPM plus excursions some personnel samples above 1.0 PPM Copoly Plants -^1.0 PPM at one plant, 1-4 PPM at other plant plus excursions both plants.
Number of Points:
12, 30, 36 points at monomer plants
Sampling Methods:
Gas chromatographs plus portable meters Personnel - tubes
Masks:
Air and canisters
Contractors:
Contract Maintenance - treat as employees
Outside - explain with video tape and place burden on contractor
Residual VCM:
Z5 PPM in copolymer
Miscellaneous:
Use EDC or oil in double sealed pumps Expect to deregulate both copolymer plants but admitted some deregulated areas may have excursions. This is one of the in consistent positions we noted.
ETEYL-VCM PLANT
Average VCM Readings:
Z.5 to 1.0 average plus excursions
Number of Points:
10
Sampling Methods:
Have Miran but switching to GC with computer Using carbon tubes because Miran does not work
Masks:
Canister and air - not finalized
Physicals:
Mandatory - no refusals
Contractors:
Burden on contractor, help with hardware and training
OCC 5315
6- -
ETHYL - PVC FLAM1
Average VCM Headings:
1-2 PPM plus excursions above 25 PPM 68% of personnel readings in reactor area are below 1.0 PPM Miran shows 1.0 above background plus ex cursions
Sampling Methods:
Miran, carbon tubes, Century Portable Good results with large carbon tube, working with head space method
Masks:
Installing air line, will carry masks, presently canister - Will deregulate all but poly area
Physicals:
Same as VCM plant
Contractor:
Same as VCM plant
Residual VCM:
Low RV Homopolymer 5-10 PPM, Higher MW 1-5 PPM Emulsion grade <^3 PPM
Miscellaneous:
Deputy Directory NIOSH on 2/5 told Ethyl Medical Director by telephone theie is under development a 10-12 hour inexpensive mask with takes up VCM on inhalation and releases it on exhalation. Not allowed by standard. Also mentioned the possibility of a nine month extension of the optional use of masks
GENERAL TIRE - HARLAN JEWITT
Average VCM Readings:
Control room k0.5> poly floor 1.0 PPM Finishing and bulk areas ^1.0 PPM Workshop is a problem area T/P is problem area but unattended
Number of Points:
16 points
Sampling Methods: \
Flame ionization, also Miran for VCM and THF, (they clean with THF) Carbon tubes, Bendix Flasher Head space method - some problems
Masks:
Canisters and air line Warehouse - will issue one canister per day to truckers URW called in OSHA to complain of rust in breathing air
Physicals:
Mandatory - no objections Use a medical van and like it. Will give information if requested. (They have a female who is pregnant. They are a little concerned.)
OCC 5316
GENERAL TIRE (cont) Contractors:
Residual VCM:
-7-
Provide booklet and make contractor responsible
50 PPM max. Extrusion grade 10 PPM max. 1-3 PPM typical Calender grade 50 PPM max. 15 PPM typical Copoly 50 PPM max.
Inconsistencies in this presentation. Tank farm cannot be always unattended. Finishing and bulk areas were said to be less than 1.0 PPM but canister masks will be issued to warehouse truckers.
GEORGIA PACIFIC PLAQUEMIME - Open Air
Average VCM Readings:
Less than 1.0 PPM, TWA 0.25 - Computer never calculated any area to be over 1.0 PPM
TWA - Reactor and TP areas regulated Personnel samples for mechanics and lab
people sometimes show over 1.0 PPM TWA Referred to occasional large spills
Sampling Methods:
Bendix GC, alarm at 1.0 PPM - carbon tubes
Masks:
Air line masks for exposures (not a consistent presentation)
Physicals:
Mandatory - no objections
Contractors:
Evacuate above 1 PPM, log in and monitor with area monitors
Residual VCM:
General purpose pipe resin 95% 10 PPM, 90% x5 PPM, 60% ^1.0 PPM
Miscellaneous:
Monitor boundaries and log with computer
B. F. GOODRICH - HENET WALTEMATE
Average VCM Readings:
0.5-4-.0, new poly plant ^0.5 PPM and not regulated - Personnel 0.5 - 1*5 PPM
Number of Points:
10 per area
Sampling Methods:
Changing from total hydrocarbon analyzer to GC. Will use flasher - Use head space for residual VCM but don't like it
for personnel
Masks:
Half face air, canisters - Run "April 1" trials occasionally for one day - Have approval form Washington to use half face piece with canister for -less than 10 PPM. Approval from Grover Wrenn
OCC 5317
8- -
B. F. GOODRICH (cont)
Contractors:
Regular contractors treated same as employees. Have Kentucky OSHA approval to consider contractors not covered by standard if they evacuate at 5 PPM
Residuals:
GP with strippers -kl PPM, Paste resin 10 PPM variable
Miscellaneous:
Said you can be cited for 75 PPM even with all personnel in masks. If any are without masks, this is a second citation
GOODYEAR - NIAGARA RALLS (shutdown half, working now like after April 1)
Average VCM Readings:
0.3 average plus excursions Personnel <.0.5 PPM 8 hour TWA
Number of Points:
10 points going to 20
Sampling Methods:
Bendix, 8 hour carbon tubes with Sipin pump Bendix alarms at 5 PPM and people put on masks. (This is not truly like April 1)
Masks:
Half face air line, no canisters
Physicals:
Mandatory
Contractors:
Evacuate at 5 PPM, take position not covered by standard
Residuals:
One dispersion type average 5 PPM other not labelled
Miscellaneous:
Cleaning reactors with THP, rarely (pen them
GOODYEAR - LOUISIANA
Average VCM Readings:
1.5 PPM average Personnel 38% k.0.5 PPM, 63% ^1.0 PPM, 17-5% 1-5 PPM, 0 over 5 PPM
Number of Points:
20 points
Sampling Methods:
GC, planning alarms, checking with Century carbon tubes
Masks:
Half face, continuous flow - no canisters but may have to use them
Physicals:
Mandatory, well received
Contractors:
Contract Maintenance - like employees Outside - burden in on contractor
OCC 5318
9- -
GOODYEAR (cont.)
Residual VCM:
35-40 typical, max. 50 PPM
Miscellaneous:
Valve leaks a big problem
GREAT AMERICAN - J. PLOROS
Average VCM Readings: Number of Pcints: Sampling Methods:
Masks:
Physicals: Contractors: Residual VCM:
HOOKER
1.4 average, Personnel 60% PPM
60 points
Areas with computer - 8 hr. bags for personnel
Half face, continuous - using them 4 hours per shift, few problems
Mandatory, no refusals
Provide masks, burden on contractors
10 PPM max. - customer requirement 3 PPM typical for higher MW
Average VCM Readings:
<3 PPM average, 10-12 excursions above 5 PPM per day
Number of points:
40 points
Masks:
No canisters
Physicals:
Mandatory but in in arbitration now
Contractors:
Burden on contractor, provide nothing
Residuals:
^.10 PPM
KSYSOR CENTURY - KEN LAW
Average VCM Readings: Sampling Methods:
Masks Physicals: Contractors:
3-4 PPM plus excursions
Installing area monitors - Hewlett Packard 9 points
Pull face continuous flow and self contained
Mandatory, no objections None used
OCC 5319
-10-
PANTQSOTE - JIH PARREL
Average VCM Readings:
1-5 PPM in Passaic, 5-8 in Pt. Pleasant 2.5 PPM personnel
Number of Points:
18 points in poly area
Sampling Methods:
EOCOM computerized in Passaic - 0S3A approved for personnel monitoring Miran in Pt. Pleasant
Masks:
Half face to 1000, then Scott Air Pak
Physicals:
Mandatory, no objections
Contractors:
Give orientation - evacuate
Residual VCM:
10-50 PPM, working on Inis
PPG - LAKE CHARLES VCM PLANT
Average VCM Readings:
<10.5 PPM, one excursion per 5 days
Sampling Methods:
Areas, moving probes away from leaks Computerizing now
Masks:
Positive demand air and continuous
Physicals:
Rejecting 60$ of applicants No females capable of becoming pregnant used in VCM areas - Instituted discussions with OSBA and EEO - EEO backed off
Contractors:
None used
PPG - PUERTO RICO
Average VCM Readings:
kl PPM, storage area ^5 PPM Personnel TWA <L PPM
Sampling Methods:
Bendix, carbon tubes, Sipin pump
Masks:
Air line, use masks regularly on certain Jobs
Physicals:
Mandatory
Contractors:
In house - same as employees Others - burden on contractor
occ 5320
-11-
SHELL - LEER PARE
Average VCM Readings:
0.04--0.07 PPM average for 24- hours 94-% less than 1 PPM few excursions over 5 PPM
Number of Points:
20 points
Sampling Methods:
GC
Masks:
Half face, no canisters, use masks regular ly on some jobs, Scott over 100 PPM
Contractors: Miscellaneous:
Burden on contractors - evacuate
Process area considered regulated only during start up and shutdown
STAUPFER DELAWARE CITY - BILL HAGAR
Average VCM Readings:
Area 0 to ?5 Personnel 0.2 to 2.0
Number of Points:
90 points
Sampling Methods:
5-10 points Areas units Bags for personnel
Masks:
All use them - air line
Physicals:
Mandatory
Contractors:
Handle 'program for regular contractors Others - no coverage
Residual VCM:
Homopolymer 5 PPM Copoly 100 PPM
TENNECO - PETE BOGART (Plant A-Burlington, B-Flemington, C-Pasadena)
Average VCM Readings: Number of Points:
1-3 PPM 60-80 points per plant
Sampling Methods: Masks:
Bendix, computerizing Pasadena has remote control room
Must carry air mask and plug in at 5 PPM Will use canisters Using bottled air but installing compressors Complaints of nose bleeds with bottled air Others agreed Complaints air is too cold Will humdify Certain jobs are mandatory air - reactor cleaning and unloading
OCC 5321
-12-
TENNECO (cont)
Physicals:
Mandatory, no objections Make no blood tests after paydays or Mondays - effect of alcohol Same for lead tests
Contractors:
Using many, burden on contractor, will provide masks
Residual VCM:
Mostly below 10 PPM, some below 1 PPM
UNIPIT CARBIDE - South Charlestown - sol'n &, disp Texas City - sol'n &. susp Comments mainly on suspension
Average VCM Readings:
1.5 PPM, poly 2.0 PPM, recovery 2-3 PPM
Sampling Methods: Masks:
In house flame ionization system Carbon tubes Canister and air line from bottles, Scott Air Fak
Physicals:
Optional, 6 refusals
Contractors:
Slide tape training program, otherwise burden is on contractor
Residual VCM:
Sol'n. resin PPM Suspension homo typical5 PPM, max. 10 PPM ViAc copoly ^300 PPM get poor color when stripping harder
NORSK HYDRO - (Revisions complete, production almost normal)
Average VCM Readings:
Average zl PPM, typical 0.5 PPM Personnel - same During January and February, area 1.5 PPM personnel 1.3 PPM, cold months, closed
plant
Number of Points:
\
Sampling Methods:
12 points
Bendix with computer, alarm at 15 PPM Carbon tubes and Sipin pump
Masks:
Air line and canisters
Physicals:
Twice yearly
Contractors:
Few used but treated same as employees
Residual VCM:
^5 PPM for low BD types ^50 PPM for high BD types
FFH/KHG:lss 3/2/76
OCC 5322