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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