Document yk3v64nVvVrOqzkaM3Lkk2eKr
, .JHS' File #OC1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 1
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 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.
CONFIDENTIAL
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, lrIJHST File #0C 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 2
OCCUPATIONAL HEALTH GOALS AND PLANS 1990-92
"-- --' -- ' --`
Industrial Hygiene Monitoring: Comprehensive Chemical (8-hr TWA & Excursion) Shutdown Monitoring Noise (Area & Personal) Hexachlorobenzene Wipe Testing
Hearing Conservation Training (annually):
Asbestos Training (annually):
Ventilation: Ventilation Survey Manometer Check
Ergonomics: Initial Training Evaluation of Manual Lifting Activities
Heat Stress Training:
Hazard Communication: Review written Hazcom 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 SCBA, airline and dust mask
Inspections-
Mouthbit
SCBA, airline, ELSA
Protective Equipment Training (biannually)
Radiation Inspections Visual (location, labels, sign) Wipe test, survey
DATE LAST
- - - - COMPLETED
DATE
OE
1989
1988 ........
1990
1990
1992 1991 1991 1991
1991/92
1991/92
1989 quarterly
1992
1991 1991
1991
1990 1990 1990 1990 1990 as needed
1992 1992 1991 1992 1991
1990
1992
before each use and annually
before each use, weekly, and
annually by fire department
.......
1990
Biannually (Feb./August) Biannually (May/Nov.)
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R&S 154032
,,IHS File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101
Page 1
MONITORING PROGRAM
1 . RATIONALE
Personnel monitoring was conducted during 1987-89 to evaluate employee exposures to vinyl chloride, vinylidene chloride, ethylene dichloride, ethyl chloride, 1,1,1-trichloroethane, 1.1.2-trichloroethane, and carbon tetrachloride. Eight-hour time-weighted average exposures for each monitored job classification were less than the acceptable guidelines with one exception. The Process Technicians in the loading area had average exposures to vinyl chloride of 0.97 ppm. This exceeds the OSHA Action Level of 0.50 ppm for vinyl chloride and is close to the Permissable Exposure Limit of 1 ppm. The OSHA Standard for vinyl chloride requires quarterly monitoring when employees are exposed, without regard to the use of respirators, above the action level and monthly monitoring when exposures exceed the Permissable Exposure Limit (PEL). Because the average exposure of 0.97 ppm for loading technicians is close to th OSHA PEL of 1 ppm, monthly monitoring is presently being conducted at Unit I. A new tank car sampling system was implemented in 1989 in an effort to reduce exposures. Personnel monitoring conducted after implementation of the new system indicated exposures continue to exceed the OSHA Action Level and remain close to the PEL Additional engineering controls are being investigated. Until additional controls have been implemented and exposures have been proven to be well below the PEL, monthly monitoring will continue to be conducted of the loading technicians.
Personnel exposures to ethyl chloride, 1,1,1-trichloroethane, 1,1,2-trichloroethane, and carbon tetrachloride have all been less than 10% of their respective guidelines. With the exception of excursion monitoring during carbon tetrachloride tank truck unloading, these chemicals will not be monitored in 1990-91 unless conditions change such that exposures may significantly increase.
A comprehensive chemical survey will be conducted as part of the 1990-92 Occupational Health Program at Unit I. Chemicals evaluated will include vinyl chloride, ethylene dichloride, benzene, 1.1.2.2-tetrachloroethane, and 1,1,1,2-tetrachloroethane. The tetrachloroethanes have not previously been evaluated at Unit l. 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. Both 8-hour time-weighted average (TWA) and short-term monitoring will be conducted.
Monitoring will also be conducted to evaluate employee exposures to vinyl chloride and ethylene dichloride during plant shut-down activities. Both 8-hour TWA and short-term monitoring will be conducted.
Texas Operations Safety Standard 0-46 (Hearing Conservation) requires that a noise survey be conducted every three years. The previous noise survey at Unit I was conducted in 1988; therefore, a comprehensive area and personal noise survey will be conducted in 1991.
Preliminary wipe testing for Hexachlorobenzene (HCB) will be conducted in selected process areas at to determine if the chemical is present in significant amounts. If significant levels of HCB are found during the preliminary testing, additional process and non-process areas will be tested to determine if there is a potential for skin exposure.
CONFIDENTIAL
R&s 154033
IHS File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101
Page 2
MONITORING PROGRAM (CONT.)
2. SAMPLING STRATEGY
A. S-Hour TWA Chemical Monitoring
Job Classification1
Number of Employees
Process Technician-OXY, BPR, VD, VF, l&E Process Technician-DC Process Technician & Unit Technician-LD Process Technician & Unit Technician-R Process Technician-Lab Process Technician & Unit Technician-Training Process Technologist Senior Technician Service Technician Mech. Tech. Spec., Mech. Supervisor, Mech. Techngst Pipefitter/Contractor
5/area 5
2
7 2
3
2 6
1
3 1
Chemical2
Number of
Samples
VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2, Benzene
VI
VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2
VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2
VI; EDC; 1,1,2,2; 1,1,1,2 VI; EDC; 1,1,2,2; 1,1,1,2
6/area 6/area
14
6 3
3 3 6 1
3 3
1. OXY=oxychlorination, DC=direct chlorination, BPR=by-product recovery, VD=vinyl distillation, VF=vinyl furnace, l&E=instrument & electrical, LD=loading, R=repair.
2 VI = vinyl chloride; EDC = ethylene dichloride; 1,1,2,2 = 1,1,2,2-tetrachloroethane; 1,1,1,2 = 1,1,1,2-tetrachloroethane,
B. Job Task Monitoring
Job lash
Area
Process Sampling Process Sampling Filter Changing Breaking into vessels/ pipes
All areas DC DC
All areas
Tank Truck unloading, sampling/analysis
VF
Chemical
VI; EDC; 1,1,2,2; 1,1,1,2 Benzene roc
VI; EDC; 1,1,2,2; 1,1,1,2
CCL4
Number of Samples
3/area 3 3
As many as practical
3
CONFIDENTIAL
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IHS File #00-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 3
MONITORING PROGRAM (CONT.)
C. Shutdown Monitoring
Both 8-hour TWA and short term monitoring will be conducted during plant shutdown activities. The number of samples and tasks to be evaluated will be determined during a pre-shutdown meeting.
D. Noise Monitoring
Job Classification
Process Technician-OXY.DC BPR, VD, VF, l&E Process Technician/ Unit Technician-LD Process Technician/ Unit Technician-R Process Technician-Lab Process Technician/ Unit Technician-Training Process Technologist Senior Technician Service Technician Mech. Tech. Spec., Mech. Supervisor, Mech. Techngst Pipefitter/Contractor
Number of Emolovees
5/area
2
7 2
3 2 6 1
3 1
Number of SamDles
6/area
4
8 3
4 4 6 3
4 3
E. Wipe Testing
Aifia-------------------- -------------------------------------------------# of Samples
D-25, T-20, R-140, D-36, D-24, D-254
2/Area
3. SAMPLING METHODS
Sampling for vinyl chloride, ethylene dichloride, 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 DLMHM-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.
CONFIDENTIAL
R&S154035
. -4HS File #OC1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
MONITORING PROGRAM (CONT.)
Page 4
Wipe testing for HCB will be conducted with Whatman #2 filter paper, 5.5 cm diameter. Approximately 100 cm^ of surface area will be wiped in a cross-hatched format with as much pressure as can be applied without tearing the paper. The filter will be placed in a clean labeled glass vial and sealed immediately after sampling. Gloves will be worn while sampling and changed frequently between samples to avoid cross contamination. Filters will be analyzed by Analytical Services.
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.5
5. EVALUATION CRITERIA
Material
Vinyl Chloride Ethylene Dichloride 1,1,2,2-tetrachloroethane 1,1,1,2-tetrachloroethane Benzene Noise Hexachlorobenzene
Industrial Hvaiene Guide
1 ppm 1 ppm 0.1 ppm -- 1 ppm 85 dBA-TWA 300 ng/100 cm^
Excursion Guide
5 ppm-STEL 2 ppm-STEL -- .... 5 ppm-STEL 90 dBA-Ceiling
Source
OSHA-PEL OSHA-PEL Dow IHG ....
Dow
CONFIDENTIAL
R&s 154036
, ,,IHS File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101
Page 5
REVIEW OF PAST MONITORING DATA A. CHEMICAL REPORTS:
TABLE I SUMMARY OF 8-HOUR TIME WEIGHTED AVERAGE EXPOSURES, 1987-881
JOB CLASS/CODE
# Of SAMPLES
VI RANGE
CONCENTRATION (PPM)2*3*4
V2 EDC AVE RANGE AVE RANGE
AVE
Process Technician:
Oxychlorination/ 127005800X
3
ND-0.06
0.03
ND-0.04
0.03
0.20-0.29
0.25
Direct Chlorination/ 12700580DC
3
ND-0.10
0.07
ND-0.03
0.02
1.1-4.3
2.4
By-Product Recovery/ 12700580BP
3 0.02-0.21 0.08
N)
N)
0.32-1.2
0.73
Vinyl Distillation/ 12700580VD
3 0.02-0.76 0.30
to
ND
0.52-3.5
0.73
Vinyl Furnace/ 12700480VF
3
ND-0,05
0.03
ND
ND
0.12-1.3
0.71
Loading/ 1270078010
8
ND-15
0.53 ND-0.58
0.03
ND
ND
Repair/ 12700580R
7
ND-0.37 0.11 0.02-0.20 0,05
ND-5.3
1.6
IHG
11
1
1 Reference: Hicks, D, D., Evaluation of Exposures to Chlorinated Hydrocarbons. Noise. Asbestos, and Welding Fumes at the Vinyl Chloride Plant. Unit I. Ovster Creek Site. Texas Operations. 1987-88. IHS File OC1-3138CNA.
2- VI = vinyl chloride, V2 = vinylidene chloride, EDC = ethylene dichloride. Ethyl chloride, 1,1,1-trichloroethane, and 1,1,2-tichloroethane were also monitored however, all samples were less than 5% of their respective IHG's,
4` ND = non-detectable; Detection limits are as follows: VI = 0.02 ppm; V2 = 0.03 ppm; EDC = 0.02 ppm.
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CONFIDENTIAL
, ^ IHS File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
REVIEW OF PAST MONITORING (CONT.)
Page 6
TABLE 2 SUMMARY OF 8-HOUR TIME WEIGHTED AVERAGE EXPOSURES, 19891
JOB CLASS/CODE
Process Technician:
Oxychlorinatlon/ 127005800X
Direct Chlorination/ 12700580DC
Vinyl Distillation/ 12700580/VD
Vinyl Furnace/ 12700580VF
By-Product Recovery/ 12700580BPR
Loading/ 12700580LO
Repair/ 12700580R
Contractor/Utility Man
IHG
# Of SAMPLES
CONCENTRATION fPPM)2-3
VINYL CHLORIDE
ETHYLENE DICHLORIDE
RANGE
AVE RANGE AVE
4
N)
ND
ND-0.07
0.06
7
ND-0.19
0.10 ND-0.44 0.25
7
ND-1.1
0.40 0.05-0.24 0.11
4
ND-0.16
0.09 ND-0.31
0.18
4
ND-0.14
0.09 0.04-0.30 0.14
10
0.47-1.e
0.94
ND
ND
4
ND-0,24
0.17 ND-0.54 0.36
2 0.07-0.10 0.09 0.26-3.2 1.7
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CONFIDENTIAL
= r&SI54038
1 Reference: Blue, M. A, Evaluation of Employee Exposures to Chlorinated Hydrocarbons at the Unit 1/ Vinvl Chloride Plant. Oyster Creek. 1989. IHS File OC-3138-89C.
O
Ethyl chloride, 1,1,1-trichloroethane, 1,1,2-trichloroethane, and carbon tetrachloride were also monitored however samples were less than 5% of their respective IHG's
O
ND = non-detectable; detection limits are as follows: vinyl chloride = 0.07 ppm; ethylene dichloride = 0.04 ppm
. -,iu3 File #OC1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 7
B. NOISE REPORTS:
REVIEW OF PAST MONITORING (CONT.)
TABLE 3A SUMMARY OF 12-HOUR TWA NOISE EXPOSURES, 1988
JOB CLASS/ JOB CODE
Process Technician1:
# OF SAMPES
% OF OSHA ALLOWABLE
RANGE
AVE.
Direct Chlorination/ 12700580DC
5
19-65
31
Byproduct Recovery/ 12700580BP
5
15-50
28
Oxychlorination/ 127005800X
5 25-100 54
Vinyl Furnaces/ 12700580VIF
4 12-82 43
OSHA PEL OSHA Action Level
100 50
1, The job classification of Senior Technician/12700004 is included with Process Technician results.
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-,IH^ File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 8
REVIEW OF PAST MONITORING (CONT.)
TABLE 3B SUMMARY OF 8-HOUR TWA NOISE EXPOSURES, 1988
JOB CLASS/ JOB CODE
# OF SAMPES
% OF OSHA ALLOWABLE
RANGE
AVE.
Process Technician'*:
Vinyl Distillation/ 12700580VD
Repair/ 12700580R
Contractors:
Electrician/ 18700000C
Pipefitter/ 20910120C2
OSHA PEL OSHA Action Level
5 4
6 5
25-100 5-12
64 8
7-25 16-113
18
50 100 50
1 The job classification of Senior Technician/12700004 is included with Process Technician results. 2' The job classifications of Utility Man/18113140C and Foreman/01600000C are included in these results
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File #00-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/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 February, 1988. The survey included both area noise levels and personal job exposure evaluations. The following job classifications had exposure potential greater than 85 decibels as an eight hour TWA. Employees within these job classifications are to have an annual audiogram, required annual training, and mandatory hearing protection.
1. Process Technicians/Oxychlorination 2. Process Technicians/Vinyl Distillation 3. Contractor Pipefitter/Utility Men
2. TRAINING
Training must be conducted annually.
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. C-103 & 104 compressor 2. C-340 compressor 3. Cooling tower pump area (P-311, 312, & 313) 4. T-2 area 5. FTB-400 area 6. Area between D-204 & C-204 7. C-30 compressor area 8. Area between R-1 & T-2 9. Oxy R-100 & R-101 10. Area between F-202 & F-203 re-heater 11. P-200 area 12. Phase II area 13. Trackmobile, when operating 14. Maintenance shop, when equipment is operating 15. Yard dog towmotor, when operating
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
CONFIDENTIAL
B8ts i 54041
>, I,HS File #00-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 2
HEARING CONSERVATION PROGRAM (CONT.)
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 Universal Ear Muffs UF-1
NOISE REDUCTION RATING (NRR) 35 dBA 23-25 dBA
Other devices are available through plant supervision or the Occupational Health Department.
5. NOISE ABATEMENT PLAN
Engineering Noise Control Plans for Unit I are as follows:
AREA Vinyl Distillation (D-302 & 303) Vinyl Furnace (Compressor C-350)
NOISE CONTROL OPTION
Insulate during 1991 shut-down Isolate, insulate, check internal silencer mechanism on muffler, add silencer
Any new equipment or changes to the process, will be evaluated for noise and when feasible, engineered to Keep noise levels below 85 dBA. Contact your Industrial Hygienist.
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
6. NEXT REVIEW DATE: October 31, 1992
CONFIDENTIAL
R&Si 54042
. JHS' File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 1
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 every 6 months by Elmer Moltz (Senior Technician/Repair) for signs of deterioration. If deterioration is found the material will be repaired or removed. In the 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 6 month 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 III 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 th 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/cc), 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.
5. PROCEDURES
Written procedures have been developed for the handling of asbestos materials during the performance c maintenance, demolition, and renovation activities to be conducted at the facility. The procedures are located in the Repair Office.
CONFIDENTIAL
R&S 154043
* . JHS' File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
ASBESTOS PROGRAM (CONT.)
Page 2
6. ASBESTOS ABATEMENT PLANS All forms of asbestos containing materials are being phased out as replacement Is warranted.
7. NEXT REVIEW DATE: October 31, 1992
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. -IJltf File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE, OC-101
Page 1
VENTILATION PROGRAM
CONFIDENTIAL
1 . PROGRAM DESCRIPTION
The Unit I ventilation system includes as follows:
ID Number
Location
Last Survev
Next Survev
Average Velocitv
OC10101 OC10102 OC10103 OC10104 OC10105 OC10106 OC10107 OC10108 OC10901 OC10902
OC-101 OC-101 OC-101 OC-101 OC-101 OC-101 OC-101 OC-101 OC-109 OC-109
3/89 3/89 3/89 3/89 Demolished 3/89 3/89 3/89 7/90 7/90
3/92 3/92 3/92 3/92
3/92 3/92 3/92 7/93 7/93
139 130 111 112
117 135 144 110 111
The hoods are equipped with make-up air and are separately ducted to the outside.
2. OPERATING CRITERIA
A. Periodic Performance 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
5. NEXT REVIEW DATE: October 31, 1992
r &s i 54045
JIJS'File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/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. Physical stressors and other activities which can contribute to musculoskeletal injuries include manual lifting, repetitive motion/forceful exertions, or excessive vibration. Identification of these factors is the basic responsibility of the assigned plant ergonomics contact with assistance from the plant Industrial Hygienist.
2. MANUAL LIFTING ACTIVITIES
Jfl.b .-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 50 lb 35 lb fiberpacks
3. REPETITIVE MOTION/FORCEFUL EXERTIONS none identified
4 . POWER TOOL USE
Power tools use in Unit 1 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: October 31, 1992
CONFIDENTIAL
r &s 154046
IHS /File #001-3700-90
1990-92 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 Safety Standard 0-45 and 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, fire departments and Occupational Health are detailed in the RPM.
2. TYPES OF RESPIRATORS USED
Respirator Type
Cartridges Filter. Canisters
Sources of Breathing Air
AOR9722 Mouthbit Survivair 9811-22 Scottovista #801548-04 Full face ELSA 5 min. Pack Survivair 30 min. SCBA XL-30 Model 9838-9 or Mark I Model 9845-2 Survivair 5 min. SCBA Pack 9881-22 3M 8710 Dust Mask
OVAG (R722) NA NA NA
NA NA NA
NA Cylinder Cylinder 5 min. air tank
30 min. air tank 5 min. air tank NA
OVAG - NIOSH approved for Organic Vapors and Acid Gases
Industrial Hygiene is contacted whenever a new respirator is selected.
3. RESPIRATORY USE CATEGORIES
Job Classification
User Category
Resp. Types Used
Individually Issued
Office Personnel (Engineers,
Unit manager, etc)
Escape Only
Secretaries
Escape Only
Lab Personnel
Escape Only
Process Technician/Process
Supervisor
Routine/Emergency
MP MP, ELSA MP
All available in block
MP MP MP
MP
MP = AOR9722 Mouthbit Routine/Emergency users are fit tested and medically approved biennially.
Respirator training is conducted by:
Respirator Type MP All except MP
Trainer Plant Rep Industrial Hygiene
Freouencv Annually Annually
Visitors, contractors and employees are required to carry an escape respirator on their person while in block process areas. The escape respirator is an AOR 9722 MP.
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1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
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RESPIRATORY PROTECTION PROGRAM (CONT.)
4. USE SITUATIONS
Respirator Tvpe/Filter
Mouthbit
Chemical of Concern
chlorine, HCL
Survivair airline/ Scottovista airline
Chlorinated Hydrocarbons Chlorine, HCL
ELSA
All chemicals
Survivair 30 min. SCBA
All chemicals
Survivair 5 min. SCBA All chemicals
Dust mask
Silica, aluminacopper chloride, Gunite dust
5. RESPIRATOR CLEANING STATIONS
Use Situation
escape only
Line or equipment opening that cannot be cleared < acceptable guidelines
Escape
Emergency response
Escape
Sandblasting, catalyst addition, furnace refractory repair
Filter Chango-ool biannually or after use NA
NA
NA NA
NA
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.
Contaminated respirators and cartridges which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.
6. RESPIRATOR STORAGE
Respirator MP ELSA
SCBA (30 min.) SCBA (5 min.) Airline masks 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 Storage cabinet in supply room or personal lockers
Safety supply room
Except for the mouthpiece respirator, all respirators must be stored in secondary containers such as a plastic bag or storage box. A plastic cap is sufficient for the MP respirator. 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.
CONFIDENTIAL
m % w
o
CD
I1HS ;File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 3
RESPIRATORY PROTECTION PROGRAM (CONT.)
7. INSPECTION SCHEDULE
Respirator
Frequency
Survivair Airline/ Scottovista Airline
ELSA
Survivair 30 Min. SCBA
Survivair 5 min. SCBA MP
Before each use Weekly Annually Before each use Weekly Annually Before each use Weekly Annually Before each use Weekly Annually Before each use Annually
By
---------------------------------
----
User Plant Rep Fire Department Owner Plant Rep Fire Department Owner Plant Rep Fire Department Owner Plant Rep Fire Department Owner Owner
Documentation Relairtarf-Bv
-- ---
none Plant Rep Fire Dept. none Plant Rep Fire Dept. none Plant Rep Fire Dept. none Plant Rep. Fire Dept. none Plant Rep
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 inspections, fit testing, and training are maintained by the plant safety contact. Original signatures on training 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: October 31, 1992
C O N FID E N TIA L
R&Si 54049
\IIIS File #00-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/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 has not previously been conducted. A training program is being developed for 1991.
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. Self-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:
Temperature fFl
72 - 79 80 - 87 88 - ?
Maximum Stay Time fmin.l 40 30 20
5. NEXT REVIEW DATE: October 31, 1992
Minimum Rest Time (min.) 20 30 40
:d ocn U4Oco*jll
CONFIDENTIAL
. JHS1 File #OC 1-3700*90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101
Page l
HEALTH SURVEILLANCE PLAN
1 . HEALTH SURVEILLANCE All employees are offered core examinations every two years.
2. MEDICAL SURVEILLANCE REQUIREMENTS3
The following job classifications are included in the MSR programs as identified below:
Job Classification
MSR
Tests
Test Frequency
Process Technician
Noise
Audiogram
Annual
Vinyl Chloride
Health history, physical measurements, blood chemistries, (hepatic), hands on physical
Unit Technician
Vinyl Chloride (10 + years)
same as above
same as above same as above
Semi-annual same as above
3. DOCUMENTATION Results are reported individually and in group format to area supervision.
CONFIDENTIAL
R&S154051
JIJS'File #OC1-3700-90
1990*92 OCCUPATIONAL HEALTH PROGRAM UNIT 1/VINYL CHLORIDE, OC-101
Page I
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. Copies of the training records will be stored in the Industrial Hygiene Manual until the time of the next regularly scheduled Occupational Health Plant Program review. 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 1990/1992:
1Ml Vinyl Chloride Ethylene Dichloride Benzene Hydrogen Chloride 1,1,2,2-Tetrachloroethane Sodium Hydroxide
1992 Vinyl Chloride Ethylene Dichloride Benzene Chloroform 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 ail materials with Priority Rating of 3 (see CPAI or Appendix F) d. health hazard information for the key agents listed above
See Section 11.2. of Hazcom for other training requirements.
Any temporary employees shall review and document: b,c,d.
6 . ASBESTOS TRAINING
All personnel who work in Unit I must receive initial training. Personnel who handle asbestos must receive annual training. Consult the Texas Operations Asbestos Handbook for training requirements.
CONFIDENTIAL
R&S 154052
^I|S 'File #OC1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 2
INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
7. NOISE TRAINING
Noise training for Unit I is required on an annual basis as some job classifications are on the Hearing Conservation Program. Refer to Safety Standard 0-46 and 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 th 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 (one time, documented):
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 on a periodic basis for experienced employees. Training should be documented.
1 1 . PROTECTIVE EQUIPMENT TRAINING
Per 29 CFR 1910.132 protective equipment shall be provided, used and maintained for employees with potential of exposure to environmental or process hazards. Personnel are to be trained on the proper use or applicable 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 Safety Ref. 7.
CONFIDENTIAL
R&S 154053
,UiS 'File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-101
Page 3
INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
1 3. 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.
All new employees must receive at least 24 hours of initial training. Current employees do not need the 24 hours of initial training if equivalency can be proved. Certificates of training must be issued to all employees. Eight hours of refresher training is required on an annual basis.
CONFIDENTIAL
R&s i 54054
IHS' File #00-3700-90
1990-92 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 hygien , 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 biennally 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:
PPE Item
Totally encapsulated suits (Maintenance activities)
Test Method Visual Inspection
Frequency Biannually
ay Dept Rep
Chemical protective gloves (high hazard operations)
Air test method
Each use
User
Electrical rubber gloves Electrical rubber blankets
High voltage test Air test method
High voltage test
Biannually Each use
Biannually
Elec Shop User
Elec Shop
CONFIDENTIAL
H&S154055
fIHS File #00-3700*90
1990-92 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
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:
There is no on site laundry at Unit I. Cotton gloves and Nomex suits are cleaned at Brazoria Laundry.
Material Safety Data Sheets are sent to Brazoria Laundry 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: October 31, 19923 * 05
CONFIDENTIAL
3 0cn wi oc0n5
r IKS* File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 3
TABLE 1 UNIT l/VINYL CHLORIDE PPE INVENTORY, 1990
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 gloves 3. North #E214B dielectric natural rubber gloves 4. Scooba #JPS 10B Cotton Gloves
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 - Survivair 30 min, SCBA XL-30, Model 9838-9 or Mark I Model 9845-2 - Survivair 5 min. SCBA Pack 9881-22 2. Airline Respirators Survivair 9811 -22 3. Half-Mask Respirator - none 4. Dust Mask - 3M8710 5. Escape Respirator AO Mouthpiece R9722 with organic vapor/acid gas cartridge - ELSA 5 min. Pack
F. HEARING PROTECTION 1. Carboflex # 600 Sound Ban (NRR=22) 2. E-A-R Foam Ear Plugs (NRR=29) 3. Wilson Ear Muffs
G. FALL/RESCUE PROTECTION 1. RTC 430 Body Harness 3. RTC 252 Lanyard
C O N FID EN TIAL
R&S 154057
fIHS' File #OC1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE. OC-IOl
Page 1
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
IsotoDe
Cesium 137 Cesium 137 Cesium 137 Cesium 137 Cesium 137 Cesium 137 Nickel 63 Cesium 137 Cesium 137
Activitv (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 Varlan 3700 GC D-35 D-35
TRAINING:
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. Dale Green
(Environmental Supervisor) is responsible for conducting the inspections.
--
The GM radiation meter used for surveys at Unit I is located in meter calibration program,
office and is in the annual
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.
G. NEXT REVIEW DATE: October 31, 1992
r HIi File #001-3700-90 Direct__ Chlorination:
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
DEPARTMENT ACTIVITIES
Page 1
Oxvchlorl nation: Vlnvl Furnaces:
CONFIDENTIAL
' * rIHS File #OC 1-3700-90 '
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Yinyi Distillation-
DEPARTMENT ACTIVITIES (CONT.)
n Page 2
PV-PfddVCt__ Recovery:
Repair: Lab: Loading:
O H W a
CONFIDENTIAL
REDACTED
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liiejDejQ mo|j | nun
CONFIDENTIAL
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B&si5406i
ti
06-00i-130 # a||J SHI
3
f IHS File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 1
JOB DESCRIPTIONS
Unit Manager. Unit Secretary. Sr. Clerk Tvplst: 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.
Process Technician - Control: The Control Center 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 Control Center Technicians time is spent in the control room.
Process Technician. Unit Technician - Loading: 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, Unit 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 ar 50% in the office.
290t'S lS 18fci
' t III!) File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 2
JOB DESCRIPTIONS (CONT.)
Senior Technician: Sr. Technicians rotate between areas and serve as lead workers for the Process Technicians. Responsibilities are the same as the Process Technicians in any one area in addition to the training of new technicians. The time distribution is roughly the same as the Process Technicians.
Process Technician. Unit 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.
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, Production Supervisor,Sr. Production Engineer, Process Engineer, Process Specialist. 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. Sr. Process Chemical Specialist. 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.
Purchasing Tech. Specialist: The Purchasing Tech Specialist is responsible for ordering parts, supplies, and equipment for plant maintenance and addition projects. He also maintains the inventory of stock, tools, parts and equipment used in routine plant activities. Estimated time distribution is 100% in the spare parts room and warehouse.
Contractors: A significant amount of maintenance activities in the plant are performed by contractors in various capacitU including welding, pipefitting, carpentry, insulation, painting, and electrical work. Estimated time distribute vary depending on the nature of the work.
CONFIDENTIAL
R&S 154063
Ills .File #001-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 1
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 (HAZWOPER). 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 and Asbestos standards. There are three initial requirements the plant must complete to be in compliance with the Benzene standard. They are as follows:
1. Initial personal monitoring, both 8-hour TWA and excursion, must be conducted to evaluate employee exposures to benzene.
2. Initial training of the existing Dow employees and Contractors must be conducted as outlined in the standard.
3. Benzene training should be included as part of the Unit I orientation program.
There are periodic monitoring requirements depending on the initial monitoring results. In addition, monitoring needs to be conducted whenever there is a process or procedural change which may result in new or additional exposures and after a cleanup of a spill or repair of a leak, rupture or other breakdown.
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.
CONFIDENTIAL
R&S1 54064
' IHS * File #OC 1-3700-90
1990-92 OCCUPATIONAL HEALTH PROGRAM UNIT I/VINYL CHLORIDE, OC-101
Page 2
OSHA SPECIAL REGULATIONS (CONT.)
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 O
a
1
H
*
R&S154065