Document ykOajDn01ve93mx7g8Vaj2Ebr

INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS TO (NAME) Dr. R. J. Anderson, 312 COMPANY Mr. M. E. Eisenhour Dr. D. H. Glenn LOCATION Mr. J. L. Hockersmith Mr. J. B. Leverton Dr. W. R. Manning, 511 Mr. W. A. Mazzolini Mr. C. E. Moyer Mr. F. S. Provenzano Mr. M. E. Sutherland, 511 Mr. G. F. Tacquard Mr. R. J. Taylor Mr. R. N. Wheeler, 514 Suspension Vinyls Staff From: R. L. Frantz f, O. BOX 471, TEXAS CITY, TEXAS 77590 date October 31, 1977 subject vinyl Chloride Safety Association Meeting - October 6 & 7, 1977 Valley Forge, Pennsylvania This regular meeting of the Association had a record attendance of eighty-three members from virtually all of the domestic VCM and PVC producers as well as representatives from several foreign countries, including Canada, Mexico, U.K., Germany, Italy and Norway. Union Carbide was represented by Mr. R,, N. Wheeler and the writer. A complete attendance list will be mailed to me; if any of you are interested in receiving a copy, let me know. The first item on the agenda was a discussion of the physiological effects of VCM by Dr. R. W. McBurney, a physician from Diamond Shamrock. Some highlights of his presentation were: VCM is a relatively non-toxic chemical - it can cause narcosis and even death by asphyxiation. It is detoxified in the liver. Its target is the lining of small blood vessels and can cause Reynaud's phenoma by plugging up the blood vessels in the end of the fingers which can lead to AOL (loss of bone structure in the end of the fingers). It can also cause cirrhosis of the liver, enlargement of the spleen and of course angiosarcoma of the liver. Angio is Greek for worms (small blood vessels) and sarcoma is cancer. All of these effects are rare. VCM is a very weak carcinigen - only one in 3400 of those who've had prolonged, extended high exposure to VCM developed angiosarcoma. It is not a risk for workers ex posed to from one to twenty-five ppm (his opinion, of course), VCM is picked up in the blood and transferred to the liver and lungs is expelled through the lungs. A question from Herm Waltemate of B. F. Goodrich to Dr. McBurney was of perhaps more interest than Dr. McBurney's answer. It was "Is it more likely to get angio sarcoma from ingestion than from breathing?" The answer was "No". It was pointed out that there have been sixty-four deaths attributed to angiosarcoma over the last twenty-five years. UCC 093373 Vinyl Chloride Safety Association Meeting - October 6 & 7, 1977 Valley Forge, Pennsylvania 2. A brief discussion of OSHA related problems followed a presenta tion on medical surveillance and brought forth these items of note: 1) Air Products allows outsiders in the regulated area for forty-five minutes if the monitors show less than 5 ppm VCM. 2) Several companies report only large emergency VCM releases to OSHA. Someone stated that there is an OSHA program directive which says that OSHA should be notified if an employee is exposed to 100 ppm VCM without a respirator. Others said they report only when an employee is exposed to a massive release in an emergency situation. In the absence of exposure, need not report to OSHA. 3) A poll showed that 18 - 20 companies do not allow fertile females to work in regulated area, while ten companies do. Herm Waltemate of B. F. Goodrich reported on a rash of OSHA inspections at nearly all of their VCM - PVC plants early in August of this year. There were several non-serious citations most of which did not relate to VCM. B. F. Goodrich has a serious problem at their Louisville location - the employees do not believe the monitoring data; they believe the VCM levels are higher than indicated. The OSHA inspection at Louisville was the result of a union complaint and lasted twelve days. B. F. Goodrich said 80% of their OSHA inspections resulted from employee complaints. In the last two years, nineteen companies reported OSHA inspections; thirteen times OSHA sampled for VCM; three citations because 1 ppm was exceeded. Air products got a citation for re-entering the area after an accident without monitoring. Firestone was cited for using a MSA mask with a Scott canister. Both Dow and B. F. Goodrich are testing badge monitor devices. Four companies use area monitors only for compiling personnel ex posures; seven use area monitors plus carbon tubes and the rest carbon tubes only. Only Pantasote who uses the Eicom monitoring system felt that there was good correlation between area monitors and carbon tubes. The rest felt that area monitors generally gave slightly higher results. UCC 093374 Vinyl Chloride Safety Association Meeting - October 6 & 7, 1977 Valley Forge, Pennsylvania J. A poll on average VCM concentrations in the reactor area showed: <0.5 0.5 1.0 2.0 >5 ppm - 1.0 - 2.0 - 5.0 ppm ppm ppm ppm -2 -6 -8 -8 -0 (I voted here) There was a 50 - 50 division between having VCM unloading facilities regulated all the time and only when unloading VCM tank cars. B. F. Goodrich reported that 75 - 90% of their area monitoring points were below 1 ppm. The range of area monitors was from 0 to 10 ppm up to 0 - 3600 ppm. Most use VFA's; three or four use IR. Nine have more than one sample point per reactor. Alarming at 1 ppm Alarming at 5 ppm Alarming at 10 ppm Alarming at 25 ppm - 9 14 (UCC) 1 1 Zone Alarms - 11 Only control room alarms -7 Alarms @ each point - 9 (UCC) Lights & audible - 19 (UCC) alarms David Kuhn of Conoco gave an update of EPA activities since October 21, 1976. Nothing much was presented that we have not already received from Nick Wheeler. There seemed to be general agreement that by law all VCM relief device openings and blown rupture discs should be reported to EPA; however, I had the impression that it was pretty common not to do this. I described briefly the problem we had with RB-90 discs not opening fully and that we were going to the S-90 type (without knife blades). There was considerable interest in this and I went into greater detail with several people who inquired about it after the meeting. Some discussion ensued on testing and inspecting VCM storage tanks. Most have T & I schedules of five years or more - some of twenty-five years. One case of checking inside VCM storage tanks after seventeen UCC 093375 Vinyl Chloride Safety Association Meeting - October 6 & 7, 1977 Valley Forge, Pennsylvania 4. years and finding no corrosion. Bob Wilson of Stauffer presented a list of information on changes in DOT regulations for VCM tank cars - head protection, thermal protection, new type labels, etc. From what I've seen of UCC's new VCM tank cars, I believe that our Distribution Department must be tuned in to all of the new requirements. Next was "True Confessions". Leading off was a very complete slide presentation, including some excellent photography of an explosion and fire at the Primex 80 MM pounds per year PVC Plant in Pueblo, Mexico. On June 19, 1977 all six of their VCM storage tanks were destroyed by fire. They had six (4 - 90,000 lb, 2 - 60,000 lb) above ground horizontal VCM storage tanks located ten feet apart. Cause of the accident was human error and described as follows: An experienced (ten years in this department) employee was assigned to remove a malfunctioning actuator from a remotely operated, spring loaded Tufline valve on the bottom of one of the VCM storage tanks (33 meters long, 3.3 meters dia meter) . He had done this job many times before since this seemed to be a recurring problem. Instead of removing the actuator from the valve, he started removing the bolts that held the valve onto the tank. All the bolts came out and a three-inch stream of liquid VCM started spilling out the bottom of the tank. A large vapor cloud just drifted back and forth. People inside and outside the plant were told to shut off sources of ignition. Water was sprayed on the vapor cloud. Yet, one hour and twenty minutes after the incident started, there was a visible cloud 1100 feet long, 800 feet wide and five feet high. One hour and twenty-five minutes into the incident the cloud ignited 400 feet south of the spill from outside the plant. Four people were injured, one who was outside the plant using a fire hose died eight days later. Damage was three million dollars. Black smoke towered 1000 meters high. The fire caused a chain reaction ultimately catching all six of the VCM storage tanks on fire. One tank was still burning the next day. Pictures of one tank which was aluminum (just a melted blob) and one tank which was completely flattened were impressive. Interesting to compare with our C-l accident are some figures which were quoted. The steel storage tanks were 5/16" carbon steel rated for vacuum to 150 psig service. One tank traveled through the air 540 meters (^ 1780 feet) after it over-pressured. Other large sections went 300 meters and 200 meters . UCC 093376 Vinyl Chloride Safety Association Meeting - October 6 & 7, 1977 Valley Forge, Pennsylvania 5. Safety valves on the storage tanks were sized by the ASME code, not the NFPA code which calls for larger capacities. Primex plans to install a big sphere for VCM storage designed for vacuum to 90 psig, put a big pond of water under it, insulate the bottom half and size the safety valves per NFPA Section 56 for LP Gas. The next "True Confession" was a brief description of Carbide's Labor Day Explosion of Non-Solvent C-l Autoclave at Texas City presented by the writer. Since the investigation team had not yet issued its report, I could not give the cause of the accident or very many of the details. I did promise the group a more complete report at a later date. In answer to a direct question, I did state that equipment failure was not a factor. Next, Esso in Sarnia, Ontario reported they had noted chloride stress cracking in two 304 S.S. pressure vessels adjacent to welds. Vessels had been in VCM service since 1966 under a range of temperatures from 50C to 85C (probably resin stripping tanks). They did not find such cracking in 316 S.S. NOTE: I discussed this with Bill Ashbaugh and he indicated that there should be no difference between 304 S.S. and 316 S.S. in this respect. Following a presentation by Amos Dixon of Goodyear on Safe Methods For Handling Peroxide Catalysts (all of which we follow with the exception that we do not have a back up diesel generator) there was one final "True Confession" show stopper by Pete Bogart of Tenneco. At one of their New Jersey PVC Plants they had the first incident in history where a water sprinkler system caused a fire. They have a water deluge system inside their catalyst storage freezer Due to a hydraulic shock caused by suddenly shutting water off the system, a water line broke flooding the walk-in freezer with three feet of 75F water (catalyst was supposed to be kept below 28F). Several hours later the catalyst started to decompose. No one was hurt, but they lost $4,000 worth of catalyst. A poll showed that of eighteen companies that have walk-in cat storage freezers, nine have water deluge systems inside. Carbide does not. One final note of interest. During a discussion of methods of VCM Emission Control from vents a poll was taken which showed twenty-five locations are using or plan to use incinerators (most with scrubbers in conjunction) - seventeen of these will have duplicate incinerators since on stream time is only 50 - 90%; six locations have opted for absorption in solvent and five locations for carbon adsorption. As usual, this meeting was very worthwhile with many mutual items of safety discussed in an open and frank manner. UCC 093377