Document 066Dqd8456k3e9Rop25MXKEGk

PLAINTIFF'S EXHIBIT INTEROFFICE MEMORANDUM SH-1629 AUGUST 17, 1992 FROM: T. M. DOSSEY, SUPERINTENDENT FACILITIES SUPPORT DEER PARK MANUFACTURING COMPLEX TO: ALL HEALTH AND SAFETY COMPLEX ORDER BOOK HOLDERS DEER PARK MANUFACTURING COMPLEX SUBJECT: REVISED COMPLEX ORDER S-125, ASBESTOS Attached is the minor revision to Health and Safety Order S-125, Asbestos. The Order has been revised to clarify requirements when working with asbestos-containing materials. Highlights of the revisions include: 1. The Order includes an expanded definitions section to clarify terms and concepts. 2. Shell employees will only do incidental asbestos work. Asbestos work which is not incidental will be done by qualified contractors. 3. Asbestos training for Shell employees includes awareness training for all employees and hands-on training for employees doing incidental work. 4. Inspection and maintenance procedures shall be developed to ensure the continued integrity of asbestos-containing materials. 5. The EPA Asbestos NESHAP regulations require government notification and an on-site trained person for demolitions and renovations. As part of the revisions to asbestos training, new training packages are being developed at this time. A new video and leaders guide package will cover awareness training. A hands-on class will cover procedures and practices for incidental removal. These training packages are scheduled for delivery in October 1992. To allow for completion of the training, the revised Order becomes effective November 17, 1992. Please insert the revised Order in Volume 2 of your Health and Safety Complex Order book and discard the old Order at that time. Questions on the Order should be directed to D. L. (Lynne) Tackett, Group Leader, Health and Safety-Facilities Support, at 246-1218. T. M. Dossey Attachment DPMC-OIOOO lam 007517 SHELL DEER PARK MANUFACTURING COMPLEX COMPLEX SUMMARY: S-125 ASBESTOS SAFETY ORDER POINTS OF INTEREST: 1. All insulation shall be treated as asbestos-containing material (ACM), unless there is documentation the insulation is non asbestos. 2. Examples of ACM that may be found at the Complex include: insulation purchased prior to 1973, gaskets, building materials, and brake linings. 3. Departments with ACM will establish inspection and maintenance procedures to ensure the continued integrity of the ACM. 4. Asbestos is a potential health hazard when taken into the body. Asbestos may enter the body by inhaling airborne fibers or ingesting asbestos contaminated foods or beverages. 5. Personal hygiene is very important in protection from asbestos. 6. Storage, preparation, and consumption of food or beverages where exposure to airborne asbestos is likely is not permitted. 7. Respiratory protection and protective clothing are required for all asbestos related work. 8. Annual medical surveillance exams are provided for employees with potential exposure to asbestos. 9. Periodic training and maintenance of training records are required. 10. Environmental Compliance is to be notified prior to demolition or renovation of ACM so that proper notification to the Texas Air Control Board can be made. All employees are responsible for knowing and understanding the requirements of this Safety Order. S-125.DOC/S006 - 00019 DPMC-OlOOl LAM 007518 SHELL DFFR PARK MANUFACTURING COMPLEX COMPLEX ASBESTOS SAFETY S--125 PAGE 1 OF 8 NOVEMBER 17, 1992 (R) I. INTRODUCTION A. Purpose and Scope The purpose of this Order is to establish minimum requirements for managing and working with asbestos-containing materials (ACM) at the Complex. Occupational exposures to asbestos are regulated by the Occupational Safety and Health Administration (OSHA). Asbestos demolition, renovation, and waste disposal are also regulated by the Environmental Protection Agency (EPA). B. Use of Asbestos Asbestos is a mineral silicate occurring naturally as a variously colored fiber. It is most frequently encountered within the Complex as insulation on equipment, piping and structures installed prior to 1973. While purchase of new asbestos-containing insulation has been discontinued, asbestos-containing insulation may be encountered in older units for many years to come. Asbestos may also be found in other materials at the Complex (see Attachment I). C. Health Hazards of Asbestos Asbestos is a potential health hazard when taken into the body, even in very low concentrations. Asbestos can enter the body by inhaling airborne fibers or ingesting contaminated foods or beverages. Asbestos is associated with a variety of diseases. These include: 1. Asbestosis, a non-malignant scarring of the lungs. 2. Bronchogenic carcinoma, a malignancy, or cancer, of the lungs. 3. Mesothelioma, a malignancy of the lining of the chest cavity. 4. Cancers of the stomach, colon, and rectum. S-125.D0C/S006 - 0001 DPMC-01002 LAM 007519 ASBESTOS SAFETY S-125 PAGE 2 OF 8 NOVEMBER 17, 1992 (R) These diseases develop slowly, and usually do not become evident until many years after initial exposure. Recent scientific studies have shown that individuals who smoke and have exposure to asbestos have a significantly greater health risk than asbestos workers who do not smoke. II. DEFINITION OF TERMS A. ACM - asbestos-containing material. B. ADEQUATELY WET - to mix or penetrate ACM with liquid to prevent the release of particulates. If visible emissions are observed coming from the ACM during handling, then it is not considered adequately wet. C. AUTHORIZED PERSON - any person authorized by their employer and required by work duties to be present in a restricted or regulated area. D. COMPETENT PERSON - one who is trained and has authority to take corrective action during asbestos work. Training shall include identification of asbestos hazards, removal procedures, practices for reducing the hazard, and contents of the OSHA asbestos standards. E. DEMOLITION - wrecking or taking out any load-supporting member of a facility or the intentional burning of a facility (see Attachment II). F. HEPA - a high efficiency particulate air filter capable of trapping and retaining at least 99.97 percent of 0.3 micrometer diameter mono-dispersed particles. G. INCIDENTAL ASBESTOS WORK - asbestos related work that is non-repetitive, lasts no more than one hour, and involves small amounts of ACM. To assist in determining whether a task is incidental or not, the following examples are provided: 1. The repair or removal of no more than 3 linear feet of ACM on piping with a diameter of 12 inches or less. 2. The repair or removal of no more than 3 square feet of ACM on other components. 3. Removal of asbestos-containing gaskets, packing or similar ACM on a single piece of equipment. 4. Electrical or other cable work that disturbs ACM. S-125.D0C/S006 - 0002 DPMC-01003 LAM 007520 ASBESTOS SAFETY S-125 PAGE 3 OF 8 NOVEMBER 17, 1992 (R) 5. Changing the filter in a HEPA filter asbestos vacuum. Work disturbing hot ACM shall not be considered incidental asbestos work. Hot ACM presents additional handling concerns because it is difficult to keep the ACM adequately wet. Hot ACM may also melt disposal bags. ACM shall be considered hot if the temperature of the material is at or above 150 degrees Fahrenheit. H. REGULATED AREA - a work area where asbestos work is taking place and where airborne asbestos concentrations will or will likely exceed the permissible exposure limit. I. RENOVATION - altering a facility or facility component in any way, including the removal of ACM from a facility component. Renovation of ACM may be encountered during upgrading of insulation, or during turnaround and maintenance activity in some units. J. RESTRICTED AREA - a work area where asbestos work is taking place and where airborne asbestos concentrations will not exceed the permissible exposure limit. III. GENERAL REQUIREMENTS The following are general requirements for managing ACM: A. In the absence of specific knowledge to the contrary, all insulation shall be treated as ACM. Insulation can be verified as non-asbestos material by: 1. A bulk sample analysis to determine the presence or absence of asbestos. 2. Specific documentation that the insulation has been previously tested and proven to be non-asbestos. B. No one shall be exposed at or above the permissible exposure limits for asbestos. The permissible exposure limit for asbestos is 0.2 fibers per cubic centimeter (f/cc), as an 8-hour time weighted average (TWA). The short-term excursion limit is 1 f/cc, as a 30-minute TWA. S-125.D0C/S006 - 0003 DPMC-01004 LAM 007521 ASBESTOS SAFETY S-125 PAGE 4 OF 8 NOVEMBER 17, 1992 (R) C. Departments responsible for facilities and equipment with ACM will establish inspection and maintenance procedures to ensure the continued integrity of the ACM. These procedures shall include: 1. identification of ACM; 2. routine inspection of ACM; and 3. cleanup and repair of deteriorating ACM. D. Insulation containing asbestos shall not be purchased, nor recovered for re-use. When replacing other ACM, use non-asbestos substitutes when practical. E. Departments responsible for facilities and equipment with ACM shall post unit danger signs (see Attachment III) at the unit boundaries to indicate that the unit contains asbestos materials. F. Shell employees will only do asbestos work that is considered incidental asbestos work. All other asbestos work will be done by contractors trained to do asbestos-related work. Minimum work practices for asbestos work are identified in Attachment IV. G. All external ACM shall be removed prior to equipment, piping, or structures being transported from the originating department. ACM that is installed inside equipment, piping or structures shall be removed if it could be disturbed during transportation or during planned maintenance. The ACM shall be removed prior to the equipment, piping, or structures being transported from the originating department. Internal ACM that will not be disturbed during planned maintenance or during transportation may be left in place. Equipment, piping, or structures with internal ACM being transported from the originating department shall be accompanied by notification that the equipment contains asbestos. All equipment, piping or structures that are to be disposed via salvage shall have all ACM removed prior to being transported from the originating department. S-125.DOC/S006 - 0004 DPMC-01005 LAM 007522 ASBESTOS SAFETY S-125 PAGE 5 OF 8 NOVEMBER 17, 1992 (R) H. Departments planning demolition or renovation work involving ACM shall notify the Environmental Compliance Department Asbestos Contact. One month advance notification shall be made when: 1. There is any demolition work, even if there is no ACM involved (see Attachment II). 2. There is renovation involving the removal of 260 linear feet or more of ACM on piping or 160 square feet or more of ACM on other components. A list of information required in the notification is included in Attachment V. For emergency maintenance work involving ACM, notification must be given to the Environmental Compliance Department Asbestos Contact prior to the start of work. For emergency work during other than normal business hours, contact the Environmental Supervisor prior to the start of work. I. Changes to the original demolition or renovation notification require a revised notice (see Attachment V). The Environmental Compliance Department Asbestos Contact shall be notified of any changes atleast one week prior to the original start date. J. All demolition and removal work requiring notification will also require the presence at the job site of a person trained in the provisions of the EPA Asbestos NESHAP regulations. A certificate of completed training shall be posted at the job site. This requirement shall be met by attaching a copy of the trained person's (generally the contractor supervisor) certification to the safe work permit posted at the job site. If a regulated area is established, a competent person, trained in the provisions of the OSHA Construction Asbestos standard is also required at the job site. K. All asbestos waste shall be doubled-bagged in at least 6 mil polyethylene bags. All bags used for disposal shall be labelled with the OSHA hazard label language and the identification of the waste generator (see Attachment III). S-125.DOC/S006 - 0005 DPMC-01006 LAM 007523 ASBESTOS SAFETY S-125 PAGE 6 OF 8 NOVEMBER 17, 1992 (R) IV. TRAINING REQUIREMENTS A. Awareness Training Upon initial assignment to the Complex, all employees shall receive asbestos awareness training. The training shall cover the areas identified in Attachment VI. All employees shall complete annual refresher training by reviewing this Order and passing the test in the Health & Safety Orders (HSO) System. B. Incidental Asbestos Work Training In addition to awareness training, employees who do incidental asbestos work shall complete the hands-on Incidental Asbestos Work Training class. This class covers specific work practices, procedures, and controls required for incidental asbestos work. Employees shall receive this training prior to starting a job task involving incidental asbestos work, unless the employee has received this training within the previous twelve months. C. Training Records Each department shall document employee asbestos training, including awareness and incidental training, in the Shell Training Administration and Records System (STARS). V. MEDICAL SURVEILLANCE REQUIREMENTS An asbestos medical surveillance program is provided for Shell employees with potential exposure to airborne asbestos. The current entrance criteria is exposure to asbestos concentrations at or above the action level of 0.1 f/cc, as an 8-hour TWA, for 30 or more days per year. Employees whose historical job tasks involved periodic installation or rip-out of ACM are also eligible for the medical surveillance program. Annual medical examinations are provided to those employees in the surveillance program. S-125.DOC/S006 - 0006 DPMC-01007 LAM 007524 ASBESTOS SAFETY S--125 PAGE 7 OF 8 NOVEMBER 17, 1992 (R) VI. RESPONSIBILITIES A. Each employee shall be responsible for: 1. Following all required work practices when doing incidental asbestos work. 2. Specifying asbestos hazards and work practices on work permits when asbestos will be encountered. B. Each department responsible for facilities with ACM is responsible for: 1. Establishing inspection and maintenance procedures. 2. Providing and documenting employee training. 3. Notifying Environmental Compliance of demolition and renovation work. 4. Posting unit danger signs. 5. Removing external ACM and appropriate internal ACM from equipment before transporting. C. Environmental Compliance is responsible for notifying the Texas Air Control Board (TACB) of demolition and renovation work. For emergency maintenance asbestos work during other than normal business hours, the Environmental Supervisor is responsible for notifying the TACB. D. The Health and Safety Department is responsible for: 1. Providing technical support for administration of a) training, b) compliance with requirements, c) bulk sample analyses. 2. Exposure monitoring during incidental asbestos work. E. The Medical Department is responsible for administering medical surveillance examinations. S-125.D0C/S006 - 0007 DPMC-01008 LAM 007525 ASBESTOS SAFETY S-125 PAGE 8 OF 8 NOVEMBER 17, 1992 (R) F. The Environmental Operations Department is responsible for administration of asbestos waste disposal. VII. REFERENCES A. 29 CFR 1926.58 Asbestos, Occupational Safety and Health Administration. B. 29 CFR 1910.1001 Asbestos, Occupational Safety and Health Administration. C. 49 CFR 61 National Emission Standard for Hazardous Air Pollutants for Asbestos, Environmental Protection Agency. Approved By: Superintendent Facilities tort S-125.DOC/S006 - 0008 DPMC-01009 LAM 007526 ATTACHMENT I EXAMPLES OF ASBESTOS CONTAINING MATERIALS FOUND AT THE COMPLEX Insulation Fire retardant paper Refractory - Coatings Insulation Cements Heater Boards Heater Mantels Electrical Cords Floor Tiles Ceiling Tiles Roofing Materials Wall board Transite Gaskets Seals Darcon Cups (for pumps) Machinery packing Compressor rings Brake linings Clutch linings Friction linings Concrete piping Concrete products Fire proofing PIastics Welding blankets S-125.D0C/S006 - 0009 DPMC-01010 LAM 007527 ATTACHMENT II DEMOLITION ACTIVITIES Demolition is defined in the OSHA and EPA asbestos standards as the wrecking or taking out of any load-supporting structural member of a facility or the intentional burning of a facility. A facility is considered a building or structure. For further clarification, EPA - defines load-supporting members as structural components such as beams and load-supporting walls. The following list is provided to assist in determining whether or not demolition notification is required when no asbestos removal is involved in the demolition: FACILITY/EQUIPMENT NOTIFICATION REQUIRED Office Building Yes Control Room Yes Maintenance Shop Yes Other Buildings (pump house, analyzer shed, sub-station) Yes Cooling Water Tower - wall - fan Yes No Furnace/Boiler - wall - tubes Yes No Piping No Pumps/Compressors * No Vessels/Columns/Tanks * No Heat Exchangers No Flares No Stairways/Steps/Ladders/Platforms No Wastewater DAF/Clarifiers/Ponds/Separator Boxes No * includes foundations S-125.D0C/S006 - 00010 DPMC-oi laM 007528 ATTACHMENT III ASBESTOS HAZARD WARNING SIGNS AND LABELS A. UNIT DANGER SIGN DANGER THIS UNIT CONTAINS ASBESTOS B. WARNING SIGN Standard OSHA Warning Sign Language: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA C. HAZARD LABEL Standard OSHA Hazard Label Language: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD D. WASTE GENERATOR IDENTIFICATION SHELL OIL COMPANY HIGHWAY 225 DEER PARK, TEXAS 77536 S-125.D0C/S006 - 00011 DPMC-01012 LAM 007529 ATTACHMENT IV INCIDENTAL ASBESTOS REMOVAL SAFE WORK PRACTICES The following work practices are minimum requirements when doing any asbestos work. Additional work practices, such as establishing a regulated area, a mini-enclosure, or full negative pressure enclosure, may be required when doing more than incidental asbestos work. A summary of safe work practices is provided in Table IV-A. A. Consider the potential for encountering asbestos when planning a job and again when preparing a work permit. Take bulk samples as needed for positive identification. B. Contact the area Industrial Hygienist when planning incidental tasks to arrange for exposure monitoring. Personal exposure monitoring is required to determine potential asbestos exposures. C. Establish an asbestos work area. 1. Demarcate the area with asbestos barricade tape. 2. Post hazard warning signs around the perimeter of the restricted area. D. Wear the following personal protective equipment, as a minimum, to enter an incidental asbestos work area: 1. Respiratory protection. A half-mask, air-purifying respirator with high efficiency particulate air (HEPA) filters. 2. Disposable protective clothing, including: coveralls, head covering and foot coverings. All disposable clothing must be disposed of as asbestos waste. Disposable clothing may be worn over personal fire retardant clothing when working in incidental or restricted asbestos work areas. Personal clothing shall not be worn into asbestos regulated areas. 3. Gloves and goggles. E. Use glove bags and polyethylene sheeting to collect ACM and prevent contamination of work surfaces and adjacent equipment and piping. Bag all removed ACM immediately. F. Adequately wet all ACM during removal and handling to minimize the release of asbestos fibers. Use a fine mist spray of water amended with a wetting agent, or equivalent. In places where water may not be used, such as those involving electrical systems, work practices shall be reviewed with the area Health & Safety Inspector. Available equipment for asbestos work is listed in Table IV-B. S-125.DOC/S006 - 00012 DPMC-01013 LAM 007530 ATTACHMENT IV (CONTINUED) INCIDENTAL ASBESTOS REMOVAL SAFE WORK PRACTICES G. Maintain a clean work area by wet wiping and/or vacuuming with a HEPA filtered vacuum after completion of asbestos removal and at appropriate intervals to minimize the potential for generating airborne asbestos. Use polyethylene sheeting to cover exposed ACM to minimize airborne asbestos during idle work periods. H. Transfer all bags of asbestos waste to the labelled bins at the asbestos storage and transfer facility located next to the Complex landfill. Alternatively, labelled asbestos storage bins may be set up at the job site for large removal projects. A Waste Disposal Request, DPMC-6 form is required for all transfers to the storage and transfer facility. I. Do not store, prepare, eat or drink food or beverages; chew gum or tobacco; or apply cosmetics in work areas where asbestos work is taking place. Do not smoke in asbestos work areas. This is because medical evidence indicates a greater health hazard exists for individuals exposed to tobacco smoke and asbestos. This prohibition is applicable regardless of the level of asbestos exposure and applies to all personnel in the work area regardless of whether or not they are handling or disturbing ACM. J. Take reasonable cleanup precautions prior to leaving the work area, either for break or at the end of the work shift. Remove the outer layer of protective clothing at the work area and handle as asbestos waste. Wash hands and face and vacuum clothing with a HEPA filtered vacuum before leaving the work area. K. Because of the potential to generate increased concentrations of airborne asbestos fibers, do not do any of the following activities when doing asbestos work: 1. dry sweeping, 2. use of compressed air systems, or other high pressure systems (unless these systems are equipped with a HEPA filter ventilation system to capture dust), 3. use of high speed abrasive disk saws (unless the tools are equipped with appropriate engineering controls to capture dust). S-125.D0C/S006 - 00013 DPMC-01014 LAM 007531 TABLE IV-A SUMMARY OF ASBESTOS WORK AREA HEALTH AND SAFETY PRECAUTIONS REQUIREMENT RESTRICTED REGULATED INCIDENTAL AREA AREA 1. Barricades R RR 2. Warning Signs R RR 3. Respiratory Protection R R R 4. Disposable Coveralls R RR 5. Head Covers R RR 6. Disposable Foot Covers R R R 8. Goggles R RR 9. Gloves R RR 10. Exposure Monitoring Data R RR 11. Wet Methods R RR 12. HEPA Filter Vacuum R RR 13. Double Bagged & Labelled R RR 14. Negative Pressure Enclosure N NR 15. Adjacent Hand Wash Facilities R RN 16. Use of Showers & Clean Room N NR 17. TACB Notification N MM 18. On-Site Trained/CompetentPerson N MR 19. Use of Power Tools ONLY WITH APPROPRIATE CONTROLS R - Required M - May be required, depending on amount removed N - Not required S-125.D0C/S0Q6 - 00014 DPMC-01015 LAM 007532 TABLE IV-B EQUIPMENT AVAILABLE IN MATERIALS WAREHOUSE DESCRIPTION Asbestos Removal Kit * Adhesive, Lock Down Spray, Can Bag, 6 mil Labelled Asbestos Disposal (case) Barricade Tape, Red Asbestos Warning Brush, 2" Disposable Paint Brush, 4" Disposable Paint Brush, Shoe Handle Wire Brush, Stainless Steel Toothbrush Style Wire Coveralls with Hood & Boots, Med. Coveralls with Hood & Boots, Lg. Coveralls with Hood & Boots, XLg. Coveralls with Hood & Boots, XXLg. Encapsulant, Wrap-n-Cure, 6" x 9' Roll Glove Bag, 44" x 60" Horizontal, One Arm Set Glove Bag, 60" x 72" Horizontal, One Arm Set Glove Bag, 60" x 84" Horizontal, Two Arm Set Glove Bag, 72" x 120" Horizontal, Four Arm Set Glove Bag, 120" x 60" Vertical Glove Bag, 60" x 72" Vertical Knife, Poly Nipper, Crescent End Saw, 18" Flexible Wire Saw, 24" Flexible Wire FOLIO NUMBER 9001-134088-0 9001-132088-0 9000-082000-0 9001-129088-0 8000-002300-0 8000-003600-0 9000-082800-0 9001-127088-0 9001-140088-0 9001-141088-0 9001-142088-0 9001-143088-0 9001-133088-0 9001-120088-0 9001-121088-0 9001-122088-0 9001-123088-0 9001-124088-0 9001-125088-0 9001-126088-0 7800-955088-0 9001-130088-0 9001-131088-0 S-125.D0C/S006 - 00015 DPMC-01016 LAM 007533 TABLE IV-B (CONTINUED) EQUIPMENT AVAILABLE IN MATERIALS WAREHOUSE DESCRIPTION Scraper (Putty Knife) Scraper, Short Handle Screwdriver, 5/16" Flat Scrub Pad Sealer, 2 gallons Mastic Sheeting, 20' x 100' Clear Polyethylene Roll Sign: "DANGER - THIS UNIT CONTAINS ASBESTOS" Sign: "ASBESTOS DUST HAZARD" Sign: "DANGER - ASBESTOS HAZARD" Snips, Wiss M-3 Sprayer, Industro Pressure Tag: "CAUTION - CONTAINS ASBESTOS DUST" Tape, 2" Roll Duct Wetting Agent (Concentrate) FOLIO NUMBER 7800-147688-0 7800-148008-0 7800-236288-0 9001-128088-0 8000-061300-0 9000-037400-0 9000-084600-0 9000-078600-0 9000-078300-0 7800-214788-0 9000-047000-0 9000-065800-0 9000-071200-0 6000-309000-0 * Asbestos Removal Kit contains 1 can adhesive spray, 1 roll duct tape, 5 asbestos disposal bags, 1 quart wetting agent/surfactant, 1 quart encapsulant, 2 rolls wrapping encapsulant, 2 horizontal glove bags, 1 vertical glove bags, 1 flexible saw, barricade tape, 2 asbestos hazard warning signs, 1 large and 1 extra-large pair coveralls with hood and boots, polyethylene sheeting drop cloth, 1 pressure sprayer, snips, utility knife, 2 wire brushes, spray application quart bottle, scraper, 2 scrub pads, disposable rags, paint brush, and fiber drum (kit container). S-125.D0C/S006 - 00016 DPMC-01017 LAM 007534 ATTACHMENT V INFORMATION REQUIRED FOR DEMOLITION AND RENOVATION NOTIFICATION TO THF TEXAS AIR CONTROL BOARD ORIGINAL NOTIFICATION: 1. A description of the facility where asbestos removal will take place. 2. The type of removal taking place (demolition or renovation). 3. The process unit or DPMC site location where the removal will take place. 4. The approximate facility size. 5. The number of floors if removal is to be done inside a building. 6. The total square footage of the building or unit where the job will be done. 7. The approximate age of the facility. 8. The approximate amount of asbestos-containing material to be removed (either in linear feet of piping or square feet). 9. The scheduled start and completion dates for the entire demolition or renovation project. 10. The scheduled start and completion dates for the asbestos removal work. 11. A description of the demolition or renovation work. An example of this would be the removal of asbestos from a heat exchanger shell to conduct maintenance on the exchanger. 12. A description of the work practices and engineering controls to be used in prevention of asbestos emissions to the environment during the asbestos work. Items to include here would be that the removal will be done using wet methods, inside a glove bag, and/or using a negative pressure enclosure. CHANGES THAT REQUIRE A REVISED NOTIFICATION TO THE TACB: 1. An increase of 20% or more in the amount of asbestos to be removed. 2. A change in the start date of the job. 3. A change in the end date of the job S-125.D0C/S006 - 00017 DPMC-01018 LAM 007535 ATTACHMENT VI ASBESTOS AWARENESS TRAINING REQUIREMENTS Asbestos awareness training shall covering the following topics: 1. The health hazards associated with asbestos. 2. How to recognize asbestos-containing materials. 3. The relationship between smoking and asbestos exposure in producing lung cancer. 4. The types of operations that could result in exposures. 5. The specific work practices, procedures, and engineering controls required when doing asbestos related work. 6. How to adequately protect against exposures. 7. The purpose, proper use, fit, and limitations of respirators and protective clothing. 8. The purpose and requirements of the medical surveillance program. 9. The OSHA asbestos standards. 10. Health and Safety Order S-125. S-125.D0C/S006 - 00018 DPMC-01019 lam 007536 SHELL DEER PARK MANUFACTURING COMPLEX COMPLEX SUMMARY: ASBESTOS, SAFETY ORDER S-125 SAFETY ORDER POINTS OF INTEREST: 1. Asbestos is a potential health hazard when taken into the body. If exposed, it may enter the body through breathing, eating or drinking. 2. Asbestos may be found in insulation purchased prior to 1973, gaskets, building materials and brake linings. 3. Unless proven otherwise all insulation should be treated as asbestos. 4. Personal hygiene is very important in protection from asbestos. 5. Storage, preparation, and consumption of food and beverages where exposure to airborne asbestos is likely shall not be permitted. 6. Respiratory protection is required. except for incidental work. Protective clothing is required 7. Annual medical exams are provided for certain Shell employees. 8. Annual training is requiredand training records shall be maintained. 9. This order specifically details: A. Health effects of asbestos. B. General practices in asbestos management. C. Definitions D. Work practices applicable at DPMC. E. Demolition and renovation of asbestos materials. F. Disposal. G. Medical exams and employee training. All employees who may come into contact with asbestos are responsible for knowing and understanding the details in the text of this safety order. BCAA8614704 - 0001.0.0 DPMC-01020 LAM 007537 SHELL DEER PARK MANUFACTURING COMPLEX COMPLEX ASBESTOS SAFETY S-125 PAGE 1 OF 7 APRIL 15, 1989 (R) I. INTRODUCTION Asbestos is a mineral silicate occurring naturally as a variously colored fiber. It is non-combustible, non-conducting, and resistant to deterior ation and chemical attack. Because of these properties, it has found widespread use in thermal insulation, asbestos floor tile, roofing and transite materials, gaskets, coatings, plastics, and brake linings. Because of its fibrous nature, it can be woven into cloth, or used to add strength to other materials. Asbestos is a potential health hazard when taken into the body even in very low concentrations. Asbestos fibers are associated with a variety of diseases, including (1) Asbestosis - a non-malignant scarring of the lungs; (2) Bronchogenic Carcinoma - a malignancy (cancer) of the lung; (3) Mesothelioma - a malignancy of the lining of the chest cavity; and (4) cancer of the stomach, colon, and rectum. These diseases develop slowly, and usually do not become evident until many years after initial exposure. Asbestos fibers can enter the body via the breathing process or via eating/drinking. The small lightweight asbestos fibers easily become "airborne" and can contaminate the work area. Recent scientific studies have shown that individuals who smoke and have exposure to asbestos have a significantly greater health risk than asbestos workers who don't smoke. The 8-hour time-weighted average (TWA) permissible exposure limit (PEL) /n\ for asbestos is 0.2 fibers, longer than 5 micrometers, per cubic ' centimeter of air (f/cc). The excursion limit for asbestos is 1.0 f/cc for any 30-minute period. No employee shall be exposed to airborne concentrations of asbestos equal to or exceeding the PEL. Asbestos is most frequently encountered within the Complex as insulation on pipes and structures installed prior to 1973. While purchase of new insulation containing asbestos has been discontinued, asbestos insulation may be encountered in older units for many years to come. II.GENERAL PRACTICES 1. Asbestos-containing materials shall be handled in a wet state whenever practical. Engineering controls, such as enclosures, exhaust ventilation, or dust collection should also be used where (R) required to maintain exposure to asbestos below the PEL. As a precaution, respirators shall be worn for all tasks which involve disturbance of materials containing friable asbestos (refer to BCAE8524103 - 0001.0.0 DPMC-01021 LAM 007538 ASBESTOS SAFETY S-125 PAGE 2 OF 7 APRIL 15, 1989 (R) Respirator Safety Order for proper respirator selection). Any material containing more than 1 percent asbestos by weight, that hand pressure can crumble, pulverize, or reduce to powder when dry, is considered friable. 2. Wherever practicable, replace materials containing asbestos with non-asbestos, substitutes. Insulation containing asbestos shall not be purchased, and asbestos blankets and insulating tape may not be used. 3. In the absence of specific knowledge to the contrary, treat all insulation as containing asbestos. Insulation can be verified as non-asbestos material by (a) field tests performed by the Health & Safety Department, or (b) specific knowledge that the insulation was installed after 1973, which is the date when DPMC began using only non-asbestos insulation. All units which have asbestos-containing materials installed shall post signs at the unit boundaries which state: THIS UNIT CONTAINS ASBESTOS MATERIALS. 4. Reinsulate equipment that is frequently maintained, such as control valve manifolds, pumps, etc., with non-asbestos insulation at an early opportunity. Equipment insulated with asbestos may be sent outside the Company for maintenance, providing the insulation wi 11 not be disturbed or removed for that maintenance, and providing that such equipment shall be accompanied by notification that the insu lation contains asbestos. This notification shall include the standard asbestos warning label on the equipment (see Attachment I) and suitable notices accompanying the truck manifest and the purchase order. Asbestos insulated equipment that requires maintenance which wi 11 disturb the insulation shall have the asbestos thoroughly removed prior to leaving DPMC. Execution of these reinsulation programs and notification practices are the responsibility of the Shell supervisor or foreman most immediately involved in arranging for the equipment transfer. 5. Use work permits to ensure compliance with asbestos work practices for maintenance tasks. It is the joint responsibility of maintenance and operating representatives to anticipate encountering asbestos when planning a job or preparing a work permit. When asbestos will be encountered, the departmental safe work permit shall specify "asbestos work practices in effect; respirator required". 6. All insulated equipment that is to be disposed via salvage shall have insulation removed at the originating location. Insulated equipment will not be accepted at the salvage yard. However, by special arrangement with Material Control, large pieces of equipment with non-asbestos insulation may be sent to salvage. BCAE8524103 - 0002.0.0 DPMC-01022 LAM 007539 ASBESTOS SAFETY S-125 PAGE 3 OF 7 APRIL 15, 1989 (R) III. DEFINITIONS 1. Regulated Area - Any work area where asbestos exposures may reasonably be expected to equal or exceed the PEL. Regulated areas shall be identified with warning signs (Attachment 1) and roped off with hazard warning tape. Access to regulated areas shall be limited to authorized personnel. All persons entering a regulated area shall wear an approved respirator and protective clothing. All persons working in areas surrounding regulated areas shall be informed as to the nature of the work to be performed and of the existence and requirements of the regulated area. Negative pressure enclosures shall be established where required to maintain asbestos concentrations below 0.1 f/cc in areas surrounding the regulated area. Exposure monitoring will be required (contact Industrial Hygiene). A competent person will be required onsite to insure all requirements are being followed. 2. Restricted Area - Any work area where asbestos-containing materials wi 11 be disturbed, such as, removing insulation or transite materials, and the work will last longer than 1 hour. Exposures to asbestos are not expected to equal or exceed the PEL. Restricted areas shaTl be identified with warning signs (Attachment I) and hazard warning tape. All persons entering the restricted area shall wear an approved respirator and protective clothing. 3. Incidental Asbestos Work - Short duration work tasks (less than 1 hour) with asbestos-containing materials where asbestos exposures are not expected to exceed the PEL. 4. Competent Person - The competent person will generally be a Certified Industrial Hygienist, an industrial hygienist with training and experience in handling asbestos, or a person who has such training and experience as a result of on-the-job training and experience. Contact Industrial Hygiene regarding appropriate training courses which are available. IV. WORK PRACTICES The following work practices apply at DPMC: 1. Identification of Work Areas - Post warning signs (Attachment I), which are available from the tool room, around all work areas while involved in removal or disturbance of asbestos-containing insulation, or cutting of asbestos-containing transite, except for incidental work. If airborne concentrations of asbestos can reasonably be expected to exceed the PEL, a regulated area must be established. BCAE8524103 - 0003.0.0 DPMC-01023 LAM 007540 ASBESTOS SAFETY S-125 PAGE 4 OF 7 APRIL 15, 1989 (R) 2. Respiratory Protection - All persons shall wear respiratory protection during any operation where airborne asbestos fibers could be generated. Approved respirators include: half and full face twin cartridge respirators equipped with HEPA fiIters (purple cartridges), or any supplied air respirator. Respirators are available from the green respirator cabinets. (See Respiratory Protection Safety Order). Employees who use respirators are to be trained annually, and fit tested semi-annually. Semiannual fit testing will apply only to employees who wear respirators in areas where asbestos concentrations exceed the PEL. All other employees who wear respirators will be fit tested annually. 3. Asbestos Removal - The removal of asbestos insulation should be done in a wet state to prevent or minimize the formation of airborne asbestos fibers. Portable spray cans using water or commercially available wetting agents may be used. Wetting agents (surfactants) may be added to water to allow more effective penetration and permit more thorough soaking of the asbestos-containing materials. Wetting agents are generally prepared by mixing 1-3 ounces of wetting agent to 5 gallons of water. Special work situations where water cannot be used, such as those involving electrical systems, should be reviewed with the area Health and Safety Inspector. 4. Ventilation Systems - Inspect local ventilation equipment used to control asbestos fibers at least quarterly. Inspection records are to be maintained by the principal department using such equipment. 5. Housekeeping - Clean the work area by wet sweeping and bagging of all asbestos debris, or by use of a HEPA filtered vacuuming device after completion of asbestos removal and at appropriate intervals to minimize the potential for generating airborne asbestos. In all cases, the asbestos debris must be properly handled for disposal (see section entitled "Disposal"). Precautions should be used to minimize airborne asbestos during idle work periods. For example at the end of a workday large pieces of unprotected insulation are to be moistened and loose insulation picked up. Exposed insulation that cannot be maintained in a wet state during idle periods shall be enclosed in plastic or encapsulated with commercially available encapsulants. Dry sweeping or "blowing" are not permitted. 6. Personal Activities - The storage, preparation, and consumption of food ancl beverages is not permitted in areas where exposure to airborne asbestos is encountered. No employee may eat, drink, smoke, chew gum or tobacco, or apply cosmetics in work areas where asbestos materials are being handled. It is the responsibility of all employees that work with asbestos materials to take reasonable cleanup precautions prior to eating, and also at the end of the work shift. As necessary, washup areas are to be provided for washing. BCAE8524103 - 0004.0.0 DPMC-01024 LAM 007541 ASBESTOS SAFETY S-125 PAGE 5 OF 7 APRIL 15, 1989 (R) 7. Clothing - Employee personal street clothing is to be protected from asbestos contamination. Employees assigned to regulated or restricted work areas, or tasks where airborne exposure or clothing contact with asbestos may reasonably occur shall wear disposable coveralls. Efforts must be made to assure the effectiveness of the coveralls. The use of different size disposable coveralls will minimize tearing; all snaps or buttons shall be used as is necessary to protect undergarments. Torn or ripped coveralls shall not continue to be worn. All contaminated disposable clothing must be disposed of and transported in sealed plastic bags and labeled (Attachment 1). Coveralls are not required for maintenance or operations tasks encountering incidental asbestos work, providing generation of airborne asbestos and contamination of street clothing is prevented by procedures outlined in this section. 8. Chanqe/Decontamination Areas - Decontamination areas shall be established for all "regulated areas". The decontamination area shall be adjacent and connected to the regulated area, and shall consist of an equipment room (contaminated change room), shower area, and clean room in series. All employees shall enter and exit the regulated area through the decontamination area. The clean room shall be equipped with a locker or appropriate storage container for each employee. The showers shall be located between the equipment room and clean room where feasible. Where the shower area is not located here, asbestos must be removed from employee's work clothing using a HEPA vacuum before proceeding to the shower area. V. DEMOLITION AND RENOVATION OF ASBESTOS MATERIALS Demolition and renovation of insulation and transite containing asbestos must be accomplished in accordance with OSHA and EPA regulations, and written notification to the Texas Air Control Board (TACB) is required. Demolition of insulation may be encountered when process units are retired, when interunit insulated pipelines need replacement, or when individual columns or large vessels are replaced or retired. Maintenance of insulation may be encountered during upgrading of insulation, or during major turnarounds in some units. To prepare for planned maintenance asbestos work, the responsible Field Team Manager, Supervisor, or Project Engineer shall contact Health & Safety to determine whether the material contains asbestos. The Environmental Conservation Regulatory Affairs group shall then be advised if more than 160 square feet is involved. For demolition work, Regulatory Affairs must be notified of the approximate square feet of asbestos to be removed, regardless of amount (even if there is none). One month's advance notification to the Regulatory Affairs group is required. For emergency maintenance asbestos work, verbal notification must be given to BCAE8524103 - 0005.0.0 DPMC-01025 LAM 007542 ASBESTOS SAFETY S-125 PAGE 6 OF 7 APRIL 15. 1989 (R) the TACB prior to work starting. Regulatory Affairs, or the Environmental Supervisor, is responsible for that notification. The responsible foreman, supervisor, or project engineer shall prepare written instructions for the job. These instructions shall then be used as a basis for TACB notification, and for conducting the job. The infor mation which should be included for notification shall include the process unit, who will be removing the asbestos (contractor name), asbestos removal start and completion dates, nature of asbestos removal, and if any special handling procedures, other than routine, will be used. Environmental monitoring will normally be performed by Industrial Hygiene personnel for jobs that require TACB notification. In July of each year, Regulatory Affairs prepares an annual report to the TACB, estimating the quantity of asbestos that will be removed for all demolition projects and planned maintenance jobs over 160 square feet. A list of all demolition projects are included in the notification. Further notification for any of the jobs listed in the annual report is not necessary. Emergency maintenance asbestos removal work over 160 square feet, or any other asbestos jobs which arise during the year and not included in the annual report, requires notification to the TACB before the job begins. Contractor pre-bid conferences held are to include the specific hazards of asbestos and required procedures. Also, advance notification of Purchasing - Procurement is necessary to allow sufficient time for contract preparation. VI. DISPOSAL Place the wetted asbestos in heavy duty plastic bags and seal them securely as soon as possible after the bags are filled and prior to moving the bags. An asbestos warning label, as shown in Attachment I, is re quired on each bag. The label may be pre-printed on the bag or may be on a tag attached to the bag. Bagged asbestos and transite will be disposed of onsite. A Waste Disposal Request form, DPMC-6 (Attachment II), is required for all shipments. The quantity shipped should be indicated on the form in cubic yards. It is the responsibility of the generating department to see tnat the asbestos is placed in the trench provided in the landfill. Contact Environmental Operations with questions concerning disposal. Dispose of non-asbestos insulation wastes by placing them in the regular refuse bins. I. ANNUAL MEDICAL EXAMS AND EMPLOYEE TRAINING Annual medical examinations are provided to Shell employees prior to engaqing in activities regularly exposed to airborne concentrations (^ 0.1 f/cc) of asbestos. The intent of this medical program is to include BCAE8524103 - 0006.0.0 DPMC-01026 LAM 007543 ASBESTOS SAFETY S-125 PAGE 7 OF 7 APRIL 15, 1989 (R) employees who work with asbestos-containing materials on a regular basis (30 or more days per year) or who have had known exposure through previous assignments. In addition, this order shall serve as a training instrument. Those employees that work regularly with asbestos materials shall be retrained annually, by reading and discussing this order and by viewing the asbestos training tape which is available from the Training Department. Key items to be emphasized in the training are: 1. Methods of recognizing asbestos. 2. The health hazards associated with asbestos. 3. The increased risk for smokers. 4. Types of operations that could result in exposure. 5. Precautionary work practices, engineering controls, housekeeping procedures, hygiene facilities, protective clothing, respirators, decontamination, and waste disposal. 6. Purpose for and proper respirator use, fitting, and limitations. 7. Medical surveillance program requirements. 8. A review of the OSHA Standards. 9. The use of warning signs where exposure may apply. The manager shall retain appropriate training records documenting the names and dates of the training for 40 years. Attachments (3) (R) Updating Responsibility: Manager Health & Safety Approved By: Complex Superintendent BCAE8524103 - 0007.0.0 DPMC-01027 LAM 007544 ATTACHMENT I ASBESTOS WARNING SIGNS AND LABELS SIGN Standard OSHA Warning Sign - 14" x 20" - with legend per OSHA Standard: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA LABEL Self-Adhesive Type Label, bearing legend per OSHA Standard: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD BCAE8524103 - 0008.0.0 DPMC-01028 LAM 007545 DPMC-f> (Revised 8/bb) DPMC WASTE DISPOSAL REQUEST ATTACHMENT II NOTE: ALL ITEMS IN SECTION A MUST BE ENTERED BY ORIGINATOR. SEE BACK OF THIS SHEET FOR CODE TABLES AND INSTRUCTIONS. A. Originator Completes This Section: This form is to be filled out once you are satisfied the waste material can be handled and disposed of in a safe and environmentally sound way. NOTE: It is the responsibility of the ORIGINATOR to find, if possible, a use for the material either in his department or another department in the Complex. Arrangements for disposition of the material should always be made (except in an emergency) and approval of Environmental obtained before pick-up is scheduled. 1. MONTH/DAY/YEAR .2 GENERATOR DEPT. CODE 3. WASTE CODE 4. DISPOSAL SITE CODE (JOB ORDER/ACCOUNT NUMBER) (DEPARTMENT NAME) (DISPOSAL SITE NAME) 5. MATERIAL DESCRIPTION (ESTIMATED QUANTITY/UNITS-BBLS, YDS, ETC.) .6 SOURCE (VESSEL, TANK, ETC.) 7. QUANTITY (ESTIMATED TIME REQUIRED) 8. COMMENTS SAFETY (Safety precautions must be indicated.) See the attached Safe Work Permit EQUIPMENT REQUIRED: Gloves Goggles Protective Clothing j | Type Respirator , Fresh Air , Rubber Boots Special Precautions: _____________________________ ________________________________________________________ ISSUED BY (ORIGINATOR) B. Complete Part A and then call Environmental for approval at: 6706, 7280, or 7653. (Off Hours call 7340 or 6397) APPROVAL (ENVIRONMENTAL) BY (ORIGINATOR) DATE TIME C. Driver Completes This Section: DATE QUANTITY DRIVER BBLS, LIQUIDS BBLS, SOLIDS YDS TRUCK NUMBER TIME STARTED ___________________________ TIME FINISHED Note to Driver: Turn completed forms in to your supervisor daily. Mail to ECB-131. CHBR8623201 DPMC-01029 LAM 007546 SAFETY: Safety instructions must be clearly and completely stated on the DPMC-6 for* or on a separate Safe dork Permit (indicate on the waste disposal fort if a safe work pernt is issued). A dork Pernt Addenout should be attached to the DPMC-6 fori or to the Safe dork Periit fore. NSTRUCTIONS: Before completing this fora you should detemne, as exactly as possible, the coiposition and quantity of eatenai you have. In addition you should lake arrangeeents within your own department or with another department to recycle or reuse the material if possible. Please do not guess at which codes to use. If you are not sure, discuss with the environmental representative when you call for approval. CODE NUMBERS FOR WASTE DISPOSAL CODE i-'v: :::e name 170750 170770 179640 1B3050 249890 400000 450000 500000 550000 600000 650000 750000 800000 909390 910230 910590 913700 914680 915190 941520 950430 970210 9792E0 979430 979840 asbestos RISC. PLANT dASTES (CONTAMINATED TRASH) SOLID RESIN BPA BIOSOLIDS ACID SOLUTIONS BASE SOLUTIONS CHEMICAL SOLUTIONS RECOVERED OIL OIL/WATER CLEAN DIRT/RUBBLE RECLAIM DRUMS DRUMMED dASTES API SKIM PHENOLIC TARS LAB dASTES LIQUID RESIN 0R6 CHLORIDE dASTE BPA PANDRIER BTHS CONTAM. DIRT/RUBBLE OILY SLUDGE SPENT CATALYST BRUCINE CONTAINERS PCB'S OILY DIRT CODE DEPARTMENT NAME 01 A 02 6 03 V 04 CAT CRACK INS 05 PURCHASING/MATERIALS 06 BA/SR 07 ENVIRONMENTAL SOUTH 08 ENVIRONMENTAL NORTH 09 LABORATORY 11 DISTILLIN6/L0FU 14 TANKFARM 15 THERMAL CRACK/ALKY 16 MAINTENANCE 17 PHENOL ACETONE 18 BPA 19 LUBE LOGISTICS 20 OLEFINS 21 UTILITIES NORTH 22 UTILITIES SOUTH 23 UTILITIES CENTRAL 24 RESINS DISTRIBUTION 25 RESINS OPERATIONS 27 CONSTRUCTION 30 SAFETY 31 HYDROCRACKING/SR/CR 34 AROMATICS 35 GAS RECOVERY 36 LUBE A 37 LUBE B 46 BASE CHEM 6 SOL 47 DOCKS 50 UTILITIES DISTRIB. CODE DISPOSAL SITE NAME 01 PRI SOLIDS LASOON 1 02 PRI SOLIDS LA600N 2 03 PRI SOLIDS LA600N 3 04 BIOSOLIDS DIGESTER 05 OIL RECOVERY TANKS U-301,10,11,12,13,21) 06 DECANT TANKS (1-324,5,6,7,8) 07 DECANT PIT 08 ACID NEUTRALIZER 09 RISC. PLANT dASTE COMPACTORS 10 JONES LAKE 12 BELTWAY CLEAN STRG 16 HC1N FEED TANKS 17 SOUTH EFFLUENT TREATER TAK1, '-.,,300,1301 T-1302,1306,1310,1317,1318,1323,13145,13146 18 DRUM RECLAIM (SOUTH ET/SALVAGE YARD) 19 SITE 102/103 20 USE THIS NUMBER FOR OTHER FACILITIES 21 DRUM STORAGE BLD6 DPMC-01030 lam 007547