Document 0J2RavM0LDJmZe88ZQYD2DEMn
ASARCO
Department of Environmental Sciences
M O Varner Va^ager
March 21, 1979
Mr. G. Sidlo CAPCO - Ragland Plant
Environmental Survey Report
Enclosed for your review is the D.O.E.S. report for the environmental survey conducted at the Ragland Plant on December 4-5, 1978. I particularly call your attention to the Executive Summary and the Recommendations on page 13. In general, the recommendations are listed in order of descending importance. In other words, the first few recommendations are the most critical in the opinion of the environmental scientist making the survey.
If you have any questions concerning this survey, please contact me or Stanley G. Cothrin, the author of the report. I would appreciate receiving your comments on the recom mendations contained in the report or any other aspects you deem worthy of comment.
MOV/cah
cc:
WTWhitley MJMessel DHSoutar KWNelson AJGillespie, RCBeckstead WTSweat Dr. CHHine JLWoods
Jr.
M. 0. Varner
CA'CO AL
004-0650
ENVIRONMENTAL SURVEY
CAPCO Ragland Plant
December 4-5, 1978
Prepared by:
Stanley G. Cothrin Environmental Scientist Department of Environmental ASARCO Incorporated Salt Lake City, Utah
Sciences
Report Date:,
March 21, 1979
Distribution:
GSidlo VTTWhitleyc MJMessel DHSoutar . KWNelson AJGillespie, RCBeckstead WTSweat Dr. CHHine MOVarner JLWoods
Jr.
CAPCO ALV 0040651
ENVIRONMENTAL SURVEY
CAPCO Ragland Plant
December 4-5/ 1978
TABLE OF CONTENTS
1*2*.
EXECUTIVE SUMMARY..........................................................................................................li
`
I. OPERATING CONDITIONS........................................................................' . . 1 '
II. SAMPLING AND ANALYTICAL PROCEDURES.....................................................1
A. Air............................................................................................................................1
B. Noise.......................................................................................................................1
III. SAMPLING RESULTS..................................................................................... .
2
A. Personal Monitor Samples.....................................................................2
B. Noise.......................................................................................................................7
1. Noise Dosimeter Measurements................................................7
2. Sound Level Meter Measurements................................. 8
IV. COMMENTS. . ....................................................................................................................9
A. Asbestos. ...........................................................................................................9
B. Respiratory Protection........................................................................11
C. Noise....................................................................................................................11
D. Solid Waste...................................................................................................12
E. Process Water..............................................................................................12
F. Program Director......................................................
12
V. RECOMMENDATIONS.....................................................................................................13
VI. PHOTOGRAPHS.................................................................................................................14
CAPCO ALV 004-0652
ENVIRONMENTAL SURVEY
CAP CO Ragland Plant
December 4-5, 1978
EXECUTIVE SUMMARY
One of ten personal monitor time-weighted average (TWA) exposure samp'es' obtained during this survey (dust, collector tender) ex ceeded the current OSHA asbestos standard, of 2 fibers/cc. Four of the ten TWA exposure samples exceeded the proposed OSHA TWA limit of 0.5 fibers/cc.
Noise dosimeter measurements indicated noise exposures exceeding OSHA limits for the pipe machine tender and autoclave charger. Noise dosimeter measurements for the batch' operator, cutoff saw operator, hydrotester and MOA lathe operator were in the range of potential violation of the OSHA standard.
A great deal of improvement has been made in solid waste hand ling since the June 1977 D.O.E.S. survey report. The landfill now appears to be operated in a manner which assures compliance with the EPA National Emission Standard for Asbestos.
The Ragland Plant now has a full time Industrial Engineering and Safety Director which should help greatly in the plant effort to maintain compliance with.applicable OSHA safety and health regu lations.
Recommendations include: enclosing and venting the reclaim tank baghouse to the atmosphere; mandatory wearing of hearing pro- tection for employees with excessive noise exposure; issuance of protective clothing for all employees; implementation of plans to replace the present wet charge mixer with a dry system and investigation of the feasibility of finishing line engineering controls for noise for the pneumatic control system, cutoff saw and finish lathe.
CAPCO ALV 004-0653
ENVIRONMENTAL SURVEY o
CAP CO Ragland Plant December 4-5, 1978
I. OPERATING CONDITIONS All operations were normal.
II. SAMPLING AND ANALYTICAL PROCEDURES A. Air: Individual asbestos fiber samples were collected with M.S.A. personal monitor pumps equipped with open-face Millipore filters (0.8 micron pore size). The asbestos fibers were counted using a Zeiss phase-contrast micro scope/ according to the method specified in the NIOSH criteria document. B. Noise: 1. Sound level measurements were taken with a B & K Model 2205 Sound Level Meter using the "A" scale and "slow" response setting. The meter was cali brated with a standard noise source before each set of measurements. 2. Personal noise exposure data were collected using-. DuPont Permissible Audio Dosimeters, Model D-100, which measure noise exposures in terms of the pre sent 90 dBA OSHA standard. A DuPont Audio Dosi meter Readout (Model R150) was utilized to decode each dosimeter memory cell and produce a reading as a percentage of the current 90- dBA standard. .A DuPont Audio Dosimeter Calibrator was used to check dosimeter calibrations.
u
(
CAPCO ALV 004-0654.
A. PERSONAL MONITOR SAMPLES CAPCO-RAGLAND
O 1978 SAMPLING
NAME S.S. NUMBER
JOB TITLE CRESP. T YPE > (3)
DATE *. TIME $H I FI<4 M IN. >
ANAL- CONC'N. YSIS Cfi/cc )
BAGWELL BAGUELL BAGBELL
JONES . JONES
JONES
A/C PRODUCTIOH-CAPCO
STRIPPER OP. 9
12/ 5 0
142
STRIPPER OP. 9
12/ 5 D
97
STRIPPER OP. 9
12/ 5 D
153
CALCULATED TWA EXPOSURE
12/ 5 D
392
BATCH MIXER 1
12/ 5 D
145
BATCH MIXER 1
12/ 5 D
113
BATCH MIXER 1
12/ 5 D
160
CALCULATED TWA EXPOSURE
12/ 5 D
413
ASS ASB . ASB ASB ASB ASB ASB ASB
.0?
.01 .05 .05 .68 1.62 .95
(2) 1.04
redacted
CAPCO ALV 004-0655
NAME 3.S. HUMBER
A. PERSONAL MONITOR SAMPLES (Cont.) CAPCO-RAGLAHD
J08 TITLE CRESP. T YPE>,J'
1978 SAMPLI DATE A..TIME SHIFTaHIN. >
ANAL- CONC'N. YSIS <fi/c c >
ECHOLS 418369610 ECHOLS. 418369610 ECHOLS 418369610
TRAMMELL
TRAMMELL
TRAMMELL
A/C PRODUCTIOH-CAPCO
MACHINE TEND 9
12/ 5 D
120
MACHINE TEHD 9
12/ 5 D
106
MACHINE TEND 9
12/ 5 D
162
CALCULATED TWA EXPOSURE
12/ 5 D
338
CALENDER OP. 9
12/ 5 D
142
CALENDER OP. 9
12/ 5 D
98
CALENDER OP. 9
12/ 5 D
166
CALCULATED TWA EXPOSURE
12/ 5 D
406
ASB ASB ASB ASB ASB ASB ASB ASB
.57 . .66 .'Z (2 .58 .39 .68
.51 (2)
.51
redacted
CAPCO ALV 0040656
NAME S.S. NUMBER
A. PERSONAL MONITOR SAMPLES (Cont.) CAPCO-RAGLAND
JOB TITLE CRESP. TYPE>lJ'
1978 SAMPLING
D*TE h) TIME SHIFT1*' CHIN. )
ANAL CONC'N. YSIS <fi/cc >
-
DAFFRON 420540596
DAFFRON 420540596 *
DAFFRON 420540596
DAFFRON 420540596
A/C PRODUCTION-CAPCO
DUST COL TEND 1
(Reclaim Baghousa)
12/ 5 D
145
DUST COL TEND 1
12/ 5 D
100
**
DUST COL TEND
12/ 5
1D
(Empty baghse- hop.)
DUST COL TEND 1
12/ 5 D
43 125
CALCULATED TUA EXPOSURE
12/ 5 D
413
ASB ASB ASB ASB ASB
2.98 .97
6.94 .12
2.04
ODONNELL 417320116
ODONNELL 417320116
ODONNELL 417320116
A/C FINISHING -CAPCO
Resaw Oper. 9
6"
12/ 5 D
131
Resaw Oper. 9
12/ 5 D
82
Resaw Oper. 9
12/ 5 D
139
CALCULATED TUA EXPOSURE
12/ 5 D
352
ASB ASB ASB ASB
.21 .16 .13 .17
CAPOO ALV 0040657
NAME S.S. NUMBER
A. PERSONAL MONITOR SAMPLES (Cont.) CAPCO-RAGLAND
JOB TITLE CRESP. TYPE)(J'
1978 SAMPLING
DATE L TIME
ANAL- CONC'N.
SHIFT(4'CMIN. > YSIS Cfi/cc )
CAMPBELL 416709559 CAMPBELL 416709599 CAMPBELL 416709599
JOHNSON
JOHNSON
JOHNSON
A/C FINISHING-CAPCO
MEE/MOA LATHE
12/ 5
9 S> (Short,small diameter)
162
MEE/MOA LATHE 9
12/ 5 D
85
MEE/MOA LATHE 9
12/ 5 0
133
CALCULATED TV ft EXPOSURE
12/ 5 D.
380
COUPLING LATHE 9
(6" - 150)
COUPLING LATHE 9
12/ 5 D
169
12/ 5 D
73
COUPLING LATHE 9
12/ 5 0
140
CALCULATED TWA EXPOSURE
12/ 5 D
382
ASB ASB ASB ASB ASB ASB ASB ASB
.10 .07 .09 .09 .05 .02 .09 .06
REDACTED
CAPCO ALV 0040658
NAME S.S. HUMBER
JOB TITLE n, CRESP. TYPE) 1 ;
1978 SAMPLING
DATE Ai)TIHE
ANAL- CDNC'N.
SHIFT (MIH.J
YSIS (fl/cc >
AFC fIHISHIHG-CAPCO
KAY <421706619
FINISH LATHE (6") 9
12/ 5 D
98
ASB-
.04
KAY 421706619
FINISH LATHE 9
12/ 5 D
133
ASB
.02
CALCULATED TA EXPOSURE
12/ 5 D
?33
ASB
.03
CARROLL
MEE/MOA LATHE
12/ 5
,9 D
(Short, large diameter)
137
ASS
.04
CARROLL
MEE/MOA LATHE 9
12/ 5 D
67
ASB
.02
CARROLL
MEE/MOA LATHE 9
12/ 5 D
130
ASB
.03
CALCULATED TWA EXPOSURE
12/ 5 D
334
ASB
.03
(1) Exceeds OSHA 8-hour time-weighted average limit (TWA).
(2) Exceeds OSHA proposed 8-hour TWA.
(3) Respirator type: 1 = half-mask air-purifying, 9 = None.
(4) Shift Notation: D = Day
CURRENT OSHA STANDARDS
Asbestos Asbestos
2 fibers/cc (8-hour TWA) 10 fibers/cc (ceiling)
PROPOSED OSHA STANDARDS
Asbestos Asbestos
0.5 fibers/cc (8-hour TWA) 5 fibers/cc (ceiling)
REDACTED
CAPCO ALV 0040659
B. Noise: 1. Noise Dosimeter Measurements
Department
Employee S.S. Number
Job (Hearint Protec tion Worn?)
1978
Production Jones
Batch Op. (No)
12/5 D
Sampling Dosimeter
. Adjusted
Time Readout
to 8 hr.
(Min.) (Percent)^ ' (Percent)
115 dBA Exceeded
418 90
103(5). .
,No
/. #
* Echols
Pipe Machine 12/5
388 .
132
418369610 Tender (No)
D
163(4)
No
Trammel
Calendar Op. (No)
12/5 D
406
0
.0 No
Bagwell
Stripper Op. (No)
12/5 D
392
48
59 No
Bean 420524089
Tray Loader Helper (No)
12/5 D
McCullough Autoclave Chg . 12/5
(No)
D
Finishing Odonnel 417320116
Cutoff Saw Op . 12/5
(6") (NO)
D
St. John
Hydrotester (No)
12/5 D
Campbell 416709599
Short M0A Lathe Op.
(No)
12/5 D.
368 368 379 374 421
(1) Readout based on elapsed sampling time.
29 38 114 149 (4)
96 122(5) 76 98 (5) 79 90 (5)
..REDACTED
No No No Yes<3> Yes(5)
(2) The 8-hour adjusted readout is an extrapolation of the original dosimeter reading. This extrapolation assumes that the employee will be exposed to the same noise level during the remainder of the shift when the dosi meter is not worn.
(3) The OSHA noise standard does not allow employees to be exposed to sound levels greater than 115 dBA. However, experience to date shows that most ' dosimeter measurements greater then 115 dBA are the result of employee mischief, i.e., shouting into the microphone of the dosimeter. There fore, these data must be interpreted cautiously.
(4) Dosimeter readouts greater than 100% indicate a violation of the OSHA' noise standard. However, the accuracy of the dosimeters (as specified by A.N.S.I.S1.4 - 1971) is + 2 dBA which translates to an upper confidence
CAPCO ALV 0040660
limit of 133%. Therefore, only readings greater than 133% are a posi tive violation of the OSHA noise standard.
(5) Readings from 75% - 133% fall within the dosimeter calibration limits and may be violations of the OSHA standard.
(6) .Shift Notation: D = Day.
2. Sound Level Meter Measurements
Department Production
Finishing
Location Batch Operator.Booth
dBA 84
Mixer Control Panel Background
87
Chg. Mixer
93
Pipe Machine Tender Area
Background Chg. Mixer
85 93
Asbestos Storage Area
82
By Pipe Machine Hy draulic Pumps
92
Calendar Operator
88
Stripper Operator
Background
85
Coupling Cutoff Air Noise
91
Pipe Machine Takeoff End
Background
82
Crane Travel
91
Short MOA Lathe Op. (Small diameter)
Cutting
84
Air Noise
88
OSHA Permissible Noise Exposure Duration Per Day (Hrs./Min
8+
8+ 5/17
8+ 5/17
8+ 6/4
8+
8+ 6/58
8+ 6/58
8+ 8+
CAPCO ALV 0040661
Department Location
dBA
Finishing
Short MOA Lathe Op. (Large diameter)
Cutting
88
Air Noise
.92
Coupling Cutoff
Cutting
88
Air Noise
93
Coupling Lathe (6"-150)
87
Hydrotester
Background
88
Finish Lathe Noise
93
Firish Lathe Op. (6")
Background
88
Lathe Noise
93
Unitizer- Area
87
Cutoff Saw Op. (6")
Not Cutting
85
Cutting
101
OSHA Permissible Noise Exposure Duration Per Day (Hrs./Min.)
8+ 6/4 .
8+
5/17
8+
8+
5/17
84-
5/17
84*
841/44
IV. COMMENTS
A. Asbestos
One of ten personal monitor time-weighted average (TWA) samples obtained during this survey exceeded the current OSHA asbestos TWA limit of 2 fibers/cc, and this was for the dust collector tender.
Four of the ten TWA personal monitor samples (batch mixer, machine tender, calendar operator and dust collectortend er, exceeded the proposed OSHA limit of 0.5 fibers/cc.
An examination of the dust collector tender's personal
CAP CO ALV 004-0662
monitor sample results shows a fiber concentration of
2.98 fibers/cc for a 145 minute sample and a concen tration of 6.94 fibers/cc for a 43 minute sample.. The 6.94 fibers/cc sample occurred when the dust collector tender empties the baghouse hopper into plastic bags, an operation which occurs daily. The 2.98 fibers/cc sample was caused by work performed on the reclaim tank
baghouse. This baghouse has the bag chamber open to the warehouse area and at the time of the survey, broken bags had left visible deposits of settled dust around the baghouse (see section VI, Photographs). To avoid j ^ , reentry of asbestos fibers into the working area it is / <r
recommended that the baghouse bag chamber be enclosed I * ' .and discharged to atmosphere rather than back into the/
building.
v
`'
. With the exception of the dust collector tender, these sample results are consistent with those found during sampling performed in September 1978 and June 1977.
In-plant changes since the 1977 D.O.E.S. report include: use of a wet resaw instead of a dry, ventilated unit; ventilation for steam removal from the autoclaves; (section VI, Photographs), enclosure of the fiber charg ing operation in a booth; and a new lunchroom which is separated from the production area.
One obvious source of visible dust to the wet end of the pipe line is the batch mixer. When water is pumped into the mixer, displaced air from the mixer is forced out carrying fiber and cement dust with it. It is understood that there are plans to replace the wet mix ing systems with a dry system similar to the Van Buren Plant.
Present plant policy is to issue company clothing in the form of disposable coveralls to any employee that requests them. Most employees observed did not wear coveralls. It is recommended that plant management seriously consider issuance of at least coveralls or other protective clothing to all employees, regardless of' their asbestos exposure level, to reduce the possi bility of lawsuits involving the employee's families in the future.
The current OSHA asbestos standard requires monitoring of representative employee job classifications every six months "for employees whose exposure to asbestos may reasonably be forseen to exceed the limits." Based on this and previous monitoring, it appears that most job classifications can be dropped from the six month monitoring requirement of the standard although it is
CAPCO ALV 0040663
recommended that at ieast annual monitoring of repre sentative job classifications be continued with moni toring every six months for job classifications with potentially excessive asbestos exposures (i.e., batch mixer, machine tender, calendar operator, dust collector tender). Because the asbestos concentration appears to remain relatively constant during the shift, the taking of samples to cover the full work shift is not necessary to represent average employee exposure or comply with the standard. However, samples of too short a duration should be avoided because of inaccuracies. A single sample of nominal two hours duration should be sufficient to represent the average exposure of a job classification . and still avoid overloading the filter. If varying ex posures during the shift are expected, however, multiple samples will need to be taken.
B. Respiratory Protection
The plant supplies the 3M8710 and Norton 7400-6 dust respirators when necessary for dust exposure. Respira tor wearing was observed for the batch mixer and dust collector tender during this survey.
C. Noise
Noise dosimeter measurements indicated definite viola tions of the OSHA noise standard for the pipe machine tender and autoclave charger. Noise dosimeter measure ments for the batch operator, cutoff saw operator, hydrotester and MOA lathe operator were in the range of potential violations of the OSHA standard. The noise dosimeter measurements are consistent with those found during the June 1977 D.O.E.S. survey except that the calendar and stripper operator levels were significantly less during this survey.
The pipe machine tender's and batch mixer's operator's noise exposure is primarily due to the charge mixer. The pipe machine tender's work area is around the charge mixer whereas the batch mixer operator uses a bench at the mixer console for a rest area. If the charge mixer is replaced with a dry system as planned, the excessive noise problem may be eliminated. In the interim, the pipe machine tender should wear hearing protection and the batch mixer operator should take his breaks in a different area.
The autoclave charger's noise exposure appears to be due to exhaust noise from the Erickson lift truck. The existing muffler should be replaced with a guieter unit.
(
CAPCO ALV 004.0664.
o
o
(
The MOA lathe operator's noise exposure is primarily due to air exhaust noise from the pneumatic material handl ing system (see sound-level meter measurements). It is recommended that the feasibility of installing suitable air exhaust mufflers be investigated.
The cutoff saw operator's and hydrotester's noise ex posures are due to pipe sawing noise and finish lathe noise respectively. OSHA may view enclosure of the finish lathe and cutoff saw as a feasible engineering control method of noise reduction. Enclosures with viewing windows and leaded vinyl curtains for entry and exit of product have been used successfully in the Wood* - vrorking industry for several years. It is recommended that the feasibility of engineering noise control for the finish lathe and cutoff saw be investigated. ..
The plant supplies insert and muff type hearing protec tion for employees on request. Only the dust collector tender was observed to be wearing hearing protection during this survey. It is recommended that the pipe machine tender, autoclave charger, cutoff saw operator and finish lathe area employees should be mandatory hear ing protection job classifications.
The Ragland Plant has its own audiometric testing booth and an individual certified as an industrial audiometric technician who conducts pre-employment and annual audio metric tests on all employees.
D. Solid Waste
A great deal of improvement has been made in solid waste handling since the last D.O.E.S. report. The entire dump has been fenced and posted, empty asbestos fiber bags are contained in plastic bags which are buried, and waste . pipe is crushed with a crawler tractor and buried (see section VI, Photographs). The landfill appears to be operated in a manner which assures compliance with the EPA National Emission Standard f~r Asbe^cos.
E. Process Water
The process water continues to be,handled in the same manner as discussed in the 1977 D.O.E.S. survey report. Additional dikes have been added below the settling basin with the dragout conveyor. It is understood that an additional dragout conveyor will be located at the water discharge point from the plant itself.
F. Program Director
The Ragland Plant has hired an individual (Mr. Saleem)
CAPCO ALV 0040665
Or to administer safety and industrial engineering duties as recommended in the 1977 D.O.E.S. survey report. It is understood that Mr. Saleem will work in conjunction with Mr. Swafford as regards asbestos monitoring.
V. RECOMMENDATIONS
A. The reclaim tank baghouse should be enclosed and vented to the atmosphere.
B. The wearing of personal hearing protection should be mandatory for the pipe machine tender, autoclave charger, cutoff saw operator and for employees work ing in the immediate vicinity of the finish lathe.
C. Management should consider issuing protective cloth ing to all employees.
D. Plans to replace the present wet mixing system with a dry system (Van Buren type) should be implemented.
E. The feasibility of noise engineering controls in the form of mufflers for the finishing line pneumatic control system exhausts and enclosures for the cut off saw and finish lathe should be investigated.
SGC/can
Stanxey u. cotnrxn Environmental Scientist
( CAPCO ALV 0040666
r--
Leakage from broken bags in r* laim tank o oachouse caused dv.st collector tender to
have --xcessive asbestos exposure (Note settled dust on duct.)
( Wet cutoff saw demonstrated very low finer exposure levels. CAP' O _V 0040667
Autoclaves, showing new ventilation for steam removal.
CAPCO ALV 0040668
VI.
:T0: "
rr>r*,T-+- \ W w. w J
Waste disposal site showing plastic bags containing eir.pty bags of fiber.
CAP CO ALV 004C 369