Document 37ygB7bZj2Q6jz73kGoORMOma

May 2*t 1979 TO: COPY TO: FROM: SUBJECT: Hr. J. R. Soice lr. CI . W. Carman Hr. V. A. Garrett Hr. E. C. Shipley Hr. J. L. Worstell D. R. Paugh AMATEX Asbestos Tape (Your Letter Dated Hay 1, 1979) On Harch 27, 1979 I issued a letter to Hr. H. H. Frazier agreeing with his recommendation to discontinue use of the AHATEX tape in our 511 Construction Group. I have rechecked with Hr. E. C. Shipley our Construction Craft Hanager and confirm that we are complying with this request. DRP:oh D. R. Paugh Hanager of Construction UCC 016907 a.? ; To: Mr. Peter Barna Copy To:: Dr. B. H. Avashia Mr. C. W. Carman Mr. C. W. Evans Mr. R. G. Hull, Jr. Mr. G. F. Hurley Mr. S. E. Illikainen Mr. E. H. Kivett, Jr. Mr. H. C. McGinnis Mr. D. R. Morgan Mr. G. F. Morris Mr. D. R. Paugh Mr. R. E. Peele Mr. E. C. Powell, Jr. Dr. R. J. Sexton Mr. F. Williams From: H. H. Frazier Date: March 15, 1979 Subject: Use of AMATEX Asbestos Tape in Plant 512 Memorandum dated March 13, 1979 from Mr. McGinnis to Mr. Kivett relates concerns expressed by Dr. Sexton regarding asbestos dust conditions generated by application of a type woven asbestos tape. Industrial Hygiene responded to this communication by making certain inquiries and inspecting the subject material along with tape supplied by other vendors. Three brands of two-inch wide insulating tape are presently supplied and used at the Institute Plant. Basic comments relative to each are: 1. FORTEX webbing is made in England and contains a dust suppressant. The material may be asbestos free but is difficult to apply and may often result in a less than effective insulating job. - 2. NOVATEX tape is a product of RM Industrial Products. The asbestos fibers appear to be well contained by sizing material and the tape is easily applied. 3. AMATEX woven tape is a product of Mexico supplied by AMATEX, Incorporated. The tape contains raw asbestos fibers of various lengths including dust. Potential for exposure to asbestos is ever-present from unpackaging, storage, application, usage and finally removal. UCC 016908 Mr. Peter Barna -2- March 15, 1979 Mr. Powell has indicated that asbestos tape is not a specification item and since he is of the opinion that its usage should be minimized he will investi gate the availability of substitute materials. Our measurements on previous occasions involving application and handling of dust suppressed asbestos tape does not indicate excessive personal exposure. Mr. Hurley*s group has made three measurements where the AMATEX tape was used at the Technical Center. The results ranged between 0.03 and 1.9 fibers per cc of air. Although these values do not exceed the present standards, more extensive usage at plant locations could result in significant problems. The current OSHA standards state that, "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than five micrometers, per cubic centimeter of air." The eight-hour time-weighted-average (TWA) exposure limit is two fibers and a further reduction to 0.1 fiber per cc has been proposed. Conversation with Mr. Thompson of the Purchasing Group indicates that present stocking of tape insulation material is a matter of availability rather than cost savings. The fact that AMATEX tape is included in the current in ventory does, however, present a problem. Plant 512 Industrial Hygiene believes the following statements to be pertinent: First: AMATEX asbestos tape is not a quality product in terms of personal protection from exposure to asbestos fibers. It does not contain the necessary dust and fiber release suppressant to avoid fibers becoming airborne. The potential problem is not only current but exposure to the elements will likely increase the potential. Second: Although personal exposure measurements have not been made at this loca tion of employees working with AMATEX tape, observation and inspection of the material indicates the degree of expected problems. Costs associated with Industrial Hygiene monitoring of exposure situations and Medical Depart ment monitoring of exposed employees would exceed any savings in material procurement and warrant efforts to obtain a suitable material or an acceptable substitute. In view of the above. Industrial Hygiene recommends that AMATEX no longer be purchased for Plant 511 Construction usage or dispensing within the limits of Plant 512. Consideration should be given to disposal of the current stock of AMATEX and application be restricted to NOVATEX tape where this type of material is necessary until an acceptable asbestos-free substitute becomes available. HHF:mc UCC 016909 ?() MEMO TO__ AVOID ORAL INSTRUCTIONS DATE /V^ / s j'^~ O/^Ci-* ./I ,il / " ?Ur^yCS^yis3; ----- s'LS/. tSy / < f yS S' /* ^ % 197 ^ ^ryo/2^r- X/3 /i-tu? yZ&sui/P JjLL j u. tsj J* + DO IT THE SAFE WAY + lZ________ -J& &-i*_ p /&dyy y^tLt// SIGNE UCC 016910 INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS To <Name) D. vision Location Mr. E. C. -Shipley 511-2009 Institute Plant Mr;..- L. -R. Mr. H. L. Dr. R. J. Mr. C. C. Dr. T. N. Noble . Robinson Sexton Smith, Jr. Spencer P. O. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 Dare --March 5, 1979 originating Dept.Technica 1 Center IH/EP Subject Medical Examinations Re: OSHA Asbestos Standard Dear Mr. Shipley: After our discussion on asbestos March 2, I have discovered an OSHA administrative order, copy attached, which interprets the asbestos standard in terms of medical requirements. It appears that medicals will be required of all employees who are exposed to a ITminimum of 0.1 asbestos fiber longer than 5 |jl per cc of air." ` Since application of engineering controls as specified in 1910.1001 subpart (C) (i) arep^ot^feasibl^for^tripping^^aRsrbestos we are using respiratory protection as allowed in 1910.1001 (d)(ii) By copy of this letter, Ij>aiii^requesting^:tke*^^ mine if use' of "respiratory protection constitutes reduction -of~~ex~ pos ur e be low 0.1.-Jtlber,.~per^ cub ic.^ceaLtimet^i^* ^ Very truly yours, GFH/sc Attachment % (t G. F. Hurley Technical Center Industrial Hygienist ~UGG> 01-6911 2'. H15B Magnesium arsenate. Sodium arsenite. Zinc arsenate. ,Jnc arsenite. MAainncufaflucoturorearrsseonfadtees.icca.I ts. . Example : Orthosarsenic ac: 1. g.. Manufacturers of wood p -eservatives. Some examples of these proc ucts are as follows: (1) Amrppniacal copper arsi nite. (2) Chromated copper arsed ate. (3) Mixture of chlorinatec arsenate, .fluotlBe and phenolic salts th aqueous solut! 3n. (4) Zinc-chrVnium arsenate. (5) Copperizad zinc-chromi: im arsenate. (6) Fluorchror\e arsenate p aenol. h. Manufacturers of feed ac ditives. Some examples qf these products are as Allows: (1) Arsanilic aci( (2) 3-Nitro-4-hydrbxyphenyj arsomc (3) 4-Nitrophenyla;Ssonic ac d. (4) 4-Ureido-l-phenylarson, c acid. i. Manufacturers of iharmjLceuticJls for use in veter inary medicine. Some examp_ les of thes ro |ucts/&re as follows: (1) Acetarsamide. 'i g (2) Carbarsone. (3) Dichlorophenarsine. (4) Lead arsenate. (5) MeJarsonyl. . (6) Neoars.phenamine. i (7) Thiacetarsamide (Caagajsl^ate). j. Manufacturers of gla t use arsenic trioxide as a refining agent and a decolor k. Manufacturers of dnoys >nferrous metals and arsenic. Some examples of pjbduct.l manufactured from these alloys are as follows: (1) Lead shot. (2) Cable sheathi/g (lead aid arseni (3) Battery grid(lead and j irsenic). (4) Battery electrodes (leacjand arsenic (5) Speculum metal. (6) Boiler tubjes (Copper arjl arsenic). (7) Arsenic tironze. (8) Special Jtolders such a used on bod^joints and seams in the Automobile indujtry. (9) ArseJlic brass. (10) Arsenical Babbitt. l. UsedT of solders that lontain arsenic as\i com ponent injfrhe alloy. Example: Automobile and ruck body manufacturers. m. Manufacturers and/c users of arsenic-\ased flotation reagents. n.^discellaneous. .. rsenic and/or arsenic-c ntaining, inorganic po/nds are used in each of t te following types of estab lishments. However, every employer does not necessarir >e them. HtFERENCE FILS tanneries (2) ManTT enamel. (4) Manu^citrf^fsofpyrotechnics? 2fftfnufacturers of semiconductors. OSHA PROGRM-; DIRECTIVE #300-16 ----- October 11,'1978 TO: REGIONAL ADMINISTRATORS/OSHA Subject: 29 CFR 1910.1001(j)(2) or (3) or (4), Minimum Airborne Fiber Concentration for Initiating and Continuing Asbestos Medical Examina tions. 1. Purpose The purpose of this directive is to provide uniform inspection and compliance procedures for the medical examination requirement in the asbestos standard, 29 CFR 1910.1001(j)(2), or (3) or (4). 2. Documentation Affected . This directive supplements and provides reference for the OSHA Industrial Hygiene Field Operations Manual (IHFOM) and the OSHA Field Operations Manual (FOM). 3. Background . In 29 CFR 1910.1001(j)(2), or (3) or (4), Medical ex aminations, the term ". . . exposed to airborne concen trations of asbestos fibers. . . ." has been the subject of considerable discussion and.debate as to the meaning or interpretation of "airborne concentrations." 4. Action a. Definition. In 29 CFR 1910.1001(j)(2), or (3) or (4), Medical ex aminations, the term ". . . exposed to airborne concentra tions of asbestos fibers. ..." is administratively interpreted to mean exposed to a minimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air, as deter mined by the sampling method prescribed in section 4.c. of this directive. The phrase "fibers longer than 5 micro meters per cubic centimeter of air" shall hereafter be abbre viated as "fibers/cc." . b. Scope and applicability. . Medical examinations as per 29 CFR 1910.1001(jX2), or (3) or (4) will be required for any 7- to 8-hour time- weighted average concentration of 0.1 fibers/cc, or for a greater concentration. c. Sampling information. . (1) Sampling procedures will follow Chapter X of the IHFOM., with the additional guidance of 4.c.(2) and (3) of this directive. (2) Exposure to asbestos dust with low levels of con tamination (e.g., mixed with other minerals). (a) For exposures to dust that is mostly asbestos and is expected to be below the permissible exposure limit, the same filter should be used for the entire shift, but no longer than 8 hours. (b) For exposures expected to be at or above the per missible exposure limit, several samples may be re- Occupationai Safety & Health Reporter UCC 016912. 36 '7uo i hlMlL i i ruK.11 l_ i , to crr >y<vii.xjn il.o- q; Ired during the shift to avoid overloading the filters. (3)Exposures to asbestos dust with high levels of contamination. (a) Several samples may be required during the shift to avoid overloading the filter. (b) Filters should be changed only after a minimum of 1 hour of sampling time for exposures expected to be close to 0.1 fibers/cc. Seven or eight l-hour samples can be collected during the day. d. Examples of types of violations. (1) Where an employer does not provide the required medical examinations, and an employee is exposed to 0.1 or more fibers/cc, it would be considered a "serious" violation of 29 CFR 1910.1001(j)(2), or (3) or (4). (2) For definitions and guidance on "repeated," "will ful," or a "failure to correct" violation, see the FOM, Chapter VIII. 54 -Effective Date This directive is effective immediately and will remain in effect until further notice. \ J 12-21-78 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., WASHINGTON, D.C. 20037 UCC 016913 dpy to Mr. D. E. Deese Mr. D. L. Engle Mr. J. S. Knight Ms. M. G. Manetti - 501 Mr. A. E. Montagna - 501 Mr. R. E. Peele - 511 AAr. F. S. Provenzano Mr. J. L. Rosenberger Mr. J. W. Whittlesey - 501 SUBJECT Industrial Hygiene Monitoring of Contract Personnel to Meet OSHA Standards_____________________________ Ref: Letter by 0. L. Rosenberger to W. D. Weber "Rough" Drafts of Asbestos^and Benzerr#^Procedures for Construction Texas City dated July 1, 1977 Dan: RECEIVED This is to request: i-i v (..7 (1) Your transmittal of reference above with drafts to the HEA Bus i ness; Tea in /for consideration/comment/approval. (2) Your guidance and direction to insure that Texas City is consistent with corporate and C&P intent/policy relative to monitoring of contract personnel when required by OSHA health standards. During the interim period, Texas City will: (1) Follow the draft procedures developed by Mr. Rosenberger. (2) The Texas City HEA Department will provide Industrial Hygiene services to the contract divisions upon request, as available resources permit. r ~s \ KJJ When resources imited. y will be oiven to plant fUCC) emolovees. Dan, I feel this is the most economic and practical way for this plant to approach this problem. However, I'm sure that at times existing I. H. resources won't be able to handle the contract as well as regular plant demand. Thanks for your help. Please contact if questions. JBL: i r r-j :~*~ if \ .-CL "7" } \ / 77 f) v'UL is 1977 J. L. 2 / <2 B. LEVERTON 06 UCC 016914- ..... r To: RE: Mr. George Hurley Bldg. 701-334 Asbestos Removal - Contractor June 27, 1977 George, The attached letter by J. L. Rosenberger, Construction Site Manager, Texas City, may be of interest. My present concern is for a program inclusion of our own Engineering personnel, including possible exposure to VCL and/or Benzene. Mr. Rosenberger has been encouraged by me to discuss these needs with his supervision. CWC:bkb Att. be: E. B. DelGrande C. W. Carman UCC 016915 UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P. O. BOX 471, TEXAS CITY, TEXAS 77590 RECEIVED JUN ? 7 1977 SAFETY CEPT. June 23, 1977 TO: COPY: FROM: SUBJECT: Mr. Dave Leach - Johns-Manville Mr. C. D. Matthews - Johns-Manville Mr. G. M. Parrish - United Engineers Mr. E. L. Agnew Mr. . C. W. Carman * Mr. D. E. Deese Mr. T. V. Griffith - United Engineers Mr. J. B. Leverton Mr. B. W. Lloyd Mr. R. P. Melton Mr. J. H. Rapp Mr. R. J. Taylor Mr. W. D. Weber Mr. L. L. Wilcox J. L. Rosenberger Industrial Hygiene Department Monitor Report Removal of Asbestos on the Ethyleneamines Shutdown 6-21-77 Please find attached a report from the Industrial Hygiene Department of the Construction exposure to asbestos during the subject project. Note that at no time did the exposure exceed the permissible exposure per OSHA Procedures. Congratulations to all of you for a job well done. ' The extra effort required, in my opinion, to accomplish the OSHA standards and to maintain the exposure below the permissible limits was minimum compared to the overall job and definitely minor compared to the benefit of preventing our people from being exposed to asbestos. Obviously, the procedure that we have established is valid and will be followed for all future work at Texas City. ' Again, thank you for a job well done. JLR:rj j Attachment UCC 016916 Industrial Hygiene Department PRELIMINARY REPORT TEXAS CITY j Date: 6-21-77 SUMMARY: Monitor for asbestos fiber exposure during tear-out of old Kaylo insulation at Bldg. 51. Requested by J. L. Rosenberger PROCEDURE: j DISTRIBUTION: I TO: J. L. Rosenberger COPIES: 1 R. P. Melton | D. H. Glenn, M.D. ' |J J. B. Leverton i .................................................................... .................... ........ .. Samples were collected on filter membranes by UCC Method 38C-29X4-R1 and analyzed by phase contrast microscopy. RESULTS: Name Matthews, D.M. Brummerhop,' H.A. Botkin, D.H. Smith, E. - Dunten, W.H. Area Sample SAMPLED 6-19-77 S. S. No Craft Fibers/cc > 5 466-76-8311 Insulator 0.13 464-34-9440 Insulator 0.06 462-60-4421 Insulator 0.11 453-66-9124 Laborer 0.07 446-16-3630 Operator 0.00 Downwind at NO. 1 Fletcher 0.01 Company Johns-Manville Johns-Manville Johns-Manville Johns-Manville Union Carbide TLV - 8 Hr Time-Weighted Average - 2 Fibers/cc > 5 y CONCLUSIONS/Recommendations All precautions required by OSHA Chapter IVII, Part 1910.93a were carefully followed by the personnel involved in the tear-out. All results show exposures well below the allowable levels. Surveyed By: Approved By: C. W. Perry UCC 016917 T. K. Campbell Rt J. Santo*, M# 0. iNstmmriANT Mi. ft. H Stainbot* Mr. F. VvtlHveM Mr. F. 5taffor/Mr. ft. NqI Mr. ft. C. Keani* Mr. ft. J. Otiirut/Mr. 0. F* Springer Fibers txposwe Dear Or* Sentoni Lifted beta* am the nomas of Constvuetlcit pMsnoii *rta ham hud for enpastive to airborne a&ettcs. **e staff attempt to keep yoor list up to data at Hit #ork fore# increases tm number. At Hi* prosam time many of tta tmuiateet am >.vriifi$ at Marietta, Chlo, arid rtll not bo ailly available during tta torkrtk. tmulatofs ftmplayee No* Irauiator* ftmptoyee No ft* ft. Smith J. f . Samples H. L. fteveat C.8. K*lgl* v*, S. Tindur J. ft* Iryanf ft. Starts V* H* Out J* F* Chandler `V. J. ftisklne J* M* Uviay P. w. Ymus ft* ft. Copier *V. 5* Roberts C * P* Stamblin 0* U Carpenter J* Lambert K.F.C#M J* tf* Symtide 405 m9 Salary 1176 UiO 1193 1195 1204 1209 1220 3030 1174 1175 1176 1113 1191 mi 1210 1161 D* C* StambfIn 1210 3* Tenner 2420 C. Miilr 1189 C. a. Turley 1217 G. C. Thompson, Jr. 1166 F. ft* Sunderland 4077 O H Onlay 0460 D* i. Johnson 1200 S* E^gletan 1171 J* *V* Pauley 0205 C* H. Smith 0620 ,, J*ftSoyt 3483 U.M. Sritton 2301 D M, 8oum 3053 G. P. Halt 1097 *V. J* iitkina J* ft* ftryent 1220 1m J* F* Chandler UCC 016918 R* J* Sosctaft, Mi Di *2- January 8, 1973 0. It. Out* O.C. Skonttk. M, McCluro H. L. GondM A. p. Colo S. M. MtrMsP & Do*oy A* F. Urban J. U Morris H. E. OiIHm C. M. A'otfinc/bwuar O. E.RIffl# Employe No* 0330 036b 037) 0395 0445 09)2 2571 03*0 0419 0392 0*61 23*6 L.1. MitaMI tf. J. Cgelcftm 1. V.Mfcart n14 *f Jwy-e --v 0* Robies F* M. Seeltoe H. C. Mtt H* l* Alter* MW< 0327 1)99 03)5 3204 3808 4125 4061 3993 , loborom M. C. Edwordl S. Muter H* Snyder H. L. Melos employee No* 0907 3774 3969 0399 Also, to moot CSHA requirement*, m mI requesting, by copy of Hilt 2after, tfeo employee rotations reocojontafivo to soboduta physical ooamJnetfen for ony of tho omployeos Ittted shod* Hmy doetao to terminote omptaymont, or bo tohodylod for taypff. \#ooroym Avmrwtejlfl ojoftwfMotMii f C .Comon/obe UCC 016919 INTERNAL. CORRESPONDENCE NOV 1 1972 CHEMICALS AND PLASTICS INSTITUTE PLANT To (Nam*) Division Location Mr. R. H. Steinberg Building 2009 Construction Department 30 October 1972 Originating Dept. Medical Department - Plant 512 Answering Utter date Subject Annual Examinations Asbestos Fibers Exposure For many years we have followed a group of D&C employees - sandblasters and insulators - th annual chest X-rays. This was accomplished usually in the early months of the year and in 1972 included : employees. It is believed that this program was useful but it now .oust be broadened. - A new OSHA ruling requires that every employee exposed to airborne concentrations of asbestos fibers must have a comprehensive medical examination ANNUALLY consisting of the following: (1) A medical history to elicit symptomatology of respiratory disease, (2) Pulmonary function tests and (3) A posterior-anterior 14" x 17" chest X-ray. In addition, any employee who has worked in an occupation where he has been exposed tc) air- bomt asb'e~St!5s~~FIbers must have a comprehensive medical examination on termination of employmentw- ---- ......... .... This is a request to provide as soon as possible a list of the names of D&C employees who are presently working in occupations where they are exposed to airborne concentrations of asbestos fibers. If employees in work classifications other than sandblasters and insulators are exposed to asbestos fibers, please also include their names. These examinations must be completed by 31 Jan 73. Very truly yours. RJS:gh Plant Medical Director UCC 016920 si - tfftlON 'CARBIDE INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS INSTITUTE PLANT NOV 1 1972 fCs) 1, CHARLESTON, WST VIRGINIA 25330 To(Nam) Dhhion Location Mr. R. H. Steinberg Building 2009 Construction Department Copy to Doto 30 October 1972 Originating Dopt. Medical Department - Plant 512 Antwring iottor dat Subjoet Annual Examinations Asbestos Fibers Exposure For many years we have followed a group of D&C employees - sandblasters and insulators - with annual chest X-rays. This was accomplished usually in the early months of the year and in 1972 included 66 employees. It is believed that this program was useful but it now must be broadened. A new OSHA ruling requires that eVery employee exposed to airborne concentrations of asbestos fibers must have a comprehensive medical examination ANNUALLY consisting of the following: (1) A medical history to elicit symptomatology of respiratory disease, (2) Pulmonary function tests and (3) A posterior-anterior 14" x 17" chest X-ray. In addition, any employee who has worked in an occupation where he has been exposed to air borne asbestos fibers must have a comprehensive medical examination on Termination of employment. This is a request to provide as soon as possible a list of the names of D&C employees who are presently working in occupations where they are exposed to airborne concentrations of asbestos fibers. If employees in work classifications other than sandblasters and insulators are exposed to asbestos fibers, please also include their names. These examinations must be completed by 31 Jan 73. Very truly yours. RJS:gh UCC 016921 LiC 149-2 INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS T(Nam) Division Location Mr. R. J. DuBrul Building 2 Copy fo Mr. A. F. Booth Mr. G. D. Brown Mr. T. L. Collins C. U. Dernehl, M.D. Mr. P. E. Drake Mr. D. L. Garrison Mr. R. H. Johns Mr. G. R. Kraft Mr. H. C. McGinnis Mr. R. E. Peele Mr. B. G. Perry Mr. B. D. Tissue J. J. Welsh, M.D. INSTITUTE PLANT P. 0. 30X 2331, CHARLESTON. WEST VIRGINIA 25330 Dot* 1 August 1973 Originating Dipt. Medical Department - Plant 512 Answering letfvr dait Subject Asbestosis Enclosed is a report describing a Medical Department survey conducted on employees of the Plant Maintenance and Utilities Departments. RJ S : gh Enc. UCC 016922 C* 1 OINFiON CARBIDE INTERNAL CORRESPONDENCE 9(it) CHEMICALS AND PLASTICS institute plant p. o. box 2831, charleston, west Virginia 25330 rofNamt) OMsfon location Copy to Mr. E. B. DelGrande Building 791 - Room 33 Technical Center Mr. C. E. Allen Mr. L. L. Bissett Mr. C. W. Carmen Mr. F. J. Casabona Mr. R. J. DuBrul C. U. Dernehl, M. D. E. Q. Hull, M. D. Mr. G. R. Kraft Tracy Spencer, M. D. Mr. B. D. Tissue J. J. Welsh, M. D. Mr. Fred Williams Daim 5 Oct 73 Originating Dipt. Medical Department - Plant 512 Ansmring /offer data Subl9tt 1973 Asbestosis Survey The Institute Plant Meciical Depar^tment has provided complete medical service for Design and Construction hourly employees since 1955. A component added on certain Design and Construction employees, to disclose the presence and extent of asbestosis. Enclosed is a report that described pertinent findings on construction employees in several crafts. To provide essential introductory and background information, but to avoid reiteration, is attached an earlier, equivalent survey report completed on Institute Plant employees. It is suggested that the recipients read the latter report prior to reading this report. RJS:pc enclosures (2) UCC 016923