Document 3NapgL1pqXp0XgEBbzqGrELgO

INTRACOMPANY CORRESPON: NCE a.98 (RV. !-48) PLAINTIFFS EXHIBIT FROM Pnnalri F.. Benton - Industrial Hygiene, GOB RMC-459 T O' COPY: W. S. THCMAS ~ BATON ROUGE CALCINED COKE P1ANT Paul L. Patty, D. E. Birasher, D. R. Mason, J. R. Acoott - Baton Rouge; H. V. Helton, E. J. Gates, T. N. Brown, W. A. Wright, P. R. Laden, D. B. Mortimer, B. J. Sasser, Dr. E. C. Irby - EXO DATE & SUBJECT: July 27, 1983 ASBESTOS PROGRAM In the early 1970's, Reynolds Metals Company instituted a program to remove all non-essential asbestos-containing products from our manufacturing facilities. Although this program has been quite successful, several areas still remain where asbestos is currently being used. Consequently, the Medical Department, along with Central Engineering, has begun a final effort to eliminate all inhala tion exposure to asbestos. In order to accomplish this goal, all asbestos-con taining products which have feasible substitutes will be eliminated from HMC facilities. Where there are no feasible substitutes, appropriate work practices will be developed, so that there will be no inhalation exposure to asbestos while using the product. As part of this effort, the Baton' Rouge Plant was visited on April 12-14, 1983, to evaluate the status of the plant's asbestos control program. During this audit, those asbestos-containing products in inventory were identified, as well as those items already in place or currently being used by the plant. Results of this visit indicate that the Baton Rouge Plant has performed a tre mendous job in eliminating the usage of many asbestos-containing products. Several small areas, however, need additional attention. First, those asbestos-containing items currently being used by the plant were identified. Fran these items, a list was compiled of those products which may represent a potential exposure to the worker. As a result, the plant should remove these items from use and substitute a non-asbestos product. Table 1 lists each of these products, as well as potential substitutes. Where possible, the plant should return its current inventory for credit. If this is not feasible, then the plant should place the material in labeled, sealed plastic bags and dispose of it in an approved sanitary landfill. Contact the Environ mental Control Department for information on proper disposal procedures and approved landfills. Second, nine (9) bulk sanples of material already in place or currently being used were collected and screened for asbestos content (Appendix II). Based on these results, Table 2 was developed, identifying the various applications of those products found to contain asbestos. It should be noted that, for those products already in place, the presence of undisturbed asbestos (e.g. burner cap gasket, transite pipe, outer covering on #1 kiln electrical cable) does not represent an exposure hazard. Consequently, there is no requirement to remove these items fran the plant. If, however, work is performed on any of these products (e.g. demolition, repair, removal), then non-asbestos substitutes should be utilized, where available, and appropriate work practices followed (Appendix III) to eliminate any inhalation exposure to asbestos. If work is performed on an item R MC3300020000104 PAUL L. PATTY - BATON ROUGE ASBESTOS PROGRAM 2- July 27, 1983 ret listed in Tables 1 or 2, it should be handled as asbestos, until appropriate analytical results can be obtained. Third, there were severed places noted in the kiln area where scrap pieces of the old asbestos rope had been discarded. Seme were hanging frem metal beams, while others were on catwalks and other walkways where they could be damaged. Consequently, all scrap rope should be removed from the plant and sealed in labeled plastic bags for appropriate disposal. Employees involved in this task should wear approved respiratory protection (e.g. 3M #8710; American Op tical #1050) and place the respirators in the plastic bags for disposal when the job has been completed. The transite pipe left over from the same enginesi'ing project does not represent an exposure hazard, however, and does not need to be removed. Please contact COS Central Engineering or the Industrial Hygiene Department, if any future application is. anticipated. In order to acocrplish the objectives of this program and to ensure its con tinued effectiveness, it is recamended that someone at the Baton Rouge Plant be designated as contact person. In this regard, that individual would receive and disseminate information concerning non-asbestos substitutes. In addition, he vrould review all Material Safety Data Sheets (MSDS) for new products, to ensure that no asbestos is contained in them. (Note: A procedure is currently being developed through Purchasing which will allow RM2 to determine whether or not asbestos is in a product before it enters the plant). Finally, this individual will be responsible for making certain that the appropriate safe handling procedures are utilized when walking with asbestos-containing products. If you have any question concerning this report or if further information is desired, please feel free to contact us. REB/mjm Att Robert G. Burton RMC3300020000105 Table 1 BATON ROUGE CALCINED COKE PLANT ASBESTOS PRODUCTS AND SUBSTITUTES ASBESTOS PRODUCT Sleeves on laboratory clamps Cloth in laboratory SUBSTITUTES Fiberglass, ceramic and silicone fiber sleeves are available. These sleeves are fabricated from cloth that is also available. See above. Electrical wire All manufacturers make non-asbestos high temperature jacketed wire, such as SMRL. Gaskets Gaskets are available for all ap plications, depending upon use, temperature, and the abrasion encountered. Wire screen in laboratory Thin sheets of ceramic fiber paper or cements will work for heat distribution. RMC3300020000106 PLANT BflTCN HUGE CALCINED COKE PLANT LOCATION ,,________ DIVIS ION Prinre-rv SURVEYED BY R. E. Benton? R. G. Burton DATE April 12-14, 1983 ASBESTOS SURVEY SAMPLE SAMPLE *LOCATIONAPPLICATIONRESULTS ANALYTICAL 1 Kiln Floor Burner casket, #3 kiln YES 2 t If Sichtclass casket. #3 kiln YES 3 It II Burner blower aasket, #3 kil 1 YES Duter covering, elec, cable, 4 it n S.side #1 kiln YES Control roan, outer wall 5 n ii siding (S.end) NO 6 Cooler Ground level Sasket mat'l., #1 cooler NO 7 Storeroom Elec, wire (coil) YES 8 Door, #3 cento, chant . Door seal YES Burner cap joint gasket, 9 Kiln Floor exit end kiln YES RMC3300020000107 BATON ROUGE C A LC IN E D COKE PLANT RMC3300020000108 APPENDIX III SPECIAL HANDLING PROCEDURES RMC3300020000109 SPECIAL HANDLING PROCEDURE "A" This procedure is for those products which should pose no asbestos exposure while removing or handling the material. Eranples of the types of materials included are: Asbestos covered wins, clutch facings, ccnpressed gaskets, and asphalt roof coating. SPECIAL EQUIPMENT REQUIRED: labeled 6 mil plastic trash bags with ties (available from local safety supply distributor). MEDICAL EXAMINATIONS: None required. PERSONAL PROTECTIVE EQUIPMENT: None required. WORK PRACTICES: 1. No asbestos scrap shall be left on the floors, walkways, or equipment. 2. All asbestos scrap shall be placed and sealed in labeled plastic bags and disposed of at an approved sanitary landfill. 3. No blowing or dry-sweeping, scraping, or sanding of asbestos materials or surfaces covered with asbestos-containing ma terial shall be permitted. MONITORING: None required. RMC3300020000110 SPECIAL HANDLING PROCEDURE "B II This procedure is for those products which, when handled or removed from existing surfaces, should not result in asbestos exposures above the OSHA permissible exposure level. (Exposures may, however, be above the 0.1 fiber/cc medical maintenance level.) Exanples of the types of materials included are: Rope, cloth, gloves, blankets, and coats. SPECIAL EQUIPMENT: Labeled 6 mil plastic trash bags with ties (available frcm local safety supply distributor). MEDICAL EXAMINATIONS: Annually, personnel involved in the removal or handling of materials in this group shall be provided a physical examination, if exposures exceed 0.1 fibers/cc. This examination shall include a chest x-ray, pulmonary function test (FVC and FEV), and a complete history. PERSONAL PROTECTIVE EQUIPMENT: Half-mask air-purifying respirator (Exanples: 3M #8710 or #9900 Series, American Optical #1050, or any other NIOSH respirator approved for asbestos). NOTE: Employees issued respirators must be instructed as to the proper use, care, and fit of the respirator. WORK PRACTICES: 1. No asbestos scrap shall be left on the floors, walkways, or equipment. 2. No blowing or dry-sweeping, scraping, or sanding of asbestos material or surfaces covered with asbestos-contairrLng material shall be permitted.* 3. All disposable respirators and scrap asbestos naterial shall be placed and seeded in labeled plastic bags and disposed of at an approved sanitary landfill. MONITORING: Periodic monitoring will be carried out by, or under the direction of, the Corporate Industrial Hygiene Department. Based on the results of the monitoring study, any necessary reccxrmendations will be madia. *All asbestos-containing material shall be kept thoroughly wetted, while handling and/or removing the naterial. RMC3300020000111 SPECIAL HANDLING PROCEDURE I C" This procedure is for those products which, when handled or removed from existing surfaces, may result in exposures above the OSHA standard. Exarrples of the types of materials covered are: Furnace and oven wall, door, and ceiling insulation find stearnpipe and boiler insulation. SPECIAL EQUIPMENT: 1. Labeled 6 mil plastic bags with ties (available from local safety supply distributor). 2. If available, vacuum cleaner equipped with special filter, to prevent re-entrainment of asbestos fibers into the work place. 3. Warning signs indicating ASBESTOS HAZARD. MEDICAL MONITORING: Annually, personnel involved in the removal or handling of materials in this group shall be provided a physical examination, if exposures exceed 0.1 fibers/cc. This examination shall include a chest x-ray, pulmonary function test (FVC and FEV), and a complete history. PERSONAL PROTECTIVE EQUIPMENT: 1. Half-mask air-purifying respirator, equipped with a high efficiency filter (Exarrples: WILLSON #1210, NORTON #7506, MSA Confo II (#459440), or any other NIOSH-approved non-disposable respirator. NOTE: Employees issued respirators must be instructed as to the proper use, care, and fit of the respirator. 2. Disposable coveralls, head and foot coverings, ancl gloves shall be provided to each enployee involved in the demolition, removal, and/or handling of asbestos insulation. WORK PRACTICES: 1. Prior to beginning removal or demolition of any asbestos material, caution signs shall be placed around the work area, at a distance safety away from any dust which may be created. For large projects (i.e. furnaces, ovens, boilers, etc.), the immediate work area shall be enclosed in a plastic roan. RMC3300020000112 "C" Page 2 Work Practices Continued 2. A decontamination area shall be established, to allow the workers a place to don and remove the personal protective equipment. 3. Disposable coveralls, gloves, and head and foot coverings shall be disposed of in the labeled 6 mil plastic bags. 4. All asbestos insulation material shall be kept thoroughly wetted, while haniling and/or removing the material. 5. No blcwing or dry-sweeping, scraping, or sanding of asbestos material or surfaces covered with asbestos-containing ma terial shall be permitted. Wvene practical, the residual scrap material on work surfaces should be vacuumed with a special vacuum cleaner equipped with an HEPA filter, to present re-entrainment of the asbestos fibers into the workplace. Otherwise, work surfaces should be double-wet cleaned. 6. All scrap asbestos material, as well as the disposable personal protective equipment, shall be placed and sealed in a labeled plastic bag and disposed of at an approved sanitary landfill. (The plant or corporate Environmental Control Department should be contacted for any specifics.) MCNTTORING: 1. Measurements of airborne asbestos fibers, during the handling and/or removal of asbestos material, shall be conducted by, or under the direction of, the Corporate Industrial Hygiene Department. 2. Based on the results of the monitoring study, the Corporate Industrial Hygiene Department will make any necessary recom mendations concerning additional monitoring, enployee notifi cation and training, and any changes in personal protective equipment. RMC3300020000113 SPECIAL HANDLING PROCEDURE "D" This procedure covers the reccrtnended work practices to be used when changing/installing brake shoes. SPECIAL EQUIPMENT: 1. Labeled 6 mil plastic bags with ties (available at local safety supply distributor). 2. Heavy-duty paper towels or rags, for wiping brake drums. MEDICAL EXAMINATIONS: Annually, personnel involved in the reitnalor handling of materials in this group shall be provided a physical examination, if exposures exceed 0.1 fibers/cc. This examination shall include a chest x-ray, pulmonary func tion test (FVC and FEV), and a complete history. PERSONAL PROTECTIVE EQUIPMENT: Half-mask air-purifying respirator (Exanples: 3M #8710, 9900 Series, American Optical #1050, or any other NIQSH-approved respirator for asbestos). NOTE: Employees issued respirators must be instructed as to the proper use, care, and fit of the respirator. WORK PRACTICES: 1. All brake drums shall be wiped clean, using a wet paper towel or rag. No blowing or dry-sweeping shall be permitted. 2. All disposable respirators, tcwels, and/or rags ussed to clean the brake drums shall be placed and sealed in labeled plastic bags and disposed, of at an approved sanitary landfill. (The plant or corporate Environmental Control Department should be contacted for any specifics.) MONITORING: 1. Measurements of airborne asbestos fibers during the removal, cleaning, and reinstallation of brake shoes shall be conducted by, or under the direction of, the Corporate Industrial Hygiene Department. 2. Based on the results of the monitoring study, the Corporate Industrial Hygiene Department will make any necessary reccrmendations concerning additional monitoring, employee notification and training, and any changes in personal protective equipment. RMC3300020000114 MEMORANDUM TO: W. Sibley Thomas FROM R. E. Benton - GOB R. G. Burton - EXO DATE: July 25, 1983 SUBJECT: ASBESTOS SURVEY AND REPLACEMENT PROGRAM We would like to thank you for your cooperation during the visit to your plant on April 12-14, 1983. It is now Company policy that where feasible substitutes are available for asbestos; that they will be purchased; and that where we must purchase asbestos no machining, cutting or grinding will be done to the material. In this package there is enclosed the following: 1. A list of materials that will substitute for asbestos that we found in use in your plant. 2. A list showing common places in which you can expect to find asbestos containing materials in your plant and an attachment that gives you the precautions that must be taken when these materials are worked with, or when they are removed and disposed. These safe handling procedures have been developed to eliminate any inhalation exposure to asbestos when working on a product containing asbestos. 3. A list of asbestos replacement products with telephone numbers and names or companies that can assist in replacing asbestos containing products or offer alternatives to present replacements. This survey and replacement program is intended to increase everyone's awareness and should be covered with plant personnel, especially maintenance, engineering, and purchasing. We would also like to stress that this asbestos program is an ongoing program and that we will be available to assist in the applications and problems associated with asbestos on a continuing basis. We can assist in obtaining trial samples and coordinating information as you require them. Thank you for your cooperation. Ronald E. Benton Industrial Hygiene 804/281-2265 (222) Reyphonet RGB/eb Robert G. Burton Central Engineering 804/281-3524 (222) Reyphonet RMC3300020000065