Document 4vqYw8jqxRjGeVVLLBzRnxN9R

FILE NAME: Mead (MEAD) DATE: 1974 DOC#: MEAD021 DOCUMENT DESCRIPTION: Unpublished Internal Report Environmental Survey ,:''~;;.i'c'<?Vr .5S#!-".'/:-5< ` * * AMERICAN SMELTING ANO REFINING COMPANY Department of Environmental Sciences Salt Lake City, Utah Plant: CARCO - Ragland Field Work: J. P. Sieverson Survey Dates Report Date: November 20-22, 1974 January 20, 1975 ENVIRONMENTAL SURVEY I. OPERATIN6 CONDITIONS * Operations were normal during the survey, U . SAMPLING PROCEDURES A. Air; 1. Individual and stationary asbestos fiber samples were collected with M,,S,A, personal monitoring pumps eguipped with open-face Millipore filters (0.8 micron pore size The asbestos fibers were counted using a Zeiss phasecontrast microscope, according to methods specified in the NIGSH criteria document. 2. An individual dust and fume sample was collected with an M.S.A, personal monitoring pump equipped with closed face:(plastic cover in place and inlet plug removed) Millipore filters (O.fi micron pore size), This filter was weighed to check total particulate loading. B, Noj.se: No*se measurements were taken with a B&K Model 2205 Sound Level Meter using the "A" scale and "slow" response setting The meter was calibrated with a standard noise source befo and after each set of measurements. C, Water; : Water samples were collected from six locations: 1. Discharge before going to settling ponds, I s * j ASARQO ALV 0000379 -2- 2. Discharge after treatment, sampled near CAPCO pro perty line {just above railroad culvert). 3. Discharge just above confluence with Trout Creek ft mile from plant). 4. Trout Creek above confluence with discharge (at railroad bridge). 5. Trout Creek below confluence with discharge. 6. Discharge from Hydrotest machine. j I All water samples were analyzed for total suspended solids and number of asbestos-like fibers. 111. SAMPLING RESULTS I Airi 3-* Asbestos Monitoring Employee Name and No, a. Employee Samples Job Title Sampling 1974 Time , Date (Min.) Asbestos Fiber Count Based on Sampling Time {>5 u/cm3 air) J, Clones #196 Fiber 11/21 92 (Respirator worn) Charger ^ ) (day) J. Jones #196 (Respirator worn) Fiber Charger 11/21 9 (day) 8.1 * *& 15.0 C. Scott M S (Respirator worn) Fiber Charger 1.1/21 44 (afternoon) 15.1 ** J. Looney #38 Laborer ^ 11/21 45 1.0 (Respirator worn) (afternoon) M. Ford #216 Flextester 11/21 176 0.4 (No respirator) (day) C. Johnson #12 (No respirator) Flextester 11/21 44 (afternoon) 1.8 <5) C. Wolfe #228 Hydro Operator 11/21 59 0.4 (No respirator) (day) ASARCO ALV 0000380 -3a. Employee Asbestos Monitoring Samples (con't.j Employee Name and No. J. Jackson #205 (No respirator} W. Morgan #243 {No respirator) W. Echols 218 {Respirator worn) B. Kay #33 (Respirator worn) A. Kay #193 {No respirator) C, Alverson #143 {No respirator) H, O'Donnell #141 (No respirator) D. Kay #200 {No respirator) S. Rich #220 (7) D. Kay 235 (No respirator) Job Title sampling 1974 Time Date {Min,) Coupling! Tester 11/21 86 (day) Lathe Operator 11/21 51 .(day) Coupling 11/21 80 Lathe Operator May) Small Coupling 11/21 85 Lathe Operator May) Coupling Cut-off 11/21 80 May) Tap Coupling Operator 13/21 ;{flay) 89 ^ Cut-off Saw :11/21 80 Operator (flay) Cut-off Saw '11/21 31 Operator afternoon) Cut-off Saw 11/21 98 Helper {day) Cut-off Saw 11/21 28 Helper afternoon) Asbestos Fiber Count Eased on Sampling Time <>5u /cm3 air) 0.7 0.2 0.7 1.0 2,1 4,7 3 2 9.9 * 4.5 <7> 3.7 I ASARCO ALV 000038 Footnotes for Employes Asbestos Monitoring Sampling Data; * Exceeds OSES. 8-hoar time-weighted average (TWA) exposure to asbestos of 5.0 fibers > 5 ji long per cm3 of air. ** Exceeds OSHA ceiling concentration (not be be exceeded during an 8-hour shift} for asbestos of 10.0 fibers > 5 |i long per cm3 of air. {1} Dumped 4 Kollergang charges during sampling period; each charge consisting of 2h bags of blue asbestos and 6*j bags of white asbestos. <2} 1 Rollergang charge. (33 2 Kollergang charges. (4) Worked around pipe machine and shot blaster. (5) Did soma handgrinding during sampling time. {6} Includes 15linute break during sampling period. (73 Cleaned dust collector. Wore respirator while cleaning but not around saw. ! OSHA Standard for Asbestos; 8-hoar time-weighted average (TWA) Airborne Concentration Ceiling Concentration {not to be exceeded) 5.0 fibers > 5 (i long per cm3 of air 10.0 fibers *5 jl long per cm3 of air ASARCO ALV 0000382! 'S' 1. Asbestos Monitoring b. Stationary Sample Area fiber Warehouse Location On pallet east of unloading area 2. Personal Monitoring Employee Name and No. d. Looney #38 dob or Operation Laborer around pipe machine and shot blaster Sampling 1574 Time Date (Min.) 11/21 90 (day} Asbestos Fiber Count Based on Sampling Time (>5y/csr air) 16.6 Sampling 1974 Time Date (Min.) 11/21 159 (afternoon} Anal- Cone* ysis (mg/m.3 Total 2.0 Parti- culate OSHA Standard.for nuisance particulate: . 3 1S.0 mg/ra as an 8-hour time-weighted average B. Noise Measurements; Area Coupling lathes Location ________________ Noise Level (dBflj Six feet east of north lathe - 89 net running Two feat north of electic 95 motor for hydraulic control of lathes Small coupling lathe - operator's 88 station while cutting Coupling cut-off - operator's 89 station OSHA Permissible Noise Exposure Duration per day (Hrs/Min) * 9/11 4/0 , . 10/34 9/11 I ASARCO ALV 0000383 -6. V Br Noise Measurements (cont.); Area Cut-off Saw location Operator's Station while cutting Noise level (dBA) 91 OSHA Permissible Noise Exposure Duration pa yday (Hrs/Min) 6/58 Operator's Stationnot cutting 86-88 13/56-10/34 Helper's station while cutting 98 2/50 Helper's station not cutting 86-88 13/56-10/34 Boiler Area Bear column with chart paper storage 86 13/56 Hyster Hyster hauling mandrels - 87 Front End at idle loaders Hyster hauling mandrels - 92 at V throttle 12/8 6/4 Small hyster hauling couplings- 89 at idle 9/11 Small hyster hauling couplings- 96 at % throttle 3/29 Pipe bathe Dust Collector Ground floor with hopper 96 vibrators on Shaking floor with hopper 104 vibrators on (operator's station) 3/39 1/9 * .Permissible exposure limits taken from Proposed OSHA Boise Standard, as published in the October 24, 1974, > Federal Register. The exposure limits are the same as the existing OSHA Standard, except that additional time limits are proposed for employee exposures between 85-89 dSA, J ASARCO ALV 000038^ - 7 C. Water Sampling Suspended Solids Sample Location______________ (mg/1)_____ 1. Discharge before settling ponds 3900 2. Discharge after settling ponds (just above rail road culvert) 184 (95% removal) 3. Discharge ten feet above 111 confluence with Trout Creek 4. Trout Creek above conflu- 3 ence (at railroad bridge) Heavy oil sheen observed on surface of creek. 5. Trout Creek below conflu- 6 ence. Oil sheen still .present, 6. Discharge from Hydrotest 386 machine. Heavy oil sheen observed. Asbestos-like fibers * {106 fibers/liter) 1,370 0.7 (99% removal) 1.4 5.7 -0.5 2.6 * Positive identification of fibers (observed during microscopic counting) as being asbestos cannot be made. Only fibers longer than five microns were counted, IV. COMMENTS A. OSHA 1, Asbestos This plant has never had an OSHA industrial hygiene o safety inspection. The sampling results show that most employee exposures are below the present SHA asbestos standard of 5 fibers/cn>3. One area which does not comply with the 5 fiber standard is fiber charging. The employee charging asbestos fiber apparently receives exposures above the OSHA ceiling limit. ! ASARCO ALV 000038S -- -- A stationary sample taken near the work area also shows a high concentration of asbestos fiber. The exposure may be the result of inadequate ventilation for the bucket eleva tor, numerous broken bags of white asbestos in the warehou^^r and/or poor housekeeping, around the warehouse. The air ve lo city at the face of the hood for the bucket elevator should be checked with the Alnor velometer (available in the lab) The average face velocity should exceed 100-150 fpm. The problem of broken bags may be resolved by requesting the use of stronger bags or by wrapping the shipping pallets with plastic at Lake Asbestos. All sampling results sihould now be compared against the 2 fiber limit which is effective July 1, 1976 -- a scant 1$ months away. The sampling results indicate a number of exposures exceeding the 2 fiber limit (for 1976); a. Fiber charger -- this has been discussed previous!^. The operator wears a respirator when charging, b, Tap coupling operator -- This operation appeared fc<|> be adequately ventilated. Further samples should lj>e collected to determine the source of the exposure, The sample may have been "salted," The operator dies not wear a respirator, but should be required to do so unless future samples fall below the 2 fiber lijfiit. c> Cut-off saw operator and helper -- Ventilation in this area appeared to need improvement. Neither man was observed to wear a respirator around the saw. Respirators should be required until future sampled fall below the 2 fiber limit, d, Coupling cut-off lathe -- Housekeeping was poor in this area, Employees work on a mound of asbestos cuttings. The operator did not wear a respirator but should be required to do so. Ventilation for the various coupling lathes appeared inadequate and should be improved. One operator was observed to cut very dry couplings on the small coupling lathe resulting in excessive fugitive emissions. The plant has an area with water sprays to keep couplings wet, and the operators should be instructed to return djry couplings to this area and work only with wet couplings. e. Flextester -- This exposure is probably related to the amount of harsdgrinding done during the shift. The handgrinder is not presently ventilated. Further sampling is needed. I ASARCO ALV 0000386 OSHA has -a number of specific requirements for asbestos operations, An addition -to the employee exposure standards already discussed. Some of these requirements are being complied with, such as: a. Change rooms are available. Requirements for six-month environmental or person:al monitoring surveys and associated record-keeping a;.re met. Plant personnel make regular surveys using t<70 WUS.A, pumps, which are calibrated before and aftefc each survey. The D.O.E.S lab presently counts the asbestos samples, however, the CAPCO Van Buren plan,t has received the necessary equipment and will soon be capable of counting samples from Ragland. SampjL.es should be cross-checked with the D.O.E.S* lab to insure quality control. The results of some past surveys have been reported as eight-hour TWA -exposures, based on the assumption that the employee received no additional exposure to asbestos fiber after the sampling period. This assumption is not valid at CAPCO properties becaus employees are continually exposed during their shift to various levels of airborne asbestos fibers. Eighthour exposures can be constructed if a series of samples is taken at the various working and resting areas used by an employee during his shift, and th time at each area is recorded. Plant personnel ma wish to do this for the fiber charger operator. c. Caution signs are posted around areas which may ex ceed the 5 fiber limit, and, preferably, should be posted in areas which may exceed the 2 fiber limit The signs should be mounted in a conspicuous place A sign at the entrance to the fiber warehouse was not mounted but was -sitting on a horizontal steel beam d. Annual medical exams are given to all employees. The exam should include a chest x-ray, respiratory disease history, and prescribed pulmonary function tests Some OSHA requirements have not been met, or -compliance is questionable, such ass i-h-i:;TM" a. Local exhaust ventilation and dust collection syst eras should be checked for conformance with AKSI stands rd = ; 29.2-1971, *American Matronal Standard Fundamental s Governing the Design and Operation of Local Exhau t I# Systems." A reference copy is available from D.O E.S., but the plant engineer should obtain a personal copy. - ASARCO ALV 0000387 1-3 The plant has received three used baghouses from a closed mine and plans to install the baghouses to increase ventilation volumes, These new collection systems should also conform to the ANSI standard. Machine operators should be trained to use the ver tilation properly. For example, the big M.O.A. lathe was not working, hut the ventilation pick-up was ojpen. Dampers should be installed at each station, and operators trained to shut off ventilation to unuse machinery. b, A respirator program meeting ANSI standard 288.21969, "American National Standards Practices for Respiratory Protection," needs to be established, reference copy is available from. D.O.E.S,, but a copy should be ordered for the plant. The plant makes three respirators available? 1} 3M #8710 Disposable 2} Welsh #7406 3} GlenAire IBM-21A-83 Of these three, only the 3M #8710 is shown as ap proved respiratory protection"against asbestos on the list of NIGSH Certified -Protective Equipment. The Welsh #7506 (as opposed to the #7406 used in the plant), equipped with #7500-4 cartridges and #?50(j) 6 filters, is also NIOSH-approved for respiratory priotection against asbestos-containing dusts. It is important to use such "Certified" equipment to av4>id a citation by an OSHA safety inspector. OSHA also requires "the maintenance of an historic file" in connection with the respirator program, hut the documents needed in the file are not defined. This requirement may refer only to regular inspections of emergency-type respirators. The ASARCQ Safety De partment may have more information on this requirement. Respirator use observed during the survey was poojr Employees did not appear to have been adequately trained in the proper use, fit, or care of their respirators. Respirator use should be required of an: employee whose job involves exposures greater thah 2 fibers/cm3 until improved ventilation is installed, engineering or process changes are made, and/or fu:rthur sampling shows exposures fall below the 2 fi ber limit. ASARCO ALV 0000388 11 Two separate clothes lockers need to be provided for each employee. d, Employees presently take their clothing home for laundering, GSHA requires that contaminated clothing be transported in sealed, impermeable bags, which are properly labeled. An in-plant laundry should be considered to prevent any future liability over alleged family exposures, e. All hand-operated and power-operated tools, which (may produce or release asbestos fibers resulting in ar excessive employee exposure, should be provided with local exhaust ventilation. This would apply to the handgrinder used on the pipe finishing line and, pos sibly, some shop tools. The lathes and other major pipe finishing tools already have exhaust ventilation, , Housekeeping needs improvement,' OSH& requires that all external surfaces be maintained free of accumula tions of asbestos fibers if, with their dispersion there would be an excessive concentration. The large amounts of asbestos used in the plant combined witlh the many finishing operations, such as lathing, sajwing, and grinding, make compliance with this requirement extremely difficult, Piles of loose asbestos waste were noted -on the pipe finishing line and around tjhe lathes. Increasing air velocities at ventilation ' points (to pick up a greater amount of wastes) by installing the three additional baghouses should help the housekeeping problem. Assignment of more emplo yees to housekeeping may also be necessary, Employees involved with housekeeping should be advised to wet down the waste, whenever possible, to prevent dusting during handling. For example, one employee was observed during the survey to vigorously shovel dry asbestos waste into an open skip for disposal. The shoveling resulted in dusty fugitive emissions Th employee wore a respirator, but other employe#, in the area did not. , g, Asbestos waste should be disposed of in properly 1abelect, sealed, impermable bags (or other .containers) ; unless the plant is prepared to show OSHA that an] reasonably foreseeable handling of the waste will not result in airborne concentrations of asbestos exceeding the OSIIA standard, Most of the waste from cleaning the baghouses or housekeeping around the plant is dumped into open skips and thence into a dump truck for disposal. 1 ASARCO ALV 000038S -- 12 Waste bags from the fiber charging area are put in large plastic bags for disposal, h. The fiber charger operator {or any other employee receiving exposures in excess of the ceiling level of 10 fibertm3) should wear coveralls, head and foot coverings, and gloves to comply with OSHA. i. Any employee found to have been exposed to concen trations above S fiber/em3 should be notified in writing. The CAPCO Van Buten plant has a standard form which is signed by the employee, Ragland presonnel may wish to use the same form. This notifi cation should be given to the exployees found to have received excessive exposures, as reported in this survey. OSHA requires notification of the employee within 5 days after finding an exposure above the standard. j . Medical exams should also be given within thirty days after the initial employment or termination o:: any employee exposed to airborne asbestos fibers 2, Dust The one sample taken for dust exposure was well within OSHA standards, However, the sample did not cover the dust iest portion of the shot blaster operation. This job shoufd be resampled using pre-waighed filters (available from D.O.E.S.) to determine compliance with the OSHA nuisance dust standard. Possible employee exposures to dusts from unloading or handling silica flour and cement dust should be checked, 3. Noise The noise exposure of the helper around the cut-off saW probably exceeds permissible levels. Because increased ven tilation for the saw is indicated, any new or changed enclo sure should include sound absorption material, such as glass wool and/or Acoustilead, to reduce sound levels. The helper should wear hearing protection until sound levels fall below 90 dBA, i Hyster drivers may also receive excessive noise exposures Improved mufflers should be installed on the various loaders, The laborer who cleans* the pipe lathe dust collector should wear hearing protection while cleaning. Engineering controls may not be necessary because one man shakes- the bags for ten.minutes about 3-4 times per shift, and his expostir may fall within the permissible exposure time. 1 ASARCO ALV 0000390 -- 13 -- The possibility of excessive noise levels around the three additional baghouses should be considered, locating the baghouses inside the main building may not be desirable, All noise exposures can be checked more thoroughly us frig noise dosimeters {available from D.O.E.S.) if desired. The Ragland plant owns and operates a Beltone manual audiometer (Model 90} and an I.A.C. testing booth. The audiometer was last calibrated in December, 1974. Preemployment and annual audiograms for employees working in noisy areas are given by an office employee trained as an audiometric technician. All audiograms are reviewed by a consulting audiologist, Dr. Sataloff in Philadelphia, Penn sylvania. The new OSHA noise -standard will require pre employment audiograms and annual audiograms for all employees exposed to 85 dBA or greater sound levels. The plant does not .presently have a sound level meter, but these instruments are available from D.O.E.S. or can be purchased. Regular sound level surveys should be made. 4 * Lab lab personnel use hydrochloric acid to clean glassware Acid mist is exhausted by a kitchen-type hood mounted over the sink. The air flow appeared inadequate. A lab-type hood with a minimum face velocity of 100-150 fpm should be installed. The Corning atomic absorption instrument is not presently vented. If the A.A, is used often, ventilation should be provided. The lab has a safety eyewash bottle station and safety shower. Lighting was good, 5. Safety This plant does not employ a professional safety and/o environmental specialist. The plant has a need for regular safety inspections to insure compliance with OSHA safety :' requirements. A joint program with the Van Buren plant majy f be possible. '' ' The plant should obtain Material Safety Data Sheets from suppliers of all chemicals used around the plant if the chem ical composition is unknown or proprietary. An example is the KYSO EP Machine Oil (from Standard Oil.) used to lubri cate pipe ends for the hydrotest machine. These Safety Beta sheets should be reviewed for handling problems and ventil ation needs. ~ ASARGO ALV 0000391 6. Employee Smoking Employees -were observed to smoke on the job at the Rag1 land Riant. The effects of smoking and exposure to airhorn asbestos fiber are considered to fee synergistic, resulting' in a higher risk of disabling illness for asbestos workers who smoke. For this reason, the Ragland Plant should pro hibit smoking on the job and should also consider an antismoking campaign in the work force. A smoking history should be included as part of the pre-employment and annual medical exams. Selection of new employees should include a prefer ence for non-smokers, assuming that anti-discrimination laws would not be violated. B, Water Treatment The plant has two discharges j 1. A discharge from the hydrotest machine flows along the south side of the building and thence into a ravine on land belonging to the cement plant (next door). This dis charge reportedly enters the settling ponds for the cenpent plant, The discharge is quite oily and contains suspeiaded solids in excess of most water standards. An NPDES discharge permit has not been sought because the dischuxge runs into the cement plant's settling ponds. The legajL responsibility for this discharge should be clarified, A discharge from the batch mixing area flows into two small concrete settling ponds and thence into Trout Craek via an open ditch, An NPDES permit was sought for thijs discharge, and a proposed permit was received at the plant during the survey. The permit contained trouble' some effluent limitations on oil and: grease, total sus;send ed solids content, and pH. Revisions for the permit a ee being pursued. The plant has plans to recycle this dis charge, and construction is underway. The muck removed from the settling ponds is now piled around the ponds. The muck should be buried in a land fill. The recycling program should include provision to cover the existing piles and reclaim the land around tjhe settling ponds* The reduction of asbestos-like fibers in Trout Creek below the plant effluent cannot be explained. The D.O.E.S, results should be interpreted with caution because large dilutions are needed in order to count the fibers, and fibers cannot be posi tively identified as asbestos, D.O.E.S. has contacted Central Research to ^determine the feasibility of using electron microscopy and electron,- or x-ray, diffraction, to positively identify, cqunt, and classify asbestiform fibers in air and water samples. ASARCO ALV 0000392 15 -- f V. C, M r Pollotion This plant is located near a small rural-type community There are a few residences near the plant. A cement plant with uncontrolled particulate emissions is adjacent to the plant Local concern over air pollution is virtually all directed towirds the cement plant, An electrostatic precipitator was under conf structxon at the cement plant, There is also -a brick factory within 1/2 mile of the plant. Air pollution emission controls at the brick factory are unknown. The plant has a number of baghouses, some of which exhaust within the main building. Two baghouses are located outside the main building on the south side. Ho baghouses had visible emis sion. This plant should be regulated by EPA under the NESHAP Pro gram (National Emission Standards for Hazardous Air Pollutants) as is the Van Buren plant. However, it is not known whether the Ragland plant has- ever submitted the required information (a de tailed source report) to EPA. The deadline was July 6, 1973* Plant management personnel should determine whether the Ragland plant has complied with the NESHAP requirements. If not, legal, assistance from the New York office should be requested before taking any formal action. At the present time, NESHAP requires only a source report and allows no visible emissions. HESHAP has not set allowable emission standards for asbestos because toxic levels are difficult to delineate and because sampling and analytical techniqu4s for source missions are presently lacking for asbestos. The Stanford Research Institute has recently published a "Survey of Manual Methods of Measurement of Asbestos, Beryllium,...in Sta tionary Source Emissions" which details a source sampling method involving electron microscopy, A source sampling evaluation has never been done, nor has any ambient air monitoring been conducted. Such monitoring is desirable if methods of analysis can be successfully developed. NESHAP may eventually become involved in solid waste disposal to preclude fugitive emission^ of asbestos, The installation of three additional baghouses may require modification, construction, and/or operating permits from the EPA/NESHAP program and/or the State agency responsible for air pollution control. Plant management should check on the neces 5ity of obtaining, these permits. \ v f' -'fj . ' ' D. Solid Waste Solid wastes are disposed of in a semi-landfill operation at a large ravine west of the plant site. This operation should be converted to a sanitary landfill. State agenoy permits may be necessary. ASARCO ALV 0000393 local residents were observed -to enter the dump* presumably for scavenging purposes, This area should be fenced and posted to keep but unauthorized personnel, There is also an abandonee, dumping area north of the emplo yee parking lot. All wastes in this dump should be covered; and the land should be reclaimed, if possible, V. RECOMMENDATIONS A, Steps should be taken to reduce all employee asbestos expo sures below the 2 fiber limit effective in duly, 1976. Such steps should include improved ventilation, better'housekeep ing, process or engineering changes, and further sampling to document all reductions* B, Immediate action should be. taken to reduce the exposure of the fiber charger operator. Ontil this exposure is reduced, the operator should wear whole body clothing, as required by Q S m , Compliance with the EPA/NESHAE1 program should be determined as soon as possible. Legal assistance from the New York office may be needed. The legal responsiblity for the discharge from the Hydrotest machine should be clarified. E, Ventilation in some areas o f :the plant appeared inadequate but the installation of three additional baghouses should improve ventilation. However, the installation of the bag houses should be checked fox* conformance with the cited ANSI standard; necessary permits from EFA/NESHAP and/or thfe state air pollution agency may be needed; and the siting op the baghouses should take into consideration the possible noise problem caused by hopper vibrators. P. All .existing ventilation and.dust collection systems shouli be checked for conformance with the ANSI ventilation standi;ird. G. Machine operators should be trained to u~ exhaust ventila tion properly, H. A respirator program (meeting the ANSI standard for respir atory protection) should be established. All respirators should be BuMines, or NI01.H., certified for respiratory pro tection against asbestos* Enforcement of the respirator program by supervisory per sonnel should be improved. Although not required by OSHA all employees exposed to airborne asbestos fibers over the 2 fiber limit should wear respirators until further^sampling shows that their exposures fall below the 2 fiber limit. ASARCO ALV 0000394 -- IV -- X V l. Smoking on the job should be -prohibited, and an anti-smoki n caapaign in the work force should be considered. A smoking history should be included as a part of the pre-employmentP and annual medical exams. Selection of new employees should include a preference for non-smokers. 3. Plant personnel should continue to make regular environmeh tal surveys for asbestos exposures. The D.o.E.s. lab will continue to count the asbestos samples until the Van Surer lab is ready to make counts. Samples should be periodical]!; cross checked with the D.O.E.S. lab. All sample results should be reported to D.O.E.S. The plant personnel should consider more extensive sampling, sampling more often than the required six months, and con structing 8-hour time-weighted average exposures for certain jobs or employees (as noted in the comments). JC. Housekeeping will need improvement to keep external surfaces free of asbestos fibers. Employees involved with housekeeping should be advised to wet down the wastes, whenever possible, to prevent dusting during handling. . boose asbestos waste should be placed in plastic bags or other containers for disposal. This requirement could be avoided if a sampling program can be instituted which show that handling of the waste does not result in excessive cojv centrations of airborne asbestos. M, Caution signs should be conspicuously posted around areas which may exceed the 5 fiber limit, and the plant should consider posting caution signs around areas which may exceed the 2 fiber limit. N. Two separate clothes lockers need to be provided for each employee. O, An in-plant laundry shouli be considered to prevent any future liability over alleged family exposures. In the meantime, clothing taken home by employees for laundering should be placed in plastic bags which have the proper cau tion labels. P. All hand-operated and power-operated tools should be pro vided with local exhaust ventilation, as discussed in the comments. ' 'g " S i ASARGO A LV OOOG39S 18 Q. Any employee found to have been exposed to concentrations of asbestos fiber above 5,0 fiber/cm3 should be notified ir writing. R. Medical exams should be given to new and terminated employees S. Employee exposures to dust around the shot blaster and dust, from: unloading'or handling silica flour and cement dust need to be evaluated. 1. The presence of asbestifom fibers in water needs to be studied further, as well as the collection of stack or ambient air samples for asbestos, ' * 0. The hearing conservation program should continue and should include annual audiograms for all employees exposed to sou levels over 85 dBA, as well as pre-employment audiograms. Periodic surveys of sound levels around the plant should be made,. Sound level meters and an octave-band analyzer are available from D.O.B.S, The audiometer should continue to be calibrated annually. Hearing protection devices should be made available to all employees? and their use should be enforce! in areas where permissible noise exposures are exceeded until the necessary engineering controls can be installed, such as sound absorption material around the cut off saw and improved mufflers for the various loaders, V. A hood should be installed in the laboratory to exhaust aoi(d mist from the. use of hydrochloric acid. Ventilation should be provided for the Corning atomic absorp tion unit if it is used often, W. Material Safety Data Sheets should be obtained for proprie tary chemicals or .chemicals and solvents.of unknown compo sition. X. The recycling of the discharge from the batch mixing area should move ahead as fast as possible. Revisions for the proposed HPDBS permit should be pursued. Y. Muck from the settling ponds should be buried in approved landfill. The area around the settling ponds should be . covered and reclaimed, if possible. Z. The existing waste disposal site should be converted to a sanitary- landfill. State-issued permits may be necessary, AA. The waste disposal site should be fenced and posted to keep out unauthorized personnel. I ASARCO ALV 0000396 19 BB. An abandoned dumping area near the employee parking lot should be covered-and the land reclaimed, if possible. JPS/nrh Enel. CC JRCarpenter MJMessel - DHSoutar KWNelson AJGillespie,Jr./JPStetson -EHHaug RCBeckstead Dr.CHHine MOVarner James P. Sieverson Environmental Specialist C ASARCO ALV 0000397 SMALL COUPLING LATHE Dry couplings are being cut, and venti lation system, is not picking-up all of the dust produced, Floor around operator is covered with asbestos waste, SMALL COUPLING LATHE Bettor housekeeping to prevent accumula- , tions of asbestos waste/ as shown on the machine and floorf is needed, 1 ASARCO ALV 0000398 -i-' FLEXTESTER The employee is using a handgrinder which is not ventilated, SHOP m t & Housekeeping around the shops should be improved. J ASARCO ALV 0000399 WASTEWATER TREATMENT Concrete settling ponds for water discharge from hatch mixing area. WASTEWATER TREATMENT Natural pond be lew concrete settling ponds provides additional treatment Cement plant is in background 1 ASARCO ALV 0000400 I: t * SOLID WASTE DUMP Pile of loose asbestos waste is near center of picture. SOLID WASTE DUMP The dump should be converted to a sanitary landfill. A State permit may be needed. ASARCO A LV 000040