Document 6bwRrkrObgXDLJp0mJr46yRxR

SM-32 (R V. 5*78) Shell Oil Company Interoffice Memorandum ENVIRONMENJAL/IND. HYGIENE, / / c7 PfiSX siv. ^Wc/Uc7 Return Document to File _ X Record Copy in File 1 information Copy Record Copy in SEPTEMBER 5, 1986 Copy: __ I______ mCirculate: LAINTlFF'S EXHIBIT SH-1860 FROM: SR. INDUSTRIAL HYGIENIST, HEALTH & SAFETY, MFG. & TECH. TO: SEE ATTACHED DISTRIBUTION LIST SUBJECT: ASBESTOS GASKETING For your information, the attached brochure from the Asbestos Information Association is somewhat dated (3/15/85), but it is a timely reminder of the Recommended Work Practices For Asbestos-Containing Gaskets. If the latest round of monitoring reveals significant exposure potential due to gasket handling. Head Office Engineering will be asked to revisit their September 1984 guidance on this subject. "r? P. J. Snyder PJS:bjd Attachment cc: K. C. Crawford A. D. Ditmar BT8624505 LAW 004838 DPMC-02473 INDUSTRIAL HYGIENE REPRESENTATIVES ANACORTES REFINERY D. D. SMART DEER PARK MANUFACTURING COMPLEX A. F. SCHMIT GEISMAR PLANT M. T. BARCLAY MARIETTA PLANT M. W. HERSHMAN MARTINEZ MANUFACTURING COMPLEX M. B. KOVACEVICH NORCO MANUFACTURING COMPLEX A. K. MENARD ODESSA REFINERY E. N. GEE TAFT PLANT J. J. DELAUNE WILMINGTON MANUFACTURING COMPLEX S. V. SEVER WOODBURY PLANT R. NOCCO WOOD RIVER MANUFACTURING COMPLEX W. M. CUNNINGHAM HEAD OFFICE HS&E, S&IH G. L. GREENE J. D. RANSDELL BT8624505 LAM 004839 DPMC-02474 r Recommended Work Practices for AsbestosContaining Gaskets LAM 004840 DPMC-02475 Contents Introduction................... 3 Asbestos and Health ........................................... 4 Summary of OSHA Asbestos Standard ............ 4 Products and Operations................................... 5 Recommended Work Practices......................... 5 Storage ............................................................ 5 Fabrication .................................................... 5 Original Installation ....................................... 6 Casket Replacement......................................... 6 Housekeeping and Waste Disposal .............................................. 7 Appendix Federal Waste Disposal Standard ....................................... 9 Introduction The Occupational Safety and Health Act (OSH Act) in the United States and similarlaws in Canada and other countries were enacted to ensure every worker a safe and healthy workplace. This legislation is far-reaching. It covers millions of employees and nearly every employer. The information and guidance in this booklet have been developed to assist in assuring compliance with the OSH Act and the Occupational Safety and Health Administration's (OSHA) standard for occupational exposure to asbestos dust (29 CFR Part 1910.1001). Because state or local regulations may differ from the OSHA standard, they should be reviewed to ensure total compliance. The use of good work practices is recognized as one of the means of reducing health hazards associated with exposure to asbestos dust. The recommendations that appear on the following pages were developed through experience, study, and field testing. They were designed to achieve safer and more healthful job site conditions when working with asbestos-containing gasket material. March 15, 1985 LAM 004841 DPMC-02476 Asbestos and Health Exposure to asbestos fibers can increase the risk of developing certain diseases over a period of years. Diseases associated with inhalation of asbestos fiber are: asbestosis, a non-malignant scarring lung condition; cancer of the lung; mesothelioma - a rare cancer of the lining of the chest or abdominal cavities; and, possibly, cancer of the digestive tract. It should be emphasized that the evidence of adverse health effects (malignant and nonmalignant lung disease) due to the combined action of cigarette smoking and exposure in the workplace is well established. Workers who handle asbestos greatly reduce their health risks by not smoking cigarettes. We will continue to see cases of asbestos-related disease for some years because of the unfortunate legacy of excessive past exposures. However, the present state of scientific knowledge shows clearly that minimizing exposure to airborne asbestos dust reduces the risks of asbestos-related disease. Good work practices are one means of significantly reducing generation of dust. Summary of OSHA Asbestos Standard Under the current OSHA standard for occupational exposure to asbestos dust, it is the employer's responsibility to assure that exposure of employees to airborne concentrations of asbestos fibers does not exceed the following permissible exposure levels: a. Eight-hour time-weighted average (TWA): 0-2 Two fibers longer than 5 micrometers, per cubic centimeter (2 f/-cc). Z P/C.C. j. CeiUng concentrajions^Tert fibers/ longer tfyan^'mierometers/percutnc-dentlmefer (10 f/ccf OSHA Instruction CPL 2-2.21 A of February 18, 1981 states that the medical examination requirements of the asbestos standard will be required where the 7 to 8-hour TWA fiber concentration is 0.1 f/cc or greater. 4 Extensive field monitoring has demonstrated that the proper use of asbestos-containing gaskets can result in dust levels which are less than an 8-hour TWA of 0.1 f/cc. By following the work practices recommended in this booklet when using such products, dust levels can be minimized. Products and Operations These work practices apply to the use of nonfriable asbestos-containing compressed, beateraddition, and gasket millboard material when furnished as precut gaskets or in sheets and rolls. Operations to which these work practices apply include: A. Storage ^ B. Fabrication ^ C. Installation D. Replacement ^ E. Housekeeping and Waste Disposal ^ Recommended Work Practices A. Storage Gaskets materials are typically received in three forms: sheets, rolls, and precut gaskets. Storage areas should be kept clean and dust free, either bv wet sweeping or with the use of a vacuum cleaner fitted with a high efficiency particulate aerosol fHEPA) filter. Any information provided by the manufacturer, such as health warnings and handling requirements, should be retained. B. Fabrication 1. Handpunching Bolt holes are often made with the use of a hand punch and mallet. If feasible, the material should be dampened while it is being worked. All areas where hand punching takes place should be kept clean and dust free. Scraps of waste from hand punching should be disposed of in the proper manner. 5 LAM 004842 DPMC-02477 2. Hand Shaping Hand shaping of gaskets is carried out with the use of a scribe, pocket knife, or scissors. Gasket sizes are scribed onto a flat sheet of asbestos gasket material and then cut by the use of scissors or a pocket knife. The gasket material should be dampened during scribing and cutting, if feasible. In this operation, as in others involving asbestos, work areas should be kept clean and dust free and waste scraps should be promptly disposed of in the proper manner. 3. Die Cutting * Hand Operated Press Gaskets are sometimes cut to size and shape on hand operated mechanical cutting presses. The surfaces of these machines and the surrounding work area should be maintained to be clean and dust free. Gasket scraps should be promptly disposed of in the proper manner. 4. Die Cutting - Power Press Power-operated presses used in gasket fabrication should be provided with local exhaust ventilation as needed. Maintain sharp dies to reduce burrs that will increase the potential for dust and require further handling. The work area should be kept in a clean and dust free condition. Note: Large pieces of gasket material left after the fabrication operation may be returned to storage for future use. C. Original Installation No special controls are required. D. Gasket Replacement - Removal and Installation Replacing worn or scheduled service gaskets often requires the use of a scraper or a wire brush to remove all of the old gasket material from the flange surface before a new gasket is put into place. Begin by prying or levering off the old gasket with a scraper. 6 such as a wood chisel, in order to remove it in the largest possible pieces. Where practicable, surfaces to be ground, scraped or brushed should be wetted. Work areas should be cleaned promptly. Unless airborne concentrations are known, respiratory protection is advisable. Note: Some gaskets may be coated or surface treated with a parting agent so that when gaskets are removed, there is no need for excess grinding, scraping or brushing. . Housekeeping and Waste Disposal Housekeeping is an essential part of any safe operation. Airborne asbestos dust created by the lack of good housekeeping has the potential for harm to employees and others. Keep work areas clean by wet wiping or wet sweeping, or by vacuuming with a unit equipped with a high efficiency particulate aerosol (HEPA) filter. NEVER DRY SWEEP OR BLOW ASBESTOS WITH COMPRESSED AIR. The scrap offcuts and webs from these operations are not considered a "hazardous waste' under the Resource Conservation and Recovery Act (RCRA) and can be shipped to local landfills for disposal. Consult the Appendix for the federal regulations covering asbestos waste disposal. AVOID CREATING DUST. 7 LAM 004843 DPMC-02478 Appendix ENVIRONMENTAL PROTECTION AGENCY 40 CFR part 61 (AD-FRL 2515-8) National Emmisslon Standards for Hazardous Air Pollutants; Amendments to Asbestos Standard Agency: Environmental Protection Agency (EPA) ACTION: Final rale $61,152 Standard for waste disposal for manufacturing demolition, renovation, spraying, and fabricating operations. Each owner or operator of any source covered under the provisions of 61.144-61.149 shall: (a) Deposit all asbestos-containing waste material at waste disposal sites operated in accordance with the provisions of 61.156; and (b) Discharge no visible emissions to the outside air during the collection, processing (including incineration), packaging, transporting, or deposition of any asbestos-containing waste material generated by the source, or use one of the disposal methods specified in paragraphs (b)(1), (2), or (3) of this section as follows: (I) Treat asbestos-containing waste material with water. (1) Mix asbestos waste from control devices with water to form a slurry; adequately wet other asbestos-containing waste material; and fii) Discharge no visible emissions to the outside air from collection, mixing, and wetting operations, or use the methods specified by 61.154 to clean emissions containing particulate asbestos material before they escape to, or are vented to, the outside air, and (iii) After wetting, seal all asbestos-containing waste material in leaktight containers while wet; and (iv) Label the containers specified in paragraph (b)( IMiii) as follows: CAUTION Contains Asbestos - Avoid Opening or Breaking Container Breathing Asbestos is hazardous to Your Health Alternatively, use warning labels specified by Occupational Safety and Health Standards of the Department of Labor. Occupational Safety and Health Administration (OSHA) under 29 CFR 1910.1001 (g)(2)(iii). (2) Process asbestos-containing waste material into nonfriable forms: (i) Form all asbestos-containing waste material into nonfriable pellets or other shapes; and (ii) Discharge no visible emissions to the outside air from collection and processing operations, or use the methods specified by 61.154 to clean emissions containing particulate asbestos material before they escape to, or are vented to. the outside air. (3) Use an alternative disposal method that has received prior approval by the Administrator. 61.156 Active Waste disposal sites. To be an acceptable site for disposal of asbestos-containing waste material under 61.151 and 61.152, an active waste disposal site must meet the requirements of this section. (a) Either there must be no visible emissions to the outside air from any active waste disposal site where asbestos-containing waste material 9 LAM 004844 DPMC-02479 has been deposited, or the requirements of paragraph (c) or (d) of this section must be met. (b) Unless a natural barrier adequately deters access by the general public, either warning signs and fencing must be installed and maintained as follows, or the requirements of paragraph (c)(1) of this section must be met. (1) Warning signs must be displayed at all entrances and at intervals of 100 m (330 ft.) or less along the property line of the site or along the perimeter of the sections of the site where asbestos-containing waste material is deposited. The warning signs must: (i) Be posted in such a manner and location that a person can easily read the legend; and (ii) Conform to the requirements of SIcm x 36cm (20' x 14*) upright format signs specified in 29 CFR 1910.145(d)(4) and this paragraph; and (iii) Display the following legend in the lower panel with letter sues and styles of a visibility at least equal to those specified in this paragraph. Lrpiai Nouom Alhoiot Wutc Oapaui Sat Do not Crate ................. ... Irathing Abmaa s Hurtous to Your Ha.tfc 2-5 ea (10 Sam Sen/. Cotac of Stock. t.l an (KO Sent Sen/. Gotti* or Slock. 14 Po*QI CoOuc ! j j > 1 ! Spacing between any two lines must be at least equal to the height of the upper of the two lines. (2) The perimeter of the disposal site must be fenced in a manner adequate to deter access by the general public. (3) Upon request and supply of appropriate information, the Administrator will determine whether a fence or a natural barrier adequately deters access by the general public. (c) Rather than meet the no visible emission requirement of paragraph (a) of this section, an active waste disposal site would be an acceptable site if at the end of each operating day, oral least once every 24-hour period while the site is in continuous operation, the asbestoscontaining waste material which was deposited at the site during the operating day or previous 24-hour period is covered with either. (1) At least 15 centimeters (6 inches) of compacted nonasbestoscontaining material, or (2) A resinous or petroleum-based dust suppression agent that effectively binds dust and controls wind erosion. This agent must be used as recommended for the particular dust by the manufacturer of the dust suppression agent. Other equally effective dust suppression agents may be used upon prior approval by the Administrator. For purposes of this paragraph, waste cranltcase oil is not considered a dust suppression agent. (d) Rather than meet the no visible emission requirement of paragraph (a) of this section, an active waste disposal site would be an acceptable site if an alternative control method for emissions that has received prior approval by the Adminstrator is used. (Sea. 112 jnd <FR Doc. of the Can Air Act filed 4-1-44. i 43 *m) irneruletj (42 L1 S.C. 7412. lam 004845 DPMC-02480 r NORTH AMERICA ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway Arlington, Virginia 22202 LAM 004846 { DPMC-02481 LAM 004837