Document 70oGrNkVJvmrpY97da2bLMb8g

PLAINTIFF'S EXHIBIT ASA-344 mwco Department of Environmental Sciences M. 0. Varner Manager December 1 1980 MOV .. RDP .. J&r DAR .. ' o ldw .. -gSGC . ^0- > SDB .9^, RCM DLW ..'o' - WCF .. """ Mr^__ G-- B-^- White-- "Corpus Christi Plant Confidential Quarterly Monitoring Reports Enclosed is a copy of the quarterly monitoring summary dated November 10, 1980, for your confidential files. The status of each job classification exceeding (at a minimum) the action level is marked in pencil. For the most part, this computer printout indicates a record of timely monitoring for job classifications determined to be in excess of the applicable OSHA limits. Job classificiations which need to be monitored to achieve com pliance with OSHA regulations appear to include the following: Department Job Classification Monitoring :Frequency Mechanical/Maintenance Yard Mill Sample Zinc Roasters Sulfide Cell Oxide Leach Oxide Cell General Leadburner Front End Loader Power Sweeper Operator Supervisor Forklift Operator Laborer Beltman Sampler Front End Loader Belt Watcher Zinc Dust Helper Dross Mill Helper Bar Buffer Operator 2nd Grade Operator 3rd Grade Operator Laborer Utility Semiannual Quarterly Quarterly Semiannual Initial Initial Quarterly (Pb) (Pb) (Pb) (As) (As) (Pb) (Pb) Quarterly (Pb) Quarterly (Pb) Semiannual (Pb) Quarterly (Pb) Initial Initial Quarterly (Pb) (Pb) (Pb) Quarterly (Pb) Semiannual (Pb) Initial (Pb) Initial (As) ASARCO Incorporated 3422 South 700 West. Salt Lake City, Utah 84119 (801) 262-2459 ANZ 0004145 Y 2- - Several job classifications have been recently monitored at con centrations which exceed the maximum use limit for negative-pressure half-facepiece respirators. These employees, pursuant to OSHA regulations (29 CFR 1910.1025 (f) (2) (i)), must be provided with fullfacepiece negative-pressure, air-purifying respirators or with powered air-purifying respirators in the following job classifications Department Yard Sample Job Classification Front End Loader Operator Power Sweeper Operator Sampler In addition, engineering or administrative controls must be investi gated and instituted if found to be technologically and economically feasible to reduce worker exposures to levels below the OSHA per missible exposure limit. LDW/bjs Attach. cc: PSRandazzo (w/o attach) KWNelson "" MOVarner'-"^^ " Lowell D. White, Ph.D. Senior Environmental Scientist ANZ 0004146 ASARCQ Department ol Environmental Sciences M. O. Varner Manager January 11, 1979 Mr,---r.--B1 Whi te Corpus Christi Plant Asbestos Monitoring Results The filter cassettes sent under your cover letter of December 27, 1978, have been analyzed for asbestos fibers. No fibers were found on any of the filters. The sample " for one welder (D.N. Tischler) was dark brown which made it optically impossible to accurately discern or count fibers and, therefore, is not reported on the attached form. LDW/bjs Attach. cc: KWNelson (w/o attach) HLMontague (w.attach) RMHudson " MOVarne r " Lowell D. White, Ph.D. Environmental Scientist ASARCO Incorporated 3422 South 700 West, Salt Lake City, Utah 84119 (801) 262-2459 ANZ 0004147 ASARCO Department of Environmental Sciences M 0 Varner Vsnager November 21, 1978 In accordance with your request of Novmeber 9, 1978, seven personal monitor samples were analyzed for asbestos fibers by the D.O.E.S. laboratory. The results are attached. None of the results exceed the existing nor the proposed OSHA exposure limits. The OSHA asbestos standard provides that employees be notified of their monitoring results only if the OSHA limit is exceeded. Therefore, a posting form is not included. The OSHA asbestos standard further provides in (i)(2) that employees shall have access to only that portion of the record "which indicates the employee's own exposure to asbestos fibers." In accordance with Mr. W. 0. Hart's instructions in his letter of November 8, 1978, the Union representative can have access to only those monitoring results for which he has specific written authorization from the affected employee(s). Lowell D. White, Ph.D. Environmental Scientist LDW/bjs Attach. cc: KWNelson (w/o attach) HLMontague (w.attach) RMHudson " MOVarner " ASAPCO i-icorporateC 3-22 SouV 7~C ,\er Sa'I LaKe C.ly. Plan 64: 19 (801) 262-2453 ANZ 0004148 Department of Environmental Sciences M 0. Varner Manager October 10, 1978 Mr. C. B. White-- Corpus Christi Plant {>" \V'7 Asbestos Sampling Results The personal monitor samples submitted to D.O.E.S. under your cover letters of September 26 and 29, 1978, have been analyzed for asbestos. The results are attached. One of the filters (Marroguin) appears to have been tampered with. The filter was scraped, rubbed, and even slightly torn amongst the smudges. It is highly doubtful that this sample is representative of any occupational exposure. Since none of the sample results are in violation of any OSHA standard, these results need not be posted but should be placed in your confidential files. LDW/ss Enclosure cc: KWNelson * ' end) HLMontague/ " MOVarneri/fw/encl) RMHudson " Lowell D. White, Ph.D. Environmental Scientist ASARCO lncorpora!ed 3422 South 700 West, Sa'A Lake City, Utah 84119 (801) 262-2459 AN2 0004149 Department ol Environmental Sciences M. O Varner Manager October 2, 1978 r'' Mr. C. B. White Corpus Christi Plant V, Personal Monitor Sample Result The analytical result for the personal monitor sample submitted to D.O.E.S. on September 22, 1978, for asbestos analysis is attached. No asbestos fibers were found. Lowell D. White, Ph.D. Environmental Scientist LDW/bjs Attach. cc: KWNelson (w/o attach) HLMontague " MOVarner^(w. attach) RMHudson " ASARCO Incorporated 3422 South 700 West, Salt Lake City, Utah 84119 (801) 262-2459 ANZ 0004150 Department of Environmental Sciences M 0. Varner Manager VIO ---Wy r'yy February 6, 1978 -^ Proposed Respirator Program At your request, the Corpus Christi proposed respirator program has been reviewed and the following comments are offered: Section I a. Delete the 3M 9900 respirator from the list because it does not carry NIOSH/MESA approval for mists but only for toxic dusts. Although air sampling in the cell houses has not indicated any need for mist respirators, the 3M 9910 is approved for both dusts and mists and also is equipped with adjustable straps which should more nearly insure wearing of the respirator in an approved manner. b. Suggest including contaminants for which the respirator is approved. Example: (3M 8712 - Black - Organic Vapors). c. Because there is no disposable respirator available which is approved for fume, it is recommended that a fume respirator be included in the Section I list for use by welders, lead burners, and other personnel working with molten metal when their type of work may cause excessive fume exposures. The MSA Custom Comfo II with Type S filter, which is presently stocked at Corpus Christi, is approved for dust, mist, and fume. Section II a. Respirator 3M 8712 - Change to read: Respirator 3M 8712 with prefilter #8718. b. Respirator 3M 8714 - Change to read: Respirator 3M 8714 with prefilter #3718. Delete Sulfide Cell and Oxide Cell Departments. ASA-DC '"omc-s-ac 2-22 So," /.? Sa'i l=Ae C \ r-l !9 ;80:) 262-24-9 ANZ 0004151 2- - c. Respirator 3M 9900 - Change to read: Respirator 3M 9910. Delete Roasting and Acid and Maintenance Departments. d. Add Respirator MSA Custom Comfo II with Type S filter for Maintenance Department. Section IV This section will have to be changed to reflect the use of a non-disposable fume respirator. The El Paso program require ment of turning-in after each day's use is recommended because these respirators would need to be used only intermittently. A separate section should be included which lists jobs or operations that require respirator wearing. OSHA regulations (51910.134(b)(6) require that "Respirators shall be stored in a convenient, clean, and sanitary location." This requirement should be included in the written program and stressed in the training sessions. On Section II.C.l of the training session, delete 3M 9900 and') add MSA Custom Comfo II. Brochures on the 3M 9910 respirator and #8718 prefilter are attached. Your effort in preparing and implementing this program is appreciated. SGC/bjs Attach. cc: CBWhite (w/o attach) KWNelson MOVarner " Stanley G. 'Cothrin Environmental Scientist ANZ 0004152 ASARCO Corpus Christi Plant January 9, 1978 Robert D. Putnam.. -u.D. Supervisor of Technical Services ASARCO Incorporated 3422 South - 700 West Salt Lake City, Utah 84119 Dear Dr. Putnam: As per telephone conversation with Mr. Klenke of the Personnel Office on January 6, 1978, attached is the Corpus Christi plant's proposed respirator program for your review and comments. Please note that a brochure for the 3M 9910 respirator is not available. Thank you for your prompt attention to this matter. DMK/gw ANZ 0004-153 RESPIRATOR PROGRAM CORPUS CHRISTI PLANT I. The following air-purifying-disposable respirators are approved for use in the Corpus Christi Plant: 3M 8712 Black 3M 8714 White 3M 9900 Yellow 3M 9910^: The above respirators are NIOSH approved. All other respirators must be discarded. II. Following is a list by department of acceptable respiratory protection: Department Respirator - 3M 8712 Maintenance -- Painters Respirator - 3M 8714 Respirator - 3M 9900 Roasting and Acid Sulfide Celt Oxide--Se-11- Yard Sulfide Leach Sulfide Cell Oxide Leach Oxide Cell Utilities Maintenance III. Maintenance employees and others entering these departments should have the appropriate respirator for the department in which they will be working if needed. IV. The above respirators are the disposable type and are to be replaced whenever warranted. V. Air-purifying, half-mask respirators will not be worn for protection in baghouses during times when baghouses are being cleaned. Air line hoods provided by the departments must be used during these times. VI. Respirators must be periodically tested for proper seal and fit. Appropriate use of respirators and their limitations are to be stressed during training sessions conducted by the safety repre sentatives and department supervisor, or his designated represent ative. VII. Beards and facelets are not permissible because they do not permit a proper seal. ANZ 0004154 Department of Environmental Sciences M O. Varner Manager September 27, 1978 / X Mr. C. B. White X\&' Corpus Christi Plant y ^ Erratum in My Let _____________Asbestos In this letter, I discussed several regulations pertaining to requirements which employers must follow during teardown operations where there might be an asbestos exposure. Dr. R. D. Putnam questioned whether my reluctant conclusion that "perhaps the provision of the disposable suits" would be re quired to avoid citations. I had failed to note any triggering level for the clothing requirement in section (c) and had so concluded. I had failed to note that 1910.1018(c)(2)(iii) stated that provision of the special clothing was to be done "in accordance with paragraph (d)(3) of this section." The very last phrase in (d)(3) states that special clothing is required only at concentrations of airborne asbestos "which exceed the ceiling limit." Therefore, special clothing must be provided only when the 10 fibers/cc level is exceeded and, since the highest of the monitoring results was only 0.26 fibers/cc, management in this situation did not need to nor were they required to provide special clothing to these workers. It was a nice courteous gesture on the part of management. LDW/ss cc: KWNelson MOVarner RMHudson Lowell D. White, Ph.D. Environmental Scientist ASARCO `ncorpo'3'e 1 3-122 Scjta 7C0 .Vest. Sa't Lake C ty, Utah 347 19 (801 / 262-2^59 ANZ 0004155 ASARCO Department ol Environmental Sciences The results for the personal monitor samples recently taken in the roaster building during teardown operations have been reported by the D.O.E.S laboratory and are enclosed for your confidential files. It may be noted that most of these samples are short-term sam ples taken during potential peak exposure periods, and yet, the sample results are more than 50 times lower than the OSHA ceiling limit. These sample results show that potential worker exposures during these work activities are in complete com pliance with OSHA regulations. However, due to the fact that these samples show that some as bestos fibers may be present at some potentially measureable concentration, 1910.1001(c)(2)(iii) requires that the company nevertheless must provide the workers with respiratory protection and "... with special clothing in accordance with paragraph (d)(3) of this section" whenever such workers are dealing with the "... removal, or demolition of pipes, structures, or equip ment covered or insulated with asbestos, etc." The regulation does not mention any triggering concentration for this require ment. Also, 1910.1001(c) requires in several subsections that wetting and other means be used during all operations involving asbestos to assure that the OSHA exposure limits are not ex ceeded. Based on these regulations, it would seem prudent to continue to require the use of respirators and wetting tech niques during these operations and perhaps the provision of the "disposable suits" so that citations for these paragraphs can be avoided. According to the OSHA regulations, these results need not be reported to the workers. Access should be permitted only upon receipt of permission from Mr. W. O. Hart in New York. In the G.A.F. court case it was ruled that annual medical ex aminations must be provided to all workers exposed to "measurable" ASARCO Incorporated 3422 Scj:~ .Vest. Salt Lake City. Utah 84119 (801) 262-2459 ANZ 0004156 ASARCO M. O. VARNER Man*9r AMERICAN SMELTING AND REFINING COMPANY DEPARTMENT OF ENVIRONMENTAL SCIENCES 2422 SOUTH -- 700 WEST* SALT LAKE CITY, UTAH 04110 July 12, 1974 CONFIDENTIAL Mr. C. B. White Corpus Christi Plant I am enclosing the results of the personal monitor samples taken during the recent OSHA inspection of the plant. You will recall that these samplers were placed on the same individuals that the OSHA compliance officers monitored during their inspec-j tion. Because we were limited in the number of samplers we were! able to assemble on such short notice, I could not duplicate all of their sampling efforts. There were approximately four indivi duals for which duplicate samples were not obtained. It is reassuring to know that none of the samples were found to exceed the current OSHA standards for cadmium, zinc, lead and respirable dust. RDP/nrh Enel. cc: RHudson HLMontague KWNelson AJGillespie/JPStetson Dr.CHHine RCBeckstead MOVarner y' Robert D. Putnam, Ph.D. Supervisor of Technical Services ANZ 0004157 PERSONAL MONITOR RESULTS OSHA INSPECTION1 ------ CORPUS CHRISTI PLANT Department Employee and No. Job or Operation Samplinq 1974 Time Date (min.) Ele ment Conc'n. (mg/m3) Oxide Cell J. A. Silva #559 Caster Helper 6/18 (no respirator worn) 360 Cd Pb Zn * <0.01 0.07 0.01 Stripping Floor Fred Flores #175 Stripper (no respirator worn) 6/18 320 Cd <0.01 Pb <0.01 Zn 0.05 Cadmium Casting Jose M. Ramirez #423 2nd grade (no respirator worn) Operator 6/18 320 Cd 0.05 Pb <0.01 Zn <0.01 Cadmium Casting Pete Perez #1529 Le adman (no respirator worn) 6/18 315 Cd 0.01 Pb <0.01 Zn <0.01 Oxide Casting Frank Mendez #1458 Caster (no respirator worn) 6/18 310 Cd <0.01 Pb <0.01 Zn 0.59 Oxide Grinding G. Martinez #1414 2nd grade (respirator worn Operator when inside building) 6/18 375 Cd <0.01 Pb <0.01 Zn 0.12 Total Par- 1.3 mg/m ticulates Oxide Cell House Matias Garcia # Leadburner (no respirator worn) 1st Class 6/18 420 Cd <0.01 Pb 0.17 Zn 0.04 Oxide Cell Eoisteo Martinez #1541 (no respirator worn) Caster 6/19 400 Cd <0.01 Pb 0.12 Zn <0.01 Sulfide Cell Casting Oscar Salazar #490 3rd grade (no respirator worn) Operator 6/19 387 Cd <0.01 Pb 0.01 Zn 0.48 Cadmium Stripping R. Herrero # Relief Helper 6/19 (no respirator worn) 415 * Represents total Zn by atomic absorption analysis. Amount attributable to ZnO fume was not determined. Cd Pb Zn 0.04 <0.01 <0.01 ANZ 0004158 --2 OSHA 8-hour time-weighted average: Pb Cd fume Cd dust ZnO fume Inert or Nuisance dust (respirable fraction) 0.20 mg/m3 0.1 mg/m^ 0.2 mg/m^ 5 mg/m3 5 mg/m3 ANZ 0004159 Department of Environmental Sciences 0 Varner Mauser V V" t March 22, 1977 WIU----. B. Wfixte (Corpus Christi Plant ^ /U r Attached are the results of air samples for airborne asbestos fibers obtained in the oxide casting department on February 23, 1977. These samples were obtained on three employees who were relin ing furnace launders with asbestos cloth and were taken concurrently with OSHA samples on the same employees. The first sample of fourteen minutes duration on each employee included removing the old asbestos liner, placing the old liner in a bag and cutting new asbestos cloth. The second sample of fifteen minutes duration included placing asbestos cloth in the launder and mudding it in. Because the samples include the entire time that the employees worked with asbestos on February 23, their 8-hour time-weighted average exposure (TWA) was: Balboa Silva Villareal - 0.02 fibers/cc 0.03 fibers/cc 0.03 fibers/cc All sample results were below the OSHA 8-hour TWA limit of 2 fibers/cc. Because the sample results were well below the OSHA limit, repeat semi-annual monitoring need not be performed unless there is reasonable cause to believe that the airborne concentrations of asbestos have changed. Also, it is our understanding that current OSHA policy requires employee medical examinations only when their 8-hour TWA exposure exceeds 0.1 fibers/cc. Since the sample results indicate exposures below this level, OSHA should not require medical examinations. Stanley G. Cothrin Environmental Scientist SGC/ms Attachments cc: RMHudson (w/attach.) KWKelson " iWt3Varner ASARCO Incorporated 3422 Sc ji- 700 West. Sail Lake City, Utah 84119 (801) 262-2459 ANZ 0004160 /./' Department of Environmental Sciences M 0 Varner Manager :-DW_____p-" SGC --------,T, SOBCK OAR -------=< February 17, 1977 Mr. C. B .__White Corpus Christi Plant . \" During-"my visit to Corpus Christi on January 21, 19 77, I sampled several departments in the plant where asbestos was being used to determine whether the plant was in compliance with the OSHA regulation for asbestos. The results of the sampling are as follows: Department Name Employee No. Job Title (Resp. Use) 1977 Date & Shift Samp ling Time (Min.) Asbestos Cone'n. Fibers/cc >5 Micron Oxide Casting J. Gonzales # 1667 Machine Caster No 1/21 D 16 1.1 Stationary Above launders' crossover -- 1/21 30 1.1 Sterling Goehring " Casting Foreman No tl 1/21 II 2 2 <.5 <5 Utility Plant Tool Room Sulfide Stationary Sample B. Gonzales # 1539 -- 1/21 65 Machine Caster Debasing Unit No 1/21 28 .02 <.04 Maintenance F.M. Lytle #1560 Kelso 1530 1st Class Bricklayer No Bricklayer Apprentice 1/21 16 1/21 20 .68 1.0 ASARCO Incorporate) 3422 Sojtn 700 West, Salt Lake City, Utah 84119 (801) 262-2459 ANZ 0004161 2 Although all of the results were within the OSHA limit of 2 fibers/cc, a few steps will have to be taken in order to bring the plant into compliance. These include: 1. Additional monitoring will have to be conducted on every employee within the Oxide Casting Department, Sulfide Debasing Unit and the Maintenance Bricklayers' Shack. If the sampling indicates that the asbestos levels are above 1 fiber/cc, then resampling must be performed at least every six months. This sampling should be done at the time the asbestos cloth is removed and installed in the launders and during normal oper ation. 2. Caution labels must be affixed to all products containing asbestos or to their containers. Instructions on this are being prepared by the New York office and will be issued in the near future. 3. All asbestos waste, scrap, debris, etc. is currently being disposed of in impermeable bags or containers, but a label must be placed on the bag indicating that the contents contain asbestos. 4. The plant must maintain records of all air sampling conducted at the plant. 5. All employees exposed to asbestos fibers, regardless of how nominal the exposure may be, must have pre-employment, annual and employment termination physical examinations. In view of the fact OSHA will soon be coming into the plant to take asbestos samples, it would be wise to implement items 1-4 above as soon as possible. The medical examinations will have to be delayed until we can obtain an accurate list of all employees affected by the regulation. This can be done by conducting an extensive sampling program in all areas where asbestos is being used. We can provide Roy Hudson with the necessary equipment or we can send a representative from D.O.E.S. to conduct the survey. I will be in Corpus Christi next week and we can discuss a sampling program at that time. RDP/ms cc: RMHudson KWNelson MOVarner^/^ Robert D. Putnam, Ph.D. Supervisor of Technical Services ANZ 0004162 Corpus Christi Plant ) i\ LOW ... & DLW OUD .... RCM OAR ... Y& WCF ... g December 14, 1979 Dr. Charles H. Hine Medical Director ASARCO Incorporated 7604 Rincon Annex San Francisco, California 94120 Dear Dr. Hine: Re: Ramiro J. Lopez, ^307 The above mentioned employee has recently had his yearly asbestos physical, and has requested that a copy of the complete physical be sent to his family physician. Dr. Manuel Ramirez. Please advise us what action should be taken regarding this request. Sincerely, RMH/gw cc: M. O. Varner./ C. B. White ANZ 0004163