Document 8VoVLxjRwLad16K30E5bazvVK

iMWll ;^-~5aag IWBHB DU 041453 r 4/3/79 beep* W.H.Sprout, PPSR, Sabine sY'y R.M.Shepherd, PP&R,D-120 I.Zeise, Engg.,L-1235 UNITKO ITATCS Of AM CM ICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION IKS K STUCCT, MW WASHINGTON, O C 2000* NOTICE OF DECISION RECEIVED APR $879 time: A/-.S T. Secretary v. E.I. duPont de Nemours & Co., Sabine River Works OSHB.C Docket No. 7S-Sfl7i 1. Enclosed herevlth is my decision in the above-entitled case. It is being filed on this date and will become the final order of the Commission pursuant to 29 U.S.C. 661 (i) on April 30, 1979r unless a Member of the Commission directs that it be reviewed. 2. Parties will not received any further communication from the Commission on this case unless review is directed by a Member of the Commission. In chat case each party will be notified and given an opportunity to submit a brief to the Commission Members prior to their final disposition of the case. Enclosure Date: March 30, 1979 DU 041454 DIT 0961261 rr UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION SECRETARY OF LABOR Complainant v. E.I. duPONT DE NEMOURS & CO., SABINE RIVER WORKS Respondent DOCKET NUMBER 78-5871 ORDER The settlement agreement of the parties filed on February 5, 1979, has been considered, and is approved under the criteria of Dawson Bros. Mechanical Contractors. 1 BNA OSHC 1024, 1971-73 CCH OSHD par. 15,039 (Rev. Com. 1972)(Commission Rule 100; 5 U.S.C. section 554(c)(1)). Dated: March 30, 1979 Washington, D.C. PAUL A. TENNEY Judge, OSHRC DU 041455 DUP 0961262 ) fitM rr Sacracary t. E.I. dufont da HmoujOmtC # TTSTT"9A01M ftltfat UdtlU 78-5871 Eaployar Mr. Haatinga S. Trigs, Jr. E.I. duPonC da Nnoura i Co. Lagal Dapartmane, Root D-7150 1007 Marieae Seraae ^ tftlaington, Dalavara 19898 DUP 0961262.001 DU 041456 February , 1979 2/6/79 bcc: W.K.Na^''" Sabine River R.M.Sher-.rd, PP&R,E>-I2Q14 I.Zeise, Engg. ]>;1235 received FEB & 1979 TIME Hr. Ray H. Darling, Jr. Executive Secretary Occupational Safety and Health Ssrsiew Commission 1325 K Street, N.W. Washington, D.C. 20006 Re: Secretary of Labor v. E. I. duPont de Nemours s Co., Sabine RiverWorks; SOL Case Ho. 07675 OSHRC Docket No. 7Kaffir CSHO No. H4631-009 Dear Mr. Darling: Enclosed please find the original and tvro copies of a settlement agreement in the above-styled proceeding. Please acknowledge receipt by returning a conformed copy of the instrument in the enclosed franked, selfaddressee! envelope. Sincerely, carbara G. Heptig Attorney Enclosures: Settlement Agreement Envelope cc: Mr. Hastings S. Trigg, Jr. ^ of Counsel E. I. duPont da Nemours and Co. Legal Department, Room D-7150 1007 Market St. Wilmington. Delaware 19898 DU 041457 UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor, United States Department of Labor, E. I. duPONT de NEMOURS & COMPANY, SABINE RIVER WORKS, Respondent, SETTLEMENT AGREEMENT Come now the parties through their respective repre sentatives and submit the following settlement agreement pursuant to Rule 100 of the Rules of Procedure: 1. Complainant has determined that Item la of the Serious Citation No. 1 issued to Respondent November 6, 1978 should be deleted and in lieu thereof. Complainant hereby amends the said citation as follows: "Citation No. 1 Item 1. (Serious) A. 29 C.F.R. 1910.1001(g)(1)(i): Caution signs were not provided nor displayed at each location where airborne concentrations of asbestos fiber may be in excess of the exposure limits: (a) at the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers." DU 041458 DU? 0961264 l r 2. Complainant hereby withdraws Items Nos. lb and lc alleging violations of 29 C.F.R. 1910.1001(h)(1) and 29 C.F.R. 1910.1001(h)(2). 3. Respondent has paid the proposed penalty of $560.00 sought by Cotaplainant and desires therefore to withdraw the notice of contest and consents to the entry of a final order by the Occupational Safety and Health Review Commission. 4. Respondent represents that the aforementioned violation has been abated. 5. Respondent agrees that Complainant shall be permitted access to its workplace during Respondent's normal business hours subsequent to the abatement dates set forth for the specific and limited purpose of permitting Complainant to con firm respondent's compliance with the abatement provisions of this agreement. 6. Respondent states it will comply with the Occupational Safety and Health Act of 1970 (29 U.S.C. 651, et seq.). 7. Respondent certifies that a copy of this settlement agreement has been served upon represented and unrepresented affected employees in the manner set forth in Rule 7 of the -2- DU 041459 DUP 0961265 \ 3 <Bi> E. I. du Pont de Nemours & Company SABINE RIVER WORKS P. O. Box 1069. Orange. Texas 77630 PLASTIC PRODUCTS AND RESINS DEPARTMENT - Wilmington - Wilmington January 29, 1979 Mr. James E. White Regional Solicitor U. S. Department of Labor 555 Griffin Square Building - Suite 501 Griffin and Young Streets Dallas, Texas 75202 ATTENTION: Ms. Barbara G. Heptig, Attorney Re: Secretary of Labor v. E. I. du Pont de Nemours & Co. Sabine River Works; OSHRC Docket No. 78-5871 CSHO No H4681-009; SOL Case No. 07678 Dear Ms. Heptig: Attached is a $560.00 check made payable to "Occupa tional Safety and Health - Labor" per the Settlement Agreement of the referenced case. The subject agreement is dated January 26, 1979 and is being forwarded to you by our Counsel Hastings S. Trigg, Jr. Sincerely WKN:mdp Attachment W. K. Nace, Superintendent Employee Relations Department DU 041461 BETTER THINGS FOR BETTER LIVING . . . THROUGH CH DUP 0961267 ; ia aaM-ai ij-MM. aSSia -/ - ... :. J~l*y^**$56fc00**1 '-1 I T ifc. --^OCCUPATIONAL' SAFETY AND HEALTHu *-1' *er _ .r'.LABOR** 1 OSHA - #H4681_-9----~P_. -- -1 ` - *-- * i-- -- -----NOT GOOD FOK MORE THAN: *3000.00 _____' --E.4. ga.TONT OE NEMOURSlft COMPANY-~ _ -- -| -- ''cashier^ccountTno...- 318 L" L" . -b*-3 iasM.*?** ^3Qna Pti: l i ?-flaw ~- T- r-TA~ ' DU 041462 DUP 0961268 umiw* ,,wiB mo# E. I. du Pont de Nemours & Company Wilmington, Delaware 19898 LEGAL DEPARTMENT January 26, 1979 James E. White, Esq. Regional Solicitor U.S. Department of Labor 555 Griffin Square Building, Griffin and Young Streets Dallas, Texas 75202 Suite 501 Attention: Barbara G. Heptig, Esq. Re: Secretary of Labor v. E. I. du Pont de Nemours and Company, Sabine River Works OSHRC DOCKET NO. 78-5871, Region 6 Dear Ms. Heptig: In connection with the captioned matter, enclosed please find the original proposed Settlement Agreement that I have executed on behalf of Respondent. You will note that also on this date a copy of the enclosed document has been posted in accordance with 29 CFR 2200.100 (c) and 29 CFR 2200.7. Please note paragraph 5 of the proposed Settlement Agreement has been amended in accordance with our telephone conversation. In addition, I have taken the liberty of correcting a typographical error in paragraph 2 by substituting "C.F.R." for "C.R.R.". Per our telephone conversation of today, you will be receiving a check in payment of the penalty under separate letter directly from Sabine River Works. If you have not received the check by the time you receive this letter, please notify me. Finally, it is understood that, upon receipt of the enclosed document and the check from Sabine River Works, you will execute the enclosed on behalf of Complainant and file same with the Occupational Safety and Health Review Commission. DU 041463 DU? 09612 MsjJoafrm* issy& T it. ' 4* s~ c UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor, United States Department of Labor, Complainant, v. E. I. duPONT de NEMOURS & COMPANY, SABINE RIVER WORKS, Respondent, ) ) ) ) OSHRC Docket ) ) No.78-5871 ) ) ) ) ) ) SETTLEMENT AGREEMENT Come now the parties through their respective repre sentatives and submit the following settlement agreement pursuant to Rule 100 of the Rules of Procedure: 1. Complainant has determined that Item la of the Serious Citation No. 1 issued to Respondent November 6, 1978 should be deleted and in lieu thereof, Complainant hereby amends the said citation as follows: "Citation No. 1 Item 1. (Serious) A. 29 C.F.R. 1910.1001(g) (1) (i) : Caution signs were not provided nor displayed at each location where airborne concentrations of asbestos fiber may be in excess of the exposure limits: (a) at the north end of the 258 area, insulation containing asbes-tos was removed from pipes in the overhead rack allowing the emission of airborne fibers." DU 041465 DU? C 9 r i / -7 4 r* J 2. Complainant hereby withdraws Items Nos. lb and lc alleging violations of 29 C.F.R. 1910.1001(h)(1) and 29 C.F.R. 1910.1001(h)(2). 3. Respondent has paid the proposed penalty of $560.00 sought by Complainant and desires therefore to withdraw the notice of contest and consents to the entry of a final order by the Occupational Safety and Health Review Commission. 4. Respondent represents that the aforementioned violation has been abated. 5. Respondent agrees that Complainant shall be permitted access to its workplace during Respondent's normal business hours subsequent to the abatement dates set forth for the specific and limited purpose of permitting Complainant to con firm respondent's compliance with the abatement provisions of this agreement. 6. Respondent states it will comply with the Occupational Safety and Health Act of 1970 (29 U.S.C. 051, et seq.). 7. Respondent certifies that a copy of this settlement agreement has been served upon represented and unrepresented affected employees in the manner set forth in Rule 7 of the 2- DU 041466 DUP 0961273 V /" c Rules of Procedure, by posting same on the of January, 1979. 26th day Agreed to this _______ day of Januaryf 1979. Agreed to this day of , 1979. CARIN ANN CLAUSS Solicitor of Labor JAMES E. WHITE Regional Solicitor JACK F. OSTRANDER Acting Counsel for Occupational Safety and Health By: SOL Case No. 07678 CSHO No. H4681-009 BARBARA G; HEPTIG Attorney Attorneys for RAY MARSHALL, Secretary of Labor, United States Department of Labor Complainant. DU 041467 3 DUP 0961274 *r US. DEPARTMENT OF LABOR OFFICE OF THE SOLICITOR S5S GRIFFIN SOUARE BUILDING-----SUITE GRIFFIN AND YOUNG STREETS SOI Dallu, Texu 75202 January 19, 1979 RECEIVED JAN 2 2 1970 Mr. Hastings S. Trigg, Jr. of Counsel TIME-__________ E. I. duPont de Nemours and Co. Legal Department, Room D-7150 1007 Market St. Wilmington, Delaware 19898 Re: Secretary of Labor v. E. I. duPont de Nemours & Co., Sabine River Works; OSHRC Docket No. 78-5871 CSHO No. H4681-009; SOL Case No. 07678 Dear Mr. Trigg: Enclosed herewith are the original and two copies of our proposed settlement agreement. If it meets with your approval, please sign and return it in the enclosed en velope along with a check in the amount of $560.00 made payable to "Occupational Safety and Health - Labor". Upon receipt I shall sign and forward the agreement to the Commission. You should post a copy of this settlement agreement for notice to the employees and notify the Review Commission certifying when it was posted by indicating such in the settlement agreement where provided in the last paragraph. I appreciate your cooperation in resolving this matter. If you have any questions, please call me at 214/767-4924. Sincerely, Barbara G. Heptig Attorney Enclosures: Settlement Agreement Envelope DU 041468 i"" nrrrlrfFifiiiMiaii ** * I rI r RECEIVED JAN 4 1979 UNITED STATES OF AMERICA __ TIME OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor, United States Department of Labor, Complainant, v' " E. I. du PONT de NEMOURS and COMPANY, SABINE RIVER WORKS, Respondent, ) ) ) ) ) OSHRC Docket ! no. 7Z-S2 ) ) ) ) ) MOTION FOR EXTENSION OF TIME TO FILE COMPLAINT Comes now the complainant. Secretary of Labor, United States Department of Labor, and moves the Review Commission to extend the time for filing his complaint in this case an additional 30 days, to and including January 25, 1979, for the reasons that: (1) The parties herein will attempt to. settle this case without the necessity of a hearing and must have the additional time for that purpose, DU 041469 (2) The period within which the complainant must file rr WHEREFORE, for the foregoing reasons complainant hereby respectfully moves the Review Commission to grant him an additional 30 days within which to file his complaint. CARIN ANN CLAUSS Solicitor of Labor JAMES E. WHITE Regional Solicitor JAMES F. GRUBEN Acting Counsel for Occupational Safety and Health By: CSHO No. H4681-009 SOL Case No. 07678 BARBARA G. HEPTIG Attorney Attorneys for Complainant. CERTIFICATE OF SERVICE I hereby certify that on the 20th day of December, 1978, I served one copy of complainant's motion for extension of time to file complaint upon respondent by sending the document in a franked envelope addressed to: Mr. Hastings S. Trigg, Jr. of Counsel E. I. du Pont de Nemours and Company Legal Department, Room D-7150 1007 Market St. Wilmington, Delaware 19898 DU 041470 BARBARA G. HEPTIG Attorney DUP 0961283 UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor, United States Department of LaJbor, Complainant, v. E. I. du PONT de NEMOURS and COMPANY, SABINE RIVER WORKS, Respondent, ) ) ) ) ) OSHRC Docket ) ) No. ) ) ) ) ) MOTION FOR EXTENSION CF TIME TO FILE COMPLAINT Comes now the complainant, Secretary of Labor, United States Department of Labor, and moves the Review Commission to extend the time for filing his complaint in this case an additional 30 days, to .and including January 25, 1979, for the reasons that; (1) The parties herein will attempt to settle this case without the necessity of a hearing and must have the additional time for. that purpose, (2) The period within which the complainant must file his complaint will expire before the negotiations are completed, DU 041471 DU? 0961285 WHEREFORE, for the foregoing reasons complainant hereby respectfully moves the Review Commission to grant him an additional 30 days within which to file his complaint. CARIN ANN CLAUSS Solicitor of Labor JAMES E. WHITE Regional Solicitor JAMES F. GRUBEN Acting Counsel for Occupational Safety and Health By: CSHO No. H4681-009 SOL Case No. 07676 BARBARA G. HEFTIG Attorney Attorneys for Complainant CERTIFICATE GF SERVICE I hereby certify that on the 20th day of December, 197S, I served one ccpy of complainant's motion for extension of time to file complaint upon respondent by sending the document in a franked envelope addressed to: Mr. Hastings S. Trigg, Jr. of Counsel E. I. du Pont de Nemours and Company Legal Department, Room D-7150 1007 Market St. Wilmington, Delaware 19898 DU 041472 BARBARA G. KEPTIG Attorney DU? 09612 U.) EMPLOYS* MUST COMPLETE CERTIPICATE OP SERVICE AMO MAIL WITHIN 41 HOURS OP RECEIPTi E . x . DO PONT DS NEMOURS AND COMPANY ~n%'52lJ MUM ___"___S__A_B__IN__E__R__I_V_E_R________ ____________ bJwMK On behalf of the employer in thw above can*. I hereby cwttify that on see below the Node* supplied by the Commission ndvininf affected amploytei of thia caao and a copy of aiaployar'i Notice of Content warn posted at each place wham the OSHA Citation la re quired to be posted, and by serving such nutice upon each local union (if any) that repre sents affected employees; * 1. Notice of Contest posted on December 18, 1978. 2. Notice advising affected employees of case posted on December 28, 1978. December 28, 1978 OATt fnaett the correct date. DU 041473 DU? 0961287 Caccictar 23, 13T6 DECEIVED CEC 2 7 197;; `r. Pay Darling, zs . executive Secretary Cccupacicnal Cafecy and .teal r.eviaw Cotssiasion 1323 It Gtreec, II..7. lasr.mcron, 1'. C. 23003 ucr;tir- ai -o-cr and Car:; anv iT.ifdan -a -'.r.n :c ver *orn.~ "o'-ir.Il CccJcuc . u . Isar ari 1CT for ...zai. ova r3 car.e an c rcoa.jj wr a a r :o ui_ i'oaracii u-i 70--' acJinovluauun ; rucau..: c of aula ir-icmeax _y racurai..>. a ac.ai.-~an car.farr.au ncv/ co us m ?.;a -unclcseu anvnlone. il*icareiy ^araara 1. .icrcio .'.ccornay enclosures. notion for 2::rension Or.velone ac .ir. i.aatincs 3. mc<2, zr. of Counsel -- a. I. uu rout -- = L.'eiuours and Company 2.apal 2-ecarmen t. Poore 3-7150 1007 .icrker Ot. w Urine con , Oelaware i?d'J'd DU 041475 ijgagidMHi- UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor, United States Department of Labor, Complainant, v- E. I. du PONT ce NEMOURS and COMPANY, SABINE RIVER-WORKS, Respondent, ) ) ) ) ) CSHRC Docket ) ) NO. ) ) ) ) ) MOTION FOR EXTENSION OF TIME TO FILE COMPLAINT Comes now the complainant. Secretary of Labor, United States Department of Labor, and moves the Review Commission to extend the time for filinc his complaint in this case an additional 30 days, to and including January 25, 1979, for the reasons that: (1) The parties herein will attempt to settle this case without the necessity of a hearing and must have the additional time for that purpose, (2) The period within which the complainant must file his complaint will expire before the negotiations are completed, DU 041476 o>< <u WEERZE ORE, the foregoing reasons complaina: respectfully moves the Review Commission to grant him additional 30 days viz complaint CABIN ANN CLAUSS Solicitor of Labor JAMES Z. WHITE Regional Solicitor JAMES F. GRU3EN Acting Counsel for Occupational Safety and Health 3v: CSHO No. H4 681-009 SOL Case No. 07678 BARBARA G. KEPTIG Attorney Attorneys for Come lament CERTIEICATE OF SERVICE I hereby certify that cn the 20th day of December, 1978, I served cr.e copy of complainant's motion for extension of time to file complaint upon respondent by sending the document in a franked envelope addressed to: Mr. Hastings S. Trigg, Jr. of Counsel E. I. du Pont de Nemours and Company Legal Department, Room D-71S0 1007 Market St. Wilmington, Delaware 19898 DU 041477 3AR3ARA G Attorney SS-tSA-l . S (10-20-71) SABINE RIVER WORKS SAFETY PRECAUTIONS 1Exoicsifciiirv Tesr Sea.% 2"ollowma Special Prcceaure (SP No. 22) Cther 3_____ Water at Jon 1Stancbv rite Ext.:(Type) 5Earricace Ares 6Life lires Required 7Soiil Possibilities Removed SStancbvor P. A. Speaker 9_____ Keep Area Wet ' 10Taros (Under) and/or (Around) Work 1 1 .___Sosr Warning Signs 12_____ Wind Direction Precaution 13Provide Blower tor Ventilation 14Tesr for Toxic Materials 15All Dust Rerrovea 16Steam Hose Standby 1 7(Air) (Hand) (Electric) Tools Only 18Eauip. Full cf (Wafer) (Steam) (Inert Gas) 19Keep Vibration to a Minimum 20__cO_Evacua:e Area if Reauested 21___^<d.Coorainate w* ith Adjacent Jobs Approver must mace a physical Inspection of the Job prior acquainted with the prevailing conditions at the job site. 22Elect. & Maint. Supervision Aoprovai for Undersurface Hazards 23______ Mech. Supv. Signature Requested 24Sufficient Oxygen 75 ----- -- ALL work and clear area if evacuation aiarm sounds 26Shield Arc 27Lubrica'e cutting edge 2SEonfme Hot Soarks or Chios 29Check/Cover Sewers & Drains 30______Ground Attached to Equipment 31Test for CO - COr 32Equipment Properly Decontaminated 33Use Job Check Card 34__=pllow iS.P. No. 29) (S.P. No. 11) 35.__d2_Const. E.no. Signature Recuired 36______Vendor Sionature Reouired 37________________ I_________________________________ 38___________________________________________________ 39___________________________________________________ 40___________________________________________________ 41 42: to approving except in those few cases where he is fuii WORK MUST NOT HE STARTED UNTIL AIL PRECAUTIONS ARE TAKEN WHEN WORK IS COMPLETED, RETURN THIS FORM TO PRODUCTION FOREMAN ALL WORE UNDER THIS PERMIT WILL CEASE IN THE EVENT OF AN AREA EMERGENCY OR A DISASTER ALARM A_ND WILL NOT RESUME WITHOUT THE AREA FOREMAN'S SIGNATURE AFFIXED HERETO. Autnorization to Resume Work: --___________________________________ ___ _____________ DU? 0961255 DU 041478 - .r PPSR DEPARTMENT MANUFACTURING DIVISION SAFETY DIVISION SABINE RIVER WORKS r October 25, 1977 TO: HOLDERS OF SAFETY MANUAL FROM: J. R. MOORE SAFETY PROCEDURE #11 INITIAL OPENING OF LINES AND CLOSED VESSELS Attached is a revision to Page 5, Safety Procedure #11, "initial Opening of Lines and Closed Vessels". The reference to protection for initial breaks in cleared systems containing cryogenics, Ethylene has been changed to require full aluminized clothing. This conforms with area Maintenance procedure in the Ethylene Division. copy. Please replace this complete procedure with attached JRM:Iss i DUP 0961296 DU 041479 r Safety Procedure #11 INITIAL OPENING OF LINES AND CLOSED VESSELS r SABINE RIVER WORKS SAFETY MANUAL Issued 5/15/72 Revised 10/25/77 Page i of 4 NOTES AND REFERENCES INTRODUCTION Equipment and/or pipeline open ings can be a serious safety hazard when unforeseen or unpredicatable conditions exist such as plugged lines or valves, sliping or sagging lines, defective valves or pipelines and other conditions that may unexpectedly release hazardous materials. Protective clothing and equipment for working on systems that are obviously not cleared of process matendl are not covered by this procedure. Work on this type equipment must be cleared per Safety Procedure #5, "Danger Tags and Safety Locks" and in some cases handled on an individual basis. It is always assumed that equipment and/or pipelines are full and under pressure or vacuum in preparing and performing the work described_. Numerous unexpected in-| cidents have proven the need] to consider all potential hazards and the necessity to| wear protective clothing until the hazards are posi tively controlled. An example of this type work] would be working on a flare header where clearing is not possible or installing blanks where process is still in the line. PROCEDURE Each division is responsible for maintaining an up-to-date list of all potentially harm ful materials used in their areas and specifying the pro tection required when opening lines and closed vessels. Attached is a list of mate rials that are used exten sively at SRW. If the protective clothing can be minimized after the initial break, the list must specify the protective requirements for sub sequent breaks. Forward a copy of the list to the Safety Division. First-line supervision of employees doing the work is responsible for acquainting them with the hazards of these materials and the protective equipment required, and then See Safety Procedure #5, "Danger Tags and Safety Locks" for complete details on tagging and locking. DU 041480 DUP 0561297 Safety Procedure #11 October 25, 1977 INITIAL OPENING OF LINES AND CLOSED VESSELS Page 2 of 4__________ NOTES AND REFERENCES to insure that the necessary precautions are followed and that the equipment is isolated for work. Familiarity with the processes and equipment im mediately adjacent to the clear ed system must be a part of their indoctrination. 4. The process equipment to be opened must be cleared, "Tried", danger tagged and locked in accordance with Safety Procedure #5. e- Refer to Safety Procedure #4, "Caution Tags", Para graph VI, for additional tagging on complex systems. 5. Automatic valves between intended break(s) and isolating guard valves must be blocked in the open position and the line cleared to ensure that no process material is trapped in the line. 6. Drain valves must be danger tagged open except in special cases where it could create a safety hazard. m- If proper training does not; occur, refer to Safety Pro cedure #29, "Unplugging Lines, Valves and Related Equipment" using temporary heat or pressure. Probing of drain lines and valves should be consider ed a last resort. 7. When opening a line that con tains flammable material consideration must be given to any process equipment in the immediate area that may have surfaces hot enough to cause ignition. 8. The job plan must include the following: Prearranged evacuation route. A safe distance required for other personnel work ing in area. DU 041481 ..TigssfaeT'r MIlWPM, ~ -iaagaialMai Safety Procedure #11 October 25, 1977 INITIAL OPENING OF LINES AND CLOSED VESSELS Page 3 of 4______ NOTES AND REFERENCES e Location of nearest safety shower, fire extinguishers, air mash, etc. e Operation of safety shower by Maintenance personnel. e Additional ventilation if needed. e Protective clothing and/or equipment. e- Barricades. Buddy system or standby man. e Bumping hazards, body clear ance, etc. e The work should be performed "up wind" if material is flammable cr toxic. 9. The initial break will be made When breaking a four-bolt away from the body and the line flange, leave one bolt snug allowed to drain before con until pressure is released. tinuing the job. For larger flanges, leave two bolts snug. 10. A standby man must wear the same protective equipment as the man doing the job. He must also station him self in a safe location (normally 20 feet from the job) and must closely observe the work. 11. If process material has a tendency to solidify at ambient temperature a flush should be used before pro ceeding beyond the initial break, prior to the complete disassembling of a section of line. e If the process material is a potential water contamin ate then containment should be considered. DU 041482 Safety Procedure #11. ' OctoC r Is; 1877 INITIAL OPENING OF LINES AND CLOSED VESSELS * Pace 4 of 4 ATTACHMENT CLEARED SYSTEMS PROTECTIVE EQUIPMENT FOR INITIAL SYSTEM BREAKS -MINIMUM REQUIREMENT PROCESS PROP ERTIE S *3 *3 n Oo > S 3 X w n 33 o33 > cn 03 M r< mw E<?U IPMENT REQUIRED > o W o Cn c H > n H4 a X ooo J8 c 03 03 n 33 Cl F n O < P3 33 > F F > Fc 2 M z w N w > W z cn c hi *1 > o cn s M w cn > z o a K 2 X > 1-3 W 30 o Cl D F> <o OZ n Cl z cn Cl O tXt 2 n cn X cn c i-3 ACETHYLENE YES YES NO X AIR ARGON ` CYCLOHEXANE NO NO NO NO YES YES NO \ MO NO X X X X CONDENSATE (2)EThyLENE riATVRAI, GAS NITROGEN OXYGEN STEAM WATER FREON WASTE OIL LUBE OIL CAUSTIC CHLORINE HYDROGEN METHANOL ACIDS NO NO NO ! 1 I YES NO MO 11 YES NO NO NO * NO NO NO - NC ' ' NO t' NO NO NO NO NO NO NO MO YES YES NC YES NC NO } NO YES YES XXX NC YES NO YES NO NC YES YES NO NO YES YE.- ; X X X X x X y X X X X X X X X X X !; i ! | 1 { X X X BRINE H' NO NO NO 1 x 4 (1) LINES ABOVE 1" DIAMETER 5 (2) IF MATERIAL IS CRYOGENIC, PROTECTED ; MUST INCLUDE c. r. MPLETE ALUMI3 NIZED CLOTHING, GLOVES. AND HOOD. DU 041483 0961300 MWapaa.; aasiaa .r PP&R DEPARTMENT MANUFACTURING DIVISION SAFETY DIVISION SABINE RIVER WORKS TO: HOLDERS OF SAFETY MANUALS FROM: J. R. MOORE r February 8, 1978 SAFETY PROCEDURE #23 "ENTERING OF VESSELS" Attached is an approved revision to Safety Procedure #23, "Entering of Vessels". The following changes were made: Par. V, A. - The oxygen content of the vessel is changed from 18-24% to 19.5-22.5%. This change is due to an OSHA requirement. Par. V, D - Reminds the clearing group that a mechanical stop, to prevent rotation, may also be required in addition to the electrical disconnect. Please review these changes with your group and file this revision in your Safety Manual. JRM:lss Attach. DU 041484 Safety Procedure .23 ENTERING OF VESSELS r SABINE. RIVERr WORKS SAFETY MANUAL Issued Revised 2/10/78 Page i of 4 I. DEFINITION NOTES AND REFERENCES The term "entering of vessels" means working inside spaces which require the person to breathe the air inside. "Agitated equipment" means all vessels or spaces which contain rotating parts. C. An "air-line buggy" or a "breathing air station" is a source of breathing air to a mask from a remote location. Usually the air is supplied through an air hose from breathing air cylinders. When using an air-line buggy or any mask which has a remote air supply, a separate self-contained "5-minute" air supply cylinder must be worn for escape purposes in case the primary air supply is interrupted. II. AUTHORIZATION An approved work permit is required. This definition applies to vessels disconnected from service in place or removed from the area for work. Rotating vessels, such as dryers, are considered agitated equipment. Note Safety Procedure #47 when welding and burning is involved, for additional authorizations. Only those groups whose name appears on the work permit may enter the vessel. ^ 'tiBWttirjf DU 041485 ( I | DUP 0S613C2 'isiffi-W" ,T' nai--i p'liaiaiia aasaacg asBM r Safety Procedure #23 ENTERING OF VESSELS Page 2 of 4 February 10,"1978 NOTES AND REFERENCES III. REFERENCES If a vessel is to be entered, several rules must be follow ed. Safety Procedure #47, "Work Permits". Safety Procedure #5, "Danger Tags and Safety Locks". Safety Procedure #37, "Car bon Monoxide Safety". SRW TS-305, "Portable Lights For Use When Enter ing Vessels". Safety Procedure #10, "Safety and Fire Equip ment" . IV. EQUIPMENT SMS-932 (Enco) "Entering Cooling Fan Enclosures". The following safety equip ment will be required for vessel entry jobs: A. Safety harnesses and life lines . Wristlets are also avail able on Maintenance rescue wagon and must be at the job site when vessel open ing is very small such as a boiler fire box, ex truder barrels, etc. B. Freon powered horn or other methods to call for help. C. Plant approved flashlight. D. "30-Minute" self-contained air masks for rescue pur poses . DU 041486 An approved lifting device must be ured if.the person is workir._ five T'( 5) feet or more below the opening of the vessel. See SRW Drawir.cs SRW-Gen.C-18511 and 19177 for details of lifting device. DUP0961303 T-1 Safety Procedure *23 February 10, 1978 ENTERING OF VESSELS Page 3 of 4 ____________ V. PRIOR TO ENTRY NOTES AND REFERENCES A. The air inside the vessel If after considerable must be checked to insure effort these conditions the oxygen content is be cannot be met, then Main tween 19.5-22.5%. The tenance , Production, and atmosphere must be free Safety must agree on the from hazardous concentra adequacy of personnel pro tions of flammables, toxic tective equipment required vapors or dusts. to enter the vessel. B. All pipelines attached to the vessel must be dis connected and/or blanked and the flanges and physi cal disconnects danger tagged by both the clear ing group and the group working inside the vessel. See TS #111, "Temporary Blanks". A disconnected pipeline means the bolts disconnect ed and the pipe pulled away from the vessel opening, or a section removed. In all cases, any flange opening leading into the vessel to be entered must be arranged so that no outside material either gas, liquid, or solids, may enter the vessel. C. During welding in a vessel, Remove hoses or disconnect, precautions must be taken the cylinders while they to guard against loss of are unattended (such as oxygen by torches or flames lunch time, shift chance, and against the possible etc.). hazards of gas leaks from torches or hoses. Guard against an over rich oxygen atmosphere during burning and welding. D. If the vessel has agitated One of the following me equipment, the motor must thods must be used: be disconnected, danger tagged and locked out. A 1) Physically disconnect mechanical stop, to pre the motor from the vent rotation, may some driven equipment by re times be required in addi moving the belts or tion to the electrical chain, or in the case disconnect. of direct coupled equipment, remove the coupling. DU 041487 DU? 096130*1 Safety Procedure #23 aanra Page 4 of 4 ENTERING OF VESSELS February 10, 1978 NOTES AND REFERENCES 2) Disconnect the motor leads. 3) Pull the fuses. VI. ENTRY A. A standby man is required. He will be alert for changes in the work area and should be trained and physically capable of carrying out a rescue. The standby man must have adequate protective cloth ing and equipment to carry out a vessel rescue. He should summons help either from freon horn or inter com, before entering the vessel. B. If possible, the standby man must be able to see and talk with the men in the vessel. If this is impossible, an exception to this procedure must be approved by supervision referred to in VII.A. Normally the standby man should be a Du Pont employee not a contract employee. C. Safety harnesses and life lines must be worn: NOTE: If there are only two men working in a vessel, both must wear a life line and harness. VII. EXCEPTIONS When there are more than two people inside the vessel, the supervision of the men entering the vessel may approve only one per son having a lifeline, to minimize the tripping hazard of several life lines . A. If a lifting device cannot Any exceptions to this pro be used because of the cedure must be in writing design of the vessel, a stating the reason for the written rescue procedure exception and must be ap will be prepared and ap proved by the persons proved by the Area Main listed in Section VII-A. tenance Superintendent, the Area Production Super The Chief Shift Supervisor intendent, and a designated may represent the Safety member of the Safety Division on nights, week Division. ends and holidavs. DU 041488 UBMiat ,UM D'J? 0S613C5 U l/WIUN .mil NUIII ICY )|\HJI n.NAL IY Houston North Aren Offlco 11, /U u.|f*. > 1 9 BCCI0N * AHC A ' PKCt < j 2320 LnHranch, Km. 2113 Houston, Texas 77004 6 1230 J 0f 1 Certified Nail No.' 354529 Return receipt requested f PENAUIE : are nut : WITHIN IE DAYS OF SERIOUS fclfMmtt NOV 91978 Fiucs.^.vr.s 0KHC12 INSPECTION DATE: 8/31/78 - 9/5/78 INSPECTION SITE: FM 1006 Orange, Texas : RECEIPT OF THIS NOTIFICA ; UNLESS : CONTEST ! (Set endoi TO: E. I. DuPont Dc Nemours Sabine River Works P. 0. DOX 3269 Beaumont, Texas 77704 ' the law requires ,h., . eoov of thi. < Booklet) Citition b posted tmmndi.itely in a promt* f^nt pi^e. .t o, n,,f ,h. i:i..on ot m. v.o- ! Thii Sectic litlon(i) cited below. Th Citation mult i Be Oetjctv rtmiin potted until ih violation! tiled be Beloit Pot hivtlow been corrected, or lor 3 working dtyi (excluding weekendi end Fedetei holi- deytl whichever it longer. Thli Ciliiion deKribet violation! ol the Oceupationel Salety end Heelth Act of 1970. The peneltylies) lilted below are bated on theta violation!. You mult correct the violaltoni referred to in thu citation by the dalci lilted below and pay the penaltiei propoied. unleti within IS working deyi (deluding weekend! and Federal holidaytl Irom your receipt ol thu citation and penally you mail a notice of conteit to the US. Department ol Labor Area Office at the addrett thown above. (See the encloted booklet which outlinti your retponubililiei end couriet ol action and mould be read in conjunction with thu form.) ITEM NUMBER STANOARO, REGULATION OR SECTION OF THE ACT VIOLATED: DESCRIPTION DATE BY WHICH l" VIOLATION MUST BE CORRECTED___! PENAI The violations described in this citation are alleged to have occurred on or about the day the inspection was made unless otherwise indicated within the description given below. r la 29 CFR 1910.100l(g)(2)(i): Caution labels were not affixed to all raw materials, mixtures, scrap, waste, debris, or other products con taining asbestos fibers, or to their containers, which during any reasonably foreseeable use, handling, storage, disposal, processing or transporation could release airborne concentrations of asbestos fibers exceeding prescribed exposure limits: (a) at the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers. Further, the insulation was not collected and sealed in impermeable bags, properly labeled. Immediately: $56 lb ' 29 CFR 1910.1001(h)(1): Places of employment were not maintained free of accumulations of asbestos fibers which, if dispersed, could result in an excessive concentration: (a) at the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers. Further, this insulation was not collected and sealed in impermeable bag, properly labeled. Immediately: ? lc 29 CFR 1910.1001(h)(2): Asbestos waste, scrap, debris, bags, con tainers, equipment, and asbestos-contaminated clothing, consigned for -disposal, which may produce airborne levels of asbestos fibers in excess of prescribed limits was not collected and disposed of in sealed impermeable bags or other closed, impermeable containers:- (a) at the north end of the 258 area, insulation containing asbestos l*r'y%rn jm ****< 3^ r- arl* .11 1 fV Hia CHliS SIC*"* ^ airborne fibers. Further, this insulation was net collected and sea1 ed in imocmeable bass, rr-coerlv labeled. Immediately; DU 041489 SABINE RIVER WORKS SAFETY DIVISION a-- ---- June 23 a 1976 TO: HOLDERS OF SAFETY MANUALS FROM: J. R. MOORE APPROVED REVISION SAFETY PROCEDURE #29 UNPLUGGING PIPING, VALVES AND RELATED EQUIPMENT USING TEMPORARY HEAT OR PRESSURE FACILITIES Attached is an approved revision to Safety Procedure #29, "Unplugging Piping. Valves and Related Equipment Using Temporary Heat or Pressure Facilities". The format has been changed and Paragraph II, E, has been added requiring Technical certification that the equipment is protected from overpressure. Paragraph IV, A, has been added to require a work permit for all unplugging operations where mechanical work is required. Please review these changes with your personnel and replace the existing procedure with this revision. JRMilss Attachment DU 041490 r* Safety Procedure # 29 UNPLUGGING PIPING, VALVES AND RELATED EQUIPMENT USING TEMPORARY HEAT OR PRESSURE FACILITIES SABINE RIVER WORKS SAFETY MANUAL Issued Revised 6/23/76 Page l of 3 NOTES AND REFERENCES I. PURPOSE The purpose of this procedure is to provide safeguards and establish responsibilities for unplugging piping, valves, or related equipment. Safe performance will re quire constant alertness of all persons involved to observe unusual situations on specific jobs. II. PRESSURE INJECTION A. Where unplugging facili ties are designed into the process piping and equipment, the procedure for their use, as set out in the area operating manual, shall be followed. B. Direct supervision by area e. g. Steam injection con foreman or supervisor is nections . required for unplugging piping, valves, or related equipment, when the facility is not designed with devices for applying pressure. C. Compressed air must not be used for unplugging equip ment which handles com bustible materials. D. Specific approval of the . The use of compressed inert Production or Maintenance gases for unplugging must Division Superintendent, be discouraged due to the of the group doing the work, high pressure potential. or their assistant, and direct supervision by a foreman or supervisor is required when compressed gases are used for this purpose. EXCEPTION': Where unplugging facilities using inert gas is designed into the svstem. rr Safety Procedure #29 June 23, 1976 UNPLUGGING PIPING, VALVES AND RELATED EQUIPMENT USING TEMPORARY Page #2 of 3 HEAT OR PRESSURE FACILITIES NOTES AND REFERENCES E. Technical must approve, in e Be alert for a relief writing, unplugging operation valve which may be plugged that requires in.iecting ex with the same material ternal pressure in excess of the design pressure rating of that plugged the system. the piping or related equip ment. The Production Division that is responsible for the equipment must initiate this action. F. No steam hose, rubber hose or other connection of a fragile nature shall be connected to equipment being unplugged. III. EXTERNALLY APPLIED HEAT A. No lines, valves, or re lated equipment in any service are to be un plugged by application of external heat except by established approved pro cedure. If the situation is new, unusual, or questionable, the operation will be supervised by a member of supervision re maining at the job site. This includes jobs being done by personnel other than area personnel. B. In applying heat for un plugging purpose, the heat application should.be started at the free or open end of the piping and then proceed slowly through the plugged portion to avoid the trapping of gas which could result in a nrsssure build-uo. DU 041492 DUP 0961308 r Safety Procedure #29 June 23 1976 UNPLUGGING PIPING, VALVES, AND RELATED EQUIPMENT USING TEMPORARYJ Page #3 of 3 HEAT OR PRESSURE FACILITIES NOTES AND REFERENCES IV. GENERAL The following precautions are listed as a guide to all un plugging operations. A. A Work Permit is required for all unplugging operations where mechanical work is re quired. B. Area supervision and the t In cases of doubt, the supervision of those perform work should be stopped andi ing the work must remain the details referred to * alert to indirect results of higher supervision for :! these operations and to unusual their advice and approval. circumstances ^hich might arise. C. Area supervision, will give com plete instructions as to the unplugging method to be used and safeguards recuired. D. Areas of danger will be bar ricaded. E. Full consideration shall be given to the characteristics of the materials handled by the lines or equipment in deter mining precautionary measures. I F. Sudden release of plugs must be anticipated and adequate pro visions made for: 1) controlling i and disposing of the flowing i material, and 2) possibility of the unsecured end of a line bend :j ing or whipping when subjected to sudden high velocity flow and pro per positioning of individuals in the event of sudden release of n plug. A G. Everyone involved must use adequate and proper personal protective equipment. DU 041493 DUP 0961309 <1 a n ii 8i ] 1 3* ! 3 -i- / . . ( UNITED STATES OF&lftEJtl OCCUPATIONAL SAFETY-'AND "HEALTH 1825 A. STREET* H, WASHINGTONS O.rtr.'^bai ` DATE 12/14/78 SECRETARY OF LABOR V. RECEIVED DEC 211978 REGrm't- 6 -;Tr OSHRC DOCKET NO. ' 7855 NOTICE OF RECEIPT OF Ca E. I. DUPONT, SABINE RIVER WORKS INSTRUCTIONS TO EMPLOYf Notice is given that the above captioned case was received by Commission on 12/11/73 and assigned the docket number listed above. All future documents and communications relating to this case should include the docket and region numbers. Enclosed are (lj a copy of the Commission's rules, (2) a copy o your NOTICE OF CONTEST, (3) a form notifying your affected employees this, and (4) a return pose card notifying us that you have notified tne.TU This post earn must be completed and mailed witnin 43 hours of receipt of this letter. <ul a 7 of cn_- rules s rts forth ths n ;c tss ir y . r;c-dur~s - jr - : anci advising off acted ahpl oyaas of tea css.?. Failur1 -.o comely i -h procauures .:i=y result in t.no dismissal of your .OTIC! " "C.-TfiT. I.i cne ;V;nt them you have olr-.?::y co-rpl i --.no vomi^i > : ti-: C s s i v.'i wi:r;_..r. L.-.T7 1 ;~t :r as t; c'-..:o i-.-.-.s. i a as a con ju . r u i s rc ' n s e j r ,, . ; <. i ; _ t i >.., s * 1 c .lavs jjouc this .riotcur. For trie EMPLOYER: HASiI NOS i. TRIJu, JR., -32. i. I. JU PONT OE N'iMCJP.S-- u i-c'j^L Jcf AR TMENT, <.' . 0-7130 I LMING7C., , 0- 1 j 29 3 Y ay -. 0 - r 1 i ng Jr . :x;cur. i v > iecretarv ( 202! h - *7 . = \ O For tne EMPLOYEES For the SECRETARY 2F LA3CR: JAMES E ,'HITE ACT I .0 R E 3 I INAL 3 .21 : 0 3 3r2 3RIFFI'! SEU.aP. : ,l,3. 3'- I F = IA,f. YO'J.'.O STR.-ET DALLAS _ , TX DU 041494 DU? 0961310 <(XT ICE .!t!T*T0 B^^YEES 0F E. X. DC PORT DX NEMOURS AND COMPANY SEETHE RIVER WORKS YOUR EMPLOYER HAS SEEN CITED SY THE SECRETARY OF LABOR FOR VIOLATION OF THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970. THE CITATION HAS BEEN CONTESTED AND WILL BE THE SUBJECT OF A HEARING BEFORE THE OCCUPATIONAL SAFETY ANO HEALTH REVIEW COMMISSION. AFFECTED EMPLOYEES ARE ENTITLED TO PARTICIPATE IN THIS HEARING AS PARTIES UNDER TERMS AND CONDITIONS ESTABLISHED BY THE OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION IN ITS RULES OF GJA DC 7J.57A1 PROCEDURE. NOTICE OP SHOULD BE SENT TO OCCUPATIONAL SAFETY ANO HEALTH REVIEW ( 13S K STRUT,MY <H WASHINGTON,DC WHS ALL PAPERS RELEVANT TO THIS MATTER MAY"BE INSPECTED AT (EMPLOYER MUST FILL IN ABOVE BLANK SPACE PRIOR TO POSTING AND SERVING THIS NOTICE! DU 041495 DU? 0961311 'la ' 1 :-. i OmJ*. **& mmm ** faf**u*M n* E. I. ou Pont oe Nemours & Company Wilmington. Delaware i969a LEGAL DEPARTMENT r December 4, 1978 REGISTERED MAIL - RETURN RECEIPT REQUESTED Mr. Gerald A. Baty, Area Director U.S. Department of Labor Occupational Safety and Health Administration Houston North Area Office 2320 LaBranch, Rxn. 2118 Houston, Texas 77004 Re: Citation and Notification of Penalty CSHA No. H 4681 9 Region 6, Area 3280 Dear Mr. Baty: E. I. du Pont de Nemours and Company, Sabine River Works, Orange, Texas, the employer named in the captioned Citation and Notification of Penalty, hereby notifies your office of its intent to contest in their entirety both the three item Citation for Serious Violation alleging noncompliance with the standards at 29 CFR 1910.1001(g)(2)(i), 29 CFR 51910.1001(h)(1) and 29 CFR 51910.1001(h)(2), and the Notification of Penalty which proposes a penalty of $560.00 for the aforementioned alleged violations. Please direct further correspondence or notices concerning this Notice of Contest to the undersigned at the address given below. Very truly yours, j HST:am .1 Hastings Sf Trigg, Jr. Of Counsel. E. I. du Pont'de Nemours and Company Legal Department, Rm. D-7150 Wilmington, DE 19898 (302) 774-5637 5UP09 6! DU 041496 ilcuw tw rzc. *r& uiaact 2520 iaiirancL, Ea. 2-" tstac., Jexar 7700i Tvafufiwla m ( SEKTOTC ttiimno MMMM# to. Btc^fiodz. 7. Sruy CoBfwsy r. C. for iOS* . . Sraax*, Serai 77632* isssc. \ \ * .* . *-- y * I .m- parcnacuTt: 'Y 76 - S/17.7S M_HInSlfL^_oCnsmn?*.OKSVsTbtixtt Szvvr fence ttrsp, Ybzs? TMC Uk* REQUIRES W ruv or ** . ChWWl w poor? WunrrNmx' . t r ~ m*; pftn at n v toccooi ar w >4r> **. ?** SXoreor. jimu >!! umC ma wwrtnm &*c U- r W 3 martin X> dtnon Oocrtor. WMim a' tin OenuACMi! kilrv m4 Harti As a" I'm. T*r pimirtyr--3 En Win n bv**v r (* t*swbMc a. nun ec.Trc tfw TMini irU.'r*t i* * mk aubc* fr. t<ikBMWariWM'lMi7iuiiinMA nwKwnnw-. ir> ward** un m*i f*onp h^orny?: injm ywr me* of tfw. CTcmof mo paur? vow rami e nous* a easns it nr -.S CNcqrvnst o? bar Atk. Oftet r oh rtonK MmA **. IS* n pnkwm tn*Wt bi bur Ians.' optmr ;w mwWW&iw W wn # Tpaa m e__i mjteur AEitAfct Rtt7U_AT/On W !E3W OF TKI ACT WTO.ATEIl' OESSRIFTTQV DATE r>r micron I yidiATlbrnwEn ' H KWflECTES Tia riclstiJ3zii> described is trii- citAtioo art tlltgvc to hart- occurred ao or tenet tbs day She, iagpe striae war nais uciw-s etaerwiw indicated virrdj. Tbs desenptiot gsves beirv. r 2$ CFE l^iw.iOOl'.t.u 2 i; Isscfar- as practjcaclf. asbertOf vt* not handled, >isec.t applied, resrvBd, see. scared. sz- cciservlsfi Merged x it *rst react ioff exert tz pr*Ten.c cat ecLsaici: ci. eirser&fc fiasrc Is essear cf prcS'Cribca tesposurs lislta lor csosircosf 2MMSdfitely {it} jet tb= acrrfc end ct the- 15: area, iasuLatiaa coctaiidiig ssbertcj v*r resored tros pipsi it the ever head rack n;> cac sxissios * eirbernt fibers. lb i t | ZMBdLttdr 2?= CUT. iOCi*vt ..2'iiiii): tsWiSTCE. eat reacval tr Itsplt-yec? csga^cd ir* the sprspas cf of pipet. Etru:cC5iresT or wqarp- ecc centre; or iarulstcd arscr- Mt*rtot, or cht rcsoTel ar denilitiflZ: sabercc; insslatioii ar ccTcriiin/ w^ro iir-t proridas vitc rt5CiTXorj equLpcatT zc scccrdasce ^.tr'purajrjph :.d)(2)'iii; cf tfcii reccioa arui rpcdil do this e is tceardancc tits, paz-agr^jtf. {i )-li; of tfeii sectica: (b; ct cat ncrt cud of tbt 153 area, isrulttion costslsicg asbeatst reeo*ei fra ptj f dr'ncra* T.Lxrt, S56C iv 2? CF? i?:Crl(Kt'i\i Initial Boaltcriaf was sit ccadactw is *s=h t aaaar te detemiae wiiather aver? eBplc-yte-' t esporure tc tir-fcsro* astxjrtoB fibers it btiow tht prvjcnbsc lixiti: (t/ at the- sertn cad of enc 25^ area, iasulaciot coctcscorEg csbestse >* r tmr~?m pdZKjr i-D rrir Ixcbd arv k^_ic%ixig -- r%c yi i iirtcrac fiben/ L/ * DTJ 041497 DU? 0561317 I j "safety Procedu 12 ASBESTOS HANDLING Simi! lo.g-, 3L SAr`~'TE JITTER WORKS /? K - HATETY HANUAL /&/*/ lH~A -- Issued October 1973 Revised July 24, 1978 Page l of : TOTES A TO REFERENCES PURPOSE This procedure presents the per missible asbestos dust exposure limits^ methods of controlling exposure, respiratory protective _ equipment, ~dispQ8al^zainr~mFthoaq-- of handling. The principle sources of exposure to'airborne asbestos dust at Sabine River Works have been: 1) Removing old insulation; 2) filter aids; 3) waste disposal; 4) mixing asbestos cemont; S) cutting transits; 6) removal of-clothing after completing asbestos Insulating duties.. A. DEFINITIONS Reference Du Pont Engineer ing Standard S 4 T. OSBA Regulation, Section 1910.9 and 1910.14l1. Asbestos d concentrations in air shai not exceed an oight/hour time weighted average of t (2) fibers longer than flv (5) microns per cubic cent meter of air./ At no time may the concentration cxcc a ceiling of 10 fibers Ion than five/(5) microns per cubic meter. / /?/*> fi - / f'v* 9i 1. Asbestos Material. - Any material containing asbestos. /Q/o. Soa t 2. Particulate Asbestos Material - Finely divided particles of asbestos material. 3. Visible Emissions - Any emissions which are visually detectable without the aid of instruments and which .contain particulate asbestos material. _ /?/# '/OOt(< ) C0 II IA 4. Removal - The taking down or stripping of Friable Asbastos Material. x-*.* DU 041499 I Safety Procedure *** '' Page 2 of 6 ASBESTOS HANDLING --WB---- IIIIMII ! ia.Liiw .jiwmiuiiimiUUlLM r July 24,1978 NOTES -AND- '-REFERENCES 5. Friable Asbestos - Any material that contains more than 1% asbestos by weight and can be crumbled, pulverized, or reduced to powder when dry, by hand pressure. (Transito is not friable asbostos material.) 6. Adequately wetted - Suf ficiently coated with water or aqueous solution to prevent dust emissions. B. GENERAL RULES 1. Each job involving the handling of asbestos must' be thoroughly reviewed. 2. Insulation to be removed and discarded should be adequately wottod prior to and during removal. Material removed shall not bo dropped or thrown to tho ground, but shall be carofully lovored to ground level. 3. Each employee handling asbestos or exposed to the dust must wear an approved respirator whereconcentrations may be above the permissible exposure limits. The 3M respirator,Type 8710 is approved for use,CTI-8750-450. Contact the Safety Division for other" approved respirators and filters. 4. Asbestos free insulation will bo used on all new or altered facilities. 5. All hand operatod or power operated tools which may produce or release asbestos fibers in excess of the permissible ex posure limits shall be provided with a dust catch' ing system. Vacuum area dally to prevent accumulation of asbestos dust on ledges, shelves, floors, and ma chines. Air hones or dry sweeping is not permitted. DU 041500 Safety Procedure 12 , *3u^y 24,. 1978 Page 3 of 6 c _ ..ASBESTOS HANDLING u" NOTES AND -REFERENCES . "- -T ? yTCV'.'X ;i-- C. ASBESTOS - MATERIAL MIXING 1, Cement, mortar, coat- "" ings, grout, and plaster containing asbeatos shall be mixed in closed bags or other containers. Any dried out cement should bo discarded. Do not attempt to re-work it. 6'*/. _ .y? D. WASTE DISPOSAL I ,<F 1.. Asbestos waste shall be collected and disponed of! in sealed, impermeable bags or containers. CTI - 87-03-110 Caution labels shall be attached conforming to Figuro 2. ...... - v - -$ .2 Tbo aroa Mechanical Foreman following the job should prepare a - purchase requisition and shipping notice (SR-630). The vendor is DFI. - The requisition must include their Code No.. PA#367. 3. Until tiio material is picked up by the vendor, it must bo stored in a place whore the bags will not bo punctured or otherwise damaged. ;- ' ' *T * * .* *'t'JE-STT' - - - * "it " *"> - Asbestos contaminated cloth ing, and throw away respire-- tors;shall be handled, in" s_ealed''labeled.baga;vith^ln^" structionsifor' propor- handl ing; ~' 14 " * - '<& ____ --* astT-niferjv The Shipping- notice must bear the followingr'"'- SRW .Coda-13 Description'- Used Material, Primarily insulation, con taining'asbestos. ClassI... * 'j:-'" 'TDWR Code - 170730 '.Disposition - Ofiff-SIte^^t*" ' **-* ItK . -- . .' :m"c: "t:__ When the material is shipped, the responsible Mechanical Foreman muat : - --1 Lyr*Jiv- fill out the Paxt I section Hr L of a TDWR Industrial Waste Shipping Control Ticket t^ form, which the carrier r.-'-M' _____ . truck driver will bring with him for each shipment nr tr'olf . DU 041501 Safety Procecure *2 Pago 4 of 6 ASBESTCS HANDLING j uxy * *, a * / o NOTES AND REFERENCES * E. RESPIRATORY EQUIPMENT 1. Respiratory protection shall be provided and worn by all personnel in areas where exposure limits may be exceeded. 2. Atmosphere supplying respirators (selfcontained units) arc to be worn when concentra tions arc expected to exceed 100 times the limit. EXAMPLES: 1. During time when local, ex haust ventilation is not sufficient. 2. During known period of over exposure. .3. Emergencies. . 4 During the spraying of asbestos* and for thn donolltion and removal of asbestos insulationT . The respirator shall be clean ed and disinfected after each use or discarded' in waste bag3 if they aro the throw away type. 3. Each employee who may use a respirator shall bo in structed in its uso and in testing it for proper fit. F. HYGIENE Exclusively assigned respira tors should be cleaned at least after each days work.' -1. Separate lockers for work clothes and street clothes ..must be provided to provont contamination for known exposure to high level concentrations. 2. Spocial clothing (coveralls) should also be provided for high concentrations such as spraying and demolition of asbestos insulation. 3. Food, gum, tobacco or any edibles shall not be con sumed in areas where asbestos .is being handled or fabricated. We SAMPLING / Monitoring is required where employees might be exposed to asbestos dust to datoraino the amount of exposure. DU 041502 Intervals between monitoring of samples shall not exceed six months. Contact the In dustrial Hygiene Monitoring Group, Dldg. 5 for assistance. Page 5 of 6 ASBESTOS HANDLING l * * i "r NOTES AND REFERENCES H. CAUTION SIGNS AND LABELS 1. Signs shall be at all approaches to areas where asbestos concentrations may be above permissible exposure limits. (See Figure 1) The signs shall be placed at a sufficient distance to permit an employee to read the signs and take necessars precautions before entering* the area. Labels conforming to Figure 2 shall be used -to identify containers of raw materials, scrap, waste and other products containing asbestos. i* * Yfttv* I.tfpf* M klk kcckjrcw^k - Qlk Icllpr* an -- ftltta kak|rav*4 Ultif Iit a4 <ryl k. |> i tivihlv at that UvtvW kataw. 1* Sana Sa)v, Carhia, ar BW Sana Savil, CaiMa, ar Black Vk" CaiMt " ... 1 11 Sfaiivf M ka laaat a^wal tm fka kavqht al I Ha cppvr mi aap hn ilaaa ASBESTOS ^^DUrr HAZARD Avl4 knctHliwi Al* Wtar vtiifM j pretetiv* On ftv* nwi I* Ofvc mIvcc f#*v rfk ftcwirov if wmr^iwy vikvitn Ait iwi; k* k*rtkp<vt t rvf k.cliK riCUKE 1 - CAUTIOM SIGN - ASBESTOS OUST CAUTION CmIvWii nkaitpl fikvn A..H fiMtif| Ait Imtlll.f fk.ll.v Alt PVf lf.iv VMifvv kWilf Ivkvl fit* vW |liti^ to I Bit, vlpikl. mri Iv-jikl.. DU 041503 flCUOE : - TYPICAL CAUTION LAfteL aatiJM" jj Safety Procedure 12 f " ,,. ' ASBESTOS HANDLING feage 6 of 6 _________ _____ July 24, 1978 NOTES AHO REFERENCES I. EPA REGULATIONS OH ASBESTOS 1." The Environmental Pro tection Agency requires certain reporting pro cedures when operational facilities containing asbestos are being de- . molished. Reporting . procedures are also required involving renovation of 80 meters (252.4 ft.} of pipe or sore than 15 square meters (161.4 sq. ft.) Of friable asbestos. 2. It is the responsibility of the Mechanical Depart ment to ascertain those locations where asbestos exists and to ensure notification prior to demolition or renovation. This requirement docs not pertain to transits siding because transite is not considered "friable". Reference Subpart B National Emission Standard for asbestos. The Industrial Hygiene Monitoring Group in Build ing 15, can assist idenbifying insulation that contains asbestos. 3. If demolition or re- / novation as outlines!/ in Provisions are made for emergency renovation and Paragraph I, 1, above is - the Environmental Co to be done, notify the ordinator, Ext.6421 can EPA Regional Administrator, assist with this require1 Dallas, Texas twenty days mont. prior to commencement of demolition or removal stating the measured or estimated amount present. DU 041504 - WEnzAWL^ r Bousaau Jorch Ai'id-w.fice 2TtC l.aUpaf*ah. to. 21 iS ;0<cs tm* u manes Be am- sc * : fc* pprftw.&iiipif'v cr. in-.-' P- iM> loeatm. r> PW Tfcifc 5* IrUanui) smri CtKu TW rma. j 0. Cm. m*M*. WW! uno! R wgutqm cat*:' t*. : (mtstp Mr tM bN* Wrr*;t*t T%' Z i>vnM ' fi-fc eitrdr. <xr3ve iotitias <r R. SeuUiiCAi' t*rrr Mf >Ui. a=> pi 1C7C Tn pMwHvfcC fsacW' d*1 oft <Ny W). Vbk CVTi-. 9 wie rte><cC u- ie t*i rrrjoc. tH ttm arem tn*C below- ** (H ptmtott Otlwirmni. W|B WOA IS OJ<". ; lOBtxKflC >M>'iir>- r^jrn. ncMtvrri from rawer- r pvr claim m9 ocasicv ear Mi 1 *! of crn*il er tfa* w-t biawrw p- , UBcr Am. O+fic* r 3m *a*tpb coom lim (N ttciottf unaelrr *ovet. (kj(tin* *<*/ 1 wmnyirto' *fcl (Mm erf not a* be , M r> can<imb *tr erw ionu i ' k rv WHlCr. * rrtw. HUMaer y7AJtf^AHC: pgC-.'r_c.T|OH 'it iCZTl0*' 0 ThC AST VIOLe^E:*: pQCTtmOX________________________________ j.<Oix.r30^*<-.^rT ~ C tOr-tC~~SX. , a. 2& -IT 2Oil; I .'r.i'.i `r Proper isapies wtrr ii,r csHertac. fra tie creamnj, to ace c.f eoair;rae.s wise tftamiciag ^rpesegg, to air- ion^ iscestir fiacre-i ii at tie tomb eni zi zu ftS sraa. Insalattat eottsixasif afbertoa -xrs: rawaveo frar pipei ft tfce crcr haas ract tim ettiSiaan --af airicra* fibers.. -c i."'; f.aspiles verr not sciitatci fra* arear c- e vrric cnrtroaaent viiiah wart- rcpnraentatrrfc tf tac iirwrtte sazsszizrtliC'Oi of aswais.? fibers .vfci-ta itt^ rctaci tew crsatii&i; *cite cf fej^iierccai \} - tn# nt-rta eni cf tht 152 ftrti, iasulctian unfair tos v iros tips-* ii- ties aver ic<zi rata allnwia* taa cniaaicn of atr come flaart. inptediatui 7- if Sir ^1".'. 00-. ; The csplet^er iid not pmrida tr Lake rrmiatic. tr taan '.apicyre, vttiia ?.0 dayt ftlloirijtg ais firrt e- plt'jTEcrr ir tr; otttp.iii.at eni-r-eo to tirbemc lavaia oi aaDsatot fldcrs- a aospithefisi *"e uaiditil etasutattac.; (-) a* ^-r-K tn.; i.f the trtt, inmlnrion aentaiaini, as&aptoi vw rera-'cej frvn ir tna sve~ pcac rack alicviag tn.c eaiatiat of airborne fiberr. l InmiLatci y '. DU 041505 iiiur.tan tv rtc. <ir&* Ciiicc Lair inch, E=s- 2^ U -/"j^ 4^ Bncstan, Texas 77004 7?///U SERTOTI t m 5ea^ aaiin, Il Ena* Cocpanv r. c. 2=r io&; Cfaaps, Teas 77621- A Jf 1 * ' * `^*5^, ______ / - [ft BTH luFcat SC^aVfmciVai*t BRnfW>MBhr>rtkekkTA^kaar Grange, Test? VK l** REO&ttltSt (W. r * or * . OMWl A HW' kinn*Hlfcii> . I ptac i r imorsmi at k >*r>. teOsauC sW Nw. Tin 3ani ikiu mm pKXZUCt Itfnft M Wrtrrtft-- m b*- MM Innr Wc Pi"nM *n 1 wnrkx* 4MA UmSwOog MMIMb *nc Mt>- KMAzrt AKjUll WtXHOt ' tfAYD> KCW OFTKtT ermt 3XLEXS soma-. ftaafcxC v cftroon docr&r, vvjuao/v a- Jv 2aft^ua<ku: !il*;v too HtirOi As or I*r7r< 77w< tk it. lam cciTaer 9m kiiUw itt*?m tt 'f-md dub** t* (hr km inr War pm- e p*ww iiww4 mwww MIW Jf mofru* aon lapuln mpr. wm fMiir l*fiw*yri injTi volt ncvtJ1 a? Bv. iiuw tret Danxrf' vau naU c paten or eanac k> Mr UjS Ztmm niiMst zb' * Crrftet r mt t/iatt Mown <fca-*_ IS* (hr iw-Cbmi boatki Wnt t? n- exwtctior met* fur krreJ -fmc ina<*nTjft*a wt worm *f S_I tOJMMf AMZ*HZ, *:tmj^s.riot or stctjcw Of tmi ct i'13-xtei^ DEscmmow .01 v&io*iTJiriBTjM^rWiIrOjc.: 1 CaWRECTcS Tt Tic*anon? discnbed is this citation art alleges to hasrt occurred ; eu or choice ths dsr the inspection was nai xmi.ttse etn&rwiaa incicaseo. j vt-chin tbs description, given beisv. ; FOU *a 29 Oil. 2001'"c)(2 !(i Isaefar as prarcLcahl*. asbeszcf vu not kgadicd, nixcav applisd, rcscTBO, act. scarad. sr- ctharvise ericci in fc TTt rtct< rcffidear tt prTart tab e: Lee ci dr'temi fl'aers in etrr.Sf prcstribco srposcrt Halts ior ascertosi %o/ at atahs* aerthi; tna cf the 25? area, latulctiaz. sactalaiiig ashes-tos vs? re.v*t froa ptp-s in tht ever hean rach all?Etas toe sxtssina ci eirtense ilcei-i. ZaBiedi&tclT S$& It 5? C1T: 1?I0. iOOii?'.v25<'i.ii): SapiUytts tageged iii the sprsriac ct is'utstns, tat rescan cr dtaa.iiticc cf pnpet. iftructarea, or tfc.paeot ccrerei or inscistec eiti asoestoa, r.r the resotTl or daxcli.tian cf isbcttc.j lasulctiaii or ccrcrincr wrr nr.t pr'C'Tidac Kite rtreir>terj qtip=ert acasrcsiice vltr'parabrupt ;d)(2)(iii) of tfcii frhctioa aao special clctaiiig la accordance fcith par-agrapn. (i)-!!/ c,f thi* aection: (dj at the aorx an o: :hs 153 area, insulation contslnrLr.g anbestet vai reec-vtsi free papes . the rvtrr Seao rati allrbong tor nt:.trios cf lirheme fiocra. it 2^ ZFR iflC.lCtfii{i ' Initial nnsitcriiir. was it cnnflncte-3 is ench & Baanar te dfoemiuf whether aTtrj wp*,^.y^' exposure tc tir'bcrae asDustoc fi&ers is below the pre'serabso licnts: (*/ at the nerta end of tun 2$l area, insulation- cantai.ru.r.g isbestea 'W fr-a p-_pMr ix. xli n v j- Usud ricX OiLcvCXig exi -( yyi nn cf airteme fibc:*s. ZaBBCiatelr DU? 09612: DU 041506 I. mmM-- ESS m INTERIMS REPORT ON OSHA INSPECTS I ' 1 -* Date of Inspection 8-28-73 (START) _____ Time Page 1 of 3 September 20, 197s 2:45 P.M. Employment Unit (Name plant, laborrtory, warehouse, construction) SABINE RIVER VCRXS, ENGR. DEPT., CCNSTR. D1V. (b. F. SHAW CO.) OSHA region in which your unit is located REGION 06 AREA 32TU Name(s) of Compliance Offieer(s):______ HIVIT, HAST What prompted the Inspection? ^ iNTERIM REPORT DATED 9-1-7S. If a com laint, were you given written copy? yes request spy? no:; Was it necesr: Was adva; .ce notice given? ____________________________________ Duration of Inspection RESIDED 9--G--78 & COMPUTED 9--7--78. What did the Compliance Officer inspect? 555 rsTK1M DATED 9-1 What measurements did he make (c..^. noise, etc.)? SEE INTERIM REPORT DATED 9-1-78. air campling fer toxic vapors What Violations did he find? DISi-p.vtitng pipe LINES covered wr:.. TX.-c;.vriON KRTSRIALS CONTAINING AS355TCS._____________________________________________ a. DID XCT WET DCX-N MATERIAL. ~b. DID XCT WEAR PROTECTIVE CLCOiS^ _______ ~C~. J-J ,\Jx MiJIL.nJ- ./A.'S. d. DID XCT MONITOR AIR. What citations did he issue? ^ CiC^IN? CG>:-~RNCE, Cw,?L. HE VJC'JLD RECCM-EMD GTE CITATION TO COVER THE VIOLATIONS LISTED IN CITATION : AS BEEN RECEIVED AT THIS DATS. Were the citations for specific standards or unde clausa? (Please identify the standards cited.)___ UNKNOWN at THIS THE. he Se a = P-y OV a Compliar.ee 00? 99 612 2 3 DU 041507 Citations which nigr_ warrant contesting 'CKN September 20, 1>j7o 12. What tine was allowed Tor abatenent? unknown - at closing cuvrzuRENCE, OSK.A ofeicsr INDICATED ABATEMENT PERIOD WOULD BE 15 TO 30 cays it a citation is issued. 13. What penalties were assessed? USKKOH AT this date, officer indicated is WOULD RSCCM-END NO PENALTY SE ASSESSED. .4. How was the initial contact handled? SEE INTERIM REPORT DATED 9-1-78. a. Compliance Officer first appeared at (Guardhouse, Main Office, etc. b. Asked to see c. Presented credentialsvoluntarily _____ upon request. V.Tas he state or federal employee? d. Did your unit have an established protocol for this eventuality? e. Miscellaneous renarks about ease or difficulty in handling initial contact. . Did officer talk with Safety Supervisor, Work's Engineer, Company Physician, cr comparable people about overall safety and health p of installation either before or after inspection? (Give brief su SEE INTERIM REPORT DATED 9-1-78. . Did officer request to see any of the Company safety and health retc.us or records of occupational hazard measurements (e.g., toxic vapors, dusts, noise, etc.)? ____NO ____YES . Remarks_________________________________ LOCITD AT CSKA 52C0 LOG AND SUNNARY Cr CCrjPATICTi, INJURIES & ILLNESS"* DUP09 61: 11-74 DU 041508 17., c, r. September 20, 'a-: What representatl.v(s) of employees accompanied officer on inspect!:: UNION STEWARD (Union Steward, compl.-iinee, etc.) How was employee representative determined? SEE INTERIM REPORT DATED 9-1-73. 18. V/hat Company representative^) accompanied officer on inspection? A. 0. WHITE (3. F. SHAV,') ; U. CAMPBELL (DU POST) W. E. TKCl-AS, JR. (DU PONT PLANT PL VO Were questions directed to employee representative^) and Ccmca.-.v re ser.tative(s) alike in presence of one another? x>'0 YES. Give" seexamples of what you consider to be most leading cuestions. 20. Did officer seem to be well versed ir. the various rules and reguluti: applicable to your operatic.-.? __ NO x YES. Was a copy of written rule and regulations taker, along for instant reference? Any discussion of, comparison wish Company standards, etc.?. Remarks OFFICER WAS VERY KXCNIErCT?>BLC CD REGULATIONS PEEEPJNING TO ASBESTOS. 21. Were photographs deemed necessary? Who took them? SFF INTERIM REPORT DATED 5-1-73. 22. Comment on closing conference. COMPLIANCE OFFICER DISCUSSED HIS FTtings ant RECTNENTATITNS TO BE INL7.UDSD -7: HIS REPORT. CONFERENCE LIAS CONDUCTED IN A BUST El 23- Do you have any general comments to make in v/ay of a summary? GENERAL CEMENTS, IF ANY, VEIL. BE MADE 'ILLJ CFFICIAL CITATION ON REPORT FROM CSHA IS RECEIVED. DUP0961340 & Signed Unit :;: T. H. rUZR, CONSTRICTION PROJECT .".'-NMI' 11-74 DU 041509 CV. (SQM]!:' E. [.DU Pont oe Nemours & Company Wilmington. Delaware 19898 plastic products ano hcsins department N. K. WALTERS EMPLOYEE RELATIONS J. T. SMITH J. W. r"'NES c. K.'jELMEYER L. F A PERCIVAL/RP-1 September IS, 1978 REPORT ON OSHA INSPECTION - SABINE RIVER WORKS The attached report from Arlon Fields, Safety Supt., covers OSHA's investigation of the plant's procedures for handling asbestos. The plant reported that, at the opening conference, the OSHA compliance officer told them that this investigation was officially separate from the just preceding investigation triggered by the_ccmpiaint of a 3. F. Shaw, Co. pipefitter. An interim re port of earlier events was sent to you with my letter of September We will keep you informed of any communications received from OSHA. A report covering the 3. F. Shaw closing conference is expected and will be forwarded when received. The insulating material involved was asbestos per analysis by Marshall Laboratory of the duplicate sample sent to them. R. M. SHEPHERD ENERGY it ENVIRONMENTAL AFFAIRS MANUFACTURING DIVISION RMS:ldb Attachment DU 041510 aQCTTcn things for ctte p living . , nouc h C M I s -O-T' (" REPORT ON 05HA- Ili'.W VI: 11T' ^ 1. Date of Visit fruk 3 1 Time- - 2. Employment Unit (Name plant, laboratory, warehouse, construction) g>w^n_ -VAJoex.b ------------------------------------ - - -____________________________ 3. OSHA region 'in which your unit is located OnuLA<?________ SX* - .-- (.City) CRegTon" "NoTJ Name(s) and Title(s) of VisitorCs): ftg\J(L Mfcg'T - o?wsPtjatvg QPp-iCfcfL 4. Was the visitor(s) from OSHA _____________ . ^joPsnm - Qivr 5oP NIOSH__, FEDERAL, STATE' Si What prompted the Inspection?; Cflp^PLAMsTt OP- Q;n4,T gmPLO TS-g If a complaint, were you given written copy? Vg Was it necessary * request copy? NO.Note: Attach copy. Had the complaint been discussed with management at your location before being filed? X, ---No- - ---------- -Yes Remarks 6. Was advance notice given? vo____________________________________ ___________ 7. Duration-'bf*Ti~s1~t~'9tP->~S'~~og' 3 0* YS - ----------------------------------------------------- 8. What was inspected?^ Pv9lNfc> UmU E^ftST0S injsui^T<qi\J___________________________ What measurements were made (e.g., air sampling for toxic vapors, noise, etc.)? k>q 9. What violations were alleged?' ______ Uts>ftOKjpeo c^sb*7DS> ^o-r PgoPSR.Lv' lPEJO~nF'g.Q ) >7V/,W * ~~ DU 041511 DLP0961242 Report on OSZIA-HEW ^ jit \ 10. Were citations issued? u> -vj err '. P-8 Page 2 Note: Attach co; 11. Citations which might warrant contesting ___________&frfeU)N? Wg V^Npoo op.____________________________ 12. Were penalties assessed? NOwg gvflHTO'C-Q_________ Note: Attach cop 13 How was the initial contact handled? IH Ve<3T;t=*P-,L ,,P,,RB-T'Lti3 ... , . OF. Cao*r CIT^P.cro<a- Amo OCUMO to a. Officer i-*gst appeared at i^eggrw** ry Pifwr (Cuardhoise, Main Office, etc.) b. Asked to. see 9o&.rr r^a.iv^(y<5g. ri OvFe'ig'vCg' c. Presentee, credentials--A voluntarily ~ ' upon request. d. Did your unit have an established protocol for this eventuality yes............................................................................................... e. Miscellaneous remarks about ease or difficulty in handling init contact...................... .............. ' ~ ............................ .. ............ .................................... ) fro teoME. ...................................................................... ............. 14. Did officer talk with Safety Supervisor, Work's Engineer, Company Physician, oy comparable people about overall safety and health prer of installation either before or after inspection? (Give brief sumr.a TPH-KttP Ujv*TM Sftpgry boPf , fh.CU#^T/A/A >_ U^/aiTU CJO* Ql NAT/g. , ftwo Pcatsit Qocrog. To fig imP^ESi.^o mrrm oyg. &pc<?C.T3 15. ) 16 * Did officer request to see any of the Company safety and health records or rt.-cords of occupational hszard measurements (e.g. , toxic vapors, dust:., noise, etc.)?NO^ YES. Remarks ______ uttP r>r cisBesroi rn0wn/rr(j gg<u( ts What other materials did he ask for znd receive? DU 041512 t-e>0KO rxr ^5gES.7^S? PgpCgQ'jeg &UT W e>c, NoT G'rr* A (jr DU? 0 9 613 4 2 Report on OSHA-HEW . jit f' i--y Page 3 17. Was a represintativeCs) of the employees requested to accompany th< officer on tie inspection .Ho ______; Yes_________ . If "yes", who was the employee?____________ ' ______________________ (Union steward, complamee, etc.) How was employee representative determined? 18/) v-- 19. 20. Did the officer have discussions with individual employees in the course of his inspection? Vcs' Attach list of employees so contacted and subject matter ot conversation if known. "S-e-e cl ~o-c. l^ryiesy^i Names and titles of Company rep.'esentative(s) who accompanied officer on i.ispection. ........... .............. ............................................................. d\e.u>s - s*^6tk 6>U-- a ccuP&Tniu&Vw. ugnctsd Cbeg.Qmprmh--______ ' Were questions directed to employee representative(s) and Company representative (s) alike in presence of one another?^___ HOYES. Give some examples of what you consider to be most leading qui'stic: 21. Were photographs taken? Ves . Did company unit take or secure dup' photographs? //(? If'so, attach copies. 22. Comment on closing conference, qeiyy cji-^PU MeN-rcAY' qp- Plants Peer ujg couuO oo ft. fteTTEfl-. ~5on> of- Cin^u^tunA vnVMiu UOQ un69nQE.O Dve to _____________________________ 23. Do you have any general comments to make in way of a summary? ftfCMgn. Cw0(?EP>Qj.O To fee CotAPg-HEKi? dr>Q ^EdSoiynjate . - 6UU Ug PsOfO.C.C',P>Tp^ TUg PLANTS t=F-gQfVTS \Kl TlYg ___________________________________________________________ DU 041513 Signed s**-*-'eTv Htci-e !i--a rr UJ.'f 7 1^/Aoyr^ as^-*~ ZZ'yP. Za. //fec. &sv\ X CZL IsJi. U. C.^T- across J botL &T <zz^i<dy st^. 7 "]y/<. *so <-'1<z.2--w^ cJL i (fOD tfC^vc*--^^ 3 ^ ^o<sPo &~?7 Ce~ ^j~-6 CL. <L ft / V / /^" ^ ^f1^" ^a^JL^' <?~--&~~ XZb-*- ~fZ^Y~z-- Py^-SicUL. DU 041514 Z"rC9l !** mrt. ii-7i ill (ItMWWIW E. I. ou Pont de Nemours & Company Wilmington. Delaware 19898 RUASTtC PROOUCTS ANO RELS1NS DEPARTMENT J. T. SMITH J. W. ^ TNES C. J. r.JJELMEYZR L. F. PSRCIVAL/RP-1 September II, 1978 N. K. WALTERS EMPLOYEE RELATIONS INTERIM REPORT ON CSKA INSPECTION - SA3INE RIVER WORKS The attached interim retort was issued September 6 by W. E. Thomas, The complaint, by a 3. F. Shaw Co. employee, alleged imoroper orocecuras for removing asses cos insulation, Samples cr the insulation were taken by OSKA (and duplicates provided Du Pen for asbestos analysis, OSHA subsequently initiated a separata inspection o the plant's procedures for handling asbestos. More detailed^ ports on the closing conferences of both investigations should se received this week and will be forwarded. n mi RMS:ldb Attachment ENERGY it ENVIRONMENTAL AFFAIRS MANUFACTURING DIVISION DU 041515 Mumuiin ... JP/TEHIM RbFOF.T ON CSHA INSPECTION* --7-- -- ------------------- -------------------------------- Date of Ir.spcctlo. -28-73 (Still ir. progress) trii. , fagc i of 3 Septeroer 1, 1978 2:45 P.M Employment Unit (Name plant, laboratory, warehouse, construction) Sabine River Works, Engr. Dept. Construction Division (3. F. Shaw Co.) OSHA region in which your unit is located Begicn 06 Area 3280 Name(s) of Compliance Officer(s) : Bevil Hart & Noah- M. Shcpenn What prompted the Inspection? Specific compliant to CSHA. Complaint against B. F. Shaw Company, a CPPC Contractor at this site.___________ __________ - 3. --.6. ---7. If a complaint, were you given written copy? Yes request copy? No _____________ ` Was it necessary Was advance notice given? NO_______________________ ' ___________ Duration of Inspection 3eoan 8-28-78 and continuing. What did the Compliance Officer inspect? An abandoned pipe line covered Jtor-td . with insulation material and area where pipe had been w 'wmi1'1 , T. What measurements did he make' (e.g., air sampling for toxic vapors, noise, etc.)? Sample of insulation oaken for identification. wm ....... *. . ... . .. .. 8. What violations did he find? Investigation still in progress. . .---------------- ----------- . ...... --------- -- . . -- - ...... s \----- ' ; ` ' " c.::- -- 9. What citations did he issue? Investigation still in progress. - 10. Were the citations for specific standards or 'under the general duty -- - clause? .(Please identify the standards cited.) Investigation stall in rress. The questions apply to the visit of a Compliance Officer, h is by a representative of Health, Education md Welfare Ie.-' = eot i a DU 041516 ..Cions which nigl. --........................................-- - Page 2 of 3 Septenoer I, 1978 warrant ..contesting inves--cation still in progress. ....... 12. What time was allowed for abatement? Investigation still in procrress. '.3.:"'What ' penalties were assessed? Investigation still in progress. * I iTT ^ ...... "* 1--. -* - ------- -----.. . . -- --- * * -- ----- How was the initial contact handled? a. Compliance Officer first appeared at Plant yair. Office _ . ' .(Guardhouse, Main Office, etc.; b. Asked to see 3. f. Shaw Germany representative. c. Presented credentials X voluntarily _____ upon' request. . Was he state or federal employee? Federal d. Did your unit have an established protocol for this eventuality? Yes r-- .. -f - _________ . ____________________ e.---- Miscellaneous remarks about ease cr difficulty in handling initial ------- contact. inspectors courteous. Refused to sicn Visitor's loo. Did officer talk with Safety Supervisor, Work's Engineer, Company Physician, or comparable people'about overall safety and health program of installation either before or after inspection? (Give brief summary.) ' ~~ Discussion Limited to caralaint. ______ ' Did officer request to see any of the Company safety and health, records or records of occupational hazard measurements (e.g., toxic vapors, dusts, noise, etc.)? ____ NO ____ YES. Remarks -______________ No ' _ " '~ I'J?C9513-*3 DU 041517 oSKA Inspection Page 3 of 3 September 1, 1978 What representative(s) of employees accompanied officer on Inspection? Union Steward________ ' (Union Steward, complainee, etc.) . - .. "~ How was employee representative detppmi ned? He wes Building Trades Steward, selected by 4.B. F. Shaw Stewards. ' 18. What~Company--representa,tlYjeCs.)_accoinpanled officer on inspection? J A. *0."Whits' (3~FT ShawfN.. J. Derrick (Du Pent); W. E. Thcmas, Jr. (Du Pont Plant ?; 19. " Were~questions directed_to .employee^ representatlve(s) and Company repr? sentative(s)..-alike in -presence of one another? __ NO __ YES. Give some --jr~-~r~e ramp 1 e s of.~jw.hat. veu--;^^^ to he most leading questions. tliirlnYestigation'-'stilirin progress.'" ~~"y~'. 20. Did officer seem to be-weli-versed in the various rules and regulation: applicable to your operation? ^__ NO __ YES. Was a copy of written rules and regulations taken along for instant reference? Any discussion the: of, comparison with Company standards, etc.? Remarks - Investigation still in progress. 21.. Were. photographs deemed necessary? Yes Who took them? Noah M. Shcoenn (cs:22. Comment on closing conference. Investigation still in progress. 23. Do you have any general comments to mak? in way of a summary?_____ No DU 041518 Qfl ^ Tin-! *- ea f(ouston, Texas 77004 .j--------------_t. Certified Mail No. 354529 PT^(vfqWttiwaiWKitf(firtW SERIOUS NOV 91978 Return receipt requested INSPECTION DATE: 8/31/78 - 9/5/78 V INSPECTION SITE: puils........m s tn i ic:i-: FM 1006 Orange, Texas TO: E. I. DuPont De Nemours Sabine River Iforks P. 0. Box 3269 THE LAW REQUIRES thi coov ot this Citation bf potted iimntduitly m 9 promt* Beaumont, Texas 77704 nent plsct at or ntar tha location of the vio- lation(t) cited below. Tha Citation mutt remain potted until the violations cited bo* low have been corrected, or for 3 working deyt (excluding weekends and Federal holt* daytl whichever it longor. Tbit citation deteribei violations ol the Occupational Safety and Health Act of 1970. The penaltyfies) listed below are bated on thete violations. You must correct the violations referred to in this citation by the dales listed below and pay the penalties oropoied. unless within IS working days (exeludmg weekends and Federal holidays! from your receipt of this citation and penalty you mail a notice of eontest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses ol action and should be read in conjunction wtih this form.) ARE MIL WITHIN IS DAYS OF RECEIPT OF THIS N0TIFJCAT UNLESS C0NTESTE (See enclose Booklet) Thu Section 8e Detached Before Posti ITEM NUMBER STANDARD. REGULATION OR SECTION OF THE ACT VIOLATEO: DESCRIPTION DATE BY WHICH J* VIOLATION MUST PENAL** BECORRECTED The violations described in this citation are alleged to have occurred on or about the day the inspection was made unless otherwise indicated within the description given below. 1a 29 CFR 1910.100l(g)(2)(i): Caution labels were not affixed to all raw materials, mixtures, scrap, waste, debris, or other products con taining asbestos fibers, or to their containers, which during any reasonably foreseeable use, handling, storage, disposal, processing or transporation could release airborne concentrations of asbestos fibers exceeding prescribed exposure limits: (a) -a't the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers. Further, the insulation .-.as not collected and sealed in impermeable bags, properly labeled. Immediately $560 lb 29 CFR 1910.1001(h)(1): Places of employment were not maintained free of accumulations of asbestos fibers which, if dispersed, could result in an excessive concentration: (a) at the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers. Further, this insulation was not collected and sealed in impermeable bag, properly labeled. Immediately lc 29 CFR 1910.1001(h)(2): Asbestos waste, scrap, debris, bags, con tainers. equipment, and asbestos-contaminated clothing, consigned for disposal, which may produce airborne levels of asbestos fibers in excess of prescribed limits was not collected and disposed of in sealed impermeable bags or other closed, impermeable containers: (a) at the north end of the 258 area, insulation containing asbestos was removed from pipes in the overhead rack allowing the emission of airborne fibers. Further, this insulation'was not collected and sealed in impermeable bags, properly labeled. Immediately 1 AREA DIRECTOR __Cerald A. S^ty NOTICE TO EMPLOYEES -- The taw gives an employeeee, /r his representative the opportunity to olriect to any abatem fit dale set lor a violation if he believes the date to be unreasonable. EMPLOYER DISCRIMINATION UNLAWFUL - The law pro hibits discrimination by an employer against an employee lor filing a complaint or for exercising any light: under this Act. The contest must be mailed to the U.S. Department of Labor \rea Office at the atiuress shown .bus*' within 15 working days An employee who believes that he has hen discriminated against may Me a complaint no later than .11) d.iyi alter the xcluding weekends and Federal holirtaysl of the receipt by discrimination with the U.S. Department ol l abut Area Office t employe! uf tho citation and penalty. at the atlslress shown almve. ployti; rirsrtiNcinti.nifc-s anu courses of action - rim irlnsetl booklet outlines employer rrsnoniihiluie. ,.,,i set ul artiun .ual .............. he fc ,,[ (n r,,ti,,to,, with tins i.ntilicatini ciTAiititr amp Ntt i im , it:gj nr rrrMi l v DUP0961350 J5f TOTAL PE TOR T CITAt v.\, ~t)OL C lr>d>rj(p O On DU 041519 Sstr.toL iv rtt era* iffsct 2320 Lair and, a. 2-ifi Bsc* tan, Ttrar 7700.1 Ai I SBCJ31 70. Bct^aaiil. 7. 52u* Cacpsty r. c. Ssx ioe$ . Orange, Texa* 77630 d 1'^ ft 1'_' '~ ~.*" t' UU k- ract jgfc fa '%& _____ n-tu.TE. / " taPost Safcint Ri-rar Barer Grange, ?ozx* THE C.A Ras.flRX <W r, a- or * r but ps a*, av Me Mssvoii * M VM amor. r**ti KI Mffi M *SXAVTl A 0U5 WITHIK 1 W.no> VLtur. 0FTWJ eCTffTt. UWIES Jr rfttoon oocrtor. vtousuf# # uw OeMuaoHi: HsUen wad Hurt! Aa or ITO. T*b> aux CC.T4CT St* HtUbW i .*! V r> Sk4 tlbM to K Mb mr Mur art pB- <M Jrtlw m wwi: Jf MnM|< aan bea**e i i i oe, * Ftetn, hoAqayr- Mtjt yar rtTFD* of am. crtRiof anct outer* vow ml a mm* a earns: k# toe `JO Onr-nT-U mi B' Ask. O'&e* r: m mm nno am. tn toy uMoubibobUbi WO svbi v com at kva ibc mu-as- at to r eerauaebar< b4> *iir *ra` r J mjBAJUfmmz+*ia :twj-.r,r<oi a rthon of tki act v'tc.ato neseHrma c*; vniDOA:_TcAEnTnIiRT)E'*WnCHTt>E.Ccchr: Tbs ricLatioaf described it tbii sitattoo art sliseyec to hart- ossa os or tsoct tbs day the inspcctxai, vs* nais ai.,1 otnarwlM indicated j i viteii: siss description gis-es, beiov. i POtAJ 29 CFE. :9iL.:001` c'u'2 IzjcIar ns prarticaiL*; isbe.fftoj vt*. rt handled, ai,spat applisd, r-carvBbj set. a corse, si tsharvlse verksd :E. u vet rttc* rcifisxes.r sc prevent sna ecLssinc si dr'aeme floors lit essssc cf pressribeo sxpos-zr* liadti ior c&osstoiu (&; r* th= nirtfc ttii cf efat Zg artRi isstn,itisc sactc.cing asbestos . v*r rencrsC trss pipes it tbs cyc be at rack fcV.-.-^r nS css ssiagiaa iff elrbcrne fibers. lanwilcttlr S5& Ik 2? CfE l?iC.S^Cuyees tags^ --` sprsnef cf is'ireatcs, eoa. r*ac"-'ti tr dtaalitioo cf pipes, structares, or qs.p- eot csrt-rzi or inrelctei to.tr asoestos. cr tb* rcani ar dadi.tiaa ef asbectc-j ULSclctiao or ttroriiigr verti iiC't pr-cridsc vitc rtscir*- Xarj equipekiet ^c tessrcaiict witc turagrupc [i)(sf tfcit section ana jpeciil clcth-.ng iz aosordancf witb parasrapa. (i)!!) cf *nLs *estioo: ' (o'j lx tht nartr cf tbs 1 tren, iesulitlcn coetslrtLcg aabestos > Rf rtnc*oci free pipe: it tin ever bena rnen allrtonf ta* atlsnan ef drbeme fisers. {i. a 2? CFR 1?:C.'.Wil'.f/i;; ' Initial Boaitcrinf mu act canioettrt iz *ncL s acmar te dr.ert.'.iif wiielher ever? ecplaye*.'* .exposure tc 'oirbense aacxutoc fibers is btiov thA pr-.'semeei licits: (t/ At the- nertt eci cf tec 2area, ix rtrorta iT-gm p^pur ix. tii orir hesa ri e: :mc fiben. D'JP DU 041520 DU 041521 LFH HST lyrT.f! 1 U . B . DEVAJaKi^'i ur i-+ "x ' OSHA Houston North Area Office DOCKET 2320 L&Branch, Rm. 2118 Houston, Texas 77004 (Orax LOCATION: SABINE RIVER WORKS (PPiR| Tx. ________ E. I. 'DU"P0NT DE NEMOURS & CO. Legal Department Labor Law Division____ Case No. qshrC DOCKET NO. 785871 SH* Ao' H4681 9 Ragion 6 Area 3280 Department: r. m. Shepherd, PPSR, D-12014, x-46360 Issue: Alleges caution was not maintained during work with asbestos fibers in places of employment and collection and disposal of the fibers. Representative: Gerald A. 3aty Area Director Address : see above Department Representative HASTINGS S. TRIGG, JR. Date Progress 11/6/78 Citation and Notification of Penalty issued of 1 serious violation with a penalty of 3560.00. 12/4/75 Notice of Intent to Contest :tailed. li/14/73 12/20/78 Notice of -.ecuitt of lass ur.d Docket ;o. assigned. MOTION For extension of Ti::.e to File Complaint filed by Barbara G. Nupuig, O8NRC, requesting additional 30 days. 12/28/73 Notice of Receipt of Case posted and card mailed to OSHRC. 1/1/79 1/19/79 Motion For Extension of Time to File Complaint granted by Ray H. Darling, Jr., Executive Secretary to January 25, 1 Proposed Settlement Agraement received for approval and j signature plus payment of penalty of $560.00. 1/26/79 1/29/79 2/1/79 3/30/79 j Approved and signed Agreement mailed to Reg.Solicitor, US DC j Penalty check mailed to Reg. Solicitor, j Agreement transmitted to OsH Executive Secretary. I Order and Notice of Decision approving Settlement Agreement 4/30/79 Order becomes final 5/18/79 Case Closed DU 041522 DL'P 0961352.001 LFH U. S . DEPARTMENT OS* LP-^'R HST OSHA Houston North. Axe* Office DOCKET 2320 LaBraneh, Ra. 2113 Houston,' Texas 77004 (Orai LOCATION: SABINE RIVER WORKS (PP4RJ Tx. E. DU PONT DE NEMOURS & CO. Legal Department Labor Law Division Case No. qsHRC DOCKET NO. 735371 OSHA No. H4631 9 Region 6 Area 3230 Department: R. M. Shepherd, PPS.R, D-12014 , x-46360 Issue: Alleges caution was not maintained during work with asbestos fibers in places of employment and collection and disposal of the fibers. Representative: Gerald A. 3aty Area Director Address : see above Department Representative: HASTINGS S. TRIGG, JR. Date Progress 11/6/73 Citation and Notification of Penalty issued of 1 serious violation with a penalty of $560.30. 12/4/73 .Tories or Ir.trr.t to Contest -.tailad. li/11/7 3 12/13/73 : ..'otice c: Recoils or Case jcci.ec.`o. -assigned. I MOTION "or Ixtar.sicr. of 7i::.e to "lie Complaint filed by 3arrara G. Jeptig MS NEC, r ague sting additional 33 days. 12/23/73 1/1/79 1/19/79 , Notice of Receipt of. Case posted and carl tailed to OSHAC. Ji Motion For Extension of Tine to File Complaint granted i by Ray H. Darling, Jr., Executive Secretary to January 15, Proposed Settlement Agreement received for approval and signature plus payment of penalty of $560.30. 1/26/79 1/29/79 2/1/79 Approved and signed Agreement mailed to Reg.Solicitor, US L> Penalty check mailed to Reg. Solicitor. Agreement transmitted to OSH Executive Secretary. 3/30/79 Order and Notice of Decision approving Settlement Agreement 4/30/79 Order becomes final 5/13/79 Case Closed DU 041523