Document DD4oDQ8M5RrJe4ax8Q4qRq5Dd

NATIONAL PETROL i INERS ASSOCIATION SUITE lOOO ta L STREET. N.W. A REFINERY'S ASBESTOS CONTROL AND REMOVAL PROGRAM By Thomas E. Megison Occupational Health Supervisor Tenneco Oil Company, Chalmette, Louisiana Presented at the 1988 NPRA FIRE & ACCIDENT PREVENTION CONFERENCE September 29-30, 1988 Four Seasons Hotel, Houston Center Houston, Texas LAM 026782 ABS-056913 This paper has been reproduced for the author or authors as a courtesy by the National Petroleum Refiners Association. Publication of this paper does not signify that the contents necessarily reflect the opinions of the NPRA, its officers, directors, members, or staff. NPRA claims no copyright in this work. Requests for authorization to quote or use the contents should be addressed directly to the author(s). LAM 026783 ABS-056914 NPRA PRESENTATION A REFINERY'S ASBESTOS CONTROL AND REMOVAL PROGRAM The original Tenneco Oil Company refinery in Chalmette, Louisiana was constructed about the time of W.W.I. and was known as the Chalmette Petroleum Corporation. In 1944, Bay Petroleum * Corporation purchased the refinery after it had been rebuilt and in 1955 it was purchased by the Tennessee Gas and Transmission Corporation. Refinery Slides At this time, it's throughput was approximately 18,000 bbls/day. Since then, we have gone through several expansions and today our crude throughout is between 140,000 - 150,000 bbls/day and will soon reach 165,000 - 170,000. The refinery has 650 employees with a salaried to hourly rate ratio of about 1:1. Of the 350 l hourly employees, the refinery has five (5) insulators and each is assigned a certain geographic area within the refinery. So, we LAM 026784 ABS-056915 know that portions of the refinery may be 75 years old - and we know that we have asbestos, so let's review our insulation removal program and how we deal with it on a daily basis. Before we begin, I would like to give you a brief outline on what is involved with our program and what we will cover this morning. First - is our in-house procedure; which involves our Safety Work Order system, the Identification of samples, our Training program, the equipment used, the removal of insulation itself, our medical surveillance and the disposal of our hazardous waste. We will also review what is involved with Special Projects, where we may use contractors to do the removal and the process in selecting these contractors. We will also review Tenneco's long range projects - complete asbestos abatement. Since most of you are from the refining industry, there is no need in rehashing Federal regulations since most of us devote a UM 026785 ABS-056916 5 major portion of our jobs to interpreting and implementing programs because of them. Whether your facility has corporate guidance or not - it's your facilities responsibility to have a program that is indigenous to it's work practices "and Local, State L Federal regulations. So, whether your employees do all the insulation removal, or have it completely contracted out, or, as in our case, a little of both - it is verv important to have a procedure that is workable and that is maintained. Procedure Slide fNon-specific - no explanation necessary] At Tenneco, we have a procedure which encompasses a variety of parameters, i.e, definitions, job classification responsibilities, who must be notified for routine or non-routine insulation removal, identification of the insulation itself, work practices, LAM 026786 ABS-056917 4- classes of respiratory protection and other (PPE) personal protective equipment, disposal of the hazardous waste, medical surveillance and training, to name a 1'ew. Our procedure also involves a number of departments, such as, the Industrial Hygiene section, the Environmental Dept., the Maintenance Coordinator, the Maint. Foreman, the Operations Department and the insulator himself. And, since this procedure affects all of the aforementioned work groups - they were all involved in developing the procedure. \ In conjunction with this, and all of our procedures, we use a Safety Work Permit system, which I am sure most of you have a similar type system. [Safety Work Permit Slide] LAM 026787 [I know there are many versions of a Safety Work Permit.] [This is a sample of our W.O. Permit used for all] [maintenance work within the refinery. ] ABS-05S918 When a Safety Work Permit is generated, it goes through a series of validations and priorities. So, if a Safety Work Permit is issued from an area that was built prior to 1977, and in any way involves insulation removal, then a sample 'is taken. These areas are considered asbestos containing areas and there is a high probability that any work which disturbs the insulation may result in unnecessary exposure. Therefore, approximately 50% of the work orders generated in these areas may involve insulation removal. LAM 026788 ABS-056919 Alright, wo have discussed how a maintenance person may get to the point of having to take a sample. Now let's review exactly what that entails. [Sample Slide f1. Empty bag ] 1 [2. Various types of samples] We emphasize in our orientation and subsequent training that samples should be taken with caution. However, insulators are not the only employees that bring me samples. I get samples from weLders, pipefitters, laborers and foremen. We stress that the samples should be taken in these small plastic bags and that they LAM 026789 ABS-056920 7 should be no larger than 1 inch square. However, I have received samples as large -as a baseball that are wrapped in a rag - and sometimes they bring the flashing or covering with it. Sometimes it is difficult for the dispersion oils to behave the way they should if the sample is wet, although that is probably the best way to take it. When I receive the sample I usually start asking questions; e.g. which unit did it come from? (This is usually a dead give-away). What type of work does the Safety Work Permit call for? What did the flashing look like? Was it banded or screwed? Was it corrugated or flat? I usually take the permit and hold it until I have had time to examine the sample. Once the sample has been identified, then the Safety Work Permit is stamped as to the results of the examination. [Stamped W.O. Permit Slides] [Asbestos - non-asbestos ] LAM 026790 ABS-056921 Unfortunately, not every job goes according to plan. Ninety eight percent of the _ time insulation samples are taken, identified, and the job goes accordingly. However, there was one occasion that comes to mind where the job was scoped out - a sample taken - and it proved to be negative. So the piping was cut out as planned knowing the insulation was not asbestos. The following day, the job scope changed; as had the work crew. Somewhere along the line, It was decided to remove more piping than originally planned. This crew was told that a sample was taken and that it was negative. So they proceeded accordingly. The following day, by chance, another insulation sample was taken on the piping that had already been cut out - and it was positive. The change in job scope had not considered that the insulation may have changed on the same length of pipe. So, samples are important and should represent the extent of the work being done. LAM 026791 ABS-056922 f Once a sample, or multiple samples is received, it is first observed under a stereoscope where the morphology of the insulation is examined. Stereo Microscope Slide I This scope is strictly for gross morphology identification.] (It is at this scope that I make my slides for a more ] [qualitative identification. If you will notice the box ] [behind this scope - it is an axial fan pulling a vacuum ] [through a 12 x 12 HEPA filter. I picked up this design ] lwhile I was at McCrone Research Lab in Chicago. ] Here slides are made using one, to several, dispersion oils. They are then examined using PLM (Polarized Light Microscopy). This technique usually confirms whether the sample is asbestos or not (positive) or (negative) and usually the type of asbestos. LAM 026792 ABS-056923 ro It actually takes less than 15 minutes to make a determina tion. Where as, should you have to send out your bulk samples for a determination, it may take from one-to-three days. Logistically, I have been put into situations where that would not be acceptable. I might also mention that, once upon a time, we used a chemical - color comparison kits and still had to make an experienced guess as to the results. For non-scheduled insulation removal, without the availability of sample determination, the insulation is automatically considered asbestos and handled according to our procedure. Once the sample is identified, it's location and other pertinent information is documented. And, as I mentioned earlier, the Safety Work Order is stamped and the Maint. Foreman is notified of the results. If the sample was taken because of piping work, then usually the insulation is removed so the job can proceed. If the sample was taken strictly because of LAM 026793 ABS-056924 H an insulation problem, then a decision can be made to either go ahead with the job or to postpone it. Should we decide to go ahead with the insulation removal, then the particulars of the job are discussed with the insulator, his helper and the maintenance foreman. Some of the considerations in making that decisions are: (1) the possibility of taking the system out of service, (2) the temperature of the line of vessel, (3) the amount of insulation involved, (1) whether to use glove bags or to enclose the vessel or lines, (5) what special equipment needed, etc. Should we decide to postpone the removal because it entails more than a couple of cubic yards, then any damaged insulation or flashing is encapsulated with a mastic compound. Or, it is - temporarily wrapped until the job can be rescheduled. Since this particular job may not reappear for weeks or months, then the piping or vessel is labeled according to it's insulation properties. LAM 026794 ABS-056925 Sticker Slide [We use two different stickers at the refinery, the ] [asbestos sticker is yellow and blue sticker is for ] [non-asbestos. The only problem is - when you run out ] I yellow asbestos stickers - our insulators improvise ] I pretty well. 1 This proves beneficial for future work in the same area both for maintenance and operations. . Originally. when Tenneco brought in "certified and qualified" contractors with the change in CFR 1910 and AHERA, our insulators developed a case of the "job jitters". The contractors were suddenly qualified to remove asbestos, had state of the art equipment, new techniques, and our insulators felt deprived. LAM 026795 ABS-056926 U Even though they had been removing insulation tor years according to industry standards. So, Tenneco stepped up it's training program sooner than anticipated. However, it wasn't jut training that had to be done. Equipment Slides I Glove bags; vertical & horizontal sprayers, trowels, snipsi [bone saw, coveralls, hood, booties, vacuum cleaner duct 1 [tape, surfactant, mastic compound stickers. ] The warehouse. not only has to stock disposal bags, barricade tape, signs and visqueen, but suddenly found itself inundated with vertical and horizontal bags, surfactants and mastic compounds, etc. Each one of our insulators had to increase his personal tools to include sprayers, bone saws and the like. LAM 026796 ABS-056927 We make it a point to monitor our employees to ensure this equipment is used properly, and that the current techniques are adhered to where feasible. Not only does Tenneco include asbestos in our annual Haz. Com. training program for* all employees, but our insulators and their heLpers get annual training specifically on the removal of asbestos. This training session may go from '1 to 8 hours and is usually a very enlightening session. During the session we discuss the standard itself and what or where they have found problems with our internal procedure. We review the latest equipment on the market and problems they may have encountered in doing asbestos removal within the refinery. We will also discuss what homemade tools one area may have come up with which aids in certain difficult removal jobs. All in all, this proves to be a very worthwhile information exchange where ideas, as well as, frustrations can be vented. LAM 026797 ABS-056928 (5) ADVF Slide [Asbestos Disposal Verification Form! [According to state law - we have an] [annual ADVF for routine maintenance! [removal, but must submit a separate| [ADVF form for major jobs 1 'S As I previously mentioned, if the job is more than routine, or greater than 1 yd3, then a separate ADVF (Asbestos Disposal Verification Form) must be completed. This is a State Regulation, as well as, Tenneco's. Tenneco's Maint. Coordinator will notify our refinery Environmental department representative (rep) with the specifics of the job, (quantity and date). This should be done LO days prior the to job which may also require additional disposal containers. This will also have to be coordinated through the Environmental Dept. LAM 026798 ABS-056929 Gondola Slides (The refinery has one hazardous waste gondola] [specifically assigned to asbestos waste. ]~ I might also mention that Tenneco has only one disposal contractor. Since this hazardous waste is ours wherever it goes, we feel it is best limiting the number of parties involved. Our Environmental dept, personnel periodically visit the landfill site to inspect our hazardous waste cell locations. We consider the ADVF and the proper disposal of our hazardous waste to be just as much a priority as. minimizing personnel exposure. UT Slides LAM 026799 ABS-056930 (Various slides showing u.t. cuts - just describe.| // I would like to ask - how many of you know why those sections of insulation are cut out - what are they used for? These are cut out by a contractor to do our ultrasonic testing for metal thickness. When our procedures changed with the regulations - so did theirs. We had to draw up specific guidelines governing how we expected them to safely limit their exposure, as well as, our employees. They usually work in pairs; one of the two is dressed in disposable clothing, wears a respirator, cuts out the sample, places it into an approved bag, and applies a mastic coat on the perimeter of the square. This is done for all new- U.T. sample points in the older units. On existing U.T. sample points in areas that have asbestos insulation, it is the contractors responsibility to apply a mastic coat prior to taking a U.T. LAM 026800 ABS-056931 is reading on the line or vessel. This again is one method of reducing all of the potential areas of exposure. Of course our procedure includes all of the required medical surveillance protocol t for all of our insulators and their helpers. And this includes: the medical and and work history questionnaire i a physical exam with emphasis on the respiratory cardiovascular and digestive systems, the respiratory disease questionnaire, a chest x-ray in accordance with Table 2 and pulmonary function tests. In conjunction with this portion of our program, is our employee respirator policy. Our insulators and helpers are fit tested semi-annually and otherwise our program complies with the prescribed regulations. Very briefly I will mention our personnel monitoring program for asbestos exposure. When we are informed of an upcoming job, via a sample, we make arrangements with the Foreman as to exactly LAM 026801 ABS-056932 1? when the job is scheduled. At that time, we take breathing zone samples on the insulator and helper for the duration of the job. Where contractors are involved in asbestos removal, we require copies of their monitoring results at the job site and periodically monitor them ourselves. All right, we have discussed routine - and some not so routine insulation removal, based on our in-house procedure. This involves the initial W.O., the identification, the equipment needed, our training program, some removal techniques and medical surveillance. Now, let's look at what is involved with larger. planned jobs. Initially, when contractors are sought - or should I say, when they find you - there must be a means of sifting through all the qualifications, references, programs, and types of insurance they possess. Don't take me wrong - there are good, Qualified contractors out there that do a very good job. However, there are also contractors that have been in the abatement LAM 026802 ABS-056933 2 business only since AHERA, and suddenly, are also the best industrial abatement contractors. So, although it may not be the most exciting part of your job, a contractor's qualifications must be examined. Tenneco interviewed several contractors and reviewed their qualifications, such as: (1) How much experience they have in working in industrial settings and; (2) are they familiar with the equipment and hazards, (3) do they erect their own scaffolding? (1) What is their safety record? (5) What type of insurance do they have? (6) Do they have ample manpower to complete a job in specified time period and can they work more than eight hours/day? (7) Because of the high manpower turnover, what is the experience of the crew that will work the job? .(8) What about their Decon unit? (9) Is there a problem with us examining and having copies of the monitoring data. Picking the most qualified contractor is not a decision I make by myself. It is a joint decision with our refinery Environmental section and LAM 026803 ABS-056934 the Area Maintenance Superintendent. The contractors we felt best qualified were given the opportunity to submit bids. We meet with the contractor prior to any planned job, and express our concerns, what the conditions will be and what we envision to be a satisfactory approach to a safe and emission free job. All the cards are Laid front - everyone knows what to expect - including the cost of the job. If there isn't this clear understanding of what is expected - don't be surprised if your enclosure looks like the Tajmahal, or, that it is too inadequate and generates problems as soon as the job starts. Also, these planned jobs usually afford ample time for your s' ADVF notification, as well as arranging extra hazardous waste containers, if needed. Coordination with operations may prove it feasible to take that portion of the unit out of service for the duration of the job. However, as most of you know, this is not LAM 026804 ABS-056935 always the case. 2Z # There are portions of a refinery that are too hot (lines of structures) to do insulation removal while in service. #3 Ref. Htr. Slides .- - [Look at the lines exiting the reactors and heaters] We recently had a TAR on the #3 Reformer and the first week of the TAR on the heater was spent removing the insulation from lines under the heaters and associated piping exiting the heaters going to the reactors. However, everything had to cool sufficiently, which took a whole weekend. So, although scaffolding was erected, much of the enclosure had to wait until the temperatures had dropped. Those of you that have been involved with TARs know of the pain involved when a unit is down - and it appears nothing is being done. LAM 026805 ABS-056936 23 With the aid of computers, turnarounds are pianned and scoped out with far more precision than in the past. When feasible, all anticipated insulation removal is done prior to the TAR. Once the refinery fills up with 500 - 1,500 additionaT pipefitters and boiler makers, a controlled insulation removal task becomes un-manageable. In contractor orientation - we stress that any unauthorized insulation removal may cost them their jobs. We've admitted we have asbestos and we try to deal with it and it's problems almost every day. Unfortunately, you still have to deal with it when the unexpected happens. Those of you in refining [Crude Unit Slide] have hud to deal with fires and sometimes they occur in units containing asbestos. So., you are suddenly faced with an unexpected shutdown and because of the immediate abatement work LAM 026806 ABS-056937 needed your downtime is extended, and your cost escalated. With this in mind, Tenneco has made several important decisions: (1) decision was made back in 1977 and that we would no longer insulate with asbestos containing materials. (2) In 4986, the decision was made to revise refinery specifications on gasketing material - to find alternatives where possible. (3) And third, in 1987, to conduct a survey to identify the areas and quantity of asbestos in the refinery and to have it removed. The first decision was easily solved. The other two goals will take several years and cost millions of dollar. It is Tenneco's view that it is in our best interest to irradicate asbestos from the refinery in a deliberate fashion. We began this project by calling in an independent CIH to do the sampling of all the areas in the refinery. LAM 026807 ABS-056938 2 We divided the complex into 22 areas - l-l of which contain a certain amount of 'asbestos. Two of these units are inactive and are scheduled for demolition - which will be handled under a separate project. The CIH survey consisted of approximately 10 samples per unit/area. If the majority of the samples were positive - then that unit (area) was considered one to be abated. We also had a separate contractor/consultant come in and estimate the quantity of insulation in one particular unit. Based on the size of this unit, by comparison, we can qualitatively estimate the cost and time needed for all the other units. Once the survey is completed, and the areas designated, then the decision will be made, as to how fast we proceed (how many workers/area and/or do we abate more than one area at a time). Since this project will take several years, we felt it best to consult the projected TAR schedule or unit outages for the next year or two and any other scheduled projects to assist us in assigning unit priorities. LAM 026808 ABS-056939 In conclusion, our asbestos removal program is probably very similar to most of yours.' It must encompass the mandatory sections of the regulations, but also be a program that is a workable one, and that means including all of the involved departments in its development. We use abatement contractors in conjunction with our own insulators, so our program must be a synergistic one. Our program has management commitment - without that - a good program will always have problem. EM-17-88 laM 026809 ABS-056940