Document DDKmGNNvjjb1x2zromVg9bmEO

PLAINTIFF'S EXHIBIT TJSX-100 Industrial Hygiene Services Environmental Health.......................................... Recognition, Evaluation, Control Survey Report Asbestos Exposure Evaluation USS Chemicals-Neville Island Industrial Hygienist: Date: S. D. Stockton, CIH May 17, 1984 Distibution: G. R. Hanington E. D. Sutilla ^"C. W. Henderson Summary: T. F. Fisher, M.D. W. D. Miller J. J. Schwerha, M.D. Approved by: F. M. Toca, Ph.D., CIH Manager-Industrial Hygiene U S E I0 0 0 0 6 3 Occupation Mechanic Mechanic Pipefitter Pipefitter Mechanic** Mechanic Mechanic Mechanic Mechanic Mechanic Mechanic Mechanic Pipefitter Pipefitter Table 1 Asbestos Exposures Common Example Operations OSS Chemicals Neville Island Plant March, 1984 Total Duration (minutes) 142 142 138 135 15 15 15 15 11 11 103 103 152 150 Eight-Hour TimeWeighted Average Asbestos Exposure (fibers/cc)* 0.56 0.88 0.10 0.10 0.77 0.82 40.01 <0.01 <0.01 0 <0.01 <0.01 0.11 0.05 Description of Operation Removing insulation fran steam heating pipes in office building. Removing insulation for steam pipe removal in plant. Cutting six (6) linear feet of Transite board with a portable power saf. Removing packing from pump and replacing it. Cutting gasket material. ii n Removing insulation fran salt cooler near barge dock. Removing insulation fran pipes near barge dock. ^Eight-hour time weighted average asbestos exposure in fibers per cubic centimeter of air analyzed in accordance with the CSHA 29 CFR 1910.1001 Asbestos Standard. The eight-hour time-weighted average is calculated assuming the employee is ex posed to asbestos for the time shown during the eight-hour workshift. The OSHA permissible exposure limit (PEL) is currently 2 fibers/cc with proposed revision to 0.5 or 0.2 fibers/cc. **During this operation, employee exposure to asbestos, when time-weighted over the entire wrkshift, is well below the current OSHA PEL. The 15 minute peak exposures however are 24.79 and 26.38 fibers/cc, vrell above the 15 minute ceiling value limit of 10 fibers/cc. USEI000064 May 17, 1984 G. R. Hanington Plant Manager USS Chemicals Neville Island Summary and Recommendations On March 5 and 6, 1984 arrangements were made to measure employee exposure to asbestos during maintenance operations which are normally randomly scheduled. These operations were representa tive of normal jobs and, in all cases, were conducted in the usual manner. Employees used all the appropriate protective equipment required by the applicable Safe Job Procedure. The results of this evaluation indicate that removal of well wetted asbestos insulation and the handling of materials contain ing well bound asbestos (gaskets, etc.) does not result in employee eight-hour time-weighted average asbestos exposures above the current Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) of 2 fibers per cubic centimeter of air (2 fibers/cc) nor the proposed OSHA PEL'S of either 0.5 fibers/cc or 0.2 fibers/cc. While the removal of insulation containing asbestos in an office area (not as well wetted) does not expose employees to eight-hour time-weighted average asbestos doses above the current OSHA PEL, such an operation may exceed the proposed OSHA PEL'S. The use of a power saw on Transite board does not result in employee eight-hour time-weighted average asbestos exposures above the OSHA PEL, but does result in employee peak exposures to asbestos of more than double the current OSHA ceiling value of 10 fibers/cc as measured over a 15 minute period. While removing asbestos insulation in office areas, greater care should be taken to thoroughly wet the insulation through the use of a more intense water spray, or by trial use of a 1:5 ethylene glycol and water solution. The area involved should be restricted to allow only the employees removing the asbestos to enter the area to prevent unnecessary exposures. Post removal clean-up should also be improved to prevent re-distribution of dust containing asbestos. Power tools should not be used on any Transite materials, and when ever possible, a substitute for Transite materials should be used. Detailed findings for each operation are contained within the report. USEI000065 May 17, 1984 G. R. Hanington Plant Manager USS Chemicals Neville Island On March 5 and 6, 1984 common maintenance operations were scheduled at the Neville Island Plant for the specific purpose of measuring employee exposure to asbestos during such jobs. Mechanics and pipefitters performed jobs which required handling materials containing asbestos that are representative of normal operations. In all cases, the Neville Island Safe Job Procedure (SJP) for working with asbestos products was adhered to including the use of all the appropriate personal protective equipment. The results of this evaluation follow. Method and Criteria To determine employee exposure to asbestos, breathing zone air samples are collected using a calibrated MSA Monitaire pump and an appropriate filter. The filter is then inspected using 450 magnification on a phase contrast microscope. Asbestos fibers at least five microns (5 >um) in length and three times longer than their diameter (3:1 aspect ratio) are counted and the occupational exposure to asbestos is calculated. The Occupational Safety and Health Administration (OSHA) has established that no employee shall be exposed to an eight-hour time-weighted average (8-hour TWA) asbestos dose of more than 2 fibers per cubic centimeter of air (2 fibers/cc). Further, in any 15 minute period, occupational exposure to asbestos must be limited to 10 fibers/cc (called the ceiling value). It is expected in the near future that OSHA will reduce the permissible exposure limit (PEL) for asbestos to an 8-hour TWA of either 0.5 fibers/cc or 0.2 fibers/cc with a corresponding ceiling value ten times the PEL (5 fibers/cc or 2 fibers/cc). All efforts to control employee exposure to asbestos should be with the recognition that OSHA will reduce these limits in the near future. Recently revised Corporate guidelines for the protection of employees against the hazards of asbestos dust exposure were distributed on April 27, 1984. These guidelines detail the requirements of the OSHA standard and offer methods for compliance. USEI000066 G. R. Hanington USS Chemicals Neville Island Asbestos Evaluation May 17, 1984 Page Two Conclusions and Recommendations The following conclusions and recommendations are based on the results of the air samples collected, data supplied by plant personnel and observations during the survey. The employee exposures to asbestos have been time-weighted averaged for comparison to the OSHA regulations. The survey results are presented in Table 1. Conclusions 1. No significant exposures to asbestos fibers were measured during the asbestos gasket cutting opera tion or during the unpacking and repacking of pumps. 2. The removal of asbestos insulation from process and steam lines in the operating areas (lines -that are exposed to the open atmosphere), and the re moval of asbestos insulation from the old salt cooler (stored near the barge dock) results in eight-hour time-weighted asbestos exposures below the current OSHA permissible exposure limit, and below the pro posed OSHA permissible exposure limits. 3. Removal of asbestos insulation from steam lines in office areas, or in areas where such lines are not exposed to the open environment results in eighthour time-weighted average asbestos exposures below the current OSHA PEL, but this operation can result in employee asbestos exposures in excess of the pro posed OSHA PEL of 0.5 fibers/cc. 4. Evaluation of employee asbestos exposure while cutting Transite with a power saw (total cut of six (6) linear feet) indicates an eight-hour time-weighted average exposure of 0.77 - 0.82 fibers/cc (well below the current OSHA PEL). This operation does however re sult in employee asbestos exposure of more than double the OSHA permissible ceiling limit value of 10 fibers/cc for a 15 minute period. Recommendations 1. The Neville Island SJP for handling materials con taining asbestos, which requires the use of respira tory protection, protective clothing and gloves, and wetting the product prior to removal, provides the maximum practical employee protection available. Continued emphasis of the SJP for all operations in volving materials containing asbestos is essential to prevention of asbestos related disease. USEI000067 G. R. Hanington USS Chemicals Neville Island Asbestos Evaluation May 17, 1984 Page Three 2. When removing asbestos insulation from steam pipes in office areas, the insulation should be more thoroughly wetted. This may be accomplished by using a water fire extinguisher such as was used when re moving the insulation from lines near the barge dock. The insulation should be wetted to the maximum extent possible, even to the point of being "dripping wet". In addition, trial of a 1:5 solution of ethylene glycol and water may better control the releasing of asbestos fibers. To avoid asbestos exposure for employees not involved in the removal procedure, the area involved should be isolated as much as possible and posted as a restricted area. After the insulation has been removed and bagged, all shelves and ledges in the room should be wiped down with a soggy cloth, and the floor carefully wetmopped to control the redistribution of dust contain ing asbestos. Clean-up employees should follow the protective equipment requirements of the asbestos SJP. Care should be taken to avoid tracking dust containing asbestos into other office areas. 3. When changes in buildings require the removal of Transite materials, the whole sheet of material should be removed with as little cutting or breaking as possible. Every effort should be made to avoid the use of any power tools without local exhaust ventila tion on any Transite materials. Whenever possible, Transite materials should be replaced by building materials which do not contain asbestos. USEI000068