Document G5JJB3qjqny4448Bob6o3Kr6x

FILE NAME Reynolds Metals RM DATE 1975 July 9 DOC RM013 DOCUMENT DESCRIPTION Internal Inspection Results from March 1974 INTRACOMPANY CORRESPONDENCE 2-98 Rev. 1-68 . - Ou mere FROM FROM GOB H. M. Cole 19 GOB 1 R. H. Featherston- EXO Sherwin R. D. Gamble M. D. Christine COPY S. Kinzey R. B. Newman R. Cline M. R. N. - & Irby Ruth Carson 100 Kibby J. A. EXO B. J. Sasser --1-1 GOB DATE & Williamsy PLAINTIFF'S EXHIBIT 440 Drs MacMill SUBJECT July 9 1975 ee I visited the Sherwin Plant Hygiene sampling recently to map out an Industrial program at the request of Mr. G. L. Mr. Suffredini asked that I write the Suffredini Industrial Hygiene Report of the September 16 1974 parisons can be made Sherwin Plant so that com- with MESA safety standards Enclosed is a Thank you mfj Enclosure Home M. Call H. M. Cole TX TINER RMC0042387 RMC0042387 .. eae mataST, RACOMPANY - 17017 vil H. M. Cole GOB cee ee 4TE a UBJECT G. L. Suffredini - Sherwin Craiz, :: C.C. FeatheH rs. tonBBrraatttt KiMn.zDe.y Ruth Carson H.N. R. M. Kibby Irby Christine Cline R.N. - Sherwin R. B. Newman Drs MacMillan & J. A. Williams - EXO B.J.Sasser a ee ee GOE ee ee es ee en, eee July 26 1974 INDUSTRIAL HYGIENE SURVEY SHERWIN ALUMINA PLANT - MARCH 24 - 29 1974 At the request of plant was made of the Sherwin management an Industrial Alumina Plant March 24 Hygiene Survey Following are the results of that - 29 1974 survey ITEM 1 Asbestos - Asbestos samples collected during the demo- lition of insulating material from several reactor vessels indicate compliance with present MESA guidelines See discussion . ITEM 2 Total Airborne Dust BAD Results of total airborne dust samples collected in the bauxite transfer tunnels and at alumina loading and unloading operations indicate non compliance with MESA regulations Although a good respiratory protection program is in effect in most much needs to be done with areas aspects of the problem regard to the engineering ITEM 3 - Solvent Vapors - Samples to determine solvent collected in the electrical shop at the motor exposure operation and while dip tank plant indicate cleaning oil bulbs throughout the compliance with MESA guidelines in all areas tested ITEM 4 ITEM 5 ITEM 6 - Sodium Hydroxide - Samples to determine were collected in the caustic exposure at the SOP filters hydrate filtration area Fac 46 Fac 35 on top of the percipitators Fac 45 indicate and in the recovery area Fac 230 Results compliance in all areas tested Noise - Noise measurements were made in the ment areas 110 and 111 power depart- on the Kiln Floor area and while calcining dicate that scaling reactor vessels Results in- hearing protection is - be required in all necessary and should scaling operations we Materials Screening Program - In order that Department might better the Medical of evaluate the hazard potential many chemicals used become in our plant locations it has necessafroyr us to implement a materials ing and evaluation program for screen- introduced In order new chemicals as they are I will be in contact that might achieve this purpose with the Purchasing Agent at your pilnafnotrmiantihoonpes of setting up a procedure to obtain this . TX TINER RMC004238A Sherwin Alumina Plant Industrial Hygiene Survey -2- September 16 1974 DISCUSSION ITEM 1 Samples were collected for airborne asbestos while insulation from several reacter vessels Results removing appear in asbestos Table 1 per millileter standard however when exposures are a time weighted basis these values would be considered on within MESA guidelines It should also be significantly lower and involved in the removal of asbestos noted that employees wearing MSA Dust Foe 66 during this sampling were Respirators which have Bureau of Mines approval No. 21B for protection against asbestos and pneumoconeosis producing dust the Therefore this respirator workers involved with adequate respiratory protection other afforded sampling and demolition period during the MESA regulations indicate that respirators shall not be substituted for measures. environmental control developed However when environmental controls have or when necessary by the nature of the not been of asbestos work demolition work for a containing materials in this case an employee may reasonable length of time in concentrations of contaminents above prescribed limits at the time of this It was also airborne indicated to me flow or survey that the plant has on order continuous pressure demand Type C respirators and special grams regarding asbestos exposure which we had outlined earlier date Although MESA regulations at an guidelines on this are not as strict as OSHA matter we at Reynolds recognize the importance of and concern which should be afforded the asbestos problem I might also add that all spraying of discontinued and substitute materials evaluated for performance asbestos insulations has are presently being used been and | In the future we need to improve on and procedures for implement our established handling asbestos containing materials and be that they are put into practice This of sure education program on the part of course requires an workers supervisors as hourly Future everyone as well carried out on at least environmental monitoring should be an annual basis The following job categories should be sampled at that time 1 dCaermpoelnitterisonremo.ving scaffolding after asbestos TX TINER RMC0042389 Sherwin Alumina Plant ' Industrial Hygiene Survey : 3 September 16 1974 ITEM 1 continued 2 3 4 5 Iron workers welding studs onto digester vessels in preparation for new insulation Employees or areas down wind from where asbestos insulation is being removed Employees involved in the installation of preformed asbestos pipe covering Monitoring should also be accomplished on any other job category where an exposure to asbestos exists I should also like to emphasize that a comprehensive medical ex- amination should be provided to employees involved in all where there is an asbestos exposure While this is not a operations MESA re- quirement it is a well established policy within Reynolds Metals Company We at Reynolds are always concerned about the health and well being of each of our employees ITEM 2 Total airborne Results appear dust samples in Table 2 were collected : throughout the . plant Samples for total airborne dust were collected for each job category which involved either bauxite or alumina loading unloading or trans- fer Samples were collected by the personal sampling technique as set forth by NIOSH and OSHA in an attempt to better categorize employ ee exposure for each job classification Personal monitors were worr by employees during their actual work Samplers were worn for up to 4 hours in an attempt to gain a representative sample Results are reported in Table cycle and as time hours 2 as actual exposures obtained during the sampling weighted average exposures extrapolated to eight Facilities and 24 - Results of samples collected in the bauxite unloading and nuisance dust transfer operations indicate compliance with standards I realize that you have an effective MESA res- piratory protection program and employees were wearing approved Bureau of Mines respirators during my visit However this method of control of a hazard is considered a temporary means of control In light of this fact we need to develop documentation that we are looking into the feasibility of controlling this potential problem If process changes or work schedules were altered at time the past which relate to a any- lowering of dust exposures this information should be extracted from past records and brought up to date In addition any proposed engineering changes that might bring about a similar reduction should also be documented In general exposures of this nature up to 12 times the Threshold Limit Value would result in very strong notice from MESA authorities TX TINER RMC0042390 Sherwin Alumina Plant . Industrial Hygiene Survey ITEM 2 continued -4- -4- September 16 1974 involved Also I had two samples of airborne bauxite crystalline determinations These dust run for free silica outside independent laboratories samples were processed by two 0.4 free silica in and results indicate a range of total dust I have discussed this bility with several people within the possi- that anything about % free silica in company and the feeling is considered quite high tend to Jamacian Bauxite would be As a result of these discussions I would question the reliability of results of free silica However it should be greater than 1-2 from other independent labs pointed out that similar analysis analytical method for might turn up comparable results The results determining free silica is quite tedious and are often scattered To better determine this matter I suggest that the our position in samples by personal plant periodically collect air silica After sampling method and process them for free we establish that we do not in fact have a problem Also I think that the information collected here handling operation is typical of information on our bauxite to collect at a later date Annual that we might expect most helpful sampling in this area would be Also we should concern ourselves with collecting respirable dust samples in the future us to separate the This procedure will allow respirable dust from the total dust hopefully provide us with additional to better determine the extent of information that exposure and will allow us the problem if at all fer and loading of this material into dicate compliance with MESA barges guidelines and other vessels inThere is no standard at this point for Aluminum Oxide and it is nuisance dust therefore treated as a as having However fibrogenic more recent information implicates A1203 The Environment and properties A recent updating of Aluminum In corporates several Human Health University of references on this subject Cincinnati In light of inthis material it would be appropriate for us to prior to new standards being developed sample this facility routinely using get our house in order In the future we should to better determine the extent of the respirable sampling equipment respiratory hazard associated TX TINER RMC0042391 RMC0042391 Sherwin Alumina Plant Industrial Hygiene Survey - 5- 5- September 16 1974 Also if there have been any process or administrative this operation in the past or if changes in that would reduce the above engineering changes are planned information should be mentioned employee exposure then such made available and appropriate records kept Facility 51 - Alumina Loading Statements related aspects of the Alumina regarding the health facility however additional co em xm pe onstusre sphrouolbdlebme amlasdoe apply to this this operation regarding . It is my feeling that exposure to aluminum oxide is overly excessive and should not be at this operation safety point of view allowed from a health or I found it difficult to see much less to walk on top of open hopper cars during my visit ITEM 3 Table 3. All measurements and should not indicate compliance with pose any health related problem MESA regulations ITEM 4 Sodium Hydroxide - Samples to determine collected throughout the plant Results caustic exposure were appear in Tabel 4 Pseordsiounmalhydsraomxpildees were collected throughout the plant to determine filters wetted exposure Samples with deionized water were collected on fiber glass and analyzed for both sodium hydroxide and sodium carbonate Results of both bined and all results analysis were com- somewhat lower than appear as sodium hydroxide Results are manifestations of expected but in light of a lack of clinical sodium hydroxide exposure the data appears in Noise - Noise suspected of a measurements were taken noise exposure problem in all areas of Results appear the plant in Table 5 Noise exposure determinations DuPont Audio Dosimeters which were made throughout the plant using the entire work shift integrate the workers Results indicate compliance exposure in all over areas TX TINER RMC0042392 Sherwin Alumina Plant Industrial Hygiene Survey ; -6- -6- -6- September 16 1974 tested except the scaling operations should be pointed out that scaler operators were wearing hearing protection during the sampling However it is difficult to determine the extent of exposure for this job category in that different tanks will require varying times to complete a job Hearing protection should always be worn during this operation and employees should be followed very closely by our Medical Department to insure that employees hearing is being monitored Your plant has done an excellent job taking care of noise related exposures in the past and I'm sure that that performance will continue ITEM 6 Materials Screening Program - The Medical Department is in the procesosf dating its records concerning the raw materials used at each of our plant locations The Threshold Limit Value Committee is quite active developing and setting and updating standards for many of these materials There in the past where chemical substances have have been occasions created considerable problem without prior opportunity by the Medical Department to evaluat thee hazard potential As result it has become necessary for us to reevaluate many of the materials inuuse and implement a materials screening program for new chemicals are introduced In order that we as they as well as might accomplish this purpose would like eventually complying with other Federal Regulations I your support in collecting this information For example information that would would have to do with the different and their make up be most helpful at your plant kinds of protective coatings In order that we might accomplish this purpose it is requested that each your purchasing agents send out a copy of the closed letter with attached Material Safety Data Sheet in en- that we might begin developing this list Whenever order amount of material that is possible the be noted purchased for a given location should In summary I would like to thank you for sideration given to me during my trip to CyooruprushelpIfanId ca tn he becon o- f any further help or answer any questions please don't hesitate to call on me Thank you HMC Enclosures Hair Hair Calc Homer M. Cole TX TINER RMC0042393 TABLE 1 SHERWIN ALUMINA PLANT ASBESTOS SAMPLING STUDY FEBRUARY 19 1974 Sample No. and Description SH W. Enriquez Service Repairman Knocking of asbestos from digester tank 1:30 pm - 1:42 pm SH L. Cadriel Service Repairman Service Repair 1:30 pm - 1:42 pm SH ' SH SH : SH W. Enriquez Service Repairman Clean up of asbestos 1:45 pm - 1:59 pm L. Cadriel Service Repairman Clean up of asbestos 1:45 pm - 1:59 pm W. Enriquez Service Repairman Clean up ) 2:00 pm - 2:20 pm . L. Cadriel Clean up 2:00 pm - 2:20 pm ; SH 2:50 up W. Enriquez Enriquez 2:40 pm - Service 2:50 pm Repairman Clean SH L. Cadriel Clean up 2:40 pm - 2:50 pm SH BLANK Milliliter of Air 0.92 3.18 10.25 2.73 16.73 5.65 3.31 1.50 + * Threshold Limit Value for asbestos fiber - 5 milliliter of air sampled eight weighted average TX TINER RMC0042394