Document GmOv7ZRZ5jgxBDwvJnG3rLnNv

PLAINTIFF'S EXHIBIT Texaco DATE: December 13, 1984 TO: Mr. L. E. Perrier Bakersfield, CA FROM: Mr. Robert A. Cox Houston, TX SUBJECT: SAF-INDUSTRIAL HYGIENE BAKERSFIELD PLANT PROGRAM EVALUATION Please refer to our May 29, 1984 memorandum to Refinery Plant Man agers, and the attached recommendations which concern the indus trial hygiene program evaluation conducted at Bakersfield Plant November 26-29, 1984. The review was conducted by Mr. D. J. Slack, Texaco USA-Manufacturing and Mr. J. D. Watts RESD-Safety and In dustrial Hygiene Group. . We appreciate the assistance of your staff, especially Messrs. G. H. Turl and B. D. Freeman in preparing for this effort and providing valuable input for improvement needs. We would also like to acknowledge the assistance provided by RESD in performing these reviews. Improvement needs are provided below for your consideration. These needs have been listed in order of priority. Develop industrial hygiene aspects of the health and safety program by increasing the frequency and type of monitoring of employe exposure to chemical and physical hazards. (See At tachment II) Revise the hearing conservation program so that it is consis tent with regulatory requirements and the Company guideline. * Develop and implement a program to control contractor safety performance (refer to Mr. R. H. Howell's October 1, 1984 mem orandum concerning this subject). The input of health and safety into the various processes of selection, evaluation, and control of contractors is critical to the success of this effort. Revise practices concerning use of respiratory protection, including a means to control exposure of personnel welding in small confined spaces, spot checking bottled breathing air quality, and additional safeguards for control of respirator selection. To avoid inadvertent connection of breathing air equipment to harmful utilities, insure that utility fittings ; WA-TEX 001174 December 13, 1984 Page 2 are incompatible and, whenever.possible, that all nitrogen lines are hard piped and do not have fittings which can be readily changed or modified. ' Provide training to those responsible for recording and re porting information required by the Toxic Substances Control Act (TSCA). Verify that the present program for medical surveillance is consistent with the program prescribed by Mr. R. H. Howell's October 1, 1984 memorandum. Implement a program to periodically evaluate the function of fixed hydrogen sulfide monitors. Implement a program to periodically evaluate laboratory ven tilation hoods. Specific recommendations concerning these program needs are pro vided in the attached computer printouts and were discussed during the survey. These recommendations will be included in the quar terly follow-up of industrial hygiene recommendations. To implement these recommendations and improve the efficiency of the EH&S staff, access of the staff to a personal computer (IBM compatible) would be beneficial. In the near future we intend to survey applications, and will provide those that have been found to be useful. Program improvement needs for this office were also identified during the survey. Develop an industrial hygiene sampling protocol and provide assistance to perform initial sampling. . Coordinate those changes with Legal which concern contractor safety provisions of BKP and LAP contracts. Provide additional guidance and tools to assist refineries in the implementation of contractor safety programs. Forward certain health and safety information and provide additional orientation and assistance. I WA-TEX 001175 Mr. L. E. Perrier December 13, 1984 Page 3 These needs will be prioritized upon completion of all plant sur veys, and objectives will be established to satisfy these needs. DJS :pb 12/11:6 Attachments CVB i m-TEX 001176 ATTACHMENT II 1985 INDUSTRIAL HYGIENE SAMPLING PROTOCOL FOR BKP CRUDE & VACUUM DISTILLATION GAS OIL DESULFURIZER HDS/REFORMER FRACTIONATING SULFUR RECOVERY ` STORAGE/BLENDING WASTE WATER TREATING MAINT. LAB BENZENE/TOHC 4 4 4 2 2 4 2 4 2 so2 2. H^S NI CATALYST 4 2 DJSjpb 12/11:6 WA-TEX 001177 1. Conduct industrial hygiene sampling per the protocol provided. 2. Advise employes, in writing, of the results of all future exposure monitoring. 3. Advise employes, in writing, of hearing loss (OSHA standard threshold shift). 4. Fit employes using only the variable size non-disposable in sert type ear protection. 5. Re-evaluate the plant noise contours and identify high noise areas where ear protection is required. 6. Continue to use the present contract service for analysis of audiometric testing data until the Texaco COMEXED system is operational. 7. Implement a contractor safety program (Re memo RHH to Ref. Plant Mgrs. 10/1/84). 8. Require local exhaust ventilation or supplied-air use when personnel are welding in small confined spaces (i.e. frac tionating tower). 9. Remove the SCBA from the laboratory. 10. Provide a respirator selection chart to the tool room. 11. Routinely check receipt of bottled breathing air lots for oxygen content. 12. Insure that SCBA bottles are filled to the "full" mark. 13. Hard pipe the nitrogen purge line to the muffle heater. 14. Provide TSCA 8(e) & 8(c) training. 15. Contact Mr. Lord (Houston) and advise of status of mandatory medical surveillance program. 16. Calibrate fixed hydrogen sulfide monitors monthly and docu ment same. 17. Check laboratory hood face velocities semi-annually (minimum 125 lfpm)\ DJS:pb 12/11:6 WA-TEX 001178