Document K6jyvNRv8KRQZEMq0NaKYB830

cc: Mr. C. A. Causey ETHYL CORPORATIONT Mr. L. R. Parker INTER-OFFICE To Mr. H. O. Bourque Address From R. E. Conrad Subject Tank Car Repair and Painting Facilities Address Date January 29, 1973 As you know, the facilities have been considered inadequate to do the best job for some period of time. The proximity of the PVC Plant and its bad dust condition has aggravated an already poor situation. One recent problem has been the greatly expanded solvent car cleaning activity. As if there were not enough problems, the consideration of possible OSHA requirements is necessary. The following information will only attempt to hit the high spots. Each point made has much detail associated with it and may be later discussed in as great a detail as is felt necessary. 1. There is not enough space to most economically perform tank car repair, painting and cleaning (cleaning of non-fluid cars). 2. The lighting is grossly inadequate. 3. The drying facilities for solvent cars are very poor. Various possibilities for correcting the problems are available. The most recent attempt to provide more space by separating the repair and painting operations was several years ago and was estimated at above $300, 000. Historically every effort to consider painting off the plant has revealed that we have been able, under the conditions existing at the time, to do the painting on the plant much more economically. Deliberations have never got to the stage necessary to consider the labor relations aspect of doing painting elsewhere. No serious attempt has been made to upgrade either the lighting or the drying facilities. We "get along" with them and have not been able to justify the expenditure necessary to correct the problems. ETH00003646 2- - About three years ago an insurance inspector raised the question about whether facilities should meet the National Electric Code requirements for a painting area. There was and is no question whatsoever about the fact that the area does not meet the NEC requirements for a paint shop. There was and is a real question about whether the area must be considered a paint shop. At that time the enforcing authority for the NEC was the Ethyl Corporation. Our engineering group was contacted since they are the group which initially sets area electrical classification. Their recommendation was that the area indeed be classified as paint shop. This recommendation was questioned and a request made for a meeting in the actual area to discuss the classification. This was done and the recommendation was not changed. If it had been decided to strictly adhere to Class 1, Division II rules, there would have been several major problems to overcome: 1. Lighting and receptacles would not comply. 2. Heaters used for winter decal application could not be used. 3. Burning and welding could not be done at the time any painting was in progress. There were several reasons why immediate steps were not taken to comply with Class \ Division II requirements. 1. As previously stated, the Company was the enforcing authority for compliance with the NEC. 2. There still exists a difference of opinion on the genuine necessity for the Class I, Division II classification. 3. Compliance would have cost considerable amounts of money. The entrance of OSHA into the picture further compounds the problem in that the NEC becomes an OSHA regulation and the enforcing authority for compliance becomes the U. S. government rather than Ethyl Corporation. Before proceeding it should be pointed out that to the best of anyone's knowledge there has only been one serious incident due to the repair and paint function being in the same building. In 1969 there was a fire due to welding sparks falling into a paint solvents' drum and two major injuries occurred. The cause of this accident was improper storage of solvent and this has been and still is corrected. The accident had nothing to do with the fact that painting per se was being done in an area where welding was in progress. There is considerable sentiment that from a practical standpoint, with the open building, there is no significant hazard with our present method of operation. ETH00003647 -3- However, if it is decided that with dual occupancy the area must he classified as Class I, Division II and this classification complied with there seems to he two possible courses of action: 1, Spend the money necessary to make the area meet the requirements. This would be in excess of $100, 000 and would further compound the problem of inadequate space. 2. Do the painting off the Plant. The last comparison of on-plant versus off-plant painting was in 1966. Using those figures on the volume we will do in 1972 indicates a penalty of at least $40, 000 for off-plant painting (excluding the cost of additional cars which may be necessary). Obviously this figure is not accurate but indicates a range of magnitude. There is also the possibility of considerable labor relations difficulty with a decision to do the work off-plant-. Another course of action -building of another paint facility - -is not being seriously considered because of the probable cost. If, for whatever reasons, neither of the above alternates is acceptable a new set of problems exist. If it is decided that the facilities are not going to be made to conform to Class I, Division II specifications, a decision will be needed on how to proceed. This may prove difficult since it will not be as simple as to say "follow the NEC", but will require an objective decision on what is really needed to make the facility as safe as is reasonably possible to operate. In addition, such a decision might at some time in the future have to be defended to the U. S. government. Several proposals have been made on part way measures. One such is to spray paint on "B" shift and do brush painting and repair work on "A" shift. "While this is a possibility, it would cost $10, 000-$20, 000 for better lighting, require additional supervision, and really not solve the basic problem which at this point seems to be a legal one. I would suggest that Safety department and the Paint group, and the H-C maintenance group acting jointly look in detail at the present operation to see what, if anything, may need to be done to assure safe operation from a practical standpoint. This recommendation can be reviewed, implemented, modified, etc. as is deemed necessary. RECipmk R. E. Conrad ETH00003648 Ovi'-Cee"/--. ' h'-vivK*..D.vt-iv' i nr in\ (, or 70 tp, bir-C'-ltr, v.'i!'.rc.v u>> , Ml' }-!Ur.l vcr.tHr.-s SI 05- cists : Cl'llbLiwacfovy n )oc?.'in,." ; hot mecni .cut. i (e), <b>, H) recast* out eetipp'.ncnt fli tted if i?ia which is ssuro with <. YenttlaUminrted ml. JvSft'siirs shall be ed prow 'd leakage escape of lids. Spills > shall be movement protection ?ar on tny ,nt. 'mhuslibie a c, buildkept to a stal waste =& around > shall be trash, or ants, and :s. Flam- ' shall be >r in portstalled la )> of this - of flRJJi- in tens m process ance with ) of this lips' hfimliall be in if) (4) of sure uespressure icord&nce e Vessels, ,nd Pres- nstructedr Unlived I of the el Coda-- Process they are ,e for the /' KULCS AMD RI CW'.YISS-'S i! 1910.107 22187 r>j-pc-35 oi Art ecntrol. Where two-- used & -i.iit.'fces for Floors. The floor surtecs of a sjirny (jrr.pb.ie&i w.i surl* tbs'- i'u'U'- epertSKris. broth r-'.c opeiaio.-;. v.cG'l'.'.g area, if r-l.-'f-l-c w: t-cM-'.j .v.!>:2 ikqilc.' ..or? :;) Sfioyitl-. arei:.ir m-,.i in vhieii c--;i:bi' fiiblc, sh: h be covertu with non- from f. nro.'."'-.-'-'? i u-n :m ? : t:< cor.f.'Udo ci iin?.'.'YCi- j;combi-'Able ruacxri"i of such character a fire Li..an; V- r'n'~.:iy of of;:.- i, i ro- ! Iccr-'or rnlrng or co;rb"j;-;'cha.s, JUs; io fi.riiiUte the sate cic r.n.g and re- vsi.'iii: i,r:i ;<? imv.'e 1C f.ivcri r-~ }/,.: ,r ' hosts, or iff (re to ilic IJmov.V. oi ;%f/i<ues. t;,r. now ii, r.ujri-;., Citetes, OI elhiv suit- (4) Ditiul-vUon o; hai.lr: plates. Dis ft1,0c iVivr%13 T-. (?.i Sp-..:) booi.i. j.o'VM-VLP'halcd tribution or bails jOsi'cs, if installed to l ire eo.it;'.-:7--(!) f-'orf-ble ry.'.ip- sl-ociure provid'd to enclose or t.ccom- premoif an even flow ts r.ir threugh the sKW-f. Porh'.Vr. lire rttir.'/.iishr-.O'ii- f.t-.'l mc.if.ta a s;...r.;i'i'r fi-emth/V. to cr'h'ic boot.'! cause the r;.-.:c>sit cf overspray ccsilvoi eo'ib it/o- r'-ali !.:. in ai:o.limit t!:; i- '>'>; <: i-or, and heroes it erlesr, the ox! nixf duct, 5i;.'b qu.v.itit'r;- ,) iype:< i s S`OS-i.e.1 residve, ami i-j .'-..ttly io-ium ' w direct be id r.oueomb'riiiblc ami read for til-2 s.Ofvhfl hc.'.-'ic's of opc-ir.;:.j'5 ops' them to r.:> t--'s':*us'. system. ily removable or acc'.-r-rible on both sides ntorsf.e. f<! Wciv.-prh :;-ro'J ~,:r.Lh. A spray for r'l/iiins. Such pi-:h. ? ri'r-U not be. Gil V-'ui:r r.i-;,. Y.'s.ter sr.'-iiil;;; wwl- iionih c;.uj>.ncd v;ii' A v.;',.icr wishing Ice. .Iso in cxhv.ur.t duet.'.. r-b'c in tohimi: r (n J.nvjiy cv rv r.dequ.'-le .Mm fyrtom iVsi-iucd to riirmnii' c rsts cr res- (CO Fry type ovorsyray coitectors -- ''Sir's. )>i.r idrs-; ri'Gjr'n .- c.vV.,- ...u d> m, .-.no io per (c.rfixiis: dr Alters). 3r. convcmional diy du,'!::; oav:it;\'.ft!:':, nutemaiiv :m!v.!c:i.i5, mit ilio wf.-v.;"' of c-vvrp:v;y finishing type spray booths, overs jrry ory filters r.v v.'ttsr .-.f-rf.:' s:f.:i t..e heni is pif.ieria!. or fiitc.'' .''oils, ii installed, shall conform indies ied by the special h\7>--ii',:- of (5; T)rr sp.-u;,' booth, h rrjrny booth to the following: operation end. etor.'.-.-e. not .qin'.'-v;p.'i v.vth a v; w.'.'ihing sys (i) Tho spraying o, evcfions except ' (ni) Spichi! rprcii-! I'.ii.i- tem AS c.-ieiii-ci". it; :i',i.-p.Gf.rr.'.;.;i (3; of clsctroshiik spraying cpt-ialioms shall be piAshing cquipo'e.:'. u>ch as tl.-ei v'.i'.iiins this parf-'.:ri'i.h. A. dry rprey kodh may so designed, installed on-:i maintained fofi.ir., inert km. or dry cbeir.;;;,! shell !;? cquipprd v.itii (i) alstriir.aion or baf that the average air veioeily over the be provided as the need is i by fle plates io ii-oniot" an w en n'ow of air open face cf the boo!:.- (or booth cross til? rpccis! hazards of cpcvr.tior. and through the boot!: or cause fhe deposit section during .`.preying c-peratioiis) shall storage*. oi overture:.' brfore it e::ros i.'ie exhaust be not loss than 103 linear feet per min (j) Scope. Tri\", section r.r.p'ies !-:> ths duct; or (ii) ovei.- pr; y dry filters to min ute. Electrostatic spraying operations handling, storsjsc. and use of haiuniaUc- imwe dust." or (iu) uvcrspiey dry filters may be conducted with an air velocity ftnd combustible huuids with a fisob to rninin.iae dusts or rosioucs entering over the open face of the booth of not. point below 203' V. This section does not exhaust ducts; or overenray dry Al less than 60 lineer feet per minute, or apply to: ter rolls df-sifnsd to tninimicc dusts or more, depending on the volume- cf the (1) Bulk transportation of flammable residues entering exhaust ducts; or fv) finishing material being applied and its and combustible lieoils; where dry powders are ir-c-lng sprayed, flammability and explosion characteris (2) S!.on;cc, handlinc, and use of fuel with powder collection systems so ar tic!;. Visible gauges or audible almm or oil tanks and containers connected with ranged in trip exhaust to capture over- pressure activated devices shni! be in oil burning equipment; sprayed material. stalled to indicate or insure that the re (3; Stoiaee of fitunmable and com- (6) Fluidized bed. A container holding quired air velocity is maintained. Dry busillile liquids on farms; (4) Liquids without flashpoints that may be iisrnniohje under some condi tions. such as certain iiRlogenaicy hydro carbon; ami mixtures containing haloyena if-.'! hydresa'-!>our; powder cooling materiel which is aerated from below ro as to form an eir-supponed expended cloud oi such materia) through which the preheated ob.'cct to be coated is immersea f-.r.d f r.mspcri ed. ('!) Ficriro-dniic fi'.iicUefl i-.si?. A cem- spray booths equipped with a filler roll which is automatically advanced when the r.ir velocity is reduced to that speci fied in this subdivision should be ar ranged to cause shutdown of spraying operatic:" if the filter roil fails to rd- (5) Mists, rp; ays. or foams, except tainer bolding powder caaiii'ig materjai flammable aerosols covered in paragraph which is aerated from below so as to form (d) of this section; or an air-supported expanded cloud of such, (6) Installations made in accordance material which is electrically charged with requirements of the following with o charge opposite to tbs ch-.ige of standards: the objecfc.to.be coated; such object is. <i) National Fire Protection Associa transported through the container im tion Standard for Drycleaning Plants, mediately above the charged and acral ed NFPA No. 32-3.SV0; materials in order to be coated. (ii> National lure Protection Associa tion Standard- for the Manufacture of Organic Coatings, NFPA No. 35-1970; (iii) National Pire Protection Associa tion Standard for Solvent. Extraction Plants, NPPA No. 36-1967; or (iv) National Fire Protection Associa tion Standard for the Installation and (8) Approved. Shall mean approved arid listed by the following nationally recognised testing laboratories: Under writers Laboratories, Inc.; Factory Mu tual Engineering Corp. (9) Lisicd. Sec "approved" in ,5 1910.107 (a) (S). Use of StRt'.y.v.uy Combustion Engines (b) Spray booths--(1) Consf.racticn. EjicCGgs-'j^pincs. NFPA' Ko.-37-1970. Spray booths shall be substantially con 1910.107 Spray finishing using [n^_,..-jHahjcnd voinliasiiiilcinKIcriais. structed of steel not thinner than No. 18 U.S. gauge, securely end rigidly sup ' ported. or of concrete or masonry, except- (a) hefiiP.tiOTtr^p^aiietolhifscc- that nlumhium or other substantial non- vsiiec- auiomelicaily. Maintenance pro cedures should be established to assure replacing filter pads before excessive restriclion to airflow occurs. Filter pegs should be inspected niter each period of use and clogged Alter pads discarded Rnd replaced. Filter rolls shall he inspected to insure proper replacement of filter media. (ii) All discarded filter pads and filter rolls shall be Immediately removed to a safe, evil-detached location cr placed in a water-filled metal container and dis posed of at the close of the dry's opera tion unless maintained completely in water. (iii) The location of filters in a spray booth shall be so as to not reduce the effective booth enclosure of the articles being spiaycd. (!v) Space within the spray booth on the downstream and upstream sides of / lion--<1) Aerated solid poisdcrs. Aerated combusiihle materiel may be used for in -filters shall be protected with approved powders shall mean any powdered ma termittent. or low volume spraying. Spray automatic sprinklers. terial used ss a coating material which booths shall be'designed to sweep air cur (v) Filters or filter xolls shall not be shali be fluidised wit bin a container by rents toward the exhaust, outlet. used when applying a spray material passing air uniformly from below. It is (2) Interiors. The- interior surfaces of know to be highly susceptible to spon common practice to fluidize such ma spray booths shall be smooth and con taneous heating and ignition. terials to form n fluidised powder'bed tinuous without edges and otherwise de (vi) Clean filters or filter rolls shall and then dip the part to be coated into signed to prevent pocketing of residues be noticombustible or of a type having a the bed in r manner similar to that used and facilitate cleaning and washing combustibility not- in excess of class 2 In liquid dipping. Such beds are also without injury. filters as listed by Underwriters' Labora- Wo. 30 No. 32 No. 33 No. 35 No. 36 No. 37 & NO. 33 N0. 33 ETH00003649 "1 22188 H 1910.107 ruies and regulations tories, Ice. Filters and filter mils shall sliai) otherwise be in accordance with; cabinet spray hcoths in which Identical not be alternately used for different types subport S of this part. spray finishing mqicf.'a.) 15 used with a of coating materials, v/here the combi (5) Combustible residues, areas. Un-i combined frontal f.iv* of not mere than nation oi materials may be conducive to less specifically approved for locations 13 squose feet may have r. common ex spontaneous ignition. See also paragraph containing both deposits of rendiiy ignit- haust.. if move than one fin serves one Cg) (6) of this section. able residue and explosive vapors, there; booth, all fans shall be so interconnected (G) Frcnial area. Each spray booth shall be no electrical equipment in any that one fan cannot operate without ail having a frontal area larger than 0 spraying area, vrliereon deposits of com-; fans being operated. square feet shall have a metal deflector bustibie residues may readily accumu (4) Fan-rotating element. The fan- or curtain not less than 2/s inches deep late, except wiring in rigid conduit or in. rotating element shall be nonferrous or installed at the upper outer edge of the boxes or fittings containing no taps, nonsparking or tbs rasing shall consist booth over the opening. ,splices, or terminal connections. cf or be lined with such materiel. There (7) Convenors. Where conveyors are j (6) Wiring type approved. Electrical shall be ample clearance between the (arranged to carry work into or out of wiring and equipment not subject to de fan-rotating element and the fan casing spray booths, the openings therefor shall posits of combustible residues but located to avoid a fire by friction, necessary be as small as practical. in a spraying area as herein defined shall aiieivanec- being made tor ordinary ex (8) Separation of operations. Each be of explosion-proof type approved fer pansion and Icadin.; to prevent contact spray booth shall be separated from Class I, group I) locations and shall between moving parts and the duct or other operations by not less than 3 feet, otherwise conform to tire provisions of fan hollaing. Fan -blade; shall bs mounted or by a greater distance, or by such par subpart S of this part, for Class J, Divi on a siisfi sufficiently heavy to main tition or wul! as to reduce the danger sion 1, Hazardous Locations. Electrical tain perfect alignment even when the from juxtaposition of hazardous opera wiring, motors, and other equipment out blades of the fan are bia-TIy loaded, the tions. See also paragraph (c) (1) of this side of but within twenty (20) feet of any shait preferably to have bearings outside section. spraying area, and not separated there the duct and booth. Ail bearings shall (9) Cleaning. Spray booths shall be so from by partitions, she!' not produce be o.? the self-lubricating type, or lubri installed that all portions are readily sparks under norms! operating condi cated from the outside duct. accessible for cleaning. A clear space of tions and shall otherwise conform to the (j) Electric 'Motors, Electric motors not less than 3 feet on all sides shall be provisions of subpnrt S of this part for driving exhaust fans shall not be placed kept free from storage or combustible Claes I, Division 2 Hazardous Locations.; Inside booths cr ducts. See also para construction. (7) Lamps. Electric lamps outside of, graph (c) of this section. (10) Illumination. When spraying but within twenty (29) feet of any (C) Bells. Kelts shall not enter the areas are illuminated through glass spraying area, and not separated there duct or booth unless tlio belt and pulley panels, or other transparent materials, from by a partition, rhal! be tetchy en within the duct or booth are thoroughly only fixed lighting units shall be used as closed to prevent the falling of hot par enclosed. a source of illumination. Panels shall effectively isolate the spraying area ticles and shall be protected from me chanical injury by suitable guards or by (7) Exhaust ducts. Exhaust ducts shall bo constructed of steel and shall from the area in which the lighting unit location. be substantia iiy supported. Exhaust is located, and shall be of a ncncombus- [ (8) Portable lamps. Portable electric ducts without dampers are preferred; tible material of such a nature or so [lamps shall not be used hi ar:y spraying however, if dampers r.r.-> installed, they protected chat bicakage will bo unlikely. jaren during spraying operations. .Port shall fca maintained to that they will Panels shall he so arranged that norma! able electric lamps, if mid tiering clean be r4 su'd c-rm pcc-llisr, -;.t rfil times accumulations oi residue on the exposed ing or repairing operations, sbail be of the ventilating system is :n operation. surface of the panel will not 1-3 raised the type approved for hazardous Class (i) Exhaust duo.'s siiail be protected to a dangerous temperature by radiation I locations. .against mechanical d.arns-.Lre and have or conduction from the source of (S) Grounding. (!) All metal parts of e. clearance from unprotected combus illumination. spray booths, exhaust duets, sr.d piping tible construction or oilier combustible (c) Electrical and other sources of systems conveying flammable or com material of not less than 13 inches. ignition--(1) Conformance. All electrical bustible liquids or aerated solids shall (ii) If combustible construction Is equipment, open flames and other :be properly electrically grounded In an provided with the fellow* nz protection sources of ignition shall conform to the effective and permanent manner. applied to ail surfaces within 13 inches, requirements as follows: of this paragraph, except t. (ii) "Airless" high-fluid pressure spray Iswns and any conductive object being clearances may be reduced to the dis tances indicated: (i) Electrostatic apparatus shall con sprayed should be properly electrically la) SS-xr.je sheet metal on >/l-inebl2 (aches. form to the requirements of paragraphs grounded. > ml!! board. <h) and <i) of Lius section; (H) Drying, curing, and fusion appa ratus shall conform to the requirements of paragraph <j) of this section; (iii) Automobile undercoating spray operations in garages shall conform to (d) Ventilation--(1) Conformance. Ventilating and exhaust systems shall be in accordance with the Standard for Blower and Exhaust, cyrtems for Vapor Removal, JJFVA So. 01-1961, where ap plicable and shall also conform to the (b) GU-ge.gs sh irt ir-riii on y.-snch Clnrlirs. asbestos nv.',i ir.i'.id cync-fi out 1 Inch cn nc-hcordimtlb'.e spacer.-.. (r) sq-g-aste .'beet jr.crc! oi 1-lncb 3 inches vorkwcl b-'il-s r-.ir-forcsd with . wire mesh c.r Lea equivalent. ;(ci) Where ducts ere protected the requirements of paragraph (It) of provisions oi this .'cation. I with an approved Aiiton-.atlc tethis section. (2) General. All spraying areas shall (iv) Powder coating equipment shall e provided with nicchoificai ventilation ccuXor-rmp-thu' Terruireuients. jjfjoara- tic,junto to remove .dai.-.-nablc- vapors. /graph (1) cf this section. ''mists, or powders to a si. is location and /' (2) fi-r/iiijnxzit scpr/oi. There shafr., to coniine and centre.1 c:-:i>br.stilile re.-i- I ` ; . -j sprinkler lysli-m, properly ,~)hlrfinr;", t:*>> rir-'.^vi'cc iccpilrc-i In sufcd'vM-.n (1) of this sub'o-:r:.y.v.ph may be v-hlv-ced to 3 tarhe.i. ' be no open Kama or spaik producing duc-s so that life or prcperly is not en- 1 <?.) D!sch( r;je clearonce. Unless equipment in any spraying area nor Vianyered. Tyfcshatficol vciVdisi-cn shall pr-ray bcutll cnboxot x'-ri `'rvudra! '* , within 20 feet thereof, unless separated ie kept lu operalir-p at cli tunes nti'lo <f? 3m a v.v'.l-cr-v.VM): jpssy bard'".. ' .' '. by a partition..---;-----,----- ------------ ' Spraying operation-; arc l-r-n;,; conducted :;;o p in; sbei'i ' ' ' " (3)- Hoi surfaces. Space-heating ap ku.d for a sufficient time theraaff-.v to :!e-s chan 5 test Ac:'. .riy ' pliances, stcampipes, or hot .surfaces shall allow vapors from drying ecaic-d articles ic.i-f'Trr -,vxii cr -,uoi t:vr r.i. -'A;'-'' not be locate-! in a sprsying area where am! drying finishing material residue ci'.a ch.-clicn of r.i:v cmebn-tibi*; -' deposits of combustible residues may to he exhausted. ,sti uahn cr ynv.--:''.tvd or'-aime -7 ?., readily accumulate. * (3) Independent sn'.gusi. Each spray- r.or.':-j:v,:'inli!.'!i ...l (4) Wiring conformance. Electrical booth shall have an independent exhaust Sect. wiring and equipment shall conform to duct system OischargiGg to the eerier (9) Air csliousl. Air cxhr'.ist - , the provisions of this paiaginph and of the building, except that multiple spray operation; shall not be a*"1 - TO. 33 NO. 33 NO. 97 NO. 33 ETH00003650