Document LJOwyZr7jrz69zmwGRJ31DdRz

yOZL - I rr<--> O "L- UJiifc H5 01- fhZH-ldS PLAINTIFF'S EXHIBIT SH-2801 JUNE 18, 1979 R. L. BRUNNER Attached is a summary and interpretation of the three preliminary CCU studies at Deer Park, Wood River and Martinez. I basically agree with this summary. Attachment cc - See attached distribution list GEG HMM OPA HEALTH & SAFETY OPERATIONS '-CC JUN i b iy/M WMC PJW BJO (AM*- m ATWOOD ABS-011637 LAM 031693 DISTRIBUTION LIST MR. H. L. KUSNETZ MR. H. J. MC DERMOTT MANUFACTURING LOCATIONS DEER PARK MANUFACTURING COMPLEX SUPERINTENDENT - SAFETY AND REFINERY SAFETY MANAGER CHEMICAL SAFETY MANAGER INDUSTRIAL HYGIENE MARTINEZ MANUFACTURING COMPLEX SAFETY MANAGER NORCO MANUFACTURING COMPLEX MANAGER - SAFETY AND INDUSTRIAL HYGIENE WILMINGTON MANUFACTURING COMPLEX MANAGER - SAFETY AND INDUSTRIAL HYGIENE ANACORTES REFINERY SAFETY MANAGER ODESSA/CINIZA REFINERIES SAFETY REPRESENTATIVE - ODESSA SAFETY REPRESENTATIVE - CINIZA WOOD RIVER REFINERY MANAGER - SAFETY AND INDUSTRIAL HYGIENE DENVER CHEMICAL PLANT ^SAFETY MANAGER EL PASO CHEMICAL PLANT SAFETY AND TRAINING REPRESENTATIVE GEISMAR CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MARIETTA CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MOBILE CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT TAFT CHEMICAL PLANT SAFETY REPRESENTATIVE WOODBURY CHEMICAL PLANT SAFETY MANAGER ABS-011638 LAM 031694 SUMMARY OF INDUSTRIAL HYGIENE EVALUATIONS DURING CAT CRACKER TURNAROUNDS SUMMARY Because of a concern for personnel exposure to air contaminants, the working atmosphere was monitored at three Manufacturing locations during major catalytic cracker turnarounds in 1978. The results of these surveys indicate that personnel exposure to catalyst dust and metal fumes should be considered during future CCU shutdowns and in the design of new CC units. DISCUSSION During the surveys, all sampling was done external to any respirator or welding helmet. Respiratory protective devices were used during much of the monitoring and welding faceshields were in place during welding and cutting operations. Some investigators have reported significant protection to the welder from the faceshield diverting the smoke stream away from the breathing zone. For these reasons, the following comments, based on the monitoring results, would be applicable to unprotected workers. -- Air arc gouging may generate total particulates, iron oxide, copper, nickel, total chromium and hexavalent chromium in excess of existing standards while cutting in vessels such as cyclones, plenum chambers, spent catalyst risers and even in larger vessels with ventilation "dead" spots. -- Coated electrode welding may not result in excessive levels of dusts and fumes in enclosed spaces with ventilation roughly equal to 2000 cfm/welder. However, occasional excursions above the hexavalent chromium limit may occur during stainless steel welding. -- Refractory removal may generate refractory and trapped catalyst dust in excess of the nuisance particulate limit in most situations. -- Chipping coke deposits in the reactor may generate dust levels in excess of the TLV for Particulate Polycyclic Aromatic Hydrocarbon. -- Removing asbestos containing insulation releases asbestos fibers into the atmosphere and appropriate precautions must be taken. ARR-m 1 a LAM 031695 2 RECOMMENDATIONS Future cat cracker turnarounds (or other major maintenance turn arounds) should include industrial hygiene input early in the planning stages that may include: -- Review of health implications and pertinent exposure standards (PEL'S, TLV's) for materials used or encountered during the shutdown. -- Ventilation (general and local). -- Work practices including purging and cleanout procedures. -- Personal protection program to prevent exposure where other control methods are not feasible. -- Training for engineering field and safety inspectors on health implications of the planned work. -- Contract considerations to assure the contractor is aware of the health implications and his responsibilities. -- Dust suppression techniques. Future vessel (unit) design should consider health exposure control strategies for major maintenance work such as: -- Adequate openings for entry and ventilation. -- Purging, draining, dust removal facilities - initial and throughout the shutdown. -- Assembly that allows greater access and prefabrication flexi bility in "frequently repaired" items. -- Increase the weighting of the "ease of repair" criteria in evaluating alternative designs or materials. -- Amount of and means for providing general ventilation. Develop or follow state-of-the-art improvements: -- Ventilation techniques. -- Welding or cutting techniques that minimize exposures. -- Portable local exhaust systems - separate or integral with welding equipment. -- Respiratory protection. ABS-011640 LAM 031696 3 Consider further Industrial Hygiene surveys of major cat cracker turnarounds to broaden and extend the data base. -- Catalyst dust exposures during the shutting down phase. -- Coke dust or fractionator oil exposures. -- Asbestos exposures during old insulation removal. -- Evaluation of other potential exposures - gases, vapors, noise. -- Evaluate additional welding tasks. WMC:bjd 6/13/79 ABS-011641 LAM 031697 DISTRIBUTION LIST MR. H. L. KUSNETZ MR. H. J. MC DERMOrN MANUFACTURING LOCATIONS DEER PARK MANUFACTURING COMPLEX SUPERINTENDENT - SAFETY AND INDUSTRIAL HYGIENE REFINERY SAFETY MANAGER CHEMICAL SAFETY MANAGER MARTINEZ MANUFACTURING COMPLEX SAFETY MANAGER NORCO MANUFACTURING COMPLEX MANAGER - SAFETY AND INDUSTRIAL HYGIENE WILMINGTON MANUFACTURING COMPLEX MANAGER - SAFETY AND INDUSTRIAL HYGIENE ANACORTES REFINERY SAFETY MANAGER ODESSA/CINIZA REFINERIES SAFETY REPRESENTATIVE - ODESSA SAFETY REPRESENTATIVE - CINIZA WOOD RIVER REFINERY MANAGER - SAFETY AND INDUSTRIAL HYGIENE DENVER CHEMICAL PLANT SAFETY MANAGER EL PASO CHEMICAL PLANT SAFETY AND TRAINING REPRESENTATIVE GEISMAR CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MARIETTA CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MOBILE CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT TAFT CHEMICAL PLANT SAFETY REPRESENTATIVE WOODBURY CHEMICAL PLANT SAFETY MANAGER oz- - CCC- ABS-011642 LAM 031698 SUMMARY OF INDUSTRIAL HYGIENE EVALUATIONS DURING CAT CRACKER TURNAROUNDS SUMMARY Because of a concern for personnel exposure to air contaminants, the working atmosphere was monitored at three Manufacturing locations during major catalytic cracker turnarounds in 1978. The results of these surveys indicate that personnel exposure to catalyst dust and metal fumes should be considered during future CCU shutdowns and in the design of new CC units. DISCUSSION During the surveys, all sampling was done external to any respirator or welding helmet. Respiratory protective devices were used during much of the monitoring and welding faceshields were in place during welding and cutting operations. Some investigators have reported significant protection to the welder from the faceshield diverting the smoke stream away from the breathing zone. For these reasons, the following comments, based on the monitoring results, would be applicable to unprotected workers. -- Air arc gouging may generate total particulates, iron oxide, copper, nickel, total chromium and hexavalent chromium in excess of existing standards while cutting in vessels such as cyclones, plenum chambers, spent catalyst risers and even in larger vessels with ventilation "dead" spots. -- Coated electrode welding may not result in excessive levels of dusts and fumes in enclosed spaces with ventilation roughly equal to 2000 cfm/welder. However, occasional excursions above the hexavalent chromium limit may occur during stainless steel welding. -- Refractory removal may generate refractory and trapped catalyst dust in excess of the nuisance particulate limit in most situations. -- Chipping coke deposits in the reactor may generate dust levels in excess of the TLV for Particulate Polycyclic Aromatic Hydrocarbon. -- Removing asbestos containing insulation releases asbestos fibers into the atmosphere and appropriate precautions must be taken. ABS-011643 LAM 031699 2 RECOMMENDATIONS Future cat cracker turnarounds (or other major maintenance turn arounds) should include industrial hygiene input early in the planning' stages that may include: -- Review of health implications and pertinent exposure standards (PEL'S, TLV's) for materials used or encountered during the shutdown. -- Ventilation (general and local). -- Work practices including purging and cleanout procedures. -- Personal protection program to prevent exposure where other control methods are not feasible. -- Training for engineering field and safety inspectors on health implications of the planned work. -- Contract considerations to assure the contractor is aware of the health implications and his responsibilities. -- Dust suppression techniques. Future vessel (unit) design should consider health exposure control strategies for major maintenance work such as: -- Adequate openings for entry and ventilation. -- Purging, draining, dust removal facilities - initial and throughout the shutdown. -- Assembly that allows greater access and prefabrication flexi bility in "frequently repaired" items. -- Increase the weighting of the "ease of repair" criteria in evaluating alternative designs or materials. -- Amount of and means for providing general ventilation. Develop or follow state-of-the-art improvements: -- Ventilation techniques. -- Welding or cutting techniques that minimize exposures. -- Portable local exhaust systems - separate or integral with welding equipment. --' Respiratory protection. ABS-011644 LAM 031700 3 Consider further Industrial Hygiene surveys of major cat cracker turnarounds to .broaden and extend the data base. -- Catalyst dust exposures during the shutting down phase. -- Coke dust or fractionator oil exposures. -- Asbestos exposures during old insulation removal. -- Evaluation of other potential exposures - gases, vapors, noise. -- Evaluate additional welding tasks. WMC:bj d 6/13/79 ABS-011645 LAM 031701 '' n ^. < C-cT-- Ci--^X-3-c_-G-v_r_<:.Q> \ 1*1/</r? . H J -/ynr_& \ 'J) cru-CL J 01-kic*.-'V a. c. c/ Xd^o ~&L^f 33c. -<-^r ^-oAyC-3'-^ /iL-d- -5 Q_/3 / ^-t-y o_J2^a_. CT^_r^. ' ^l^~o ay/ -^L<^JLjLa ^ <X- , csj y & ^ <y/ JLslsq ^V>i_p <X. C^2-t-vi_-o- ~Z2, 3_ -- / Cn^, L, C-, Y~ ^--A*1 O --V_ ^ ^ ^ %y ? ?. ? -ULT peSXZJi* '<2r1^LSt. *Vv\-dxJLo ^UO"25wa^ 4 x$x% ~zx3i jx^ JUOjia Jw^y J-~ --cj^ a^-~<0 f~~\ y*r^*~^yL'-'~ S ; JLgtt^Cj ^ ^^v_/''C~ <t -X-'*'- --ji- uc-^<5-_-*^ /I ^/ t -O-*-'1'^ Cu- ` <y/) / -JLira-o. , }yu^_ JXCi^ x ~XsXj f ABS-011646 LAM 031702 Euteclic y^^lA1' tCMM(XOCT Caslolin EUTECTIC + CASTOLIN __------ MOVES FUMES / ' \ LAM 031703 / i . i . / rrr t , .... , .. L L 7 i "\.lL LjL _/ -w L l.-L L L V:'" L_:.- L L i. L. - . . - 1.. WITH AIRLUX FUME ELIMINATOR WITHOUT AIRLUX FUME ELIMINATOR an m&p r. see:.. rr- t r- r^- t rsstsr w@Sdsr pror-.T- .c rn . i `\r vj-'-s bLVdJlLLL 1 Si It's true. When you dear the air, weldors see better, feel better, work longer, and the quality of their work improves. And the productivity of people working nearby increases in a pleasant environment. A Eutectic + Castolin AirLuxTM Welding Fume Eliminator removes fumes and smoke at the source. It is portable, which means it can be carried to any job - wherever it may be-in the shop, in confined areas, on the production floor, r seven in the office. Welding jobs can be done J-^anytime, any place, without disrupting work schedules. And the AirLux Welding Fume Eliminator can save in other areas. There is no need to vent expensive plant heat as with other methods*; And you'll never have to move permanent venting systems as your production needs change... the AirLux Fume Eliminator gives you the flexibility to adapt to any change, any challenge. Consider cost effectiveness. The AirLux Welding Fume Eliminator is priced well below other, less versatile systems. AirLux filters normally operate effectively forJiio 6 months-and can be changed in seconds by the weldor, and the unit is virtually maintenance-free. (Servicing can be done easily by your own plant staff or by your Eutectic 4- Castolin Applications Specialist). "2 ABS-011648 LAM 031704 ^'^%,in jjfc.fifoi4fo.ymm ngcy .v TM *: **ffiBBr . .. ". s'.' - `l-S'Xifr'-.*W_ * 11. ^ mk M r; r'--V^ -.' mm&y&r The Eutectic^CastoliriiPdr^^ *: -=27V^'-^-L*i 5- -^rcr_ ~.j>-: ^ra-g^ Patented* filter removes up to 99.7.% of all.-. Large capacity filters dperate;witK highreffi- . - particulate matter from welding fumes, . . .ciency ior up to three months before: , : 'Removes smokeand fumeswherethey are produced, before they are dispersed in the room. ^ ^replacernentisrequired-Replacernentisv : ' clean, easy, fast; no bags to shake out,mo messy collector plates to clean. ; System efficiencyjdoes not depend obairr tight filter housing required by -some other. systems; the housing can even be punc -^Thb^ufe'ctic+GastolinTAirlux^Welding " .* .- : Furhe^limiriator. is energy-effiderit -"saves . energy by recycling heated air. tured accidently and performance'will hot" be affected. ^. Motor will not bum out if, hose becomes clogged or blockea -rit'hasitspwn in- FILTERED AIR OUT MOTOR DISPOSABLE SPARK ' dependent cooling system. - : xl-^ Motor is protected from infiltration by; metallic particles that are prevalent.in : welding fumes. - ''Motor isULlisted. Two models available:- Model 803 for stick : y welding applications (itisy>^eiful?ePqugh: v to`operate effectively with^q^bses'and v ' nozzles),-and Moder821Tdroperi:arcV. GTA and MIG welding processes; it uses a gun-mounted nozzle. MOTOR COOLING AIR OUT The'larger Model 803 weighs:6hly > ; ~ i > ; 44;pbunds,' light enough to be carried any-, where; lightweight, flexible, 15-foot (or longer) hoses provide welding fume pro- . tection in confined spaces or on top of large structures. - SMOKE AND FUMES IN SECTIONAL VIEW OF FILTER (U.S. Patent No. 3,961,924) ABS-011649 lam 031705