Document M4Knzn0wB9n44D5Lm1kzm388M

-.3* Shell Oil Company Interoffice Memorandum MARCH 24, 1983 FROM: J. L. RIVARD TO: J. A. MULLINS SUBJECT: HEALTH AND SAFETY COMPLIANCE ASSESSMENT REVIEW - FINAL REPORT SOI PURCHASING TERMINALS OPERATIONS Enclosed is the final report the Health and Safety Compliance Assessment Review (CAR) performed by Safety & Industrial Hygiene for the Galveston, Morgan City and Baytown terminals on January 11-14, 196S. There are no substantive changes from the draft report of February 15, 1988, which has been reviewed by Head Office E&P, Head Office Legal and the SOI staff. In accord with current Compliance Assessment Review procedures, this report is being furnished to you for transmittal to SOI management. Subsequently, the audited entity is to prepare a.corrective action plan for the cited concerns, with an accompanying implementation schedule, status reporting system and completion notice. JDH:sjm Attachments CAB8808401 0001.0.0 lam 023998 ABS-0071B0 be: D. P. Atwood J. D. Harris Q. J. Machac C. F. Phillips HSSE-AS (2) CAB8S08401 - CCC2.0.0 LAM 023999 ABS-0071B1 be: D. P. Atwood J. D. Harris Q, J. Machac C. F. Phillips KSSE-AS (2) CAB8S08401 - 0002.0.0 LAM 024000 ABS-0071B2 HEALTH & SAFETY COMPLIANCE ASSESSMENT REVIEW EiP shell Offshore, inc. PURCHASING TERMINALS OPERATIONS January, 1988 A health and safety compliance assessment review was done during the period January II - 14, 1988. The review provides an independent assessment that systems for implementing laws, regulations, and Shell policies on health and safety ex*`st and are working effectively in the function. The review was done by a representative of the Health, Safety and Environmental organization: J. D. Harris, Safety and Industrie; Hygiene Department. The process included interviewing supervisory and safety support person nel, touring the plants, and sampling certain records to determine compliance status. Field sites visited included Galveston, Baytown and Morgan City. Federal regulatory agency rules examined included those of the Occupational Safety and Health Administration (OSHA), Department of Transportation fDOT), U. S. Coast Guard (USCG), Nuclear Radiation Commis sion (NRC), and the Alcohol, Tobacco and Firearms Division of the Depart ment of the Treasury (A.TF). Certain state and Company requirements were also examined. Reporting and Follow-uo Procedures In a compliance review results are classified as serious deficiencies, concerns, or observations. A serious deficiency is a finding by the reviewer, which in the judgment or the manager of the responsible HS&E department, indicates {V a lack of sufficient awareness to ensure compliance, or (2) specific deficiencies which are likely to result in substantial non-compliance; substantial harm to employees, public or the environment; citations that could result in substantial fines or criminal prosecution; or major adverse publicity. A concern is a compliance problem that does not qualify as a serious deficiency. An observation is intended to supplement the overall assessment. Serious deficiencies and concerns are accompanied in this report by recommenaec corrective actions, intended to help clarify both the problem and the nature of remedial action. Locations are expected to prepare a corrective action plan for serious deficiencies and concerns, with an accompanying implementation schedule, periodic status reporting, and a completion notice. Observations do not require specific corrective action or follow-up procedures. Facility Description LAM 024001 The Galveston and Morgan City shore terminals provide logistic support to the SOI offshore platforms. Each has small warehouses, a storage yard and a marine wharf suitable for both cargo and personnel transfers. CABS802102 ABS-007183 Materials handling equipment includes fork lifts and cranes. Yard material handlers and equipment operations personnel at Galveston are contractors; those at Morgan City are both contractor and Shell person nel. Contractors provide a lead person for each location. The Baytown terminal is landlocked. Operations include cleaning anc inspecting tubing and casing before release for shipment by truck to various drilling and producing units. Nearly a1! inspection and material handling tasks are done by contractor personnel. A contractor foreman is present for direct supervision of contractor activities. Summarv In general, the Purchasing Terminals have systems in place for imple menting laws, regulations and Shell policies pertaining to~safety and health. These systems are working e-fectively. No serious deficiencies were noted durina the review. A number of concerns were identified. CA588C21C2 LAM 024002 ABS-007184 i (4) Respiratory Protection - When respirators are used in the workplace, the federal OSHA standard for respiratory protection requires a written statement describing the program, including the selection of respirators, employee fit testing and training annually. Normally there is no need for respiratory protection at the terminals. However, personnel occasionally (possibly twice annually) use cartridge respirators when retiahteninc loose or torn outer protective wrapoing previously placed over asbestos insulated equipment by platform personnel. The wrapping is applied offshore to contain asbestos insulation when handling, transporting, and disposing of old platform eauipment. Terminals like Morgan City receiving asbestosinsulated equipment awaiting demolition are conforming to the extent that the generic EaP safe work practices manual state ment is adecuate for a written program. However, personnel training and fit testing are not documented. (Morgan City) Recommendation - Prior to using a cartridge respirator accro'/ad by NIOSH for asbestos, retrain the person(s) whc will wear them when retighte.ning the outer containment covering on asbestos insulation. Ensure a good facial seal fitting is obtained. Document the training and the -fit tests. (5) Compressed Air for Cleaning - The operating contractor at Eavtown uses 100 psig hand-held air jets to clean dust and foreign material from tubing threads during the ongoing inspec tion process. The contract operators consistently wear.gog gles, gloves and hearing protection. Nevertheless, the OSHA standard for cleaning with hand-held air tools limits the working pressure to 30 psig. (1910.242) LAM 024003 ABS-007185 5 Recommendation - Require the contractor to reduce the maximum air pressure for the hand-held cleaning tool to 30 psic. Aiternatively, require a system that is not "hand-held", or use alternative cleaning techniques such as hydroblast or sandblast with appropriate safeguards. (!' Items to be addressed with contractors " Contract sand blasting nestle operators wear the reauired air-supplied blasting hcods, but helpers were noted without respiratory protection. The helpers were in the edges of the dust cloud and may be exposed. This situa tion should be corrected by the contractor. (Morgan City; f:: ocr^ * ' LAM 024004 ABS-007186 in c c <c JUD <CrL i- S- fC 5 c r> gd c- in c<s d LU LU CX 00 0cc0 CO G Z u>1 ro 0C>--0l to l i * i i ll `l l tt i1 H- 1 ! LU t 1 UJ 1 I 1| 11 11 d 11 11 l1 CO >- c ex f-- c Ol s: to s: X ,,c oo u 3 3 Q. 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