Document M79EgkE6ZqjDGDD1xOQa764x

i Qo VICE PRESIDENT Houston, Texas 77052 MIDWESTERN REGI01N August 7, 1979 mi 379 Mr. L. T. Townsend Lawrenceville, IL Rirp INDUSTRIAL HYGIENE SURVEY LAWRENCEVILLE PLANT MAY 22 - 24, 1979 c rWMF HCM UN DRW [iPD pcs V /EWM BCS Attached is a copy of Mr. J. P. Licata and Ms. K. R. Henzler's subject report. Basis the report it appears that Lawrenceville Plant is not en forcing the asbestos procedures which were reiterated in Mr. F. J. Beall* s December 20, 1978 "OSHA 29 CFR 1910.1001 Asbestos" memorandum. Asbestos hazards at Lawrenceville Plant was also the subject of OCAW's February 5, 1979 correspondence to which our April 2, 1979 response indicated that our disposal procedures would prevent exposures in excess of acceptable levels. We would appreciate your comments concerning the report's recom mendations . JFY dc:2/2 cc: DRW Attachment SIGNED: C. T. SWAN C. T. SWAN BICK000019725 TT u Industrial Hygiene Survey Lawrencevllle Plant, Lawrencevilie, Illinois May 22 to 24, 1979 James P. Lleata, Sr. Industrial Hygienist, Beacon, N. Y, Kathryn R. Henzler, Toxicology Technician, Beacon, N. Y. Summary The OSHA Asbestos regulations, 1910.1001, list very specific Instructions for the removal and disposal of asbestos insula tion. It was evident during our survey that these instructions are not being followed completely. Railroad cars are not being euoc'ked or marked with the required blue flag to indicate the car is connected for loading or unloading. Metal shatter shields at the top of bench grinders were missing or improperly 0. 3s J U3 0 0i d . Canister gas mask face pieces were not connected to the canisters which reduces their effectiveness as emergency respiratory equipment. Self-contained breathing apparatus must be main tained v/ith sufficient air pressure to prevent the employe from running out of air where there may be an atmosphere immediately hazardous to life. Portable emergency eye wash units must be maintained with sufficient air pressure and must be drained and refilled periodically. Plastic safety end caps for valve stems throughout the plant should be considered to protect employes from possible injury in case of striking the valve stem thread. The safety latches on two chain hoists were missing and must be replaced. Open buckets of cleaning solvent were noted in the machine shop. Light bulbs and/or protective glass covers were missing on the top plat forms of the PCCU. Exhaust fan above the entrance door at alkylation unit #1 Sample Building was blowing in instead of exhausting. The Sample Building of alkylation unit ft2 does net have an exhaust fan or hood over the acid sink. Recommendations - Reinstruct insulators and supervisors In the proner methods for the removal and disposal of asbestos insulation. This recommendation was oreviously submitted on our survey of Aoril 6-7, 1976. ` ' BICK000019726 2 Recommendations (Cont'd. ) 2. Chock and blue-flag-all railroad card within the plant, , 3. Periodically check all grinders to see that top shields are in place and that they are adjusted to a maximum of 1/4" clearance. This recommenda tion was previously submitted on our survey of April 6-7, 1976. 4. Canister type gas masks should be stored with the canisters attached so that they are available for immediate use. This recommendation was pre viously submitted on our survey of April 6-7, 1976. 5- The air pressure on self-contained breathing apparatus should be maintained above 1600 psi. Any cylinders below that should be taken out of service and repressurized according to manufac turers specifications. 6. All Dortable emergency eye wash units should be pressurized above 100 psi. The minimum pressure should be stencilled on each cylinder. This re commendation was previously submitted on our survey of April 6-7, 1976. 7. A system of checking the water level of portable eye wash stations on a routine basis should be established. The manufacturer recommends a monthly flushing and refilling. This recommenda tion was previously submitted on our survey of April 6-7, 1976. 8. Plastic end caps (safety orange color) should be considered for protecting the exposed valve stems throughout the plant. In many locations the valve stems present an eye hazard or possible body in jury should an employe walk into one. 9. Replace safety latch on chain hoist in the Fabri cation Shop, and on the portable hoist in the Machine Shop Annex. 10. Open buckets of 1,1,1 triehloroethane (ebloroethane) should not be left uncovered in the machine shop. If buckets of solvents are needed for cleaning parts, the lids should be replaced when not in use, and the exhaust fans should be running, at all times. B(CK000019727 - 3- Recommendations (Cont'd.) - 11. Replace missing or broken light bulbs and pro tective glass bulb covers on the top platforms of the FCCU. 12. The exhaust fan over the door of the sample build ing on alkylation unit #1 should be reversed, so that it blows air out. of the building. 13. An exhaust fan and hood should be installed over the acid sink in the sample building on alkylation unit 2. ;: Discussion A walk-through industrial hygiene survey was performed during the week of May 21st at the Lawrenceville refinery. We were accompanied by Mr. V. E. Jennings, Safety Supervisor and dis cussed the above recommendations with him prior to. our closing conference with Mr. Hoffman. We also reviewed the plans for revision of the chemical laboratory exhaust system. Previous recommendations concerning the relocating of exhaust blowers outside the building were made in H. L, Hobson's report of June if-6, 1975. He also attached copies of recommended design practice as outlined in the Industrial Ventilation manual pub lished by the American Conference of Governmental Industrial Hygienists. We reviewed the plans with the engineering depart ment personnel and gave them a copy of the cover page of the above manual so they could order a copy for their reference library. After the manual is received if there are any prob lems with the re-design of the laboratory exhaust system. Dr. H. L. Hobson, Supervisor of Industrial Hygiene and Epidemiology, Houston, should be contacted for assistance. The problem of welding in confined spaces was reviewed and we hope to be able to obtain a sampling device which will allow breathing zone samples to be taken inside a welding helmet. We will forward Information on a technique as soon as we have one available. The problem of birds and pigeons roosting on various units throughout the refinery was also discussed. We suggested the use of sterilant bird feed as one humane method of control. As yet we have not been able to obtain the source of this type feed but again will forward it as It becomes available. Asbestos insulation was seen on the ground in various areas around the plant. The most evident areas were along the LPG BICK000019728 L\ - Discussion (Cont'd.) : t- railroad unloading rack, and on the top and third levels of the PCCU. It is recommended that all insulators and super- . visors be reinstructed in the proper methods for the removal and disposal of asbestos insulation as outlined in OSHA CPR 1910.1001. .. if ' , We have attached an information sheet concerning high efficiency vacuum cleaning systems which are available. These vacuum cleaners could be used for control of asbestos fibers from asbestos tape or packing materials in the storage area or any other location where asbestos dust removal is. required. ,, -1 . .` ' (>,.- 'i 1 Railroad cars at the LPG unloading rack, the FCCU catalyst tank car, and the hopper car by the boiler house were not chocked or blue-flagged. It is recommended that this be done with all rail cars within the plant. Several canister type gas masks were found that did not have the canister attached to the face piece. In an emergency, time could be of the utmost importance. The minutes that are lost in attaching the canister could mean the difference between the safe escape from a contaminated location and possible In jury. It is recommended that all canister type gas masks be stored with canisters attached to the face pieces and bottom seals in place so that they are available for immediate use. Once the canister bottom seal is removed, the canister has approximately a one year shelf life, so the date of seal re moval must be noted on the canister. . A Haws Emergency Portable Eye Wash In the Litharge building was not pressurized to 100 psi. In order for these portable eye wash stations to provide adequate protection,, they must be pressurized according to the manufacturer's specifications. rt was also learned that there Is no program In the plant that provides for the regular draining and refilling of the portable eye wash fountains as recommended by the manufacturer. Such a program should be Instituted to insure that these units ire properly pressurized and maintained, - During our walk down from the top of the PCCU it was noted that there was a broken metal support guide on the line coming from the bottom of the regenerator, third level,,north of the elevator. The operator was Informed and started, emergency repairs immediately. At the closing conference with manage ment, we were informed that the repairs had been completed. :;;1 y\ A i BICK000019729 T./ . -- 5 - Discussion: (Cont'd.) The exhaust fan over the door of the sample building on alkylation unit #1 should be reversed to blow air out of the building. The eductor unit::'over the acid sink in this build ing had been blocked with rags. When they were removed, and the eductor turned on, it operated efficiently, but the noise levels were fairlyVhigh. This leads to the concern that it may not be used by the operator due to the discomfort caused by the noise. Consideration should be given to re placing the eductor with a fan-type exhaust hood. The sample building on alkylation unit #2 had no exhaust system over the acid sink. It is recommended that an exhaust fan and hood be installed. ; During our survey we were asked to inspect the locker rooms because of employe complaints about the contract "oXeaning service. The Men's Locker Room still had dust on the tops of the lockers after a dry mop cleaning that morning. The shower walls, floor and shower heads had a film of soap scum visible. The floor drains were clogged with dirt,; debris and hair and the toilet stalls were still: soiled after the cleaning had been performed that, morning. The Vfottn's Locker, Room was much cleaner and there had been no complaints. Mr. V. E. Jennings discussed the problem with' a representative, of the contract cleaning company and reviewed our findings. Hopefully some improvement has been noted because of these discussions. -' ' ;o- We wish to thank Mr. C. A. Hoffman, Jr. and his staff for their assistance and cooperation during the performance of this survey. J. P. LICATA K. R. HBNZLER BICK000019730