Document N2RvvZ4VVBLNGBw8GK01Y93kD

* s.-jnto ......... .g. Paul Dept, of Medicine & Environmental Health Q2WB (4-8835) February 14, 1983 >^Texas City^IH^Ionitoring . SDP pi^nt visit 2/8-10/82 G. W. Buttler - G2WB C. F. Callis - G5WA J. T. Garrett - G2WB J. L. Henshaw - G2WB T0 D. N. Campbell - 1890 R. T. Hammann - 1890 PLAINTIFF'S EXHIBIT Attached is the routine sampling program which was developed by Dan Campbell, Ray Moore, and Steve Paul during the week of February 7, 1982. This program represents the minimum-arequi rements to maintain a quality, sustaining IH monitoring program. As you are aware, it is necessary to recognize a health concern before it can be evaluated or controlled. The ability to recog nize through monitoring is critical to all downstream areas such as hearing conservation, respiratory protection, training, pro tective equipment, etc. The routine program does not include special monitoring (e.g., start-up, turn-around, request, etc.) and may need to be increased commensurate with future monitoring results and good IH sampling strategy. Texas City has committed to determine exposures during evening and night shifts and to pursue a monitoring program which includes worst case exposures. Although the net result of this routine monitoring program is to decrease the total number of samples/ analyses per year, it is extremely important that every effort be made to direct existing manpower into such areas as hearing conservation, respiratory protection, training, MEHI, and other areas that currently need attention. Note that the routine monitoring program does not include many STEL type samples since results have been so low in most cases the past 2-5 years. If exposures increase to the action level for any material, STEL samples will be increased to assure employees and the IH group that exposures are quantified and data is effectively evaluated. As results increase, monitoring frequency may increase the overall number of samples required to maintain a sound routine monitoring program. The routine monitoring program does meet all recognized regulatory requirements. Texas City/DMEH/MFIC agreed to enter results as less than the limit of detection (<LOD) rather than use zero. It was also agreed to increase monitoring for asbestos, silica, welding fumes, ventilation systems, iodine, isobutylene, lactonitrile, and oxo alcohols. The last three substances need improved analy tical methods. ACAM data will be entered into MEHI in a limited fashion as area or source monitoring. Noise dosimetry work has been left at a high level for 1983 to provide enough personal data to be confident that the worker population requiring annual attention in the hearing conservation program is accurately deter mined. Starting in 1984, personal noise monitoring will be reduced by about 50% in all areas where exposures are well docu mented and believed to be reasonably accurate. MAP 001465 LAM023341 Dan, Bob and Ray, I appreciate the cooperation you all extended me on my recent visit. I think we have agreed on a routine moni toring program which will effectively recognize health concerns and which will maximize the chances for redirecting plant resources to needed areas such as the laboratory (AIHA accreditation means more work) and method development, hearing conservation, training in general, respiratory protection, and perhaps others. Thanks again for your help. Check the monitoring program closely. If there are questions, let's talk about them. SDP: sml MAP 001466 LAM023342 Chcnlcal/ Physical Arer.ts Specify period of to ensure that sai 3> o *- 0cA>l xi 0 o- u OVi .f4 f <tf*l. O r> i *5 ug ? H-D <5 ? | 1. Ir * MtM c.- S' rt P* - e fti NA f jf (5V (*V <^` 1" L-50* 2$ SV *P ! . (V* (V- C| as & c/l r FHlIii2. aCt* W pwHoMp w I i_H!fi - 3OPna> -op?oprH-Vt- \A |^ O Ofna' r{Ct M CCiWw-Oj ct>/soJ>: ar rOKe *3 2 i? >& ^ E5 f* 1-a 1s g 0sto> so sQ ^ jft 8<h*SaO tfl A i/> t/) 9 i s- a s. ~Jn Is 5 * ? n Pl! D r ~oD !*l g 5 *1 f s 1 ? Jj-E J 11 08os 2 1 sCk & l r15 . b rt" i VO P- <Mocna CBPwp awc o> cDf ^0s0* 3 rt *O(C*a0a1 -ft UQ>j CCerDDt p. sw tOrpt- oart* i/ & ffv fJ> Th f*">*3!:?*- pr^ &rs ? B-3~ 3 if tr i? f rr 0* <* ao a e ?s cp am sa o-< Ac ? ^c* 8 r +S o ft * r rt ir -g rtS.! rt&_ . + rti * " * -- - --------------- . O aCP3-O (9 TUO9w3i CaO' *1 o^ *a o Q Pj h M 19 P-> 0 %J nc* o. nx/ >Cl (A in a</* *a Ct 0 US m m IS '* '-'C/ f*2 1 S* 8UAgi. 9, rt w >i pE- 8 "J MAP 001467 0/1 c* ;frt{V 2f 1*:*OD(01m--^frnCMCott** o>Ca(;fMvnwtA*>l> o p rrtt So wOp LAM023343 MO r3 o P o3 0/ /> n 3 LAM023344