Document N2mkDze6k9La6bnVooN8VVdJR

PLAINTIFF'S EXHIBIT i i- Nw York* How York* 10017* Jtuo 29* 1972 INOWgTRlA^HTOIgNg SURVEY PU<3*T SOUND RSyiNXRT Mm9*Ansm* Mr. D.H. Mortoft AueotUi, Woofetogtott Attacked to fbo roport of tk iado*trial feygiaa* oorvOf ebadoctod ftfc yooc plftat n Moy I 0a 10* 1972* Vo Ion boo* wftttiof tor dot* from ebomlcftl ftappllftrft which ho otUl ootboo* roeolrod. K mmaundittoH eorortog Hum* materials oro aaoded tor will bo tat to oopftrofo roport. If you boro **j qanfcionft* ploftftb lot mo know* JFL-AFQ cc: FPYjr DMM JAD JPI* R. T. RICHARDS WA-TEX 000033 Industrial Hygiene Survey Anaeortes ftflurf,Pa|t8oaad Rut Atteett*!, Washington May 8-10, 19T2 By: James P. Lieats,Industrial Hygienist Texaco be,, Health Division Haw York* Haw York SUMMARY Asbestos containing materials are befog wed lor pipe / insolation and each we should bo discontinued. Paint spray work fo 4oaa fo the warehouse #3 building without adequate enuwt ventilation or proper electrical fixtures approved lor oao fo a hassrdoua location* The mixing abed located at foe water cooling tower doea not have adequate exhaust ventilation to remove the . chromate duet evolved whea dumping bags Into ike mixing hopper* The solvent drum rack outside foe paint chop ia net equipped with the proper electrical grounding to handle a static charge build-up. The tetraethyl lead tank car unloading building ia not equipped with a flow alarm or sight-glass on the overflow tank* Mercury waa . found behind the teat panel in the instrument room. The plot plana of the high noiae arena do not shew the 90 dBA contour on tha plana. A calibration kit ahonld ho purchased for tho MSA combustible gaa indicator* INDUSTRIAL HYOIBKE SURVEY On May 8,9> and 10th, 1972 a aurvey of foe Anacortea Refinery waa made to aaalat local management fo updating some plant operations to. comply with tho Federal Occupational Health and Safety Act of 1970* Tho following recommendations are a result of thta survey. Some additional information con cerning Magnus 94XX-K and Beta Dianodic 939 has still not boon received from the manufacturer and recommendations covering these will he handled in a saparate report if needed. RECOMMENDATIONS 1. Asbestos uaeage ia befog strictly controlled under OSHA regulations* Tho moat practical alternative is to perform insulation work fo tha refinery, with non-asbeatos containing insulation materials. The present stock of aabsatoa cement in 100 lb. bags should be discarded since these are non-asbestos types readily available* All insulation which has been done with asbestos should be indicated on plant operation diagrams to enable employee to fibdhsw OSHA regulations during WA-TEX 00Q034 I -2- uptlv or ntpiunamt at iom Him la ft* Iota**. All specifications for mv installation* should prohibit ft* tu of **b*ito* containing materials for insulation* 1. 2* Paint spray work bolag porformod ia warehouse building 13 hoald b* discontinued until m adequately ventilated paiat spray booth of sttffioiaat siaa cam b installed. AMtttaftf all electrical ilataraa ia ft* room shonld bo apdatod to ft* approved typo for hasardens locations, Claaa 1 as datailod ia paragraph If10.322-1910324 HBA regulations. 3* Tha mixing shad loeatod J^p irator cooling tower should have aa adequate exhaust system iastalledr'to rsmoveeny dust evolved during the damping of Bets OlaaodU #939 into the mixing hopper. The operator wears a U.S. Bureau of Mines approved respiretort goggles and other protective clothing but the dost still contacts many exposed areas of bis skin. This water treating chemical cantatas 49% chromates. The lighting inside this shed shoold also be improved by the addttion of another light fixture over the mlxiag hopper. . ; 4. The solvent dram reck outside the paint shop should be provided with proper beading wire end grounding to prevent a static charge build-up unspecified in 08HA regaletione paragraph 1910* 104* S* The tetraethyl lead tank car unloading pump hones building is equipped with n task to eolleet eny overflow ia the event of n malfunction. This tank should be equipped with a flow alarm system or sight-glass to alert operators when this situation has occurred* 4. The interior of the instrument rowan tent panel should be checked periodically* with a magnifing glass and flashlight, for droplets of mercury. Any mercury noted should he vacuum removed using n special collecting flask attachment equipped with a h'gh velocity pick-up tube. The attachment will have to be fabricated in your laboratory as they are not commercially available. A side arsaoVacuum flask, rubber haae and a glass rod for a pick-up tube should be used..' Tho incoming air should bubble through water in the flask to collect the mercery* 7. The installation diagrams ussd for noise plot plans do not show the 90 dBA contour on the drawing* The present yellow outlines shown era the concrett pad edges in most eases and not the actual 90 dBA contour. 3. A calibration kit for your Mina Safety Appliance (MSA) combustible gas indicator should bo purchased to insure the unit is working properly prior to use. Tests for combustible vapors should be made prior to any tank or confined epece entry. ! WA-TEX 000035 3 DISCUSSION Tilt storage tr> for insulating material ha* very poor house- k--piny and control* fog >ibttoi containing materials, Tha asbestos "flat" cemsat it dispensed with a scoop from a 100 lb tack which it torn opea. Tb floor* wtro covered with athotio* fiber* and. pieces of broken pre-formed pip# insulation. Brown* aro used to dry *wo*p At* area. No respittMfctry protochoa i* worn byythe employs* Uvolvedla tha asbestos ' csmsnt mixlintfeporatlon. Tha Federal Occupational Health and Safety Act ragalatloa* ea ltbaato* war* changed oa December 7, 1971 through publicstioa of aa Emergency Standard amendment. Tha threshold limit value fat aabaatos la praaaatly S fibara loagar than 5 micron* par milllMtar of air. A apacial tody committee, which waa formad and** tha 0.8, Dept. ef Labor, ha* now raeommaadad that tha limit for asbestos bo further reduced to 2 fibers loagar than S micron* par millUitar of air. v*a if all fotora imsulatioa work i* performed with aabaato**fraa material* th* aaiatiag aabaito* containing insulation will contlnna to eanaa problem*. All lino* proaantly covered with aabaato* ehould ba indicated on piping plan* *o whan it coma* time to remora or repair *och inavilation the proper employe protective meaanree can be taken* The safe work procedures for aeboatoe include thedBdlowing; 1. All power driven or mechanical cutting equipment muat bo provided with adequate local exhaust ventilation. (ANSI Standard Z9* 2-1971). 2. U. S. Bureau of Minos approved respirator*, air supplied or self-contained breathing apparatus must be worn where duet level* exceed the Threshold Limit Valuo*. . 3, All dust must be remoyed by vacuum cleaning methods. 4. All waste material must be collected and disposed of in sealed bags or containers. 5. Warning signs must be posted as specified In the proposed standards if adopted. ' Compliance with these regulations will be very difficult and dd&grsatly to the labor cost. Zt is, therefore, important to document the exact present location of all asbestos insulation which will be subject to these regulations, as well as installing only non-asbsstos typo* in the future. A copy of the WA-TEX 000036 . . r -4- Emergency ud Proposed standards U attached for yoar information. Also attached m d*t* sheet* for n esbeetos free cement. The other items diseussed ere covered la the recommendation* listed ebore* There is on* additional item under recommendation #7 concerning the noise contours. The question of spacing of warning signs at the 90 dBA eontou line was raised* No specific distance between signs are mentioned in the "Guidelines to the Dept, of Labor Occupational Noise Standards*4 or In the OSH. regolations. I would suggest Act each contour be inspected to dstcemln* if a warning sign is visible to anyone approaching along normal routes* Additional signs mny be needed st sou# points whore items block presently posted eigne. Eech noise source should be treated individually. Additional items which were checked during my plant surrey were the open surfhee tanks in the machine shop, holler house end laboratory. The hot water bath tanks in th* lab and th* tank in th* boiler house do not present s haserd as defined by the GSHA Item 1910.94 (d) (plOSIS). The tank in th* mad shbO i* head to dean metal parts and contains a solution of Magnus 94XX-K whi druScUKlabel status is a medium strength alkali mixture* I have written to th* manufacturer for detailed information and will writ* specific recommendations operation, if aoodod. whoa file data i* received. ' X would like to thank Mr. D. H. Morton and hie staff for th* cooperation and assistance 1 received during my visit to the Anaeortes refinery. JPL-AFG Atts. J.P. L1CATA WA-TEX 000037