Document Ne82DZa6ybDwqgaVODqgKaXMw

' - SM-33 (REV. 5-78) Shell Oil Company Interoffice Memorandum JANUARY 30, 1987 D-- PLAINTIFF'S EXHIBIT FROM: SR. INDUSTRIAL HYGIENIST, HEALTH & SAFETY, MFG. & TECH. TO: SEE ATTACHED DISTRIBUTION LIST SUBJECT: ASBESTOS COMPLIANCE IMPLEMENTATION MEETING , v! On January 9, 1987, an implementation meeting on the Asbestos Standard was held in Houston for Manufacturing. The purpose of the meeting was to dis cuss common problems with the standard and opportunities for facilitating compliance. Present were: Deer Park Manufacturing Complex Mike Bush, A1 Schmit, Paul Masta Norco Manufacturing Complex Kirk Menard, Jerry Crail Geismar Chemical Plant Mike Barclay Wilmington Manufacturing Complex Sharon Sever Marietta Chemical Plant Ralph Layfield Martinez Manufacturing Complex Marj Kovacevich Wood River Manufacturing Complex Terry Harper, Don Elliot Head Office Ron Brown Bert Grant Glenda Greene Philip Snyder Lee Haring Mfg. Support II HS&E, S&IH H&S, M&T HS&E, Industrial Hygiene The OSHA Asbestos Standard as it applies to Shell Manufacturing, becomes effective January 16, 1987. Several implementation issues were discussed during the meeting (see attachment 1) and are summarized below. BT8702001 ABS-060622 LAM 031198 2 SUMMARY OF ISSUES DISCUSSED 1. When does a regulated area exist?. A regulated area exists when employee exposure "exceeds or can rea sonably be expected to exceed the permissible exposure limit". Based on experience and monitoring to date, it is believed that regulated areas would only have to be established for "major removal jobs". While a specific working definition is not available, these would probably not include working on pipe but would include working on blown-on insulation, reactors, columns, and cutting transite. NOTE: Significantly, recent discussions between OSHA and the ORC suggest that OSHA may interpret "can reasonably be expected to exceed" as data showing exposure above the action level. Meeting attendees agreed that, in general, exposure from these jobs can be controlled most of the time through the use of water and other established methods. While the-official interpretation from OSHA is not yet available for Small-Scale, Short-Duration Tasks, the group believes that regulated areas would only exist for much larger jobs than that intended to be covered by SSSD. 2. Does all of the monitoring data have to be below the permissible ex posure limit of 0.2 f/cc before a job can be treated as unregulated? For administrative purposes, Shell currently considers compliance to exist when an analysis of the representative monitoring data shows that 95% of the measurements are below the permissible exposure limit. It should be noted that for purposes of determining compliance, OSHA will use the results of their monitoring regardless of past Shell data. When an asbestos job is considered as not regulated, Shell locations need to have a sufficient data base for comparable jobs, and condi tions of exposure. The burden is on Shell to properly determine when a job may or will exceed the permissible exposure limit. While Shell industrial hygiene staff need to continue to fully char acterize each job monitored, additional documentation is recommended when exposures exceed the PEL. Factors to be documented include length of each job, procedures used and obstacles encountered, eleva tion, probable cause of overexposure, weather conditions, and the number of employees involved. 3. What is a Small-Scale, Short-Duration (SSSD) Operation? As OSHA uses the term, an SSSD operation is only a consideration after the decision is made that a regulated area exists. Generally, employers must comply with the requirements of paragraph (e) Regu lated Areas, which include: BT8702001 ABS-060623 LAM 031199 3 (e)(2) Demarcation (3) Limited Access (4) Respirators (5) Prohibited Activities (eating in regulated areas, etc.) (6) Major Tasks: Removal, renovation, and demolition require negative-pressure enclosures where feasible Small-Scale, Short-Duration Operations define an exception to (6) above. When a SSSD operation exists, employers do not have to use negative-pressure enclosures which are otherwise deemed feasible. At this time, it is believed that the definition of SSSD will not have substantial impact on compliance activities since most regulated areas will only have to be established for jobs significantly larger than an SSSD operation. It is noted that the definition will probably be important to the California locations since their proposed standard requires "feasible" negative-pressure enclosures for removal, renovation, and demolition regardless of exposure. Thus a SSSD operation would be the only ex ception to this requirement. Martinez and Wilmington will work :on a tentative definition of SSSD to aid in implementation if the OSHA de finition is not forthcoming in a timely manner. 4. Are negative pressure enclosures feasible? Several factors were discussed with regard to the feasibility of using negative-pressure enclosures. Several locations had either used such enclosures or reviewed their potential use. While problems do exist with the use of such structures (see below), most problems would ap pear to be susceptible to corrective measures, providing sufficient resources were applied. Not using a negative-pressure enclosure in regulated areas based on feasibility must be decided on a case by case basis. Significantly, feasibility does not include a considera tion of cost effectiveness. Wind - All locations noted problems with maintaining the integrity of enclosures in outdoor environments. Wind has resulted in struc tures losing the negative pressure, blowing over, and tearing. Configuration - Some jobs would not easily permit constructing a negative-pressure enclosure. Heat Stress - During summer months it is anticipated that heat stress would have to be anticipated for employees wearing protective clothing in such structures. BT8702001 ABS-060624 LAM 031200 4 Maintaining Negative Pressure - Geismar reported that they were not able to maintain a negative pressure due to thermal currents overcom ing the capacity of the fan that was used. Other locations described losses associated with tears in seams. Safety Concerns - Negative-pressure enclosures should be considered confined spaces. As such, the requirements of the anticipated future confined space regulation would probably apply. Locations are con cerned for the possible buildup of flammable or toxic gases in the enclosure. Safety issues exist with employees leaning over scaf folding to pull in plastic sheeting, employees possibly falling from heat stress, etc. Cost - Norco and Deer Park reported that using a negative-pressure enclosure would result in at least a cost increase of 300X. For example, a 60 x 40 ft. tank would cost $80,000 instead of $30,000 according to a Houston asbestos removal contractor. Costs for Shell Manufacturing are estimated to be substantial. 5. What are the benefits of using negative-pressure enclosures?. And when should they be used? Discussion Clearly the primary value of using negative-pressure enclosures is to prevent the contamination of adjacent work areas and employees in those areas. They have been more commonly found in use for indoor asbestos removal. It is unclear whether employees working inside such enclosures would have greater potential exposure because of the enclosure. Attachment 2 identifies that one of OSHA's purposes in establishing this requirement is to prevent exposure to adjacent personnel above the action level. In the preamble, 0SHA also notes that most employers will elect to use other methods of control in environments which do not "lend themselves to the construction of negative-pressure enclosures". Meeting attendees strongly felt that while enclosures would have some application (eg. as windbreaks, in areas which could not be isolated, and indoors), in general, the benefits were outweighed by the problem considerations listed above. It was felt that the 0.1 f/cc action level for "other workers" in the area could be met and documented by other methods. Negative-pressure enclosures are considered but one method to achieve this end, but not necessarily the best method even though technically feasible. The following approach was discussed. A. Conducting sufficient "boundary monitoring" over the dura tion of major removal jobs as an initial alternative to using negative pressure enclosures. This would be supple mented by monitoring of personnel in the immediate area but who are not directly engaged in the removal operation. BT8702001 ABS-060625 LAM 031201 5 B. Establishing adequate demarcation around asbestos removal work to isolate the exposure source. C. Requiring the use of the best control technique. Negativepressure enclosures would be but one alternative (with probable limited utility in outdoor environments). D. Fully characterize and document all operations that are considered regulated areas. This could include photographs of the work, documentation of the length of the job, the monitoring results, factors which influenced how the job was performed, probable reasons for exposures that are measured, etc. Such reports are now being generated by some of the contractors. Conclusions Subsequent discussions with the Shell Legal Department and HS&E reaf firm the need to use negative-pressure enclosures in regulated areas for major tasks. The only exemptions that exist are: 1) if not feas ible, 2)-if a small-scale, short-duration task, or 3) if a greater hazard would exist if an enclosure was used in a specific instance. In each case where feasibility or greater hazard is relied upon, the supporting facts will have to be persuasive and well documented. In dustry is not permitted to consider cost or effectiveness since these matters were considered in the rulemaking process. ORC reports that as of mid-January, OSHA expects the use of negative-pressure enclo sures in outdoor environments. ORC continues to work with them on this issue. 6. Who needs to have a Competent Person - Shell or the contractor? If the removal work is performed by a contractor, the contractor must have a competent person. A Competent Person is one who has received the required training as outlined by the OSHA standard. One alter native is attendance at an EPA course. It is also recommended that even if the work is contracted out, Shell should also have at least one Competent Person to perform an audit function. Shell is required to have a Competent Person on site if Shell personnel work in a regu lated area, eg. insulators. 7. Labels on installed asbestos insulation - any new options? HS&E currently recommends that the "unit container" approach identi fied under hazcom be used for asbestos. Appropriate signs would be placed at the boundary to plants (units) which (may) contain asbestos insulation. ORC reported that OSHA was agreeable to such an approach. 8. What steps should be taken before work is performed on equipment which "may" contain asbestos? BT8702001 ABS-060626 LAM 031202 6 Asbestos should be assumed to be present unless a sufficient number of bulk samples have been taken to rule it out. The revised OSHA standard should not significantly change existing practices. ORC recently reported that bulk samples do not have to be analyzed down to 0.1%, but rather 1% will be acceptable. Apparently the 0.1% rule was a carryover from the OSHA Haz-Com Standard and will not be applied to analytical requirements. 9. What are the considerations in collecting and analyzing bulk samples? Microscopic analysis is the preferred method. EPA provides a round robin quality control program for plants who do this type of analysis. Interested parties should contact Todd Morman at Westhollow. Such a quality control check is recommended for locations engaged in this work. Chemical methods of analysis are faster but have false posi tives. Many locations are using Hager Labs in Denver which can sup ply overnight microscopic analysis for about $30 per sample. Attachment 3 identifies some considerations in bulk sample collection. 10. Can water be used in cleaning up a contaminated work area? Guidance received from Environmental Conservation, Mfg. & Tech, indi cates that asbestos insulation cleanup should not permit washing of insulation debris to the sewer which could otherwise be contained and picked up by conventional methods. Introduction of asbestos to sewers would require a change in NPDES permits. After cleanup, a final wash down of equipment is permitted to minimize employee exposure. 11. What other considerations have surfaced in cleaning up a work area? While the issue of contaminated scaffolding has surfaced at several locations, no special requirements exist, providing the boards are sufficiently cleaned after use. Reportedly both vacuuming and water has been used. Some locations use a felt/tar paper as found in roofing to achieve better containment of loose debris. After re moving asbestos from piping many locations use a wire brush on the piping to remove any residual insulation. Many locations report that they lay down heavy plastic or other material where there exists a likelihood of contaminating soil, gravel, etc. 12. What are the recommendations for training? Initial and annual training is required for employees exposed in ex cess of the action level. Specific elements must be included in the training as outlined by the standard, eg. a review of the standard and it's appendices. As a practical matter, training is also required to some degree for employees who are required to follow certain pre- BT8702001 ABS-060627 LAM 031203 7 ventative workpractices to maintain exposures below the action level. The number of Shell employees who fall into the latter category far outnumber the number of employees who are actually required to re ceive training under the standard'. The Shell HS&E TRP on Asbestos was reviewed. Several locations ex pressed a reservation about using the TRP as it now exists. Some parts of the TRP do not sufficiently emphasize the operator's role in removing asbestos. In addition to these "future state" considera tions, the TRP overemphasizes the use of negative pressure enclosures. Locations would prefer to see a product which placed the emphasis on the work that is performed 99% of the time, not those few situations where negative-pressure enclosures could be considered. Comments and proposed revisions to the TRP should be sent to P. J. Snyder. Locations should move to implement the required training without waiting for a revised TRP. 13. What are the difficulties in implementing the fit testing require ments of the Asbestos Standard? Either quantitative or qualitative respirator fit testing is required every six months for "each employee wearing a negative-pressure res pirator". If this is interpreted to mean any employee who uses a negative-pressure respirator (for any reason), costs for fit testing within Shell will be substantial. DPMC reports an additional esti mated cost of $300,000/year. This is based on the precautionary use of respirators at manufacturing locations whenever asbestos is dis turbed. It is noted that the California proposed standard limits the fit testing requirement to employees who are exposed in excess of the permissible exposure limit. It was proposed that fit testing continue to be conducted at least every two years (DPMC proposes annually) for employees who are iden tified as not specifically required by the OSHA standard to wear res piratory protection. Subsequent discussions in Head Office support making an interpreta tion that this testing frequency would apply only where respirators are required. ORC reports that OSHA presently intends to use the 0.1 f/cc action level for this determination and not 0.2 f/cc. Where respirators are worn for other reasons, locations should look to the provisions of the respirator standard (1910.134) for guidance on fit testing, equipment maintenance, etc. 14. Are there any difficulties with the fit testing protocols supplied by OSHA? Local procedures now in use for fit testing should be reviewed and modified to conform to either the qualitative or the quantitative fit testing protocol- incorporated in the standard. BT8702001 ABS-060628 LAM 031204 8 The quantitative fit testing (QFT) procedure substantially reflects the approach of the proposed revision to 1910.134, the Respirator Standard (see attachment 5). While this procedure does incorporate several controversial features such as requiring jogging in place, no testing if interfering facial hair is present, and performing three independent tests every six months, no major revision by OSHA is anticipated. Locations using QFT should proceed to implement this protocol for employees who are required to wear respirators under this standard. Reportedly minor revisions to the qualitative fit testing procedure can be anticipated so as to have it more closely conform with the Inorganic Lead Standard. OSHA's intent to follow this protocol is reflected by the Preamble at pg 22697, column 1. Features which have been added to the lead standard's protocol and may be subject to modification include the selection from five mask sizes, not two; the jogging exercise; the retesting upon request within one week; retesting if significant weight change occurs; no testing if interfering facial hair is present; and recordkeeping. Until further clarification is received, locations using qualitative fit testing should modify their procedures for employees who are required to wear respirators under this standard. 15. When is protective clothing required? Protective clothing is required by the regulation when employees are exposed above the permissible exposure limit. In other words, a re gulated area must exist for this requirement to apply. It is noted that most locations do not require protective clothing where employees engage in minor tasks or incidental maintenance which might involve asbestos. Locations should assure that local procedures also minimize the possibility of employees washing asbestos contami nated clothing at home. It is recommended that coveralls be obtained in different sizes in order to cover all employee requirements. Some locations report the successful use of nylon swim trunks under coveralls when regulated areas are established. 16. What measures are recommended as minimum recommendations where expo sures are below the PEL and regulated areas are not required? Requirements for: "restricted areas" not "incidental maintenance" 1. an assumption of asbestos 2. respirator 3. wet methods 4. gloves 5. barricade 6. coveralls 7. propser disposal (bag and tag) 8. signs 9. vacuums (optional) 10. wetting agents (optional) 11. proper hygienic practices BT8702001 ABS-060629 LAM 031205 g 17. Are there any plans to systematically remove asbestos insulation and gasketing? While a few locations mentioned that consideration was being given to a systematic replacement of asbestos over a number of years (10 yrs), Ron Brown commented that there is no Head Office support at this time for the investment that this would necessitate. Marietta described their practice of creating a 4 ft. buffer zone at flanges whenever asbestos is removed, thereby minimizing future exposures. Regarding gaskets, Ron Brown is currently following an industry task force which is reviewing alternatives to asbestos gasketing. This is on the agenda for a future maintenance managers meeting and a HPRA meeting in February. Gasket handling does not represent a major source of exposure, however peak exposures in excess of 0.1 f/cc have been measured. Specific practices such as frequent vacuuming of shelving, use of plastic bags, and oiling of gaskets prior to removal have helped reduce this exposure potential. 18. If a location uses contractors to remove asbestos, what responsibi lity does Shell have? Where a contractor is exercising control of an asbestos removal job, the contractor would carry primary responsibility for complying with the OSHA Asbestos Standard. It is Shell's position that contractors must comply with applicable health and safety standards. Further, HS&E has recommended that Shell have on site a Competent Person to audit contractor performance. Additionally, third party liability for health effects allegedly re sulting from exposure to (Shell's) asbestos also suggests that an audit program be in place to verify that such asbestos work comply with the OSHA regulation. Requirements for asbestos work should be discussed in planning for a job, and then be verified during the progress of the work. P. J. Snyder PJS:bjd Attachment BT8702001 AB3-060630 LAM 031206 DISTRIBUTION LIST HEAD OFFICE Manager, Health & Safety, Mfg. &.Tech. Manager, Manufacturing Support, Mfg. & Tech. Manager, Safety & Industrial Hygiene, HS&E Manager, Regulations & Safety Services Sr. Staff Engineer, Manufacturing Support, Mfg. & Tech. Sr. Staff Engineer, Productivity/Quality, Eng. & Proj. Mgmt. Staff Industrial Hygienist, Safety & Industrial Hygiene, HS&E Sr. Industrial Hygienist, Safety & Industrial Hygiene, HS&E Industrial Hygienist, Safety & Industrial Hygiene, HS&E Technologist, Safety & Industrial Hygiene, HS&E MANUFACTURING LOCATIONS Anacortes Refinery - Manager, Health, Safety & Environment Manager, Maintenance Deer Park Complex - Superintendent, Health, Safety & Environmental Superintendent, Maintenance Manager, Health & Safety Supervisor, Administrative Support Staff Industrial Hygienist Geismar Plant Superintendent, Maintenance Manager, Health, Safety & Environment Industrial Hygienist Marietta Plant Manager, Health, Safety & Environment Manager, Maintenance Safety Assistant, Health, Safety & Environment Martinez Complex Superintendent, Maintenance Manager, Health & Safety Industrial Hygienist Norco Complex Superintendent, Engineering & Maintenance Manager, Health, Safety & Medical Maintenance Manager, Shops/Crafts Industrial Hygienist II Odessa Refinery Manager, Health, Safety & Environmental Supervisor, Maintenance Taft Plant Manager, Maintenance Safety & Training Representative Wilmington Complex - Superintendent, Maintenance Manager, Health, Safety & Environmental Industrial Hygienist Woodbury Plant Manager, Health, Safety & Environment Manager, Operations/Maintenance Wood River Complex - Superintendent, Maintenance Manager, Safety & Industrial Hygiene Industrial Hygienist Craft Coordinator, Maintenance BT8702001 ABS-060631 ATTACHMENT 1 ISSUES LISTED FOR DISCUSSION AT THE JANUARY 9, 1987 MEETING WHEN DOES A REGULATED AREA EXIST? TRAINING OF EMPLOYEES COMPETENT PERSON SMALL-SCALE, SHORT-DURATION DEFINITION MANAGING CONTRACTORS NEGATIVE-PRESSURE ENCLOSURES REQUIREMENTS WHEN EXPOSURES DO NOT EXCEED .2 F/CC SAMPLING AND ANALYSIS OF BULK SAMPLES LABELS ON INSTALLED ASBESTOS AREA CLEANUP FIT TESTING IDENTIFYING ASBESTOS BEFORE PERFORMING MAINTENANCE BT8702001 ABS-060632 lam 031208 ATTACHMENT 2 NEGATIVE PRESSURE ENCLOSURE 1910.53 (e) Regulated Areas (1) Shall establish a regulated work area where airborne concentrations ... can reasonably be expected to exceed the permissible exposure limit. (6) Wherever feasible, the employees shall establish negative pressure enclosures before commencing removal, demolition, and renovation operations. (iv) Exception: For small scale, short duration operation, ... the employer is not required to comply with the require ments of (e) (6). From the Asbestos Standards preamble pg. 22708, col. 1 "it intended to provide employees engaged in the most hazardous asbestos operations ... with the greatest possible amount of protection and also to protect members of the public and other workers on site who are not directly involved in the abatement project from bystander exposure to asbestos". pg. 22710, col. 3 "their purpose is to restrict the spread of asbestos dust that may be generated when.large amounts of asbestos containing material are handled during asbestos removal". pg. 6, col. 3 "such a requirement is necessary for construction sites where asbestos projects ... are performed because such sites are likely to involve several employers and many workers who are not directly involved ... (the enclosures) will prevent the exposure of these workers to concentrations of asbestos fibers that exceed the action level". pg. 22711, col. 2 "the small-scale, short duration operation exemption ... applies to those work operations where it is impractical to construct a negative-pressure enclosure because of the configuration of the work environment". pg. 22711, col. 2 "OSHA is confident that most employers engaged in maintenance and renovation projects in environments that do not lend them/ selves to the construction of negative pressure enclosures will elect to use glove bags, wet methods and other control measures to ensure that ... exposures ... remain below the action level". BS3635102 ABS-060633 LAM 031209 ATTACHMENT 3 Industrial Hygiene Forum Bruce A. Hcrtig, Sc.D. Department Editor JOHNT. JANKOVIC .National Institute for Occupational Safety and Health, Morgantow n. WV 26505-2SSS A review of the current asbestos hazard abatement literature provided very little in formation on the techniques necessary to sample building materials safely and effi ciently. The few techniques that were speci fied (scraping with a knife and pressing a film canister into the material) as well as others, were found to he highly disruptive when per formed dry (Table I)'. Industrial Hygienists at NIOSH's Morgantown Lab have developed a bulk sampling technique which provides an ade quate quantity of material for analysis while minimizing the disruption of the parent material. The procedure employs core sam pling, which allows collection of multi-layered materials with minimum disruption. Devices for core sampling can be fabri cated from existing or easily obtainable office, laboratory equipment (Figure I). The best coring devices are (hose in which the sampler also serves as the sample container. A short length of clear, acrylic tube (Figure 2) with one end sharpened and provided with caps has proven very effective. Modified disposable syringes or co.rk | borers serve wellas reusable samplers. How ever, they require a separate sampling con tainer such as a glass vial as well as cleaning between samples. In general, any cylindrical device that is thin walled, has a sharpened edge or an edge which can be sharpened, and a diameter of I, 4'orsouill make an ideal core sampler. If the sampler endscan be sealed tocontain the material, so much the better, as the transfer and cleaning steps are eliminated. Background In recent years various EPA procrams and regulations have focused publicattention on asbestos-containing building materials. (40 CFR, Part 61-National Emission Standards for Hazardous Air Pollutants.40 CFR. Part 763-Asbestos; Friable Asbestos-Containing Materials in School: Identification and Noti fication). As public awareness of the poten tial for building materials to contain asbes tos increased, a commensurate demand for material identification (bulk sample analysis for asbestos) followed. Many of the bulk samples received in NIOSH's Division of Respiratory Disease Studies lab arrive in large quantities, enclosed within poorly constructed containers. The physical state in which many bulk samples arrive suggests a lack of sophistication on behalf of the collectors. Further, one must conclude that if disruption of asbestos-con taining material can cause exposure, then the sample collector is at some risk when utiliz ing a disruptive sampling technique. Conclusions Fiber release during dry sampling, as meas ured with standard air sampling techniques, can produce fiber concentrations greater than 1000 fibers per cubic centimeter in the air immediately adjacent to the sampling point (Table I). Because data available to date provide no evidence for the existence of a safe (threshold) level of exposure to asbes tos, the prudent investigator should make every reasonable attempt to minimize, if TABLE I Fiber Release 10 cm From Point of Sampling Fibers/cc Sampling Method Dry Wet Cork Borer With Bag Without Bag Knife Glass Vial 7|S|A 4701550) 903(10561 1847(2160) 0(0) 9(11) 0(0) 17(20) '(Fibers/mm'j. e ; -- )3 Figure 1 -- Devices for core sampling. not eliminate, fiber exposure during bulk sampling.The best system found forcontrollins fiber release during materials sampling includes: (I) wetting the material before sampling: (2) coring with a small diameter tube; (3) utilizing the coring device as the sample container: and (4) repairing the damaged surface. If the material iu be sampled cannot oc wetted, a high efficiency particulate respira tor must be worn while sampling, as well as providing some method to contain any mate rial released during the disturbance. Bulk Sampling Procedure A. What to Sample 1. Identify areas and materials to be sam pled based on building specifications and visual observations. a. Friable materials (easily able to crumble with light hand pressure). b. Exposed and deteriorating non-friablc materials. c. Any materials which might be ex pected to contain asbestos w hich is/ will be subjected to a disruptive activity. 2. Determine the number of individual random samples necessary to make up a collective "sample"fora homogeneous material. a. EPA recommends a minimum of 3 samples fora homogeneous mate rial less than 1000 ft" in area. 5 ABS-060634 8S Am Ini Hyt *'-U>c J(*6) febiuii). 1525 LAM 031210 mrun cm exterior before capping With a reus able coring device, eject (he sample into a glass vial or other similar container and wet-wipe the lube and plunger of the sampler. Label the Sample: Use a code which can be referenced to the date, location, etc. ii i i; FIttE EDGE Clean Debris: Use wet psper towels to clean debris: discard in plastic bags Repair the Sampler Damage: Latex paint, dabbed on wet or dry material is accept Figure 2 -- Sampler/container. able for friable surfaces. Tape works samples 1000-5000 ft5, 7 samples for areas greater than 5000 ft5. and provide a means of containing/ cleaning debris. well for repairing core holes left in jacketed insulation and the like. Hair spray has also been reported as an B. How to Sample 4. Obtain a Represenlative Sample: Slowly effective sealant for friable materials. 1. Wet the Surface: This is particularly push the sampler into the material with 9. Sample Shipment: Check the require important. Use a spray bottle to apply a twisting motion until you penetrate ments of your post office before attempt uater. You may add a laundry deter the entire thickness of the material. A ing to ship samples by mail. Private gent to ser\c as a wetting agent. metal or plastic tube. I, 4" or so in di- - carriers are not restricted by DOT 2. Use a Containment Device: If you can't amctcr. works well for this. The repre when shipping asbestos for non-com wet the material, then use a contain sentativeness of the coring is the major mercial use (40 CFR 173.1090). ment device around the sampler, such quantity setting factor. However. I ccor |0. Laboratory Preparation: At the labora i as a plastic bag. so of material will usually provide an tory, forced removal of the cores should l i| 3. A Respirator is Mandatory: If you can't adequate amount for analysis. be done in a hood or under 50 mL or so i follow jtem I or 2: you must wear a 5. Place Material in Container: With a single of distilled water in order to prevent high efficiency particulate respirator use sampler you need only w et-wipe the exposure to the analyst. 'i ! i ABS-060635 lam 031211 From Wood River's proposed asbestos procedure.) ATTACHMENT 4 BID PACKAGE REQUIREMENTS 1. Contractors shall demonstrate reliability in performance of general contracting activities through the submission of a list of references of persons who can attest to the quality of work performed by the contractor. 2. Contractors must demonstrate ability to perform asbestos abatement activities by submitting evidence of the successful completion of training courses covering asbestos abatement. At a minimum, the contractor shall furnish proof that employees have had instruction on the dangers of asbestos exposure, on respirator use, decontamination and OSHA regulations. 3. Contractors must be able to demonstrate prior experience in performing previous abatement projects through the submission of a list of prior contracts including -the names, addresses and telephone numbers of building owners for whom the projects were performed. In rare circum stances inexperienced contractors may be qualified if they can demon strate exceptional qualifications in the other contractor standards. 4. Additional evidence of successful completion of prior abatement projects should be demonstrated by contractors through the submission of air monitoring data, if any, taken during and after completion of previous projects in accordance with 29 CFR 1926.58. 5. Contractors must possess written standard operating procedure? and employee protection plans which include specific reference to OSHA medical monitoring and respirator training programs. In addition, the contractor must be prepared to make available for viewing at the jobsite a copy of OSHA regulations at 29 CFR 1926.58 governing asbestos controls and Environmental Protection Agency regulations at 40 CFR Part 61, Subpart M, (NESHAPS) governing asbestos stripping work practices and disposal of asbestos waste. 6. Contractors must be able to provide a description of any asbestos abatement projects which have been prematurely terminated, including the circumstances surrounding the termination. 7. Contractors must provide a list of any contractual penalties which the contractor has paid for breach or noncompliance with contract specifi cations, such as overruns of completion time or liquidated damages. 8. Any citations levied against the contractor by any Federal, State or local government agencies for violations related to asbestos abatement shall be identified by contractors, including the name or location of the project, the date(s) and how the allegations were resolved. WRR2351/8633701 ABS-060636 LAM 031212 BID PACKAGE REQUIREMENTS 9. Contractors must submit a description detailing all legal proceedings, lawsuits or claims which have been filed or levied against the con tractor or any of his past or present employees for asbestos-related activities. 10. Contractors must supply a list of equipment that they have available for asbestos work. This should include negative air machines, scaf folding, decontamination facilities, disposable clothing, etc. 11. Contractor must provide a copy of current respirator program and include a list of available respiratory equipment. 12. Contractor must designate a "competent person" as defined in OSHA to supervise the abatement project. 13. What will constitute a completed job: A job will be considered complete when the'following criteria has been met: a. Visual inspection b. Air sampling Visual Inspection: The primary test for releasing the contractor is a thorough visual inspection of the worksite. Where ACM has been removed, substrate surfaces should be checked to insure no trace of ACM remains. Special attention should be given to pipes, beams and irregular surfaces that may have corners and hard-to-reach areas. If a sealant was specified in the contract, inspect the encapsulated surfaces to insure the correct amount of sealant has been used; there should be no holes, voids or cracks. Pay close attention to areas located behind obstructions, such as other pipes or ducts, for these signs. Inspection of entire work area is required to insure it has been adequately cleaned. Examine all surfaces for both dust and debris, particularly overhead areas such as suspended light fixtures. The use of a damp cloth to collect dust from these surfaces followed by an inspection of the cloth for evidence of dust is an appropriate method. If dust and/or debris is found, the entire area should be re-cleaned and the test repeated. Air Sampling: Sampling for asbestos must demonstrate levels below 0.01 f/cc by OSHA approved sampling methods. When enclosures are used aggressive sampling shall be implemented prior to removal of enclosure to demonstrate levels below 0.01 f/cc. A minimum of three samples required. 12/05/86 WRR2351/8633701 AB5-060637 LAM 031213 ATTACHMENT 5 OUTLINE OF THE ASBESTOS QUANTITATIVE RESPIRATOR FIT TESTING PROTOCOL I Equipment A. Negative-pressure masks only. B. Program responsibility assigned. C. Capable of showing fit factor of at least 2000. D. High efficiency filter on exhaust. E. Daily changes of cartridges, weekly for filters II Before Testing A. Assure proper adjustment. 1. positive or negative fit check 2. wear mask for five minutes III Perform Qualitative Test (screen) A. Use either: 1. isoamyl acetate a. verify ability to smell IAA b. eye protection required 2. irritant fume a. eye protection required IV Perform Quantitative Test A. Pass fail parameters 1. initial peak penetration shall not exceed 5% - i mask 1% - full face mask 2. cannot issue if mask fails two of three tests 3. minimum fit factors i mask - 100 full face - 1000 May determine graphically if variation on peaks is minimal, otherwise calculate average F.F. Note: * items are those changed from the 1985 proposed respirator standard BT8702001 ABS-060638 LAM 031214 n V Procedure A. No testing if hair in respirator sealing surface. B. Adjust mask for comfort (not .overtightened) C. Exercise regimen (five minutes estimated) 1. normal breathing - 1 min. 2. deep breathing - 1 min. 3. side to side (3 cycles, 5 sec. each position) 4. up and down (3 cycles, 5 sec. each position) *5. read "rainbow passage" - 30 sec. estimated 6. grimace - 15 seconds 7. bend-touch toes - 30 seconds 8. normal breathing - 1 min. D. Repeat three times for mask selected. refitting and retesting permitted once. E. Referral to physician those employees who exhibit breathing difficulty during test. VI Data Interpretation and Use A. Fit factor is lowest of three independent tests. B. Employee has option to have an immediate retest after trying the mask for one week. *C. Repeat testing when significant weight change occurs, etc. VII Records A. Must issue fit factor card 1. name 2. date of test 3. PF for each mask 4. name, signature of tester B. Summary of all test results to be retained for three years for all masks tested. BT8702001 ABS-060639 LAM 031215 FEBRUARY 2, 1987 D. P. ATWOOD G. T. GOLL 0. D. LONG Health & Safety, Mfg. & Tech, held an asbestos compli ance implementation meeting in January for Manufacturing locations. Minutes from this meeting are attached for your information. Attachment BT8703002 P. J. SNYDER ABS-060640 lam 031216