Document OE1Xj1rzKrakBZKnvxxN8aOo1

PLAINTIFF'S EXHIBIT **"* tT/a * * INTEROFFICE CORRESPONDENCE 2TO C. A. Stefani ( ) 0ATE DtCMbtr 21, 1972 c c V. H. Blackball - Edison A. Hernandex- Plainfield'" M. T. 0' Gorman - Kankakee H. A. Sinclairs, K.D. - NT Attn: 2. I. Daniels (2) M. E. Keller, M.D. - Joliet Industrial Hygiene Sunny Z. a, #34-72 Mobil Chemical Company Kankakee, 111. November 16 - 17, 1972 Tha attached report presents the findings of the industrial hygiene surrey performed at your plant on November 16 - 17, 1972, by Lester Levin, Eastern Regional Industrial HygienWfct. It would appear that employee exposure to asbestos fibers free* paint nixing operations are veil belts? the allowable 05HA limit aa a res Alt of proper work handling techniques and environaental controls, notably the new ventilation system, tfe do have seme racomnandatiooa for improvements in tha overhead canopy hoods and for better housekeeping in the raw mat erial storage area. If a suitable non-asbestos containing talc were available. It would be desirable, though not necessary, to substitute. A repeat noise survey indicates that employee exposure Is also well within the allevable (SSHA limits although the wearing of hearing protec tive equipment in the ball mill area should be encos*aged for those employees who might be in the area for a significant period of time, i.e. greater than 15 minutes. Should you have any questions about this report or require any additional assistance or information, please feel free to contact this office. LLavintsmh Attachment i G. B. layers, M.D. Regional Medical Director <v '?J2 447513 MOSUL OIL CORPO RATIOS Eastern Region Medical Departaant Philadelphia, Pennsylvania Hygiene end Toxicology E. X. #3^-72 '''''rrtoec 19 72 IHDOSTHIAL HTGIEHE STOVE? MOBIL CHEMICAL COMPAH? KAiatAKEE, ILL. Report by: Approved byf ) ; O' 44 447514 i / I INTRODUCTION A special environmental health study t the Kankakee Chemical Coatings Plant vaa performed on November 16, 1972, to evaluate the new ventilation system and the exposure of employees during the use and storage of asbestos--containing talc. In addition, noise level measurements were repeated in the ball mill operation to evaluate current employee exposure to noise in these areas. The evaluation of the asbestos exposure vaa particularly significant in view of the more restrictive measures recently established by the 0. S. Department of Labor under the health and safety regulations of the Occupational Safety & Health Act of 1970 (OSHA). IX SCTOCART & CONCLUSIONS 1. Based on personal air monitors, employee exposure to slrborne asbestos fibers during represemtative paint mixing operations employing asbestos-containing talc is veil below the allowable threshold limit value. 2. Similarly,, atmospheric concentrations of asbestos fibers both in the work environment and in the basement storage area are within allowable limits. 3. The storage and housekeeping of the talc material requires better control - e. g. broken bags should be promptly enclosed In heavy duty plastic bags to ore- vent disoerston of the asbostoa *Abers. ^vrevation nf --.a i.- i " Ta..i ...... -1 4. The new plant ventilation system appears to be functioning according to de sign; however, improvements in the capture efficiency of the overhead hood above the mixing containers are recommended. In some cases, the old ventilating system is still operating in competition with the new system and should be re moved. 5. With the maximum number of ball mills operating, the allowable noise expos ure for employees without hearing protection vould be about four hours per day. Based upon our observations and reports from the foremen, employee exposure would not exceed tvo to chree hours per day. However, we would recommend that workers remaining in the area should be provided with and encouraged to wear bearing protective equipment. 5. The noise levels produced by the small pebble mllla on the third floor are well below the allowable limit for full-tine exposure and vould, therefore, present no hearing damage risk to the workers. Ill ItmUSTRIAL HTCIEME SURVET A. Asbestos Exposure 1. Methods and Procedure The evaluation of exposure to asbestos fibers is based upon both personal moni toring and environmental or area monitoring. In the first case, a 25 millimeter 447515 membrane filter (Millipore, type AA) of 0.8 alcroeeccr porosity we* placed on an open-faced filter holder and attached to the collar of tha workman. The air sample was taken at a sampling rate of approximately 1 Hear par minnta with a battery-operated pump (Hina Safety Appliance Honitaire Pump) which was attached to the employee'a belt. The personal air sample was taken throughout the time employee va# adding and mixing the talc for periods of from^lO to 13 minutes. Concurrently with the personal air monitoring, environmental air sampling was performed in tha nearby work area uaing a 47 millimeter membrane filter (alao Millipore, Type AA) at a sampling rate of about 2 litera per minute. An area sample was also taken in the basement raw material storage area. The membrane filters were sent to an outside laboratory (Trapelo) for micro scopic counting by phase contrast illumination as prescribed by the OSRA health and safety regulations covering asbestos (paragraph 1910.93 a). B. Results 4 Discussion The resnlt3 of the air sampled are -shown in Table 1 below: AIRBORNE ASBESTOS CONCENTRATION K-l Lrf0*^.3 C ^ 3 Cl Baseraenc Storage Area Sampling Tine Mina. 31 vj o ts u u c * /i.3*r5 per ml of air 0.7 K-2 'Uanufacture of Valchera water epoxy-Personal Monitor 13 2.5 JC-3 Manufacture of Valchem vauer epoxy-Area Monitor within 4* 66 mixing vat at breathing level 18 0*3 1 ''mufacturs of Product 1502-04 Hole Color-Area Monitor - Based on scale approximately 5' from vat opening IS 1*9 K-4 Manufacture of Producsr 1502-04 Hole Color-Personal Monitor 10 4.1 Current 0SHA TLV (8 hour time weighted average) 5 Count shall not exceed five (5) fibers -as time-weighted average or 10 at any given tine. 447516 Th* person*! Monitors represent the maximum 1. e. actual exposers time, of the vorksra. It Is sppsrsnt that both this exposure and the concentration la tbs inosdlat* environment are sell below th* allowable eight hour tims-w*ight*d dally average. OSHA regulations also Halt exposure to a concentration of tan fibers per cc of air for any given period of tins, irrespective of time--weighting. Ve would conclude frcna the air saapling survey that the ex posure of the Kankakee personnel to asbestos fibers during paint naxmfactnring i3 veil vithin the present allowable Units. Rot*: A almilarlptudy of asbestos exposure during paint manufacturing was performed in the Edison, Hew Jersey Chemical Coatings Plant and indicated e3entially the same levels of exposure. Basement Storage Ares The air sample in tha basesent storage area was taken when no employees were active In the srsa so that the airborne concentration represents a true back ground level. Although the airborne concentration of.asbestos fibers in this largely unoccu pied ares is well below the allowable time-weighted average of five lAbers per ml, tha fact that soma asbestos fibers are present in tha air tm an indica tion et^SS*- the asbestos was not properly contained. Smut of ch '-n-.t-lining "hi ~.ilc (rr.' r..^nr-..*la \ Z 111, 1C7, 1.ZZ) hau oeen ; do i_aac maCenal spieled out and small quantities St the asbestos presumably became airborne. He would recommend that if the bag or container of the talc or asbestos- containing material is broken, i* should be promptly repackaged or enclosed in a durable and impermeable bag or other closed container. For pumoses of control, it may be advisable to score all the asbestos-containing material together or in a segregated area of the warehouse. B. Ventilation System TIi2 capture velocities at the face of the overhead hooda or flexible exhaust hoses were measured with an Alnor Velometer. Spot checks indicated that the -.tv vaucilacton system provides more than tne minimum capture velocity, e.g. cost readings vers greater than 500 fpa. However, the overhead hood above the Hockaeyer nixing vat should be extended so that it encompasses the widest nixing vat used. A1? the present time, when Che hood is levered as dose to the vat as possible. It covers only about 1/2 to 2/3 of the aiSdLng vat abetileh&e Consequently, solvent vapors and even some dust night not be completely cap tured by this arrangement. At the particular units sampled, the old ventilating system was also still being used. Thus, a flexible duct from the old system was exhausting iir in conpetitiou with the newly designed canopy and should be dismantled. You nay wish to consider incorporating the blowers from the old system into the present system to add increased exhaust rates; however, this does not seem Co be necessary based on our velometar readings and the blowers could also be renoved. 447517 I We also pointed ouc that tha atirrera from oca of the mixing vats were offcenter aottbat tha two Beal-circular cover plates could not be closed for optimise containment. The*a pLfctes should be refabricated, preferably -with a hatch cover for introduction of the rw materials. C. Boise Survey 1. Method Tha noise- measurements were made vlth a GeneralKadio, type 1565-A Sound Level meter which was calibrated accoustlcally just prior to tha measurements. The measurements In decibels were taken on the A-scale, which preferentially record* the noisa level in tha speech frequencies and is the scale uaed by OSHA to define peralsaibl* noise limits. Readings were aadd. on the second floor ball mill area when tha most probabla number of ball ni n were operating and also on tha third floor pebble mill area. The degree of employee exposure, i.a. the relative amount of time the workers spend in the area was also noted. 2. Results and Discussion Results of the noise survey See shown in the table below. 4i\J A.W -i J O A > L 1 Location Conditions Sound Level, A-scale, decibels 2nd floor Ball Mill Area Range Center of area Average anbient reading 4-5 units operating 6 units operating 6 units operating 91.5 - 93 92/0 - 95 95 93 3rd floor - Pebble Hills 1 nill on, loaded 1 mill on, dry 81 95 OSHA PERHISSIBLECtOlSE EXPOSURES Duration per day, hours 8 6 4 3 2 1 Sound Level, A-scale In decibels 90 92 95 97 100 105 447518 According to Ch* OSHA sola* criteria, ball mill employees may b* expo*ad to ch average aabient noia* level of 93 dB(A) for about 5 hour* a day, day after day without requiring bearing protection. During the entire elm* of our survey, v% did not observe any workers remaining in the work area despite eh* face that 5 all la were operating. The formen estimate that the workers would not actually be in tha work area sore than a marlana* of 2 to 3 hours oe any given day. Therefore, based on present OSHA criteria, the plant workers are not exposed to excessive levels of noise. The noise level by the pebble sill area when fully loaded and operating is only 81 dB(A) which Is veil below the allowable Unit for full rise, l.e. 8 hours per day, day after day exposure. Although we conclude that tha exposure to employees on the 2nd floor ball mill area is within allowable limits, the level is sufficiently high to warrant encouraging employee* to wear hearing protectors if they are In the area for any significant period of tine, d.e. sore than IS alnutea at a tine. Our reasons are that high level noise, l.e. above 85 dB(A) is capable of producing hearing damage with acme individuals and therefore it would be good work and safety practice to promote an ear protector of the wployee's choice when working in the are*. Secondly, it Is likely that OSHA will ultimately lower the allowable noise levels to assure greater protection for the reason cited. Consequently> va would serve both the employees' and the Company'a best interests with this preventive approach. 447519