Document RpK5RVzqB1eZ6d9dmgGmJzaxE

DATE: August 7, 1992 FROM: Michael Bergstrom, Project Engineer TO: E.M. Hawthorne R.A. Ott J.J. Niklas SUBJECT: VARIANCE FROM SAFETY ORDER S-144. FIRE RETARDANT CLOTHING Present Situation The contract work on V-BD-990, Site III, was awarded, and the first two phases of work are started. The total scope of contract work includes: - scaffolding the sphere - enclosing the sphere/scaffolding with plastic - removing the mastic coating which contains asbestos - removing the foam glass insulation - sandblasting the red lead paint primer - repainting the sphere with rollers - reinsulating the sphere The area around the sphere is considered an FRC required area. The sphere is empty and isolated from all other process. Appropriate personnel and equipment access over the concrete firewalls is nearing completion. The asbestos disposal dumpsters are located on the west side of the sphere, and the decontamination trailer is located on the southwest corner of the diked area. DPMC Policy The existing DPMC policy states the requirements for FRC use. These requirements include: - long sleeve FRC must be worn by all personnel while in field locations, including operating unit areas, tank farms, hydrocarbon loading/unloading areas, motor control centers, laboratory areas, hydrocarbon handling areas, etc. FRC is worn for initial opening of all process equipment, by vacuum truck operators, and in enclosed areas when flammable dust is generated. Proposed Variances from DPMC Policy We are requesting that the area identified in the attached drawing be temporarily classified as a non-FRC area. We want to be able to do the remaining work without wearing FRC clothing. The remaining work includes the last 5 phases of the DPMC-16027 LAM 000312 project list above. The insulation removal portion of the work is routinely exempted from FRC requirements throughout the Complex because we are unable to find a laundry that can handle asbestos contaminated clothing. Additionally, the insulation removal workers wear "cool suits" to reduce the added heat stress factor of working inside the plastic enclosure. The other phases of the project will also be conducted under the plastic enclosure with the same heat stress complications. Safeguarding for the Variance The sphere is empty and blinded. We will use a firewatch to patrol the north, west, and south sides of the plot. The firewatch can quickly identify any leaks/releases that can present a danger to the workers inside the plastic enclosure, and sound an evacuation alarm to the workers inside the enclosure. This variance has been discussed with the appropriate area H&S inspector, supervisor, and group leader. Please sign below giving permission to classify the worksite as a non-FRC required area. Michael Bergstrom APPROVALS: tt, Superintendent,Solvents & Distribution LAW1 000313 DPMC-160 I k ij fs**' r (a//Li cropa cbavix3. c-7137* t-7vrr C-TOBO c-7uz C-7U83 C-713M serr i or 7 ocscocr EouincxT - irrt m jjcct * cr 7 oasxxrr cannon - inr m BCETI OT 7 OCKGOCT COumOCT - Hit m scet s or 7 cxscocT eauinocT - nrc m SCOT * or 7 OCBGDCT EOUWOCT - IITC m SCET 7 CT 7 OOCGDCT COUinCXT - SITE D i LAM 000314 DPMC-16029 DPMC-16030 DPMC 16026.1 LAM 000311 02,c 1 JuP + P & {* t i) * ? * ^* s fV A l-1 ^ '