Document VV9BXG2Enxzy9mX47omrqVrw

January 13, 1988 SHELL OIL COMPANY One Shell Plaza P. 0. Box 4320 Houston, TX 77210 PLAINTIFF'S EXHIBIT Mr. J. E. Krebs, Manager-Production Offshore - East Division Shell Offshore, Inc. P. 0. Box 61555 New Orleans, LA 70161 Dear Mr. Krebs: REFERENCE: SHELL OIL COMPANY/SHELL OFFSHORE, INC. SERVICE AGREEMENT EFFECTIVE 1/1/82 _ ~ y> - -I __ . ^ . ' j - ^ Attached are the final reports of the Medical and Health and Safety Compliance Assessment Reviews (CAR) conducted by Shell Oil Company's Health, Safety and Environmental organization during July, 1987 for three platforms of your division. In accordance with established CAR procedures, follow-up response from the division is required for those findings classified as "Serious Deficiencies" or "Concerns". No "Serious Deficiencies" were determined 'to exist in these reviews. The follow-up reporting is to be directed to Shell Oil Company, Head Office, ESP, Production, Safety and Environmental Affairs as described in Mr. J. E. Little's letter of October 5, 1987, copy of which is attached. We appreciate the cooperation and assistance of your staff during these reviews. Sincerely yours, ffi. A. Mullins, Manager u/Envi-r-o--n--m---e-nr tal Programs Attachments (3) CD8801304 - 0001.0.0 LAM 024008 ABS-007190 cc - Shell Offshore, Inc. President General Manager, Production Shell Oil Company General Manager, Drilling and Producing Operations General Manager, Auditing General Manager, Production, Safety and Environmental Affairs Assistant General Counsel - E&P/Corporate General Attorney - Chemical/Environmental Senior Staff Safety Engineers, Production SEA HS&E-AS(2) . Shell Oil (w/o Attachments) Manager, Regulations and Safety Services, HS&E Assistant Corporate Medical Director, HS&E . ~ CD8801304 - 0001.1.0 LAM 024009 ABS-007191 HEALTH SAFETY COMPLIANCE ASSESSMENT REVIEW EXPLORATION & PRODUCTION SHELL OFFSHORE, INC. JULY, 1987 A. health and safety compliance assessment review was conducted during the period July 20 to 23, 1987. The review provides an independent assess ment that systems for implementing laws, regulations, and Shell policies pertaining to health and safety exist and are working effectively in the function. The review was conducted by representatives of_tne Health, Safety and Environmental organization: J. D. Harris, Safety and Indus trial Hygiene Department, and D. E. Miller, Corporate Medical. The Corporate Medical findings are reported separately. The review process included interviewing supervisory, safety support, and selected operating personnel; touring three platforms (Cognac, 65-B and 311-A); and sampling certain records to determine the compliance status. The federal regulatory agency rules examined included these cf the Occupational Safety and Health Administration (OSHA', the Minerals Management Services (MMS) Outer Continental Shelf orders, the United States Coast Guard (USCG), and the Department of Transportation (DOT). Certain Company requirements were examined also. In a compliance review, results are classified as serious deficiencies, concerns, or observations. A serious deficiency is a finding by the reviewer, which in the judgment of the manager of the responsible HS&E department, indicates (1) a lack of sufficient awareness to assure compliance, or (J) specific deficiencies which are likely to result in substantial ncn-ccrrpliance; substantial harm to employees, public or the environment; citations that could result in substantial fines or criminal prosecution; or major adverse publicity. A concern is a compliance problem that does not qualify as a serious deficiency. Serious deficiencies and concerns will be accompanied by recommended corrective actions, intended to help clarify both the problem and the nature of remedial actipn. Locations are expected to prepare a correc tive action plan for serious deficiencies and concerns, with an accompa nying implementation schedule, periodic status reporting, and a completion notice. Observations are intended to supplement the overall assessment, and do not require corrective action or follow-up. LAM 024010 CAB8721102 ABS-007192 2 Summary In general, the Offshore East Production Division has systems in place for implementing laws, regulations and Shell policies pertaining to safety and health. These systsns are working effectively. No serious deficiencies were noted during the review. Some concerns were identified. They are discussed below. Concerns and Recommendations Concerns requiring action are highlighted below. A more detailed listing is presented in the attached summary worksheets showing both strengths and areas for improvement in each category and for each location. CAB8721102 LAM 024011 ABS-007193 3 law 024012 (3) Substance Exposures - Although an abrasive blasting procedure exists, the potential for silica and lead dust exposures may possibly occur during the abrasive blasting of equipment in preparation for repainting. In the past, contractors have used silica sand for abrasive blasting to remove lead based paints. The abrasive blasting agent used recently may yet be crystal line silica sand, but operations personnel are uncertain. Also, the primer paints now used still may contain lead. Platform personnel indicated that the Shell Engineering Guide lines allow for the continued use of lead-based paints T'or selected end uses. The personnel did not reference the HSSE CAB8721102 ABS-007194 4 '3 guideline that lead free paints be used where possible for new applications to prevent incidental exposure from either drifting freshly applied paint or debris from sand blasting old painted surfaces. Although the blasting area is barricaded, the drift may contaminate some of the work stations elsewhere on the platform. No monitoring data exist to aid in assessing the potential for personnel exposures. OSHA 1910.1000 and 1910.1025 Recommendation - Obtain a sampling of the dust exposure potential during abrasive blasting operation under conditions which allow a dust cloud to drift to other parts of the plat form. Sample and analyze for silica and lead. Review results with Industrial Hygiene Services. (All locations) CAB8721102 LAM 024013 ABS-007195 1 9 0 7HEALTH AMD SAFETY REVIEW SUMMARY WORKSHEET -- J u ly _____ 0RGANI7ATI0N ERP S h e ll O ffs h o rn In c . _______ REVIEWER J . D. 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