Document YK8QOnZ3dpnRkkD4qZ8BeO3D

ESIS. me. 3 ClG^A company liai w. Mockinepifdiene Suite 903S Dallas. TX 75247 (214)631-4919 April 17, 1985 Mr. Terry Lohman Plane Manager ' J-M MANUFACTURING Denison, TX 75020 Re: ESIS 31-180 . Dear Mr. Lohman: On March 18 and 19, 1985, 1 visited- your plant to conduct an Environmental Health Survey. As a result of this visit, I am submitting the attached recom mendation which I discussed with you. This recommendation should receive your immediate attention and consideration. You will also find the results of the Environmental Health Report attached. This report contains the results of our survey and is an indication of the environmental health conditions that existed at that time. . I wish to thank you and your staff for the cooperation that was extended during the course of this visit. Will you please advise us or confirm the actions you plan to take regarding these recommendations. Very truly yours, Aileen Teng Certified Industrial Hygienist AT/sh cc: Dr. E. Edward Wang, Ph.D. J-M Manufacturing Co., Inc. A/C Pipe Corp. 1051 Sperry Rd. Stockton, CA ' 95206 Ms. Beth Ingleston Alexander & Alexander of New York 1185 Avenue of the Americas New York City, NY 10013 ' APR. 1 9 1985 D 002244 SC-JMM-2890 NAME: J-M Manufacturing LOCATION: CIGNA Denison. Texas 85-1 . The asbestos exposure levels were all within the current OSHA eight hour permissible exposure limit of two fibers/cc. OSHA issued a proposed standard for asbestos in April 1984 to lower the permissible exposure limit to either 0.2 fibers/cc or 0.5 fibers/cc. It is expected that a new standard will be promulgated in the summer of 1985. It is recommended that the OSHA proposed standard be used as a guideline to evaluate the worker's exposure. The sample results indicated that ten employees were exposed to asbestos levels over 0.2 fibers/cc. Of the ten, three were exposed to levels over 0.5 fibers/cc. The elevated dust concentrations may be caused by inefficient dust col lecting systems, poor housekeeping and poor work practices. To assure that the dust collecting systems are functioning properly, scheduled inspections should be conducted. If a marked reduction in performance is noted, the cause of the reduction should be identified and corrected. An industrial type vacuum cleaner equipped with a high efficiency filter system should be used to keep the workplace as free from asbestos dust accumulation as possible. Before the exposure levels can be reduced to within OSHA proposed permissible exposure limit, NIOSH approved dust masks should be worn by the workers whose exposure levels were over the proposed limit. OMAMa Ptd.inU.S.A. D 002245 environmental health report - PREPARED FOR: J-M Manufacturing Denison, Texas CONTRACT NUMBER: ESIS 51-180 PREPARED BY: Aileen Teng Certified Industrial Hygienist Loss Control Services, Inc. ACCOMPANIED BY: Terry Lohman, Plant Manager DATES OF SURVEY: March 18 and 19, 1985 D 002246 ENVIRONMENTAL HEALTH REPORT -- INTRODUCTION On March 18 and 19, 1985, an industrial hygiene survey was conducted at JrM Manufacturing, Denison, Texas to evaluate the employee exposure to asbestos fibers associated with the manufacture of asbestos cement pipes. The survey was conducted at' the request of J-M Manufacturing as part of an on-going asbestos monitoring program. The standards, guidelines, methods, results, and discussion pertinent to this report follow. STANDARDS & GUIDELINES The results of this report are based on current OSHA standards and/or accepted state of the art Industrial hygiene practices to give reasonable protection to the health and well being of your employees. . METHODS Air sampling and analyses were conducted, using the following methods: Air Contaminant Vacuum Source Flow Rate Collection Medium Sampling & Analyses Methods Asbestos Du-Pont P-2500 Sampling Pumps, MSA Model G Sam pling Pumps, & Gilian Model HFS-113A Sam pling Pumps 1.4 1.6 1pm Open face AA filters NIOSH P & CAM 239; PCM 1pm: liters per minute PCM:- Phase Contrast Microscopy, Porton Reticle; 450 x magnification. Samples were collected in the workers' breathing zones to obtain samples indic ative of actual employee exposure. Sampling pumps were calibrated prior to and after the sampling period. All analyses were performed by Environmental Health Laboratory which is accred ited by the American Industrial Hygiene Association. RESULTS Results of asbestos sampling are presented in Table I. -1- D 002247 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA JOB DESCRIPTION (J-M NO.) 13' Control Operator (D-2WE) EMPLOYEE NAME Jim Lang DATE AIR TWA SAMPLED CONC. (1) (fibers/cc) (fibers/cc) 3/18/85 0.087 0.087 SAMPLE . TIME (MIN.) 223 SAMPLE VOLUME (LITERS) 334.5 13' Utility Operator (D-8WE) Paul Morrison 3/18/85 0.12 0.12 226 316.4 13' Tender (D-1WE) Philip French 3/18/85 0.22 0.22 0.22 114 106 175.56 159 COMMENTS ti 13' Head Curcr (D-3WE) Arthur Dawson 3/18/85 0.15 0.14 0.14 233 238 349.5 357 13' Curer (D-3WE) Betty Morrow 3/19/85 0.18 0.18 226 339 (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday* This determination is based on the assumption that the air concentration during sampling period is representative of the exposure level for the entire shift. D 002248 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA I JOB DESCRIPTION (J-M NO.) Salvage Truck Driver (D-10S) EMPLOYEE NAME Johnny Crain DATE AIR TWA SAMPLED CONC. U) (fibers/cc) (fibers/cc) 3/18/85 0.085 0.085 SAMPLE . TIME (MIN.) 243 SAMPLE VOLUME (LITERS) 364.5 Willow Operator (D-7WE) Danny Hunt 3/18/85 0.15 0.15 233 358.82 COMMENTS It Gen. Service Man 'Operating Salvage Grinder (D-8WE) Gary Neil 3/19/85 0.24 0.29 Steam Tank Opera tor Emmett Morrison 3/19/85 0.055 0.27 123 114 0.055 239 189.42 175.56 334.6 In-Process Inspector (D-13S) Kevin Hannan 3/19/85 0.14 0.14 218 335.72 (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday. This determination is based on the assumption that the air concentration durtng sampling period is representative of the exposure level for the entire shift. D 002249 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA JOB DESCRIPTION (J-M NO.) EMPLOYEE NAME Large Coupling Cut Off Operator (D-15F) Dill Barnea DATE AIR TWA SAMPLED CONC. (1) (fibers/cc) (fibers/cc) SAMPLE . TIME (MIN.) 3/19/85 1.3 1.5 1.4 223 227 SAMPLE VOLUME (LITERS) 343.42 364.98 Small Coupling Cut Off Operator (D-23F) Larry Lewis 3/18/85 1.2 1.2 252 378 PVC Fitting As sembly Molder (D-11F) Paul Franks 3/18/85 PVC Fitting Assembly - Molding Swing Saw Operator (D-12F) Donna Simpson 3/19/85 0.3 1.2 0.3 * 190 266 1.2 206 288.4 Finishing Area Crew Leader Bob Reynolds 3/19/85 0.081 0.081 226 .339 COMMENTS h. (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday. This determination is based on the assumption that the air concentration during sampling period is representative of the exposure level for the entire shift. D 002250 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA JOB DESCRIPTION (J-M NO.) MOA Operator (D-6F) EMPLOYEE NAME DATE AIR TWA SAMPLED CONC. (1) (flber8/cc) (fibers/cc) Gary Templeton 3/18/85 0.28 0.56 0.4 SAMPLE . TIME (MIN.) 131 92 SAMPLE VOLUME (LITERS) 201.74 141.68 COMMENTS U UPL 01 Unit Loader (D-3F) Benny Stanley 3/18/85 0.16 UPL 02 Operator (D-2F) Billy Gordon 3/18/85 0.15 UPL 02 Helper Glen Weger 3/19/85 UPL 02 Inspector (D-US) Billy Sexton 3/19/85 0.13 0.13 0.42 0.16 222 0.15 224 0.12 0.42 232 236 231 333 Handling 6" class 150 pipes 336 357.28 363.44 346.5 Handling 12" class 150 pipes Handling 12" class 150 pipes Handling 6" class 200 pipes on UPL 01 Handling 12" class 200 pipes (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday. This determination is baaed on the assumption that the air concentration during sampling period is representative of the exposure Level for the entire shift. D 002251 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA JOB DESCRIPTION (J-M NO.) EMPLOYEE NAME UPL 02 llydrotester Lee Crain Operator DATE AIR TWA SAMPLED CONC. (1) (fibers/cc) (fibers/cc) 3/18/85 0.23 0.23 SAMPLE . TIME (MIN.) 229 SAMPLE VOLUME (LITERS) 343.5 COMMENTS Handling 12" class 150 pipes UPL 02 Unit Loader (D-5F) Ellis Pittman 3/19/85 0.19 UCL 01 Operator (D-16F) Jim Melvin 3/18/85 0.14 0.19 226 0.14 * 200 348.04 Handling 12" class 150 pipes 300 Large Coupling Lathe 0347 Larry Hallmark 3/18/85 0.10 0.10 266 404.64 Slash Saw Operator Dock Dill (D-1F) 3/19/85 0.3 0.3 208 312 (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday. This determination is based on the assumption that the air concentration during sampling period is representative of the exposure level for . the entire shift. D 002252 J-M MANUFACTURING, DENISON, TEXAS ASBESTOS AIR SAMPLING DATA JOB DESCRIPTION (J-M NO.) EMPLOYEE NAME Finishing Area Platform Driver (D-30F) Jerry Bruce Coupling Testing Area Inspector James Bush DATE AIR TWA SAMPLED CONC. U) (fibers/cc) (fibers/cc) 3/19/85 0.16 0.16 SAMPLE . TIME (MIN.) 237 SAMPLE VOLUME (LITERS) 379.2 3/19/85 0.17 0.17 218 327 COMMENTS li Sweeper Operator (D-6S) Jack Bartley 3/19/85 0.18 Mechanic (0-26S) M.E. Abernathy 3/19/85 0.12 Electrician (D-15S) W.L. McCleskey 3/19/85 0.10 0.18 238 0.12 224 0.10 230 357 336 345 (1) T.W.A. - The Time Weighted Average concentration for a normal 8 hour workday* This determination Is based on the assumption that the air concentration during sampling period is representative of the exposure level for the entire shift. \ 0 002253 ENVIRONMENTAL HEALTH REPORT < DISCUSSION The production line for 10 foot pipes was shut down permanently in November 1984. As a result, mono saw, fitting lathe, mono lathe, radial drill, nipple lathe, perforator drill, and K & C lathe are no longer in operation. As can be seen from the 'sample results presented in the Results section, all the exposure levels were within current OSHA eight hour permissible exposure limit of two fibers per cubic centimeter of air (fibers/cc) OSHA issued an emergency temporary standard on asbestos in November 1983 which lowered the permissible exposure limit to 0.5 fibers/cc. The emergency temporary standard was declared invalid by court in March 1984. Subsequently, OSHA issued a proposed standard for asbestos in April 1984 to lower the permissible exposure limit to either 0.2 fibers/cc or 0.5 fibers/cc. It is expected that a new standard will be promulgated in the summer of 1985 to lower exposure limit to asbestos to 0.2 fibers/cc or 0.5 fibers/cc. ' .' - It is recommended that the OSHA proposed standard be used as a guideline to ' evaluate the workers' exposure. The sample results indicated that ten employees were exposed to asbestos levels over 0.2 fibers/cc. Of the ten, three (large coupling cut-off operator, small cut-off operator, and molding swing saw operator), were exposed to levels over 0.5 fibers/cc. In finishing area, asbestos level of.each location sampled was higher than the levels found in the previous industrial hygiene surveys. The elevated dust con centrations may be caused by ineffective dust collecting systems, poor house- keeping, and poor work practices. To assure that the dust collecting systems are functioning properly, scheduled inspections should be conducted. If a marked reduction is noted, the cause of the reduction should be identified and corrected. The reduction In performance can often be traced to one or more of the following items: A. Reduced performance by the exhaust fan caused by reduced speed due to belt slippage, reversed rotation, wear on rotor or casing, or accumu lation on rotor or casing that would obstruct air flow. B. Reduced performance caused by defects in the exhaust piping, such as . accumulations in branch or main ducts due to Insufficient conveying velocities, condensation of oil or water vapors on duct walls, adhesive characteristics of material exhausted or leakage losses caused by loose clean-out doors, broken joints, holes worn in duct, poor connec tion to exhauster inlet, accumulations in ducts or on fan blades. C. Losses in suction velocity can also be charged to additional exhaust points added to the system and change of setting of blast gates in branch lines. 8- - D 002254 ENVIRONMENTAL HEALTH REPORT DISCUSSION (Continued) . D. Reduced performance may be caused by increased pressure loss through dust collector due to lack of maintenance, improper operation, wear, etc. . In addition to the dust collecting systems, a wet method can be used effectively to control asbestos dust. Flooding or spraying at the point of dust generation (e.g., large coupling cut-off, small coupling cut-off, molding swing saw) is a typical method. The sprays, nozzles, and runoff controls need to be precisely designed for compatibility with the machine. 4 A mobile floor sweeper Is used to prevent workplace from asbestos dust accumu lation. However, the sweeper can only clean aisles and open floors. Dusts accumulated under and between machines and on the surface of the machines and workbenches cannot be removed. It is recommended that an industrial type vacuum cleaner equipped with a high efficiency filter system (9^Z efficiency for 0.3 _jmn diameter aerosols) be used to keep the workplace as free from asbestos accu mulation as possible. Appendix I contains literature on one of the asbestos vacuum cleaners on the market. NIOSH approved dust masks should be made available to the workers and the use of the dust masks encouraged. The workers whose exposure levels were over OSEA proposed permissible exposure limit should be required to wear the dust masks until the exposure levels are reduced to within the acceptable limit. CONCLUSION Implementation of the above mentioned recommendations should assist you in pro viding a more healthful working environment and reduce the potential for occu pational disease. -9- D 002255 INUTBMAN ** - *.r. i- * r * MEETS OR EXCEEDS OSHA REQUIREMENTS FOR REMOVING AND TRAPPING DANGEROUS ASBESTOS DUST AND FIBERS AND OTHER HAZARDOUS DUST PRIMARY STANDARD FILTER - DISPOSABLE DEBRIS -' -- .-.-JMPACTION ---- .* . 7S. - ;- r plastic"1' r. ' PROTECTOR ^OR . - DISPOSABLE ' ' -DEBRIS CONTAINER . w-V v`- i* '/ D 002256 Specially engineered to provide elfiden: and dependable protection against the serious hazard of asbestos dust and otlwhealth endangering airborne pollutants. S*T OTHER s/d: ASBESTO 5 STAGE FILTRATION SYSTEM 3. Final high efficiency filter certified to exceed OSHA requirements 2. impact filter. 1. Coarse filter -- disposable, I paper bag I i 5. Paper filter protector The well established hazards of asbestos dust have resulted in strict safety regulations by OSHA and Federal Register. Volume 29. No. 125 dated June 27. 1974 Section No. 1910. 2a (b2) states that, effective July 1. 1976. The 8-hour time . weighted average airborne concentrations of asbestos fibers to which an employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method prescribed in Paragraph (e) of this section" The Minuteman ASBESTOS and irritant dust vacuum has been specially designed to aid in complying with these Federal regulations. A certified three stage filtering system provides an efficiency rating of 99.999% on particles of 5 micrometers in size-- exceeding OSHA requirements. . While control of asbestos dust has come under closest government scrutiny, this specially filtered vacuum is also highly beneficial in the filtering of other toxic airborne pollutants such as: petroleum catalyst dust, cement dust, foundry dusts, lime kiln dusts, insecticide dusts, fertilizer plant dusts and fumes, pulverized coal dust, ground limestone dust, asphalt paving dusts and others. SPECIFICATIONS f Tank 71S gal AMPS Static Air * . 11SV .. :--UH Vofurae. Height - Cord 7 .-: . --75' - 91 CFM - ;~3ZmW: 150' 16-3 Specifications According To Manufacturer's Ratings .i AMERICAN CLEANING EQUIPMENT CORPORATION 111 South Route S3. Addison. Illinois 60101 1312) 627 E900 D 002257 H/Smut&msm Series 800 Critical Filter Vacuums - Vacuums . Effective 4/15/81 Stt Vacuum Tools and Attachments tor accessories. Asbestos Vac 15 Pne C-80315-01 Minuteman Asbestos Vac--H.E.P.A. Filter Vacuum (115V. 15 Gal.. Stainless SteeL Dry Only) Includes: 75021-90--Lid Assembly (115V) W/H.E.P.A. Filter 5483.00 80501 -50 -- Cloth Filter 75022-01 --Tank Assembly Stainless Steel. S 36.50 15gaL 38004-90 -- Bag frame 76059-90-- impact filters (10) S368.70 S 7.70 S 2335 80503-80-- Filter Protectors (10) 75059-60-- Disposable Bags (10) $ 16.80 S 2335 76104-20-- Plastic Bags (50) . 76053-60--H.E.P.A. (Replacement) S 18.65 S194.00' S786.00 C-80315-02 Minuteman Asbestos Vac -- H.E.P.A. Filter Vacuum (220V. 15 GaL Stainless SteeL Dry Only) Same as (C-80315-01) except 75021-91 lid assembly (220V) 5493.00 5796.00 C-80315-03 Minuteman Asbestos Vac -- FLE.P.A. Filter Vacuum (115V, IS Gal.. Painted. Dry Only) includes: 75021 -90--Lid Assembly (115V) w/H-E-P.A. Filter $483.00 80501 -50 -- Cloth Filter S 36.50 75022-00--Tank Assembly Painted. 15 gal. S229.00 38004-90 -- Bag Frame $ 7.70 75059-90 -- Impact filter (10) S 2335 80503-80 --Filter Protectors (10) S 16.80 76059-80--Disposable Bags (13) S 2335 76104-20 --Plastc Bags (50) S 18.65 76059-60-- H.E.P.A. (Replacement) S194.00 S696.00 C-80315-04 Minuteman Asbestos Vac -- H.E.P.A. Filter Vacuum (220V. 15 GaL. Painted, Dry Only) Same as (C-80315-03) except 75021-91 lid assembly (220V) ' $493.00. S706.00 ASBESTOS VACUUMS Because it meets or exceeds OSHA requirements for cleaning the air of asbestos and other toxic and noxious dusts, this (fry-only vacuum can be used, in offices, schools and industrial areas where daily or weekly re moval of sub-micron particles is necessary. Each Minuieman Asbestos Vacuum contains 5 different titters: disposable paper bag coarse fitter (standard in 15 gal. models) for the bulk of the panicles, impact filter. H.E.P.A. filter, primary cloth filter and paper filter protector. Heavy-gauge plastic drum-line' bags may be used in the 30 and 55 gallon models to safely remove large-volume pick-ups. While specifically designed for as bestos panicles, this vacuum is also effective in filtering other airborne pollutants such as cement, foundry and lime kiln dusts, insecticides, fer tilizer dusts, coal dust fimestone dusts, and many others. With an effi- ciency rating of 99.999% on panicles of 5 micrometers, the Asbestos Vacuum is particularly useful for cleaning up after insulation operations on pipes, in removing asbestos-covered ceiling dust to prevent' snowing" and for vehicle maintenance procedures involving brakes, clutches and other asbestos-loaded material. Each unit features a 2 stage by-pess motor, from casters, 8" rear wheels and a carriage handle. An optional starter tool kit is recommended lor each unit --Effi H.E.P.A. Filter Impact Filter Cloth Filter Filter Protector Disposable Bag Intake Exhaust D 002258 fr ies 800 Critical Filter Vacuums * t fcO Ehertive 4/'.5 81 See Vacuum Tools and Attachments tor accessories. Asbestos Vac 30/55 ;30-0l Minuteman Asbestos Vac--H.E.P.A. Filter Vacuum (115V. 30 Gal.. Painted, Dry Only) Includes: 75021-90- Lid Assembly (115V) W/KE.P.A. Filter S483.00 80504-70 --Cloth Filter S 46JO 80601-70--Adapter Ring (30 gal.) . S102.00 90007-80--Tank Assembly Painted. 30 gal. SI26.00 90004-80 -- Dolly Cart S137.00 76059-90--Impact filter (10) S 2335 80503-80--.Filter Protectors (10) S 16.80 80503-70 -- Plastic Drum finers (12) S 23-25 76059-60--H.E.PA. filter (Replacement) S194.00 $957.00 30-02 Minuteman Asbestos Vac--H.E.RA. Filter Vacuum (220V. 30 Gal.. Painted. Dry Only) Same as (C-80330-01) except 75021-91 lid assembly (220V) 5493.00 $967.00 55-01 ' Minuteman Asbestos Vac--H-E.P-A- Filter Vacuum (115V. 55 Gal., Painted, Dry Only) Includes: 75021-90--Lid Assembly (115V) w/H.E.PA. fitter 5483.00 80504-70 --Cloth Filter $46.30 80601 -80--Adapter Ring (55 gal.) $102.00 90001-50 --Tank Assembly Painted. 55 gal. S 92.00 90004-80 -- Dolly Cart $137.00 76053-90- Impaa imers (10) S 23.35 80503-80-- Filter Protectors (10j S 16.80 80504-60--Ptastic Drum liners (12) S 25.70 76C55-60 -- H.E.PA. (Replacement) Si 94.00 5926.00 55-02 Minuteman Asbestos Vac -- H.E.P.A. Filter Vacuum (220V. 55 Gal.. Painted. Dry Only) Same as (C-80355-Ot) except 75021-91 lid assembly (220V) $453.00 $936.00 :9-00 rf7a Tool Kit For Asbestos Vac Dry only) Includes: ' a. 80101-00--Iff x TVj" Hose b. 80001-50--iVa' Wand (Operator's handle) c. 80007-00--Guiper Tool d. 80002-40--3" Round Brush e. 80011-60-- TVj" x 8" Swivel Connector 1. 76059-80--10 Disposable Paper Bags g. 76059-90--12 Impaction Pre-Filters h. 76104-20--50 Plastic Bags i. 80503-80--12 Filter Protectors No substitution ol tools. $218.00 40.40 28.75 38.00 14.75 14.75 2335 2335 18.65 16.80 r- 002259