Document a165Ve2x8byr575az9d8BQL3B

SHELL DEER PARK MANUFACTURING COMPLEX COMPLEX PLAINTIFF'S EXHIBIT SH-1776 ASBESTOS SAFETY S--125 PAGE 1 OF 7 JANUARY 15, 1987(R) I. INTRODUCTION Asbestos is a mineral silicate occurring naturally as a variously colored fiber. It is non-combustible, non-conducting, and resistant to deterior ation and chemical attack. Because of these properties, it has found widespread use in thermal insulation, asbestos floor tile, roofing and transite materials, gaskets, coatings, plastics, and brake linings. Because of its fibrous nature, it can be woven into cloth, or used to add strength to other materials. Asbestos is a potential health hazard when taken into the body even in very low concentrations. Asbestos fibers are associated with a variety of diseases, including (1) Asbestosis - a non-malignant scarring of the lungs; (2) Bronchogenic Carcinoma - a malignancy (cancer) of the lung; (3) Mesothelioma - a malignancy of the lining of the chest cavity; and (4) cancer of the stomach, colon, and rectum. These diseases develop slowly, and usually do not become evident until many years after initial exposure. Asbestos fibers can enter the body via the breathing process or via eating/drinking. The small lightweight asbestos fibers easily become "airborne" and can contaminate the work area. Recent scientific studies have shown that individuals who smoke and have exposure to asbestos have a significantly greater health risk than asbestos workers who don't smoke. The 8-hour time-weighted average (TWA) permissible exposure limit (PEL) for asbestos is 0.2 fibers, longer than 5 micrometers, per cubic centimeter of air (f/cc). No employee shall be exposed to airborne concentrations of asbestos equal to or exceeding the PEL. Asbestos is most frequently encountered within the Complex as insulation on pipes and structures installed prior to 1973. While purchase of new insulation containing asbestos has been discontinued, asbestos insulation may be encountered in older units for many years to come. II. GENERAL PRACTICES 1. Asbestos-containing materials shall be handled in a wet state whenever practical. Engineering controls, such as enclosures, exhaust ventilation, or dust collection should also be used where required to maintain exposure to asbestos below the PEL. As a precaution, respirators shall be worn for all tasks which involve disturbance of asbestos-containing, materials (refer to Respirator Safety Order for proper respirator selection). BCAE8524103 LAM 027185 ABS-008696 ASBESTOS SAFETY S--125 PAGE 2 OF 7 JANUARY 15, 198700 2. Wherever practicable, replace materials containing asbestos with non-asbestos substitutes. Insulation containing asbestos shall not be purchased, and asbestos blankets and insulating tape may not be used. 3. In the absence of specific knowledge to the contrary, treat all insulation as containing asbestos. Insulation can be verified as non-asbestos material by (a) field tests performed by the Health & Safety Department, or (b) specific knowledge that the insulation was installed after 1973, which is the date when DPMC began using only non-asbestos insulation. All units which have asbestos-containing materials installed shall post signs at the unit boundaries which state: THIS UNIT CONTAINS ASBESTOS MATERIALS. 4. Reinsulate equipment that is frequently maintained, such as control valve manifolds, pumps, etc., with non-asbestos insulation at an early opportunity. Equipment insulated with asbestos may be sent outside the Company for maintenance, providing the insulation will not be disturbed or removed for that maintenance, and providing that such equipment shall be accompanied by notification that the insu lation contains asbestos. This notification shall include the standard asbestos warning label on the equipment (see Attachment I) and suitable notices accompanying the truck manifest and the purchase order. Asbestos insulated equipment that requires maintenance which will disturb the insulation shall have the asbestos thoroughly removed prior to leaving DPMC. Execution of these reinsulation programs and notification practices are the responsibility of the Shell supervisor or foreman most immediately involved in arranging for the equipment transfer. 5. Use work permits to ensure compliance with asbestos work practices for maintenance tasks. It is the joint responsibility of maintenance " and operating representatives to anticipate encountering ^asbestos when planning a job or preparing a work permit. When asbestos will be encountered, the departmental safe work permit shall specify "asbestos work practices in effect; respirator required". 6. All insulated equipment that is to be disposed via salvage shall have insulation removed at the originating location. Insulated equipment will not be accepted at the salvage yard. However, by special arrangement with Material Control, large pieces of equipment with non-asbestos insulation may be sent to salvage. LAM 027186 III. DEFINITIONS 1. Regulated Area - Any work area where asbestos exposures may reasonably be expected to equal or exceed the PEL. Regulated areas shall be identified with warning signs (Attachment 1) and roped off with hazard warning tape. Access to regulated areas shall be limited to authorized personnel. All persons entering a regulated area shall wear an approved respirator and protective clothing. All BCAE8524103 ABS-008697 ASBESTOS SAFETY S-125 PAGE 3 OF 7 JANUARY 15, 1987 (R) persons working in areas surrounding regulated areas shall be informed as to the nature of the work to be performed and of the existence and requirements of the regulated area. Negative pressure enclosures shall be established where required to maintain asbestos concentrations below 0.1 f/cc in areas surrounding the regulated area. Exposure monitoring will be required (contact Industrial Hygiene). A competent person will be required onsite to insure all requirements are being followed. 2. Restricted Area - Any work area where asbestos-containing materials will be disturbed, such as, removing insulation or transite materials, and the work will last longer than 1 hour. Exposures to asbestos are not expected to equal or exceed the PEL. Restricted areas shall be identified with warning signs (Attachment I) and hazard warning tape. All persons entering the restricted area shall wear an approved respirator and protective clothing. 3. Incidental Asbestos Work - Short duration work tasks (less than 1 hour) with asbestos-containing materials where asbestos exposures are not expected to exceed the PEL. 4. Competent Person - The competent person will generally be a Certified Industrial Hygienist, an industrial hygienist with training and experience in handling asbestos, or a person who has such training and experience as a result of on-the-job training and experience. Contact Industrial Hygiene regarding appropriate training courses which are available. IV. WORK PRACTICES The following work practices apply at DPMC: 1. . Identification of Work Areas - Post warning signs (Attachment I), which are available from the tool room, around all work areas while involved in removal or disturbance of asbestos-containing insulation, or cutting of asbestos-containing transite, except for incidental work. If airborne concentrations of asbestos can reasonably be expected to exceed the PEL, a regulated area must be established. 2. Respiratory Protection - All persons shall wear respiratory protection during any operation where airborne asbestos fibers could be generated. Approved respirators include: half and full face twin cartridge respirators equipped with HEPA filters (purple cartridges), or any supplied air respirator. Respirators are available from the green respirator cabinets. (See Respiratory Protection Safety Order). Employees who use respirators are to be trained annually, and fit tested semi-annually. Semiannual fit testing will apply only to employees who wear respirators in areas where asbestos concentrations exceed the PEL. All other employees who wear respirators will be fit tested annually. BCAE8324103 LAM 027187 ABS-008693 ASBESTOS SAFEffY S-125 PAGE OF 7 JANUARY 15, 1987(R) 3. Asbestos Removal - The removal of asbestos insulation should be done in a wet state to prevent or minimize the formation of airborne asbestos fibers. Portable spray cans using water or commercially available wetting agents may be used. Wetting agents (surfactants) may be added to water to allow more effective penetration and permit more thorough soaking of the asbestos-containing materials. Wetting agents are generally prepared by mixing 1-3 ounces of wetting agent to 5 gallons of water. Special work situations where water cannot be used, such as those involving electrical systems, should be reviewed with the area Health and Safety Inspector. 4. Ventilation Systems - Inspect local ventilation equipment used to control asbestos fibers at least quarterly. Inspection records are to be maintained by the principal department using such equipment. 5. Housekeeping - Clean the work area by wet sweeping and bagging of all asbestos debris, or by use of a HEPA filtered vacuuming device after completion of asbestos removal and at appropriate intervals to minimize the potential for generating airborne asbestos. In all cases, the asbestos debris must be properly handled for disposal (see section entitled "Disposal"). Precautions should be used to minimize airborne asbestos during idle work periods. For example at the end of a workday large pieces of unprotected insulation are to be moistened and loose insulation picked up. Exposed insulation that cannot be maintained in a wet state during idle periods shall be enclosed in plastic or encapsulated with commercially available encapsulants. Dry sweeping or "blowing" are not permitted. 6. Personal Activities - The storage, preparation, and consumption of food and beverages is not permitted in areas where exposure to airborne asbestos is encountered. No employee may eat, drink, smoke, chew gum or tobacco, or apply cosmetics in work areas where asbestos materials are being handled. It is the responsibility*, of all employees that work with asbestos materials to take reasonable cleanup precautions prior to eating, and also at the end of the work shift. As necessary, washup areas are to be provided for washing. 7. Clothing - Employee personal street clothing is to be protected from asbestos contamination. Employees assigned to regulated or restricted work areas, or tasks where airborne exposure or clothing contact with asbestos may reasonably occur shall wear disposable coveralls. Efforts must be made to assure the effectiveness of the coveralls. The use of different size disposable coveralls will minimize tearing; all snaps or buttons shall be used as is necessary to protect undergarments. Torn or ripped coveralls shall not continue to be worn. All contaminated disposable clothing must be disposed of and transported in sealed plastic bags and labeled (Attachment 1). LAM 027188 3CAES524103 ABS-008699 ASBESTOS SAFETY S--125 PAGE 5 OF 7 JANUARY 15, 1987(R) Coveralls are not required for maintenance or operations tasks encountering incidental asbestos work, providing generation of airborne asbestos and contamination of street clothing is prevented by procedures outlined in this section. 8. Change/Decontamination Areas - Decontamination areas shall be established for all "regulated areas". The decontamination area shall be adjacent and connected to the regulated area, and shall consist of an equipment room (contaminated change room), shower area, and clear, room in series. All employees shall enter and exit the regulated area through the decontamination area. The clean room ' shall be equipped with a locker or appropriate storage container for each employee. The showers shall be located between the equipment room and clean room where feasible. Where the shower area is not located here, asbestos must be removed from employee's work clothing using a HEPA vacuum before proceeding to the shower area. V. DEMOLITION AND RENOVATION OF ASBESTOS MATERIALS Demolition and renovation of insulation and transite containing asbestos must be accomplished in accordance with OSHA and EPA regulations, and written notification to the EPA is required. Demolition of insulation may be encountered when process units are retired, when interunit in sulated pipelines need replacement, or when individual columns or large vessels are replaced or retired. Maintenance of insulation may be encountered during upgrading of insulation, or during major turnarounds ir some units. To prepare for asbestos demolition maintenance work, the responsible Process Manager, Supervisor, or Project Engineer shall contact Health & Safety to determine whether the material contains asbestos. The Environmental Conservation Regulatory Affairs group shall then be advised If more than 260 square feet or 160 linear feet are involved. One-month'a advance notification to the Regulatory Affairs group is required. Separate written notification to the EPA may be required for each job that involves long interunit pipelines, a column, or a large vessel. Small jobs will be covered by an annual notification described below. The Regulatory Affairs group is responsible for the EPA notifications. The responsible foreman, supervisor, or project engineer shall prepare written instructions for the job. These instructions shall then be used as a basis for EPA notification, and for conducting the job. Environmen tal monitoring will normally be performed by Industrial Hygiene personnel for jobs that require EPA notification. In July of each year. Regulatory Affairs will provide an annual notifi cation to EPA, estimating the quantity of incidental asbestos removal that will be encountered during the year. This notification will then permit the Complex to accomplish all small demolition jobs involving asbestos without further EPA notification. Larger jobs will still require separate EPA notification by Regulatory Affairs. BCAE8524103 LAM 027189 ABS 008700 ASBESTOS SAFETY S--125 PAGE 6 OF 7 JANUARY 15, 1987(R) Contractor pre-bid conferences held are to include the specific hazards of asbestos and required procedures. Also, advance notification of Purchasing - Procurement is necessary to allow sufficient time for contract preparation. VI. DISPOSAL Place the wetted asbestos in heavy duty plastic bags and seal them securely as soon as possible after the bags are filled and prior to moving the bags. An asbestos warning label, as shown in Attachment I, is re quired on each bag. The label may be pre-printed on the bag or may be on a tdg^attached to the bag. Bagged asbestos and transite will be disposed of onsite. A Waste Disposal Request form, DPMC-6 (Attachment II), is required for all shipments. The quantity shipped should be indicated on the form in cubic yards. It is the responsibility of the generating department to see that the asbestos is placed in the trench provided in the landfill. Contact Environmental Operations with questions concerning disposal. Dispose of non-asbestos insulation wastes by placing them in the regular refuse bins. VII. ANNUAL MEDICAL EXAMS AND EMPLOYEE TRAINING Annual medical examinations are provided to Shell employees prior to engaging in activities regularly exposed to airborne concentrations (2 0.1 f/cc) of asbestos. The intent of this medical program is to include employees who work with asbestos-containing materials on a regular basis (30 or more days per year) or who have had known exposure through previous assignments. s' In addition, this order shall serve as a training instrument. Those employees that work regularly with asbestos materials shall be retrained annually, by reading and discussing this order and by viewing the asbestos training tape which is available from the Training Department. Key items to be emphasized in the training are: 1. Methods of recognizing asbestos. 2. The health hazards associated with asbestos. 3. The increased risk for smokers. 4. Types of operations that could result in exposure. . lam 027190 5. Precautionary work practices, engineering controls, housekeeping procedures, hygiene facilities, protective clothing, respirators, decontamination, and waste disposal. ABS-008701 p.rafP ^4! 03 ASBESTOS SAFETY S--125 PAGE 7 OF 7 JANUARY 15- 1987(R) 6. Purpose for and proper respirator use, fitting, and limitations. 7. Medical surveillance program requirements. 8. A review of the OSHA Standards. 9. The use of warning signs where exposure may apply. The manager shall retain appropriate training records documenting the names and dates of the training for 40 years. > Updating Responsibility: Superintendent Health, Safety & Environmental BCAE8524103 LAM 027191 ABS-008702 SM-32-MC (REV. -79) Shell Oil Company Shell Chemical Company Interoffice Memorandum MAY 6, 1987 SUBJECT: ASBESTOS HEALTH AND SAFETY ORDER IMPLEMENTATION The OSHA Asbestos Standard, effective January 16, 1987, includes new requirements for labeling installed asbestos-containing materials, posting "Warning" signs around areas where asbestos removal is in progress, and strict work practices which include using wet methods for handling asbestos materials. The following information is intended to assist in implementing these requirements, as defined in the recently revised Asbestos Health and Safety Order, S-125: All areas, which have asbestos-containing materials installed, are required to label the installed materials or post signs which indicate the presence of asbestos. Shell recommends the use of "Area" signs instead of labeling installed asbestos materials. Note, the "Area" signs (Attachment I) contain different wording, and are required in addition to the "Warning" signs (Attachment II) which are required to be posted around work areas where asbestos removal is in progress (refer to S-125). Both "Area" and "Warning" signs are stocked at the North Warehouse. It is recommended that the "Area" signs be posted at the boundaries and near control room entrances of areas containing asbestos insulation. Posting the signs near the control room entrances should minimize the number of signs required at the boundaries, since anyone planning to perform work within the area is generally required to report to the control room to obtain a work permit. The removal of asbestos materials shall be done in a wet state at all times, unless special work situations, such as, those involving electrical systems are involved. Portable spray cans (Attachment III) are a stock item at the North Warehouse. These spray cans will provide an effective means of wetting asbestos-containing materials before removal or otherwise disturbing the material. In addition, a low-foam wetting agent will also be stocked at the North Warehouse in one gallon containers. The wetting agent should be added to the water used in the spray cans to provide more effective penetration and more complete soaking of the asbestos materials. CICA8712602 LAM 027192 ABS-008703 ATTACHMENT W jf ASBESTOS "AREA" SIGN DANGER INSULATION IN THIS AREA MAY CONTAIN ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD CHBT8703704 LAM 027193 ABS-008704 ATTACHMENT if ASBESTOS WARNING SIGNS AND LABELS SIGN Standard. OSHA Warning Sign - 14" x 20" - with legend per OSHA Standard: DANGER '\> ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA LABEL Self-Adhesive Type Label, bearing legend per OSHA Standard: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD BCAE8524103 LAM 027194 ABS-008705 ATTACHMENT III INDUSTRIAL PLASTIC SPRAYER 2009 -- The CHAPIN* Industrial Plastic Compressed Air Sprayer s Klaal lor usa m heavy-duty application of many maianals that are corrosiva to galvanized or stainless steal metal sprayers Rugged construction throughout! Capacity 3 gallons. e The*, industrial-grade. 8* diameter, copolymer tank e Polypropylene pump barrel with steel reinforced polypropylene-threaded closure Drop-forged brass shut-off Chemical-resistant. 36* braided hose with ad|ustable clamp e 18* brass extension routes 360 degrees Brass tan spray nozzle (.5 gallons per minute at 40 psw) e Comfortable, adjustable carrying strap and pad Model 1949_ f2009 Capacity Gallons Liters 4 15 1 3 11.4 link Tri-Poxy * Lined Steel Polyethylene Pump Brass Poly Pump Length 14" 9* Hose 48* 36* Extension 24" 18' Ship Unit 1 1 Ship Wt Lbs. ii 6'. i LAM 027195 ABS-008706 DPMC ASBESTOS PRnr.FmiRF