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A SYSTEMATIC APPROACH TO ASBESTOS IDENTIFICATION AND MANAGEMENT By Stephen W. Addison Senior Project Industrial Hygienist Texaco Refining and Marketing Inc., Port Arthur, Texas Presented at the 1988 NPRA FIRE A ACCIDENT PREVENTION CONFERENCE September 29-30, 1988 Four Seasons Hotel, Houston Center Houston, Texas LAM 026842 ABS-056973 This paper has been reproduced for the author or authors as a courtesy by the National Petroleum Refiners Association. Publication of this paper does not signify that the contents necessarily reflect the opinions of the NPRA. its officers, directors, members, or staff. NPRA claims no copyright in this work. Requests for authorization to quote or use the contents should be addressed directly to the author(s). LAM 026843 ABS-056974 A SYSTEMATIC APPROACH TO ASBESTOS IDENTIFICATION AND MANAGEMENT With the oromuloation of the asbestos standard of 1986. a new aeneration of techniaues for asbestos removal and handlino was ushered in. These new techniaues and controls reauire innovative and creative resoonses bv industry. We need to look not onlv at current restrictions. but at what restrictions the future mav hold. This oresentation details an attemDt to identify and manaoe some of the asbestos abatement oroblems in a larae refinerv. with a substantial amount of asbestos containino insulation remainina in use. Basically, the oroaram involves the identification of all asbestos insulation in the facility. Manv refineries, no matter how well oraanized or manaaed. do not have reliable records of asbestos content and location. Rapid exDansion. emeraencv reoairs. and routine maintenance over the oast 20 vears mav have covered easily identifiable locations and contents. In some cases, oriainal olans are vaaue or non-existent, and so do not aid in locatino or definina the ootential asbestos hazard. The lack of reliable information, coupled with the need to direct insulation removal activities, lead to the desire for a visible Drooram to locate, analvze and cataloo accordino to priority, all asbestos material in a facility. Advantaaes of an asbestos identification proiect are as follows: 1. Reduced chance of employee exposure The maior thrust and basis for the entire prooram 2. Establishment of priorities for removal Allows a concerted and oraanized effort to rid a facility of asbestos, if desired 7>. Aid to effective maintenance olannina Allows maintenance foremen to olan an insulation removal: are abatement forces needed or not 4 Reduction of unnecessary abatement exoenses LAM 026844 ABS-056975 Prevents mistaken and exoensive abatement of non-asbestos insulation 5. No analysis delays n-site analysis auarantees results within hours of the need, to determine abatement reauirements 6. Discovery of unknown insulation damaoe in need of reoair As the ID crew orooresses throuah the facility, areas in need of repair, such as uncovered or crushed insulation can be noted for priority repair 7. A lower analysis cost per samole With the laroe volume of samples required for a proiect of this scope, the oer sample analysis cost can be sionificantlv lower than a piece-meal samplina proaram at an off-site lab Once the decision has been made to proceed with an identification prooram. the olants needs must be considered, and a list of criteria developed. Followino is a list of criteria developed for our facility. 1. A systematic approach to identification of insulation on all units and cross plant lines. Ooeratina units to be surveyed before cross plant lines. 2. A sortable. easily updatable computer data base of results and other information associated with each samole point. - 3. On site bulk analysis to aid in expeditina when reauired. 4. A method of sealina the "wound" at the sample point, to prevent any future potential exposure. 5. A taooing system to both identify the sample point and designate the insulation either asbestos or non asbestos. 6. A method to name (identify) piping so that positive identification may be made, in the event of a fire or e::olosion. From this ooint. potential bidders mav be qualified, bids received and the contract awarded. Our successful bidder. Environmental Monitorina Service Inc., had completed surveys similar to what we wanted at other facilities, but not the laroe scale that would be needed at our plant. ABS-056976 2 LAM 026845 GRID DEVELOPMENT Basic. unit olot plans were cooied and suDplied to our contractor. Thev drew in orid lines to allow accurate location o-f samole ooints. Cross plant lines, outside of unit boundaries. 7 are identified on sectionalized plot olans of the entire olant. Each sample Doint is identified by a plot olan number, arid number and elevation letter location. When challenoed to do so. oood success has been experienced in locatino sample Doints. DOCUMENTATION PROCESS In survevs at other facilities, our contractor had utilized a sample collector workino in coniunction with a documentor and an experienced company representative (usually an operator) to name and select each sample point. In our case, it was discovered that two samole collectors could work with each documentor in a much faster and more cost effective manner. The iob duties of the documentor are as follows: to collaborate with the company representative to effectivelv name all oipino and vessels to be sampled. The documentor recedes the samole collectors and. after namina the sample ooint. places a sequentially numbered sample tao at the point where the samole is to be collected. The documentor must also note the elevation of the sample point. In congested areas of a unit, the companv representative is critical in properly namina the samole point. Cross plant lines and unit lines in less congested areas may be documented without the aid of a companv representative. esoecial1v after the documentor has gained experience in vour facilities nomenclature. The documentor is essentiallv the "lead man" for the crew. He produces a hand written loo that is retained as the oriainal record. SAMPLE COLLECTOR The sample collector is required to wear a respirator and orotective clothing and to fullv decontaminate at lunch and at the end of dav. as a precaution. The method of sample collection is as follows: 1. A knife is used to cut a small "V" in the insulation covering. 2. A vial is used to contain the insulation olua removed from the samole point. 0> LANI 026846 ABS-056977 3. Non-asbestos insulation "mud" is used to seal the insulation "wound". 4. The seouential sample tap is affixed over the sample point, using' machine screws. All exoosure data on the sample collectors to date has indicated less than the detectable level of fiber exposure. TAGS After the analvsis has been completed, all sample points are retaaaed to indicate the results (asbestos/non-asbestos). The tao svstem uses shapes and colors to indicate the content of the insulation. A two inch square qreen tag designates non-asbestos, and a two and one-half inch yellow triangle tag indicates asbestos. All newly installed insulation is taaged by the insulation applicator. The colored shapes were selected instead of using lettered signs for several reasons. First, the stamped aluminum tags should have a very long life. Secondly, the shape and color are discernable from many feet away. Lastly, in the event that a tag were painted over on a unit during an I&T, the shape would still be easily recognized. SAMPLE ANALYSIS All samples are analyzed on-site by polarized light microscopy. Rush samples are collected by the contractor and analyzed the same day. One percent of all samples are submitted to an outside laboratory for results verification. Correlation between laboratories has been perfect. DATA BASE Sample points are recorded on 5 1/4 inch floppy disks and submitted to the awning division for updating and maintenance. The database contains information such as sample ID. result, location criteria and a priority designation to be used for noting those areas in need of abatement. The computer programing is very flexible, and may be sorted and edited in several different wavs. 4 ABS-056978 SAMPLING DURATION Usino multiple sampling crews, as we are doing, each unit survev is being completed much faster than anticipated. Following are examples of times required to survey several maior units. Fluid Catalvtic Cracking Unit Crude Distillation Unit Hvdrocrackino Unit 14 days 17 days 10 davS CONCLUSION This identification program will allow absolute location of the asbestos material, and so prevent needless abatement, show good faith to regulatory agencies, reduce fear and anxiety in the work force and positively document potential exposure areas to all future contractors and construction personnel. We have been pleased with the speed with which this tvpe survev can be accomplished, and the rewards are alreadv being realized. LAM 026848 ABS-056979