Document aJEKkNgb9GoEbvvEnRq781amY

PLAINTIFF'S EXHIBIT MEMORANDUM SAFETY AUDIT BROWNSVILLE PLANT Introduction The second annual safety audit of the Brownsville Plant was con ducted February 8-10, 1972 by J. L. DeRoo of the Group I Safety Department. The audit consisted of interviews and discussions with plant management and operating personnel and an inspection tour of various facilities and operations within the plant. In addition, the current status of the recommendations which were previously reported following the 1971 plant safety audit were reviewed with the plant safety coordinator. In conjunction with the safety audit a meeting was held with the plant OSHA Committee to discuss and seek answers to OSHA-type questions arising from their "inhouse" inspection survey. Some of the more significant items discussed at this meeting are contained in this report. Safety Performance The plant*1 s 1971 injury performance was marred by two disabling injuries; one in the month of February and one in June. Prior to the February injury, the plant employees had completed twenty consecutive months without incurring a lost time injury. The year-end disabling injury frequency rate of 5.35 and serious injury frequency rate of 8.03 were achieved by working the last six months (220, 000 man-hours) of 1971 without a single serious injury. The plant1 s past three-year injury experience is summarized below: Year DIFR SIFR 1968 1969 1970 0. 00 5.44 0.00 0. 00 5.44 0.00 The 1971 fire loss experience is outstanding. The property losses resulting from twelve minor fire incidents amounted to approximately $4,000. Three Major Hazard Surveys were conducted in 1971 - Utilities Plant (Steam and Water Systems), Electrical Energy System, and Distribution Facilities. Final reports were issued for each of these surveys in 1971 and action plans were prepared by plant management. Discussion A. Progress Review of 1971 Safety Audit Recommendations Many of the safety recommendations have been successfully imple mented; the following are noteworthy: 1. The Safety and Procedures Committee is now meeting on a monthly scheduled basis. BRE 0043 2 2. Monthly safety meetings are now scheduled for technical and supervisory personnel. 3. All new technical employees are given fire extinguisher and emergency first aid training. 4. Cleaning and repairing of respiratory equipment is now being done by specially trained plant personnel. 5. Warning signs have been posted in all plant areas having high noise levels. 6. A chlorine leak, emergency repair kit was purchased and plant personnel trained in its use. Implementation of the following 1971 recommendations would Kelp strengthen and enhance the plant safety effort: 1. Top level involvement by the plant management group in monthly unit safety inspections would be an asset to the plant safety program. 2. All operating units should display their safety rules in a prominent manne r. 3. Welding operations should be properly shielded ^to protect shop personnel from the painful and harmful effects of ultraviolet and infrared radiation. 4. Oxygen equipment for emergency breathing purposes should be provided in the plant dispensary. A simple system consisting of preconnected oxygen cylinders, a fixed-in-place piping distribution system and a minimum of three quick connect type dispensing points should be considered for immediate installation. B. 1972 Safety Audit Observations and Recommendations A summary of the observations made during the field inspection portion of the audit are discussed below: Shop Building No. 424 1. The cleaning of small scale electric motor parts should be restricted to a well ventilated section of the shop. An industrial-type solvent cleaning rig should be used rather than the open top metal containers (pails, buckets, etc.) which were noted during the safety inspection. Signs should be posted instructing personnel to wear proper eye and hand cover protection while performing solvent cleaning operations. 2. Install OSHA-type safety guards on all fixed and portable ventilation fans. The openings in the present fan blade guard cages are too large. 3. The rated load limit of the overhead hoists in the carpenter shop and electric shop should be displayed on both the support beam and hoisting unit. BRE 0044 I' K 3 4. Install an appropriate sign on the sprinkler system drain valve located in the welding shop toilet room. .f 5. Welders in the shop area should be required to use portable shields to isolate the glare from cutting and reduce the hazard, of flying sparks and-welding operations (particularly arc -welding). . .. v ' % 6 Provide safety guards on all floor mounted power saws and .drill'1';- presses in accordance with OSHA regulations. 7. Check out the electrical power and lighting circuits supplied from : the breaker panels in the carpenter shop. There is a strong possi-. bility that some of the information on the circuit identification=cards>' could be incorrect. .8 In order to comply with the present OSHA general standards, a "dead-man"-type safety shutoff switch should be installed on all portable hand-held tools (pneumatic or electric driven). * 9. The welders washing and toilet facilities appear substandard and' housekeeping needs more attention. Building No. 425 1. Install a safety guard on the steam supplied roorn heater blower fan in the vehicle service garage. Plant Utilities Area j. '* 1. The discharge from the safety valve on each of the caustic metering pumps should be piped to ground, level. .C 2 Consider installing a safety shower and eye bath adjacent to the caustic drum dispensing area. C* - t-rhJ 3. ^.0 .-**^*^4. Install a locking-type handle on the sulfuric acid injection line drain valve (ball valve) to help avoid accidental opening. Install safety guards on the drive shafts of the steam boiler blower draft fans. Sandblasting and Dimetcoting Area 1. Housekeeping's extremely poor in this area. The washing and toilet facilities are not adequately maintained and the haphazard storage arrangement of assorted discarded materials within the building provide hundreds of hiding places for rats and snakes. ) 2. The food preparation area:is unsanitary.and the-practice of storing food.in the refrigerator along with bottled chemicals should be his- continued. " ..... ' ' 'V " I i .;"'l BRE 0045 4 C. Occupational Safety and Health (OSHA) Summarized below are some of the more significant questions and answers which were discussed with the plant OSHA Committee: Subpart D of Federal Regulation 1. How large can holes be around piping, etc? The approach which Group I should adopt is outlined by Mr. C. K. Wood's April 10, 1972, letter to Mr. C. S. Hines. "It is recommended that we do not change our existing Group I grating standards relating to clearances around pipe." 2. Do we go by OSHA or Construction Standards for scaffolds? Brownsville should follow OSHA standards when Brown and Root are enSaged iu routine (turn around) maintenance activities. 3. Do portable grinders need an exhaust system? Portable grinders which are used on metals such as carbon steel, stainless, monel, and similar metals do not require a dust exhaust system while metals such as Berylium, zink, lead, etc., do. * 4. The fume hood and exhaust system works well in the Black Light room but is not built according to standard. Concentration of chlorothane is well below TLV. Is it necessary to change? Based on my visual observations it appears that the fume hood will perform satisfactorily: however, I suggest you have our industrial hygienist at Houston check its performance. Subpart H 1. Are we out of compliance by having hydrogen cylinders in the lab? I see no problems arising from using a few hydrogen cylinders in the lab as long as they are securely fastened to prevent toppling and that they are accessible for immediate shut down in the event of an emergency. 2. Will the oxygen plant gas cylinder storage area west of the motor control center be acceptable if the cylinders are raised off the damp floor? Is this area too congested? The present arrangement of gas cylinders appears safe--a raised dry support surface would be needed. 3. What is standard on having acetylene cylinders adjacent to oxygen cyl inders on cutting rigs? My best advice is to continue to follow standard UCC welding practice. BRE 0046 5 4. OSHA standard calls for labeling the operating pressure and flow capa city of all tank vent units. Should this be done? Our position at this time requires that records containing this infor mation be kept on file and be readily available for review by state and federal safety inspectors. We see no advantage to affixing this information to the individual vent units. 5. Piping carrying organic liquids must be painted. What condition must paint be maintained in over a period of years? Copper, etc.? Where piping is subject to external corrosion, it should be painted in accordance with UCC painting specifications and plant practice. 6. Piping and valves on butane spheres rated at 150 psig rather that at 250 psig. Expect any problems from OSHA inspector? Paragraph 1910.110, b, 7, i, which refers to the use of 250 psig valves in liquified natural gas (LNG) service does not apply to storage of butane in chemical plants. As long as we follow our standard valve and piping specs, we should have no problems. 7. Provisions shall be made to compensate for expansion, contraction, jar ring, vibration, settling of butane spheres. Is this really necessary? Yes, all these are necessary and all were included in the original design and installation of the spheres. Subpart I 1. Should we paint the stripe on gas mask cannisters? Also, other safety equipment and sign warnings? Cannisters should be supplied from the manufacturer with the appro priate color coding; therefore, no additional painting should be required. According to the Federal Regulations, identification stripes can be in the form of colored pressure-sensitive tape. 2. What can be done about special safety glasses under gas masks, etc.? Special safety glasses should be made available for those persons who normally wear prescription glasses and are required to wear a gas mask during the performance of their permanently assigned job or are a member of the plant emergency fire or rescue squads. 3. Who should conduct training for personnel that will maintain and repair the personnel safety equipment? Start with the vendor or manufacturer; for a minimal charge they should be able to fulfull your needs. If these arrangements cannot be made, contact Mr. H. C. McGinnis at our Institute Plant; I'm sure he will be able to help. BRE 0047 6 4. Would the fresh-air equipment issued from the tool room be considered emergency equipment? Not necessarily but, it should be used and maintained in the same way as respiratory equipment which is used for emergency purposes. Subpart J 1. Will it be necessary to have hot water in all rest rooms? Y es. 2. Will it be necessary to have a rest room in the storeroom for women? Since there is only one girl involved and she has an opportunity to use the rest facilities in the main office building during her mail deliveries and switchboard relief activities, I see no reason to provide a women's rest room in the storeroom. 3. What about eating in control rooms? I see nothing wrong with eating in control rooms as long as the eating area is maintained in a clean, orderly manner and is free of chemical contami nants. Subpart L 1. Do we need pressure reducers at all hose cabinets since the pressure will go above 80 psig when the fire pumps are on? The Federal Regulations state that pressure reducing devices are needed when the static pressure on the hose supply system exceeds 100 psig. At Brownsville the normal static pressure is approximately 70 psig; thus, pressure reducing devices will not be required. 2. Should additional fire alarm boxes be provided on each floor to obtain a maximum horizontal travel distance of 200 feet to the nearest box? Does this mean we need a box on every level? At grade level in process areas we should comply with this 200-foot requirement, but for those above-grade levels, such as operating access levels in process equipment structures, where operating personnel are not permanently stationed, it is not necessary to comply. If a control room or operator shelter is located above grade in a process equipment structure, it should have a fire alarm box immediately available. 3. Are connections needed for fire truck on sprinkler equipment? Fire department connections are not needed in instances where our plants have their own fire water pumping and distribution system. BRE 0048 7 Subpart M 1. Air receiver at sand yard lies on the ground with chocks to keep it from rolling. Is this acceptable, or should it be permanently mounted on a base? I would suggest that the air receiver be supported off the ground on heavy timbers, using wood saddle supports to prevent rolling. JLDeRoo/map:ero 5/3/72 BRE 0049 4- UNION CARBIDE INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS P. O. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 To (Name) Division Location Copy to Mr. H. B. Coons (5) Brownsville Plant Mr. A. R. Anderson, Mr. J. L. Friedel Mr. R. C. Glock Mr. R. C. Hieronymus Date May 3, 1972 Originating Dept. Group 1 Safety Subject Annual Plant Safety Audit Brownsville Plant Dear Henry: The attached report contains a discussion of my observations and recommendations resulting from my February 8-10, 1972 safety audit of the Brownsville Plant. This report is in large parba confirmation of the discussions witK'your plant safety coordinator, ,Jim Friedel, and your plant OSHA Committee. Please do not hesitate to contact me for clarification or any assistance which I may provide. Very truly yours. JLDeRoo/map Attachment BRE 0041 RECEIVED MAY 8 1972 INDUSTRIAL RELATIONS BRE 0042