Document bpD6ZDxnqxmxLpVyBOMEBaj6

SM-32 (REV. 5-78) - 7Z# /k Shell Oil Company Interoffice Memorandum JUNE 10, 1980 FROM: J. G. PRATT, JR. fae [hmm JDf? health & s afetv OPERATIO NS Kcc JUN l l 1980 1----- --T---------- t---------I 1 PJW 1 R in F"ii r TO: R. J. SW0FF0RD SUBJECT: INSULATION SYSTEM REPAIRS TO MEET OSHA REGULATIONS As noted in TWX No. OSP 5796, dated June 5, 1980, we have enclosed some additional data on the project including the original note with Mr. R. J. O'Brien's concurrence with the expenditure for 1980. Although it is recognized that a problem exists with the insulation and approval has been granted to begin the work, a number of questions have been raised during the course of obtaining the approval. Most of the questions concern the scope and cost of the work in view of the apparent difficulties in relating the insulation condition to airborne particulate concentrations. (Note the enclosed article from the Houston Post. Although it was written about asbestos in buildings, the same questions apply to outdoor installations.) We would like to suggest that a meeting be held prior to the start of the full field program to review: 1. The criteria proposed to determine the repairs to be made. 2. The field procedures and inspection to control the work and to assure that the criteria are met. ~ 3. The coordination procedure with Head Office - Health and Safety Operations Department to assure that current H&S interpretations are incorporated over the full life of the project and that the experience is available to assist other locations. Head Office attendees at the meeting should include representatives of Health and Safety - Operations and Manufacturing Maintenance Support. T. J. Hayes of Site Development and General Facilities - P&A should R. P. Frutiger - DPMC DPMC-10600 GENERAL MANAGER MANUFACTURING HAY 2;> *80 SUBJECT: ASBESTOS INSULATION REPAIRS TO MEET OSHA REGULATIONS AT DPMC-NORTH Deer Park Manufacturing Complex has requested authorization to spend $1.7MM in the remainder of 1980 on an unplanned major special expense to repair damaged insulation. The damaged insulation allows asbestos fibers to be released into the air in excess of the OSHA limits. The entire program to bring the DPMC-North area into compliance is currently estimated to cost up to $5MM. $1.7MM of unplanned expense to be spent in 1980 as requested with additional budgeted planned major special expenditures of $1.6MM in 1981 and $1.7MM in 1982. It is recommended that the program be handled in three separate parts, rather than as one large unplanned project, for control purposes. Compliance with OSHA standards depends on the amount of airborne parti culates rather than the condition of the insulation system per se. To a certain extent, this is a pilot program to determine exactly how much repair must be done to achieve the proper ambient conditions. There is not enough energy savings to justify the work, therefore, the goal is to repair only as much insulation as necessary to reach compliance. Head Office - Health and Safety Department has participated in the pre paration for this program and they will continue to work with DPMC on the scope of the repairs and their effectiveness. Placing the last two-thirds of the work in the 1981 and 1982 budgets will facilitate an annual cost update and cost/effectiveness review. If you concur, we will advise DPMC to go ahead with the 1980 portion and insert the 1981 and 1982 items in the appropriate STOP forecasts. LAJW 016857 DPMC-10601 April 28, 1980 MR. J. C. SEYMOUR, JR. Re: DPMC Insulation Repair (Wire of 4/23/80) Brook: The guidelines we have established for this kind of work are that replacement is justified from a safety and health standpoint if 1) monitoring data show excessive potential exposure or 2) insulation is not covered in areas where people are likely to rub against it and cause it to sluff off (not in pipe racks, isolated locations, etc.). Per discussions with Frutiger this (2) is the justification here. There fore I support the expenditure. L kJ-- Attachment cc: Messrs. R. H. Brown W. A. Carpenter, Jr. T. J. Hayes 0. C. Me Cormick R. L. BRUNNER LAM 016858 DPMC-10602 ;jiO Igxi s tso.ucauon jrban ,school districts atlon lawsuit (lied . Independent School Uaso dtUUi aci jruu aajt 4u*tj> cooperate,' this might * us Into the lawsuit. Before the fa yu might be admitting liability. I wonder how the county attorney would feel about that? don't, It's their duty to get in to--h with us." Lyons agreed: 'Til lay you c*.uS that they know about every bit of that Fellow court members remlhdcd h'i that If the federal attorneys Want coup "public" records, they wilt mdhely su poena them. _; 'J Study indicates--'j asbestos hazards I less than believed By HAROLD SCARLETT The study was based on 40 of the testsj Post Reporter The hygienist claimed the tests, we the most sophisticated yet conducted* i A five-year study shows asbestos asbestos fiber levels inside buildings. , materials in schools and other buildings In most' buildings, Schirripa; fepori are much less of a cancer hazard than the tests showed only O.i to ,01'fib^rs p previously believed, a researcher report cubic centimeter of air. By comparii ed Thursday. . \ the asbestos standard of the Occupatio The study by Industrial hygienist, al Safety and Health Administration is James T. Schirrlpa challenged the Envi , fibers per cc of air, he said. ~j ronmental Protection Agency's approach \ Schirripa said the EPA suggests-! to the problem. such careful measurements Wassh Schirrlpa said his study shows that asbestos hazards In schools, but relies'c removing asbestos material from build a visual scoring system. He 'said th ings -- which releases the tiny fibers -- "highly subjective" approach bin re^u In many cases would result In more can In the Wrong corrective actions; v i cers than leaving the material where it Is. The study, he added, also showed that occupants of unrenovated buildings generally would die of other causes long before they developed cancer from the He said "doing nothing" Is/often th correct ^reaction, because asbestc removal, even with wetting and' otht safeguards, can, generate more than It fibers per cchFalr. ,, ,! low level of fibers found. "Our formula shows that the'greate: "Our studies begun In 1975 generally rate of potential cancer cased as'h'resu demonstrate for the areas examined a of continuous exposure In genial;occ tlme-to-tumor risk of well over 100 years, pancy buildings was 112 eases per ml a risk far smaller than previously believ lion In the population over 40 'y&i'rs an ed," he said. 2,707 cases In 75 years. That's thb'risk . Schirripa, of Industrial Hygienics Inc. In Huntington, N.Y., reported his find ings to the American Industrial Hygiene Conference. The association of industrial and government hygienists Is meeting doing nothing," Schirrlpa said. "Therisk of doing something,`remo- tag the material, was 20 times* greatc (2,245 cases per million) in 40 years an 4.5 times greater (12,349 eases).over a 7 this week in the Albert Thomas' Conven tion Center. Schirripa said his firm conducted tests in 100 schools, office buildings, industrial year period." ' 1 He said the study reinforces his tea: that society may be spending .too jrnuc money, with too little thought, on high: plants, hospitals, ships and a retail store. exaggerated risks' ' DPMC-10603 Initial systems plannee for treatment center An Incinerator and a British process Inltlal construction on a'30-acpe;Pro<: that converts hazardous wastes into csslng complex will include a latjopator "synthetic rock" will bo the first sys- administration building, storage tank LAM 016859 r -oi_OK Pops. "TVpe A - V i! i l T tfr InsFALL ALUMINUM COVt'RL OVGP- A^'rUAl..VlC plrLT ti. xfe' A-OV4 _TcPA IP, WASHED -OUT AREA IN 1MSOI-ATION OO M Lr V ' M D YilTH AOHHAUrlC FFEUT USIMG C ERA V'\A M /-f. V /mU D - IN FOui-CWF :o with complete aluminum inrap. c. Red ________ "Rtfpa\ps. ops pv:ptAc.e aluminum ccveR- D. O.RAnInE TfepVACU VALVE'S . WtATNCPi;l?r'OI- IMG- ON TEES , ELLS AMD E\ pr'i-AfNl ______RtfMOve IM5LILATION AMD FNL ikj SO LATE /COVE e. LAM 016860 DPMC-10604 is' =- c." Fi^uf.e I V' A. A-vr.Ai-v\o- pe-h-T co\/ev-.t~r> imsulatfio piping* with vu 0:*r`S TO THE l.'XTUNT &IVEN &V F\ U PA". X /- imsulatiou itapocsd CHAU. tUT K.t-'PA pJr.T-O !,\iHVAL-L- CCMPU.TE 'aJP.AP Or AAlXT- (.Ol(o" THKT.') pl-AIM ALUMIIJUH ; W n'H ?. IMCH MINIMUM G\ICP.LAP/ TP`-','MtD THE EX IOTI ITT IMEUt-ATlOW />S-ID f'V.'l.T COL/CTT. FHfT A I .uH'.lKJrt 1 Ct'IA l-L HAVE A PAPL'V. ! ICMO I'O f'P iMClUE , CoV UP- TO fcLLH p.AMDED ONJ 17. |t|CH <: f_'M TC.' PC ',`IITH 015 11 * Yt." STAIHLtT-O -OTLVC/1. C.AMW 5. ; :alnc - f coveTU-D insulated piping with YUDVWS (SK-UATtiR. THAW THAT SHOwA Esy RgoK-E X Tou.ows insulaviom Exposes ua SHALL. EL SEPAIKtfD AS Fll-I-- INI VOIDS HlTH CETCA - E.UAMVSViT C C> ^ D KNi S I T A N D MUID'IM TO NCTA RL INSULATION THlCKhfcS^ yJITH l-'GPFF 1N Tl INKS COMPOUND. CaK.-P. peMAIKlINJG ASP^ALTIC-FELT AN D R.EPA IT?. WITH Z-G>CrAO<5S INCH) PUUnI ALUM)NL>K.' NtTKJ CZO\lCR. TO HANS 2 IMCH MINIMUT a/C-piJLp. <Fo\|t-3\< TO KCi TC-ANIDCFO ON. IZ INCH CENTSfOS WITH - 015 11 a: {/-c INCH STAINLESS STF.CTL- fCAKllO. f ici cru t-.p eAR.e.iei7. lUsioe . AuvMfUOH SHALL HANff A PARTfe. <2. ore K.i.T-'Airi. DAMAGED AlAjMMNIOI-A CO\lt"P.|NQ WHEK.E IVJSUIVLTIOi 15 CXI-OC^D. DPMC-10605 LAM 016861