Document byjN6doJqbv8mMgq17Lz87Jk0

PLAINTIFF'S EXHIBIT l 1- Now York* How York* 10017* Jtuo 29* 1972 INOWgTRlA^HTOIgNg SURVEY PU<3*T SOUND RSyiNXRT Mr. D.H. Mortem AttCOItM, Wooktogtott Attacked to fbo report of tk# to&ufcrtel hygiene oorvOf coadacted at yoar pleat n Moy 8 thra 10* 1972* Vo Ion boo* waiting tor dot* from chemical euppllere which boo otUl met boo* received. 8 nnaMdi8aM covering Hum* materials oro needed toy will bo eon* to a ooparate roport. If you bare aay qaeations* plena* lot mo know* JFL-AFQ cc: FFYjr DMM JAD JPI* R. T. RICHARDS WA-TEX 000033 Industrial Hygiene Survey Anecortes ftflurf,Pa|t8oaad Rut Atteett*!, Washington May 8-10, 1*72 By: James P. Lieata,Industrial Hygienist Texaco be,, Health Division Haw York* Haw York SUMMARY Asbestos containing materials are befog wed lor pipe insulation and each we should bo discoutinuod. Paint spray work fo dune fo the warehouse #3 building without adequate enuwt ventilation or proper electrical fixture* approved lor uao fo a hasardou* location. The mixing ahad located at foe water cooling tower doea not have adequate exhauet ventilation to remove the chromate duet evolvedwhea dumping begs Into the mixing hopper* The advent drum rack outeide foe paint chop ia net equipped with the proper electrical grounding to handle a static charga build-up. The tetraethyl lead tank car unloading baildfog it not equipped with a flow alarm or eight-glare on the overflow tank* Mercury waa found behind the teat panel ia the instrument room. The plot plana of the high noiae arena do not show the 90 dBA contour on .foe plana. A calibration kit ahonld ho parchaaod for the MSA combustible gaa indicator. INDUSTRIAL HYOIBKE SURVEY On May 8,9> and 10th, 1972 a survey of foe Anacortea Refinery waa made to aaalat local management fo updating some plant operations to. comply with the Federal Occupational Health and Safety Act of 1970* The following recommendations are a result of this survey. Some additional information eoncorning Magnus 94XX-K and Bata Dianodic 939 has still not been received from the manufacturer and recommendations covering these will he handled fo a separate report if needed. RECOMMENDATIONS 1. Asbestos uasage ia befog strictly controlled under OSHA regulations. The most practical alternative is to perform insulation work fo the refinery, with non-asbestos containing insulation materials. The present stock of asbestos cement in 100 lb. begs should be discarded since these are non-asbestos types readily available. All insulation which has been done with asbestos should be indicated on plant operation diagrams to enable employee to fodhsw OSHA regulations during WA-TEX 00Q034 ( 2 repair or replacement at some time la th# future. All specifications far new Installation* should prohibit As tun* of asbestos containing materials for insulation* I. 2* Paint spray work being performed la irarskoass building #3 shonld bs dtseoatlnnsd until aa adequately ventilated paint spray booth of sufficient slsn can bs installed* Addltioafty U slsetrleal flstnrss in Ow room shoald bs updated to ft# approved typs for kaaardeos locations, Glass 1 as dstatlsd in paragraph If10.322-1910324 0HSA regulations. 3* The mixing shod located JUlfp jfeatsr cooling tower shonld bars aa adsqtaats exhaust system installedto remove any dost evolved daring the damping of Bets OUnodle #f3f into she mixing hopper. The operator wears a U.S. Bnrsaa of Mines approved respirator* goggles and other protective clothing hot the duet still contacts many exposed areas of his skin. This water treating chemical contains 40% chromates. The lighting inside Ale shed should else be Improved by the addition of another light fixture over the mining hopper. . ; 4. The solvent drum rack outside the point shop shoald he provided with proper bending wire and grounding to prevent a static charge build-up ti specified in CSKA regulations paragraph If10.104* 5. The tetraethyl land tank car unloading pump house building is equipped with a tank to collect any overflow in As event of a malfunction. This tank should bo equipped with a flow alarm system or eight-glass to alert operator* whan this situation has occurred* 4. The interior of As instrument room test panel should be checked periodically. wtA a magating glass and flashlight, for droplets of mercury. Any mercury noted should be vacuum removed using a special collecting flask attachment equipped with a h'gh velocity pick-up Abe. The attachment will have to be fabricated A your laboratory as they are not commercially available* A side exuniVacaum flask, rubber hose and a glass rod for a pick-up tube should be used..' The incoming sir should bubble Arough water A As flask to collect As mercery. 7* The installation diagrams used for noise plot plane da not show the 90 dBA contour on Ae drawing* The present yellow outlines shown ars the concrete pad edges A most cases and not As actual 90 dBA contour. 3. A calibration kit for your Mine Safety Appliance (MSA) combustible gas indicator should bo purchased to insure Ao unit is working properly prior to uss. Tests for combustible vapor* should be made prior to any tank or confined space entry. i WA-TEX 000035 -3 DISCUSSION The storage araa for insulating material Hat rosy poor house keeping aad controls for iibrntoi coatalaing materials, The asbestos "fins" comaat is dispensed with a scoop from a 100 lb sack which is torn open* The floors wore covered with asbestos fibers aad pieces of brekea preformed pipe laselation. Browns are ased to dry sweep tbis area. No respitfitgy protection is worn byytho employes UvotvsdU the asbestos ' cemeat rnfadiatfoperation. The Federal Occupational Health and Safety Act regalatioas Mmestts were changed oa December 7, 1971 throughpublication of aa Emergency Standard amendment. The threshold limit vales for asbestos is presently. 9 fibers longer than % microns per mUHMfer of air. A special study committee, which was formed aadcr the U. 8, Dept, of Labor, has now recommended that the limit for asbestos bo farther rodeoed to 2 fibers longer than 9 microns per milliliter of nir. Sven if nil fntore insulation work is performed with asbestos-free materials the existing nsbsstos containing insolation will coatlaae to caaso problsms. AU linos prssoatly eevorod with asbostos should ho indicated oa piping plane eo when it comes time to remora or repair each insulation the proper employe protective measures can be taken. The safe work procedures for asbestos include ihedEfeHowiag; 1. All power driven or mechanical catting equipment meat bo provided with adequate local exhaust ventilation. (ANSI Standard Z9. 2-1971). 2. U. S. Bureau of Mines approved respirators, air supplied or self-contained breathing apparatus must be worn where dust levels exceed the Threshold Limit Values. . 3, All dust must be remeyed by vacuum cleaning methods. 4. AU waste material must be collected and disposed of In sealed bags or containers. 5. Warning signs must be posted as specified in the proposed standards if adopted. * Compliance with these regulations will be very difficult and dddgreatly to tho labor coat. Zt is, therefore, important to document the exact present location of all asbestos insulation which will be subject to fheac regulations, as weU as installing only noa-asbsstos typos in tho future* A copy of the WA-TEX 000036 . . -4- Sm|Mey ud Proposed itudutdi is attached for few information. Also tttiehad are data shoots tor n asbestos fro* cement. The other item* discussed ere covered Is the recommendations listed above* There is one additional Item under recommendation #7 concerning the noise contour*. The question of spacing of warning signs at the 90 dBA canton line was raised* No specific distance between signs are mentioned In the "Guidelines to the Dept, of Labor Occupational Noise Standards'* or la the OSH regulations. I would suggest that each contour be inspected to detosmine if a warning sign is visible to anyone approaching along normal routes* Additional signs may be needed at some points whore items block presently posted signs. Cach noise source should ho treated individually. Additional items which were checked during my plant survey wore the open surface tanka in the machine shop, holler house and laboratory. The hot water bath tanks in the iab and the tank in the boiler bouse do net present a basard as defined by the OSHA Item 1910.94 (d) (plOSIS). The tank la the maul ah# Is used to clean mstal parts and contains a solution of Magnus 94XX-K wh! drumaslaboi status is a medium strength alkali mixture* I have written to the manufacturer for detailed information and will write specific recommendations operation. If needod. whoa too data is received. 1 would like to thank Mr. D. H, Morton and his staff for too cooperation and assistance 1 received during my visit to the Anacortes refinery. JPL-AFG Atto. J.P. L1CATA WA-TEX 000037