Document dQ6p69Jg4vYBkypLJ3JmGd609

t tIIiTnAiuIUbMBinj l#e0m* Tocours & Company i A g ' ^ILMl^^CON. cDelaware i98s c ,1 VEN^INEEPING OEPAWTMEMJ I r L?^*"s BUILDING T. t :c: L . , ,a3 --W*.. fc. rC6aL o u o c ommi L/tc6 .emrers n. r. nelae-Lcerger - >esLzr. Refer to Serial Letter ^C13 ated September Li, 1972 (Sec 13, 1973 .CARLTON, BIOCHEM., WILM. (2) k.E.ROBBINS, CENT. RES., EXP.STA. (2) H.5.EATON. SLASCHEM, WILM. (9) . K. -..-ALTERS. EMB. EEL., WILMniGTX (1) C.D.BROWN, CONSTRUCTION, LOUVIERS (1) k.r.STEWART, DESIGN, LOUVIERS (8) J.P.KLIMOWICZ, ERD, EDL (1) F.J.KAHTIN, ESD, LOUVIERS (1) K.H.hOHL, F&F, VILM. (12) W.E.NEFF, FILM, WILM. (7) V.H.MC COY, IND.CHEM. ,WIL C.W.ANDRUS, IN'TL., WILM. J.V.FLYNN, ORCHEK, CH.WKS J.J.LAURINC,PHOTO PR0D..V R.H.MC CONNELL,PIGM.,EDGE K.W.DAHL, PLASTICS, WILM. T.C.HILL, POLYMER INTER., T,------y H.G.SHULBY,PURCHASING,LOUVIER. J.A.SIGMAN, TEX.FIB., WILM. R.H.GRUSS,REM.ARMS,BRIDGEPORT STANDARDS SECTION - SAFETY k FIRE PROTECTION SUBCOMMITTEE S^T - AS3E3T0S DUST EXPOSURE, MEASUREMENT AND CONTROL This standard was approved without comments by the following departments: Construction, DSD, Photo Products, Pigments, and Purchasing. In addition, the following comments have been received from the Engineering Standards Committee. These have been reviewed by the subcommittee, with replies shown below. R D CARLTON. COMMENTS 3Y J. 3. YOUNG - BIOCHEMICALS - BELLE PLANT CCMMZNT NC. 1 - 3.l.2 - This sectioh specifies that suoplied-air or self-contained respirators shall be worn by employees engaged in dismantling asbestos insulation. This assumes'that permissible TWA exposure limits are automatically exceeded on all dismantling oper ations and hence, respiratory protective devices are automatically necessary, he believ'e Section 3.4.2 should be amended to specify that respirator protection shall oe worn on asbestos insulation oismantling operations anytime the asbestos dust concentration cannot be controlled'below permissible TV/A exposure ceiling limits by dampening with v.'ater or other suitable means. - be cannot agree that 3.4.2 should be changed at this time or atmosphere supplying respirator protection on asbestos insulation cling and spraying only when recuirea by the dust concentration leve tar.dar ' assures cr.at one _imits will be exceedea ions are performed. Dr. small Jobs cr -under favorable, controlled ions, this may not be true ..as several comments have indicated, There ore. the subcommittee will welcome test data supporting less rescr ccive procedures for future consideration. DU 062045 DUP 1153817 9/11/72 - w- recruary --9,0 w W. w -- ** * w requirea oo ao 20-- c m. ar -- v y. This s chi or* is rot very clear, ".."hat oes refe to? Some ampiificatior. appears r. crde. REPLY - This se tence was taken directly from OSKA. V.'e believe it referred to testing the espiratory device for proper fit ana we will clarify, n.iso, see rep.y to Comment pQ. CCMZET 10. 3 - 6.4 - Is there sound justification for including an urexocsed filter for analysis along with each completed sample? This doubles sample analysis costs and further loads up analysis technicians resulting in even slower return of analysis results. REPJY - Including ar^unexposed filter for analysis along with competed Sa-;ue was par- Oj. the. samp-zng.procedure recommended in the ICIOSr criteria document on asoestos.. Also, it was recommended bv one of'*tr xaboratories aoing this analysis. This was to ensure a prooer base for counting the_exposed sample. The recommendation was not made a oar- ci tie _ina- OS.-.* regulations and we will revise the standard to make* it raeqreuciorme maenn.udnaetioxonosoendlys, am.ptiew, asount ortatinhteern,deedachthabat tcehachof esxkpmosoeidesf.iltWeerwwi?olu~'~~ clarify tms point also. wcujy.ea. we wi.j. T-- nt rxfl 0^' * NZEL - 2LASCHEM - LOUISVILLE TJCJ 0. i - /Table of lypical ihist Concentrations. Most asbestos insulation iJn*. sA ta Rll"1eAd/*} by Ap, 1la*1 AnTt* foArMcAeAsA *iSnM m*> aintenance and sm_a*1 l^l _p__r_o_ je_ c_ ts is done in the field in pipe alleys and open buildings. Dust sampling is not practical in these instances because of delay to get results and we do not want to compel the use of extreme protective measures if unnecessary. Could you include a typical table of dust concentrations that could be'used for guidance for selecting appropriate control measures. REPLY - "he appreciate the difficulties resulting from the time required to get test results, and agree a Table of Typical Dust Concentrations would be very helpful. However, OSHA regulations call for exposure data to be aevelo'ped for each site. When more information is available, it may be possible to add general conclusions to the standard that would be helpful" as qualitative guides for all sites. j. - Clarification of "removal" and "dismantling" paragraphs s x*-- ana ^,,it. 2. The OSHA states insulation should be removed in a :'wet state sufficient to prevent the emission of airborne fibers cf ehe exposure limits prescribed in paragraph (b) unless the usefulness of the produce -would be^diminished thereby". If this can be done, it would appear 3*4.2 could be accomplished without the atmosphere supplying respirators providing the insuuation was wetted ana collected in inpermea'cl containers. Please expand and clarify on your instructions in 3*4.1 and PIPIT - See reel-.- to Comment 1. 1 ) DU 062046 DUP 1153818 i *rw 9/11/72 ->~ February 13, 1973 j. c. b.eecez:: ridge, co:-;ci:t by d. g. Windsor - si-?, rel. - '..timzkgtce C GILBERT NO. o - Approved with inclusion of information mentioned in w ,ueener*s letter to Departmental OSHA Coordinators (10/12) and information from Haskell Lab which has been forwarded to the subcommittee. REPLY - This information will be included in accordance with our discussions and agreement following your comment. ?.. F. STEWAE' COMMENT BY K. L. PURTELL - DESIGN - LOUVIERS *';riTTT,,w"T7T , - It should be mentioned that workers, involved in ether crafts other than those actively involved in removing insulation can be exposed to asbestos and must wear protective equipment. REPLY - This is considered implicit in the standard and we do not believe it needs to be carried further. As written, the standard applies to any personnel exposed to asbestos dust, not to "those actively involved in removing insulation". yW'Ml'iW1 * O R. D, MANNOK - F & F_ - FLINT PLANT Oi""1 r\i ^o ' tne rlint r1 k P Plant, asbestos f:jiDers, delivered in fw--o oags are used in making a Company product. This proposed standard includes no requirement"for handling bagged asbes tes fibers or disposing of empty, dusty bags. REPLY - Standard applies to the handling of asbestos in any form. However, we agree more should be included on handling bagged asbestos, waste, ana empty bag disposal. We will add. C0I-3-SNT NO. 9 - The new CSHA standard requires that asbestos debris oe renovea in closed containers or plastic bags. Empty, dusty bags might well be classified as debris, since they do cause a dust problem. Our new engineering standard should include recommendations to cover this, and be consistent with the OSHA standard. :1Y - V.'e agree and will add as discussed in reply to Comment 8. If pV * T P?TP P {. P T.TTT *TJ*'V .. w " ' clS^ro.Sp i .SpCSai. -- ggest imcraawion oe mciuaea cr* tr.e requirements for waste disposal of asbestos or asbestos containers (bags, etc.) in sealed impermeable bags, or suitable containers to avoid ' 9^ 6 ~ .loers during disposal. - .'.e arrree. oee reolv to -Comment 8. e ese *c DUP 1 153819 DU 062047 9/11/'" 2 .-eoruarv _ P.ZP1Y - V.'e will call attention to this. Sampling will be required to aetermine the extent of the exposure. (Incidentally, fibrous* talc is now under the same restrictions as asbestos. See Federal Register, p. 221..2, October IS, 1972.) cc:-:z::r I.'C. 12 - 3.1.2 - Dismantling (removal) of small sections of insulation as frequently encountered by maintenance personnel in making minor repairs to equipment cr lines would not be expected to exceed lC~tin; T7JA. Provision sho'uld be made for exception where it can be shown the exposure levels do not require this degree of protection, i.e., atmosphere supplying respirators. REPLY - See reply to Comment 1. COMZET 11. 13 - Paragraph .. - Should include preface that "Compliance not be achieved by the use of respirators and oheir use is acceptable only during the time period necessary to install engineering controls and institute work practice necessary to reduce levels below the limits prescribed in 2.3!:. REPLY - Ye agree to your proposed change but believe it should be incorporated in Section 2. COI-YZET LG. 11 - 5.2 - Believe there is a danger from over simplification of the law since ail details are not included in the standard." is fcr example, no reference is made to medical examinations. Suggest adding a caution statement that when these conditions exist (exceeding limits of paragraph 2.3) the law should be consulted for full details on the requirements. Same for 6.5 and 6.6. Suggest combining paragraphs 5.2, 6.5, and 6.6 into one section to avoid repetition of caution statement. V Phese suggestions will be carefull" considered. The manner in whicr. medical examinations are to be mentioned is being developed by Haskell Laboratory and Employee Relations Department. 3ZZZYT YD. 15 - 6.1 - Suggest clarify 6.1 with the following: where employees are exposed to asbestos fibers monitoring is required to oetermine whether an employee's exposure is below the limits prescribed in 2.3. The law states "Sampling frequency and patterns, .-.fter the initial neterminations required by subparagraph (1) of this paragraph (similar to paragraph 6.1), samples shall be c- such frequency and pattern reasonable accuracy -- he levels of extosure employees. In r.c case shall the sampling be &w mterva--S rrester trer. c months fcr employees 'whose exposure c asbestos nay reasonably be foresee: to exceed the limits prescribed Toy pa o* co tms section' . \ *" / ) --***** d--- ~ c.- -*"f'** v' } is mterpreteo to mean tr.ac alter it 'e estac-isr.e: - d. di? *c :_y oe 1 oreseer. r.ot to exceec. tne limits. C>Up 1>S38?0 DU 062048 -- > -- monitoring is required id conditions remain unchanged. It is estimated adecuate controls* can generally be established to eliminate exposure above the 'limits and probably is more typical of most Du Pont situations. Additional instructions on monitoring, therefore, are suggested for situations where limits are not exceeded to cover recommended practices for personnel and environmental monitoring, employee observation and reccr keeping which will satisfy the legal requirements. RZPLT - V/e will review and clarify. DC. 16 - 6.3 - The procedure refers only to personnel monitoring wnereas samp-.es collected from the areas of`a work environment which are representative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees may be a more convenient means of* demonstrating compliance where maximum levels are below the prescribed limits. Suggest adding note that ambient monitoring may be employed where --U.Y - This also will be reviewed to clarify the areas cf persons ancient (environmental) monctoring. * --- * *_ .w T'-r-. - UV * V. f_ _ TVT 7) TTT7M* "* * " C ITT? r -- Cn -- 1,-,^ . :;s. I7 - 2.3 - 7 don't think we can measure this. _;_t_o_r_v - V,"e presume the difficulties you are referring to are similar to tr.ose expressed in Comment 1. V.re agree proof of compliance will not be easv. * ' *J - ts V '* r*T T* v C~T^T * T ^ '^T '"T ~C T*Qrn * A Is - 2.2 - fief erence to ' insuxatxon1' snouia oe "asoestos insulationsor-"insulations containing asbestos" to avoid people think! these guidelines are for asbestos-free insulation (i.e., Super Cal Temp, ac , 51 c . i - A'e will clarify as you have suggested. -7 - oecticn c._ - r.ow u* y.Lc -oscer^^se;- a cias/. a suitable sterilizing solution, we will review further t ossicle. u _ ___ * ---- - o . ... u" ~ vr * f. w Irf.tvuS) 6 W C . M.W a.2 I*ww c_ear to me a; "methods (Sees: i) are required if permiss isle exocsure hsrwise met. oom.e cc tr.e ccr.tr c_ .etr.ccs are ^o.-..-.__rs~ ei ir. red when scan: prorcice :o helm Ami: :r.ers are recommence: DUp M5382I DU 062049 jBEMlSIL .tBM'HHWI -ii M' IftinaK rfct;3ijfcii;:Mii:ilBJ^WMHWil''a;t-MIMIWiwaf?>,;' , TUa 9/H/72 -o- February 13, 19' - -- -- * ^ *? ~ t;v " /"'TJ C' '*-- ^ ^ o <# i $/ *O . Li i-X*. w,.* -- Vflw*--J ^ CHIoYT ::o. 21 - 6.3.5 - Either delete the word j! approximate!"" in Line 1 or change "check" in Line 2 to "record", otherwise control of'precision in sampling cannot be attained. ( The usual volumetric precision limits [95ft confidence limits) is ^ 10$. REPLY - 7,'e will revise accordingly. C0.:-:si:t LO. 22 - 6.3.6 - Stoppers furnished with the filter units must be retiaced before sealing. REPLY - V,7e will revise accordingly. CCLIIIYT EC. 23 - Section 6.* - Lines 4, 5, and 6 - This control filter must not be opened to the atmosphere. Delete "which has been handled.... at * REPLY - V,'e vri.ll revise accordingly. <J > _- . , :oiyz::ts 3y j . c. ;;ari:sr - orchsm - 9Kakeers v:crks 1/ wi ICLT EC. -> - 6.2.1 and 6.2.2 - Recommend showing Du Font Company as *w*uSr S IrTrea order supolier. ID-997209 Our experience indicates Du Pont is cheaper on I?C0 showed their price $265 and delivery and two fasts months. Order was changed to E. I. du Pont de Nemours and Company, Explosive Products Division, Industrial Products Section. Price was $247 and items were received in four days. Attached is copy of Du Pont ad on REPLY - V/e will add and indicate as you suggest. J.__A. SIGI-IAIl COMMENTS BY J. M. MARTIN - TEXTILE FIBERS - CHATTANOOGA COMMENT EG. 25 - 3.2.3 - keword third sentence as follows: "All parts of the room must have vacuum cleanup on a frequency which prevents accumulation of dust on ledges, shelves, floors, and machines". --* --- "" -.----w l..c.r4,S vVxj-X oe i^aae. -'2. 26 - 3.6.2 - Reword to allow discharge into a cyclone separate o.no_ empty hopper into a plastic bag. "Discharge should be into a cyclone separator or into bag filters which meet the following criteria:" -'1Y - This change also is accepted. rwer-cuzDinz nacrmes are _ccaDea ir zsair 'e.cra\isv 1 wiss a^x-acrer* ^ se r.c neeci sc >6. is preierrea ior setter cor,,Drc_. DUP 1 153822 DU 062050 /H/72 m C W* MCt* / -- ^ y -- :::. 23 - 3.6. installation -irs u c u El? 11 - Thanh vou for c::.:c::r ::c. 29 - 5.2 vacuum employees -- El PLY - Thanh you for ^ ATT <- - "*DTTO rO rT7VmTT T* T'TCC'IDC 3 U "* < * U CL " ---l^ULHt: ^uOS6 aS ues uOS w C a. OX*!*! CeniSXl w # ` r1 .`ill add "loose as suggested. W V-'.'il'. ' ____--____________ - Respiratory Equipment. Suggest including approved respirator suppliers complete with model numbers. REPLY - Reference to Bureau cf 1-lines should suffice since models an: cricLr*ei Suppliers are listed in S2H, which is referenced. -- " - No mention cf notifying laundry. Ynis wn* oe clarified. J..31 Sl-11:, SOI-Z-SNTS BY J ,K. C OLEoiAK -V7, J .Y5KA3LS-TE2.?I3. -SRRUAI-ICE PillIT UMClP I,'C. 33 - (Comments 33-3$ are listed with proposal as written and comment indented.). 3.4*1 - "Insulation to be removed ana discarded should be dampened prior to and during removal whenever possible". Suggest consideration for rewording with reference to "prior to" as a glazed or painted exterior surface will not absorb moisture. Agree with dampening. EEPLY - he prefer to leave this as worded. JCt'-*- - J. w **.<=. wC aitierer.t. the object is to reduce dust by moisture whenever possi: -hanl you for your comment. o- - o.- - Respirators ana mas.ts : r, r r, e sceri_ize: .cr reissue. Jcnsiceraoior. for ' e>:candir*u wi.e --scuar*cs C'wC^irc.ccry scuc.pir.6iiw oc ur.cn.viuua--5, t-o os ,,-:sp' wU-.r.sc oy ureic as psrscr.au prouecuuvs ioens - mi loo ^ -- o- 'e are r.ar.v luss "ii sice ar a *r -- xu %. -- a -* DUP I 153823 DU 062051 3.1. ~:i3 9/11/7- reoruary 13, 19' COHSa. G awjiOi* 06 Lver* *co ax-iov; use or *: iV.HU-'Jj) ( "AW fillers (griaded) by those who nay have a current, plentiful supply on r*and REPLY - Either griaded or r.ongridded filters can be used. V/e understand r.ongridded are preferred by the laboratories. as close as possible to the person's me sampling is preferred." Sugges t consideration be given to to "breathing zone". REPLY - b'e will change as suggested. CCMZET EC. 37 - 6.3.5 - "Turn or. pun? and set at approximately twc (2) liters per minute rate. Check rate periodically. Wher. finished sampling, turn off pump, and record elapsed sampling time. Sampling recbrd_forms,_ EIj-2731 (see Figure 3) are available from Stationery Store: * ~>epu., .,'ij.mir.gton, --'elaware." Suggest consideration be giver, for use of an inline orifice (screwed into filter adapter) which meters air flow auto matically, and removes chance of error in setting flow manually, These adapters are available from Millipore Corporation. RSrlY - Orifice use is optional. A periodic check of rate still is aestred when using an orifice. The latter will not help if the battery goes down. CCIIZET EC. 33 - 6.-. - "Analysis. Completed samples (exposed filters) are_ p_acea in a mailing tube, sealed and sent to a qualified laboratcr** with twc_copies of the sampling record. Include an`unexpcsed filter with the sample_which has_ been .handled in the same fashion without drawing -*-- ^ub" --w. .fid laboratory imornstion is ava^--utb.e .ret a^ccv* '..mS.'.c--. _^c Suggest consideration be given to clarify whether one (1) unextosed filter is required for each sample, or one (1) ur.exposeo filter is required for each lot of exposed filters, which may be as many as* six (6), or eight (3) ir. the same :la--stic ewnU0v6elccer.^Scoe&resr- -u ggPe--sat ceira.gcn exposed san?j.e in tr.e mai--ing ce cue tuce. in a - - -pv" -- net ?-e=-r cr- "-'-is eitr.er. out one background for several exposes, filters shcuLd suffice. 7~e reply to Comment 3. .-.s to use cl .--astic enve.cpes, see., tr.e net: ,...ea sam.plir.g procedures are considered DUP 1153824 DU 062052 9/11/ nI ^~ 9 Fe -o, -v/o - T""ical Sampling F.eccrd Form 111-2751 Suggest consideration be given as to definite value of recording "Weather-Temperature-Relative Humidity". Require ment cf this may necessitate additional equipment, and`forms, when samples are taken at several Plant sites simultaneously, where temperature and relative humidity conditions vary greatly. RZP1Y - Figure 3 is a typical sampling record form and should be modified to suit local considions. However, we would expect most sites would want to have this information for studying and comparing results. M Al A1 6 OI-lZIiTS BY 0. C0TTY- TEXTILE FIBERS - 2.8 - Ada at start "When approved subs n HZPLY - We will review and revise. CCMZYT - 3.1 - This whole section should be reworked to be equally applicable to pipe or block insulation. RZF1Y - We agree and will revise. CClZ---FT Yj. l,2 - 3.12 - Some question as to whether vacuuming is a ''must" for every carton. Sugg`est that this be revised along the lines cf "Cartons cf new insulation should be checked after opening and prior to removal of insulation as to the need for vacuuming to remove dust". FZF1Y - We will review and revise. COKVENT N0_. i-3_ - _ 3.22 - Very questionable as to practicality and/or neea. u- o.-c.l is followed anyway, why this extra and impractical requirement in all cases? -~-~Fl-~ - *f:-s _not included as a "requirement in all cases". The words uset are ''should be isolated". The practicality must be determined for each case. .-'.Iso, see reply to Comment 27. - - 3.2.3 - Add new sentence "Facilities must be ter 571". -9. a refers uc wne ventaataon system earut system. The twc need not and orcba' Sl^S " C . be he ./ill revise. r. b' osed" before last w: )elete,-covered in v.1.1 (aft; e: 1 - -- / DUP II53825 DU 062053 i2E,faflL ;'.-|fiiig[-JJLi33a 9/11/72 vecruax i ^^ a " R SWi1 ^ w 0 2 o me c*3 w **e --.ciW , 0 & p 0*1 2 * .* w> be collected and disposed of in sealed impermeable bags, or other closed impermeable containers". REPLY - We will revise. See also replies to Comments 8 and 9. COM-ZNT 10. do - 4.1.1 - (a) remove the word "or", and (b) correct the last sentence after "when" to read "when the ceiling or the 8-hour TWA are reasonably expected to exceed 100 times the permissible exposure limits" '(see 2.3). Y1?1Y - (a) The "or" is needed here sentence as ou suggest. (b) We will rephrase *r.6 --ast. * O* n *rr**n r, Q / -* n - Rework the enclosed part to read the same OSrll law, or 'Shall be used when the ceiling or the 8-hour T'WA are reasonably expecced to exceed 10 times the permissible exposure li (see 2.3). REPLY - 'We will review tr.e wording :cr clarity. (However, the CSKA requirement is for: 1 to TWA, and not: in excess of LC) O VA***'*^. < ^ y\j <+.2 - Reword at start to read "Those employees who use respirators sha 1 be instructed...". REPLY - 'We will add a phrase in 4.2, "Each employee who may use respirators." Also see reply to Comment 2. C01-0*0.::T NO. 51 - 4.3 - New - "Respi: atory e equipment practices shall be in accordance with ANSI 188.2-19&9 Practices for Respiratory Protection pT'DT V We will add. -- aoncatea *. Add at end^"where asbestos is being handled cr run: - We v add. - 0.2 - The CAUTION notice seems wO 06 m *> w -- OX* CiS Eendix Corporation 'unit, as this model is approved Nines^fcr intrinsically safe for use in explosive i.c. 2u-2_9~. e revises to read: *,.-.Y*.ICN: Unless specifically apt: us atmospheres, air samplers shall net be used in hazard ** ----' Viw**0^w . pX~*nU. w vO u36 B SpSOT.rI"-'OX> CUUC UX1IT uSV. oseci r.e o.an v; S . up r/eu r a. DUP 1 153826 DU 062054 UJ -- * - 9/11/72 m e cruary > -- . +* CM!~IT 11. 5 5 - o.5 - Correct to show chat ' meaica- exar.in.aoior. records shall he retained by employees for ad lease twenty (20) years'*. REPLY - By agreement, the medical requirements will be handled through the i-Iedical Division. This standard will contain a reference only. Also, see reply to Comment 14. CCMNENT LG. 56 - 6.6 (a) Change WARNING to read CAUTION and (b) rewerd ano^epnrasTTo conform with the two different signs for Shop and Barricaded Areas as described in letter R. B. Hayden to Plant Managers 9/23/72. REPLY - (a) We will use ''CAUTION1', (b) We have requested P.. 3. Hayden's Teeter and will review. J. A. SIOMAN. COMMENT BY ?. F. PHILYA'./ - TEX. FIB. - WAYNESBORO PLANT .1.-........ .. - vve seen tnat the vaynesooro rxant nas an enective asbestos dust control program. Allowable exposure limits have been met and further reductions in dust exposure are being made to comply with future allowable limits. Cost of compliance to date has een negligible, Cose of planned future improvements will be minimal. The proposed S4T will require significant and costly step, ;o oe taler, even though limits* are being met through the use or ;ther > W*>. W-. rWww Me are also concerned that compliance with S4T as preser.e. y written wi_j. have undesirable ramifications in regards to exposure to ; ther chemicals and dusts. 'This standard should not be implemented until Engineering Superintendents at ail plants have had the opportunity no meet and discuss _r. detd-. fi o *** REPLY - Than;:_ you for your comments. Implications are bei r.g carefuxl evaluated. While there may be other ways to assure emplo; ee protecti against asbestos exposure, this standard represents an aoo eptabie app and also meets CSKA regulations. minate the word "may". to retain "may". This was taken 'O' _ 0 *C J -- rvdLd. "If ether dust cor.tro' equired in Section 2.3". ... . do not. r6ou( V w<C. V* wTi Cc :ecioe; ~e e::zee~ez , -r_* - Zss reo!** - Add :Mf exposure levels specifier in oectior. E.5 \\53&2d OOP DU 062055 9/11/72 d "lust samples shall be taker. every 6 months oliector dischargedo assure satisfactory perfcr~ar.ce cf the syswSiT** -j\is t level at the discharge point shall not exceed Units -escribed in Section 2.3TT* P~ PLY - V,'e v:iil add iten as you suggest. However, the sampling frequency will vary for different situations. We would prefer to say, "Periodically :eec.ea to assure satisiactory..... CCMCIwr 1C, 62 - 5.2 - Change the first sentence to read, "Special clcthin a crar.ge roorr., and duplicate lechers rust be provided for employees expose so concentrations which routinely exceed the ceiling limit of 2.3". PIPLY - Your addition of the word "routinely" does not clarify the senoero Is not included in the CSKA wording related to this, and v:e believe should oe orutted. C CM HIM HC. 63 - 5.3 - ^-dd "Where dust levels normally exceed the limits c.--w--oecacr. & * j> PICP1Y - V.'e will clarify, but prefer the wording in Comment 52. CCM --YY Y.Z, 6^ - 6.6 - Change the first sentence to read, "Warning signs conforming to Figure 1 shall be posted at all approaches to areas'"where asbestos concentrations routinely exceed permissible exposure limits at sufficient distance to permit an employee to read the signs and take necessary precautions before entering the area". P.ZP1Y - Again, we did not add the word "routinely" for rersens discussed --~ - * ewO o Ouuun i. o . - , Q r r" '"n' *"* t - m ^ -jV " <*< *** - --"*V * -- 1 . 1--1*7* 757-1 -57 rO* * n75r--'Hirir*. n.o.^4 & * -- = . s > si** s-in-,..*. cL- vO c.wwaCT.BQ -- ce usee a_or.g the perimeter cf a barricaded area. <e preier to stay with Figure 1 for the present, men snows MM. recuirements signs. - :.cc meaican responsici_ities ior examine 10ns ana r.eetm- simi_=~ - otar.a '2C (Hearing Censervat 0 n). - v>/"e5 s ZpZonsioi_ities_vri_C. oe handled separata . See re* 'C not crcviae "ih--omtanv -- wa^c.w yw w. GrwW. wcu_a ce aaecuate. comments However, responsoiili with the Implo"ee F.elaticr.s let ieve--0 one r* oeteminin OUP l'S5828 DU 062056 9/11/72 - 13 `ebruarv 3, v--s r/- o* COMCEHT :;c. 68 - Are we properly covered on "wetting down" as related tc OSHA 1910.^a in handling, disposing of, etc.? REPLY - We believe we are as much as possible. See reply to Comment 33 coi-szi:? ::c. 69 - Item 3.1.3 should be incorporated into 3.1.1. REPLY - We are deleting 3.1.3. COIIIZXT XC. 70 - OSHA Regulation 1910.93a references two types of sampling personnel ana environmental. Du Pont standard should specify whether either or both are required. REPLY - Both are required; standard will be clarified. COI-IEXT XC. 71 - Clarify 6.2 through 6.3.6 between personnel sampling and environmental sampling. REPLY - We will clarify. A - - KWUA 1 V- COMMENTS 5Y G. 3. KIRKPATRICK - TEX. FIB. - OLD HICKORY _L - b'.'l' 'Vfnat is the reason to ''induce an unexnosed filter witr tne sample which has been handled in the same fashion without drawing air through it::? At Old Hickory, all cartridges are kept in the box, sealed, until ready to use. If this unexposed filter is going to be analyzed also, this will double our cost. This could amount to a large amount of money at Old Hickory, since we strive to take at least five samples a week. REPLY - See reply to Comment 3. ;_ c oi-cz:: ts by l .i. tk clips ok /e . g . gsrkqi: d - te:: . b . - c he : ___________ . :.'~-"Pleference note should be added as fellows: "-- supplying respirators see paragraph 4.1.1 or paragraph 4.1.2 if the concentration of fibers is low enough." . - oee repm** to comment 1. CCIIu-XI X2. - 3.6 - nxhaust ventilation paragratn ^.z.^ tc list approved vacuum cle am wnere tr.ey can be purchased. Also to i ----tii_I sams-y tms standard. ec e DUP M53829 DU 062057 9/11/72 - 14 - ebruary 13, 197: - The use ci the figures 2o is rr.is_eac.ir.: buggest sone..,mg .ike: '-----exceed the ceiling licit (1C fibers) specified in paragraph 2.3. This is to prevent* nZPLY - The reference to paragraph 2.3 eliminates the restatement of the 717. ana ceiling limits a number of times. We believe that the number cf repetitions avoided in this case justifies the use cf the reference. CC::z::T ::c. n6 - 5.3 - Since lung cancer is considerably more prevalent in people who smoke on the job while working with asbestos, it is suggested that 1C SMGKI1G be included in this paragraph. Pm PLY - vrr.ile there is some evidence that the effects of asbestos expcsu; ana smoking are synergistic, this relationship is beyond the scope cf oh: 5 "C anCLan d + m* W rrr9 by sassakan - cent, res. - wh:z:;ot:: * Aluer ..0 uo reacT,"",^"Tn,,""a!!n7,^^aises7,,wner(^"TMsuiwao7re""-"suoc'c---u: materia_s are obtainable, the installation of asbestos should be avoided, .over if installation can be made without exceeding hazard thresholds, these may be reached later or. when maintenance or removal is required. See engineering Standard 3IC100M and SN500K for possible substitutes. Ye believe changes to 2.0 as proposed in reply to Comment v.'i_u cover your suggestion adequately. Although personnel involved in insulation will know, we will.add to 2.0, "For asbestos insulation substitutes, see the Sl-M standard series, which cover approved insulation V G l"1 l-i- 2 ZKT '0 - Alter 3.2.3 to read: The work area shall have vacuum cleanup devices specially ecuipped with a filter system capable of capturing a particle size cf 0.5 micron. This can be either a system of connected no a central dust collector, or a portable small volume vacuum device. ~-l71Y - be 'will review experience and alter 3.2.3 accordingly. To be eisective^ any vacuum cleanup system must remove particles 5.0 microns . --O'*-* The need for removal down to 0.5 microns will be investigated. ** -r -n cone cases, xarre sections ci nr.su^anea can ce vnranns :cntainin^ ashes: - ..e ce_ieye a r.umcer cc ur.usua_ ways ci containing ashes ce dsye-tpea similar tc what you have suggested, be wcuic too suon _ater when the most ^effective methods can identic is -- -- * . . -- irs, shhs r " j3~' Scanc.c.r'b . j --noanrcebbcs -- DUP 1153830 DU 062058 S.l. -rC13 9/11/72 recruary -0, REPLY - This source will be included. COM--IT EC. 11 - In a discussion with D. C. Cannon, Jr. of the Industrial products Section, he advised that the Model C115 pump is a much higher quality unit than either the Micronaire or the Monitaire (MSA) pump. He also questioned whether the wording ''Gravimetric or ' ahead cf Monitaire is appropriate, i.e., he considers it redundant. REPLY - Presentation cf pump data will be reviewed with Explosive rrooucts Section of Polymer Intermediates Department. Regarding the last question, ''Gravimetric" will be used and "Monitaire" deleted. WT^r* HILL, COMMENTS EY I. H. r REIDAY - PIP - SAVANNAS RIVER PLAET T I.'O. ~2 - item 2.4 seems to permit tne use 01 asDestcs materials wr.ere aaequate controls are not feasible and limits are not obtainable, if - protective devices are used. Item 2.8 can be interpreted to mean no asbestos can be used if limits are not met. To avoid conflict cf interpretation it is suggested that 2.8 be revised as fellows: "It is recommended that nonasbestos bearing materials be considered where asbestos contributes to a dust concentration exceeding the permissible exposure limits and where the work consists of more than the execution cf occasional repairs or replacements". REPLY - ive do not agree item 2.4 infers this. Paragraph 2.5 does address itself to this as does CSHA. In regard to paragraph 2.8, this will be revised as noted in replies to Comments 40 and 77. he believe this should satisfy your comment. .'.W 'GHLZR - ICE - COMMENT EG. G3 - 3.-.3 - hordinn is not clear - suggest cnanse to: "Scrap insulation snail be collected and disposed of in labeled and sealed bags or ether containers. Disposal and labeling shall follow plant and local government regulations. 1PLY - he will clarif". mo t:v rri----- : -r* te very neapm an ampaenentang reccmmenaacaons, .-.ccrevaataons in paragraphs 2.3 and 3.6.2_shouid conform to new Company s, _.., emb rather ^nan cc arc. at3/nir/ata ratner tnan cam/sc at. or :ur comments. w a0 -- raragrapr. a. a ----.exceed tne cea_ang --aaaa - " --SS-- ------ --.m_w ca paragrapn 2.3- -or- -.>0n exceeoea. r.owever, ~~ ^ v;e igraph ecuares ^~ ~^ --w - -v .---^-- - -- LOW 2.3 is''exceeded. a cr.ange room ano separate provided only when the he will correct accordinal' DUP 1 153831 DU 062059 u --* cove. 0u<d1om-- n .I t :k j 9/11/72 - 16 - recruarv _ ^ > -?, eering Standards Committee members advise an estimated .ses for this standard as reference per year. of additional comments, which should be received bv , this standard will be issued with the revisions shown DESIGK DIVISIOi: Standards Section C a Larsi^-^-. Senior Standards Engineer DUP 1153832 DU 062060