Document e5zEm0QmqkJ3XBgv15Bj9QQy
OCCUPATIONAL HEALTH PROGRAM FOR TRICHLOROETHYLENE/HCL B-1500, TEXAS OPERATIONS 1991-93
FILE NUMBER: / PLANT CODE:
; PLANNED START DATE: PLANNED REVIEW DATE:
B15-3839-91
Trichlor Services HCL Trichlor Trichlor Lab Trichlor Maintenance Trichloroethylene
66930 66926 66915 66940 66950 66900
June, 1991
June, 1993
INDUSTRIAL HYGIENE: MEDICAL: PLANT SUPERINTENDENT: APPROVED:
--------------
Melitsessa A. RBluii/e*
7
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V------------
Carole K. Browdy, IA.D/
Jim Burgner
. A/ZnJ
Sam Norwood Industrial Hygiene Group Leader
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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INTRODUCTION
The following programs are included in your current Occupational Health Program. The programs are scheduled to be reviewed annually and updated on a two year basis.
Industrial Hygiene Monitoring Program Hearing Conservation Asbestos Ventilation Ergonomics Heat Stress Medical Surveillance Hazard Communication Industrial Hygiene Education Program Respiratory Protection Protective Equipment Department Activities Roster and Job Descriptions (updated on a yearly basis) Chemical and Physical Agent Inventory (updated on a yearly basis)
These programs should be placed behind the appropriate tab in the Department Industrial Hygiene Manual.
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lHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
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OCCUPATIONAL HEALTH GOALS AND PLANS 1991-93
Industrial Hygiene Monitoring: Comprehensive Chemical (8-hr TWA & Excursion) Noise (Area & Personal) Hexachlorobenzene Wipe Testing
Hearing Conservation Training (every 2 years):
Asbestos Training (annually):
Ventilation: Ventilation Survey Manometer Check
Ergonomics: Initial Training
Evaluation of Manual Lifting Activities
Heat Stress Training:
Hazard Communication: Review written Hazcom program
Review industrial Hygiene Manual/Protocol Update CPAI
Review MSDS's compared to CPAI Health hazards training (annually) New chemicals training
Respiratory Protection: Fit Testing for SCBA, airline, half face air purifying Inspections- Mouthbit, half face air purifying SCBA, airline, Scott 5 min., Elsa
Training-
Mouthbit
SCBA, airline, half face air purifying, Scott 5 min, Elsa
Protective Equipment Training (every 2 years)
DATE LAST
DATE J2U
1989 1989 every 6 months
1990
----
1992 1992
1992 1991/92
1989 quarterly
1992
1989
....
----
....
1992
1992
1991 1991 1991 1991 1991 as needed
1993 1993 1992/93 1992/93 1992/93
1990
1992
before each use and annually
before each use, monthly, and
annually by fire department
1990
1992
1990
1991/92
1 992
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM T1UCHLOROETHYLENE/HCL, B-1500
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MONITORING PROGRAM
1 . RATIONALE
Personnel monitoring was conducted during 1985-1989 to evaluate employee exposures to trichloroethylene, cis-1,2-dichloroethylene, trans-l,2-dichloroethylene, ethylene Uichioride, l.i.l-iiichioroethane, carbon tetrachloride, perchloroetnyiene, 1,1,2,2-tetrachloroethane, and pentachloroethane. Both 8-hour time-weighted average (TWA) and short-term exposures were evaluated. Average exposures (8-hour TWA) for each monitored job classification were significantly less than the acceptable guidelines for each respective chemical.
Personnel exposures to vinyl chloride and vinyiidene chloride have not previously been evaluated at the Trichloroethylene plant and will be included as part of a comprehensive chemical survey to be conducted as part of the 1991-93 Occupational Health program. Additional chemicals that will be evaluated will include trichloroethylene, ethylene ' dichloride, 1,1,1-trichloroethane, 1,1,2,2-tetrachloroethane, 1,1,1,2tetrachloroethane, and carbon tetrachloride. Both 8-hour TWA and short-term monitoring will be conducted.
Short-term monitoring will be conducted to evaluate employee exposure levels to hydrogen chloride during specific job activities. With the exception of during shut-downs, HCL has never been monitored at this facility.
Texas Operations Safety Standard 0-46 (Hearing Conservation) requires that a noise survey be conducted every three years. The previous noise survey at Trichlotoethylene/HCL was conducted in 1989; therefore, a comprehensive area and personal noise survey will be conducted in 1992.
The Trichloroethylene plant is currently on a Hexachlorobenzene (HCB) quarterly wipe test program to insure HCB surface cleanliness levels are being maintained. Recent results from HCB wipe testing has indicated levels in the process areas have decreased significantly and cleanliness levels have been maintained therefore, HCB wipe testing will be decreased to every 6 months instead of quarterly.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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MONITORING PROGRAM (CONT.)
2. SAMPLING STRATEGY
A. 8-Hour TWA Chemical Monitoring
Job
Classification
Number of Employees
Chemical*
Trichlor (66915) Control A Operator Control C Operator Ass.Chem. CL A
Chemical Aide Sr. I&E Technician
5 8 Chlorinated Organics 2 8 Chlorinated Organics 1 8 Chlorinated Organics 1 8 Chlorinated Organics 1 8 Chlorinated Organics
Trichlor Services (66930) Control C Operator Class 2 Operator
1 1
8 Chlorinated Organics 8 Chlorinated Organics
Trichlor Maintenance (66950) Pipefitter Machinist Utility Man/Contractor
5 3 6
8 Chlorinated Organics 8 Chlorinated Organics 8 Chlorinated Organics
Number of Samples
4 6 3
.2
3
3 3
6 6 8
* 8 Chlorinated Organics includes vinyl chloride, vinylidene chloride, trichloroethylene,
ethylene dichloride, 1,1,1-trichloroethane, carbon tetrachloride, 1,1,2,2-tetrachloroethane, and 1,1,1,2-tetrachloroethane.
B. Job Task Monitoring
Job
Iask
Chemical*
Process Sampling Recharging filters Tank car loading Drumming Cleaning HCL compressors Line clearing
7 Chlorinated Organics Trichloroethylene Trichloroethylene Trichloroethylene 1,1,1 -trichloroethane; 1,1,2,2-tetrachloroethane
Number of Samples
3 3 3 3 3 3
* 8 Chlorinated Organics includes vinyl chloride, vinylidene chloride, trichloroethylene, ethylene dichloride, 1,1,1-trichloroethane, carbon tetrachloride, 1,1,2,2-tetrachloroethane, and 1,1,2-tetrachloroethane.
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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MONITORING PROGRAM (CONT.)
D. Noise Monitoring
Job Classification
Number of __________ ^ ~ "' 'Employees
Trichlor (66915): Control A Operator Control C Operator Sr. I&E Technician
Asst. Chem. CL A/Chemical Aid
5 2 1
2
Trichloroethylene (66900): Rotating Shift Foreman
3
Trichlor Services (66930): Control Operator C Class 2 Operator
1 1
Trichlor Maintenance (66950): Instr. Technician Sr. Electrician
Pipefitter/Welder-Pipe Machinist Utility Man/Contractor
2 1 6 3 6
HCL (66926): Control A Operator Control C Operator
5 4
Number of SamDles
4 4 3 3
3
3 3
3 3 8 6 8
4 6
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IHS File #B15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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MONITORING PROGRAM (CONT.)
3. SAMPLING METHODS
Sampling for vinyl chloride, vinylidene chloride, trichloroethylene, ethylene dichloride, 1,;,;-irichloioeihane, 1,1,2,2-tetrachloroethane, and carbon tetrachloride will be conducted using 1 gram charcoal tubes and air sampling pumps. Pumps will be calibrated both before and after use at 50 cc/min for 8-hour TWA samples and 200 cc/min for excursion samples (as outlined in DLI-IHM-81-3). Analysis will be performed by the Industrial Hygiene Laboratory.
Personal noise levels will be measured using Quest noise dosimeters (Model M-7B) and area noise levels will be measured using a Quest noise level meter (Model 215). All dosimeters and meters will be calibrated both before and after use.
Wipe testing for HCB will be conducted with Whatman #2 filter paper, 5.5 cm diameter. Approximately 100 cm2 of surface area will be wiped in a cross-hatched format with as much pressure as can be applied without tearing the paper. The filter will be placed in a clean labeled glass vial and sealed immediately after sampling. Gloves will be worn while sampling and changed frequently between samples to avoid cross contamination. Filters will be analyzed by the Industrial Hygiene Laboratory.
4 . QUALITY CONTROL AND EQUIPMENT
Routine quality control procedures shall be an integral part of the sampling and analysis procedures and functions. These shall include:
a Routinely introduced sampling of blanks and spikes (known content) along with other samples for analysis
b. Routine checking, calibrating, and maintaining in good working order all equipment and instruments. Air sampling pumps will be calibrated both before and after use.
c Routine checking of procedures and results. d. Participation in Dow's Analytical Proficiency Testing (APT) Program.
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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MONITORING PROGRAM (CONT.)
5. EVALUATION CRITERIA
Material_________________
Vinyl Chloride Vinylidene Chloride Ethylene Oichloride
1,1,1-Trichloroethane Carbon Tetrachloride Trichloroethylene 1,1,2,2-tetrachloroethane Noise
Exposure
Guideline
1 ppm 1 ppm 1 ppm 350 ppm 2 ppm 50 ppm 0.1 ppm 90 dBA-Ceiling 90 dBA (8 hr, TWA) 85 dBA (8 hr. TWA)
Excursion Guide 5 ppm
----
2 ppm 450 ppm
....
200 ppm
--*-
115 dBA
Roiit/SaL
OSHA-PEL OSHA-PEL OSHA-PEL OSHA-PEL OSHA-PEL OSHA-PEL Dow-IHG Dow-IHG OSHA-PEL OSHA Action Level
1 Dow IHG = Dow Industrial Hygiene Guide OSHA-PEL - Occupational Safety and Health Administration Permissible Exposure Level
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
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REVIEW OF PAST MONITORING DATA A. CHEMICAL REPORTS:
TASLE 1 SUMMARY OF 8-HOUR TIME WEIGHTED AVERAGE EXPOSURES, 1S891
JOB CLASS
# OF SAMPLES
Control A Operator
Control C Operator
Class 2 Operator/WHSE
Pipefitter
Machinist
EXPOSURE GUIDELINE (8 HOUR TWA)
5 5 5 5 5
1,1,1 0.01 0.01 ND 0.79 0.64
350
CONCENTRATION (PPM)2*3
CCL4 EDC
TCE
PCE
1,1,2,2
PENTA
0.02 0.02 ND ND 0.01
0.01 0.01 0.03 ND ND
0.39 0.11 12 0.14 0.31
0.03 0.04 0.04 0.03 0.03
0.01 0.02 ND 0.03 0.02
0.01 0.01 ND 0.02 ND
2
1
50
25
0.1, S
--
Reference: Sorrells. M.J.. 1989 Evaluation of Area and Personal Chemical Exposures Purina Trichloroethvene Cycle at Trichloroethylene Plant. B-1500. IHS File B15-3173C.
2- 1,1,1 = 1,1,1-trichloroethane; CCL4 > cartoon tetrachloride; EDC = ethylene dlchlorlde; TCE = trichloroethylene; PCE = perchloroethylene; 1,1,2,2 = 1,1,2,2-tetrachloroethane; PENTA = pentachloroethane
3 ND = non-deteetable; detection limit = 0.01 ppm
Personnel monitoring was conducted in 1989-90 to evaluate employee exposures to chemicals during plant shut-down activities. Chemicals evaluated included cis-1,2-dichloroethylene, trans-1,2-dichloroethylene, carbon tetrachloride, ethylene dichloride, trichloroethylene, perchloroethylene, 1,1,1,2-tetrachloroethane, 1,1,2,2-tetrachloroethane, and hydrogen chloride. All 8-hour TWA exposures were well within acceptable guidelines with the exception of 1,1,2,2-tetrachloroethane for Control C Operators during the Trichloroethylene plant shut-down at 0.24 ppm. On the days in which these exposures occured, the Operators were clearing lines.
Short-term personal and area monitoring was conducted in 1989-90 to evaluate employee exposures to welding fumes. Analysis was conducted for 14 metals or metal oxides and total fumes. The personal and area monitoring indicated all routine welding fume exposures of the Welder/Pipefitter and Utility Man/Contractor were below acceptable guidlines.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TR1CHLOROETHYLENE/HCL. B-1500
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B. NOISE REPORTS:
REVIEW OF PAST MONITORING (CONT.)
TABLE 3 SUMMARY OF 8-HOUR TWA NOISE EXPOSURES, 19891
JOB CLASS/ JOB CODE
# OF SAMPES
% OF OSHA ALLOWABLE
RANGE
AVE.
Production Foreman Control A Operator Control C Operator/HCL Control C Operator/TCE Class 2 Operator Sr. Instr. Technician Machinist Pipefitter Utility Man/Contractor
4
4.8 - 27
17.4
4 1.0 - 2.6 1.7
6 17 - 44 28
4 1.3 - 21 14
4 2,2 - 58 25
6 2.1 - 9.9 4.8
6 3.4-18 9.8
6 3.2 - 34 24
20 13 - 63
29
OSHA PEL OSHA Action Level
k^
100 50
1 Reference: Sorrells, M.J. , 1989 Evaluation of Personal Noise Exposures at Trichloroethvlene/HCL Plants. B-1500. . IHS File B15-3173N.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
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HEARING CONSERVATION PROGRAM
1 . JOB CLASSIFICATIONS IN A HEARING CONSERVATION PROGRAM
The date of the last noise survey was July, 1989. The survey included both area noise levels and personal job exposure evaluations. Personal noise dosimetry data for the monitored job classifications indicated that all average noise exposures were below 50% of the OSHA-PEL. Therefore, participation of employees at Trichloroethylene/HCL in the Hearing Conservation Program is not required.
2. TRAINING
Training is recommended every 2 years.
3 . HEARING PROTECTION AREAS
The following areas are designated as required hearing protection areas since they are at or above 90 dBA. These areas are posted with signs requiring hearing protection.
1. The following equipment in the maintenance areas: Disc, cone, plug, and wheel grinders Pipe threading machines Impact wrenches Percussion tools (noise levels >105 dBA) Metal hole puncher Metal disc saw Disc buffer
2. Mycom compressor and fin fan deck in HCL process area 3. Underneath the furnace in the B-column area 4. Air bleed on drum valves in warehouse
Temporary jobs that have equipment with noise levels at or above 90 dBA require temporary signs and mandatory use of hearing protection any time the equipment is in operation. This includes such areas as sandblasting, hydroblasting, use of portable air compressors and hand tools.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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HEARING CONSERVATION PROGRAM (CONT.)
4 . HEARING PROTECTION TYPES
Hearing protection devices utilized at this department need to have a NRR rating over 19 dBA. Some of the devices available in the plant are:
DEVICE
E-A-R. plugs Bilsom Universal Ear Muffs UF-1 Bilsom Viking Ear Muffs #2318 Willson Sound Ban # 20 E-A-R Ultrafit with cord
NOISE REDUCTION RATING (NRR)
29 dB 23-25 dB 28 19-22 dB 27 dB
Other devices are available through plant supervision or the Occupational Health Department. 5 . NOISE ABATEMENT PLAN
There are no noise control plans at this time. They will be developed as part of the 1992 noise survey.
Any new equipment or changes to the process, will be evaluated for noise and when feasible, engineered to keep noise levels below 85 dBA. Contact your Industrial Hygienist.
6. NEXT REVIEW DATE: June, 1993
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IHS File #B15-3839~91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
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ASBESTOS PROGRAM
1 . INVENTORY
Asbestos is contained in this block in the following forms :
gaskets
transite
insulation
An inventory of all asbestos containing materials and their respective locations is attached. The inventory must be maintained until the materials have been removed. Labeling of asbestos is by block signs located at entrances to the block.
2. INSPECTION SCHEDULE
Asbestos containing materials will be inspected every 6 months by Bonnie Martinez for signs of deterioration. If deterioration is found the material will be repaired or removed. In the event removal is required insulation services will be contacted for assistance. Removal and disposal will be according to appropriate procedures as outlined in the Texas Operations Asbestos Handbook (TOAH).
Questions may arise at the time of removal of insulation or at the time of the 6 month inspection as to whether a particular piece of equipment contains asbestos or not. If this situation arises, the material will be sampled and sent to analytical services to be analyzed.
3. TRAINING
The following job classifications are identified as having potential to handle asbestos containing materials and should be trained according to Section III of the TOAH.
Pipefitters
All individuals in the above job classification will be trained before initial assignment and annually thereafter. Training will be documented and forwarded to Industrial Hygiene Services for inclusion in the plant's Industrial Hygiene files.
4. RESPIRATOR CERTIFICATION
For those jobs that require a respirator, an approved respirator will be chosen and mandatory medical certification and fit tests completed before initiation of the job. If exposure exceeds the Action Level (0.1 f/cc), the employee must be fit tested semi-annually and have annual medical examinations. Currently there are no employees at Trichloroethylene/HCL that require medical surveillance.
5. PROCEDURES
Written procedures have been developed for the handling of asbestos materials during the performance of maintenance, demolition, and renovation activities to be conducted at the facility The procedures are located in the Industrial Hygiene Manual.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
ASBESTOS PROGRAM (CONT.)
6 . ASBESTOS ABATEMENT PLANS There are no asbestos abatement plans at his time.
7. NEXT REVIEW DATE: June, 1993
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VENTILATION PROGRAM
1 . PROGRAM DESCRIPTION
The Trichloroethylene/HCL ventilation system includes as follows:
ID Number.
150101 150601 151002
Lest
Next
Average
,, Location_________ Survey_________Survey_______
B-1501
10-02-90 10-01-93
136
B-1506
03-15-89 03-14-92
116
B-1510
03-15-89 03-14-92
93
The hoods are are separately ducted to the outside.
2. OPERATING CRITERIA
A Periodic Performance Evaluation and Maintenance Programs -Administered by Industrial Hygiene Services and lab personnel at Trichloroethylene/HCL.
B. Laboratory-.Fume-Hood Performance Criteria -Utilize marked static pressure manometers to provide direct readouts and fall under the quarterly inspection guidelines.
3. DOCUMENTATION
The Industrial Hygiene Contact for Trichlorethylene/HCL is responsible for maintaining documentation on hood surveys and inspections.
5. NEXT REVIEW DATE: June, 1993
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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ERGONOMICS PROGRAM
1 . INTRODUCTION
The plant ergonomics program is dependent on the work situation and other specific factors which contribute to musculoskeletal injuries. Physical stressors and other activities which can contribute to musculoskeletal injuries include manual lifting, repetitive motion/forceful exertions, or excessive vibration. Identification of these factors is the basic responsibility of the assigned plant ergonomics contact with assistance from the plant Industrial Hygienist.
2. MANUAL LIFTING ACTIVITIES
Job Activity
Moving waste drums (tilt & roll) Placing empty 55 gal drums on conveyor belt
Frequency
Once/mo (<5 drums) varies daily to weekly (50-100 drums)
Weight 200 lbs
25-30 lb
3. REPETITIVE MOTION/FORCEFUL EXERTIONS
Computer personnel (keyboard entry) 4 . POWER TOOL USE
Pipefitters (wrenching action)
Typo QtJOQl Disc grinder
Frequency of use daily
Duration 30 min
5. TRAINING
Basic training on the identification of ergonomics factors is recommended for all block employees on a periodic basis.
6. NEXT REVIEW DATE: June, 1993
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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HEAT STRESS PROGRAM
1 . HEAT STRESS INVENTORY
The plant heat stress program is dependent upon the work situation and other specific factors which would generate excessive heat for the employee. The two factors to be considered are environmental temperatures and heat build-up due to the activity level of the employee. Based on previous heat stress studies, work/task evaluations, hot process operations and/or use of personal protective equipment such as impermeable suits, the following are identified as potential heat stress problems:
Outside manual labor with or without chemical protective clothing (PPE for HCL spill)
2. TRAINING
The following job classifications are identified as having potential for heat stress and should be trained in the recognition, prevention and treatment of heat stress:
1. Maintenance Personnel
2. Control C Operator
Heat stress training is conducted every 2 years.
3 . HEAT STRESS ABATEMENT
The following drinking fluids are available for fluid replacement:
Water
Gatorade
The following checked personal protective equipment for the prevention of heat stress is available at this plant:
none
Recommended work practices for reduction of heat stress include:
1. Fluid replacement
2. Self-paced work
WORK REST SCHEDULE
3. Scheduling
4. Acclimation
The heat stress prevention work/rest schedule for jobs requiring impermeable clothing is as follows:
Ismpeature_(F) 72 - 79 80 - 87 88 - ?
Maximum Stav Time fmin.)
40 30 20
NEXT REVIEW DATE: June, 1993
Minimum Rest Time (min.)
20 30 40
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HEALTH SURVEILLANCE PLAN
1 . HEALTH SURVEILLANCE All employees are offered core examinations every two years.
2. MEDICAL SURVEILLANCE REQUIREMENTS
The following job classifications are included in the MSR programs as identified below:
Job Classification
MSR
Tests
Test Frequency
HCL (66926): Control C Operator
HCB*
Blood Chemistries (Hepatic) HCB Level
Annual If 2. 50, annual
If < 50;>25 biennial
Trichloroethylene (66900): Production Foreman
HCB
Trichlor (66915) Control C Operator Control C Operator/PRG
HCB HCB
Trichlor Services (66930): Control C Operator Class 2 Operator
HCB HCB
Trichlor Maintenance (66950):
Pipefitter
HCB
Machinist
HCB
Same as above
Same as above Same as above
Same as above Same as above
Same as above Same as above
Same as above
Same as above Same as above
Same as above Same as above
Same as above Same as above
* HCB = Hexachlorobenzene 3. DOCUMENTATION
Results are reported individually and in group format to area supervision.
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INDUSTRIAL HYGIENE EDUCATION PROGRAM
1 . INTRODUCTION
Training will be documented using the forms located in the "Hazard Communication" section of the facility's Industrial Hygiene Manual. Copies of the training records will be stored in the Industrial Hygiene Manual until the time of the next regularly scheduled Occupational Health Plant Program review. The original documentation will be sent to Industrial Hygiene Services at B-101 for filing in the plant compliance files.
2. TRAINING PLANS - CHEMICALS
The Industrial Hygiene Education Program will focus on the following key agents for 1991/1992:
19JL1 Chlorine Ethylene Dichloride Diisopropyl Amine
Vinyl Chloride Butylene Oxide Methylene Chloride
1992 o-Dichlorobenzene Diisobutylene Ethyl acetate
Methyl Pyrrole 1,1,2,2-tetrachloroethane
3 . RESPIRATORY PROTECTION TRAINING
Trichloroethylene/HCL will follow the guidelines defined in the Plant's written respirator program (located in the Industrial Hygiene Manual). Annual training is required.
4 . CHEMICAL SURVEY RESULTS
A report of the results of sampling conducted in accordance with this protocol will be written and communicated individually and in a group session.
5 . HAZARD COMMUNICATION TRAINING
All new employees shall review and document with signatures:
a. hazard communication videos (2) b. the facility's hazard communication program c. health hazard information for all materials with Priority Rating of 1, 2, or 3 (see CPAI) d. health hazard information for OSHA regulated chemicals with Priority Rating of 1, 2, 3, or 4 e. health hazard information for the key agents listed above
See the Plant's written Hazard Communication program in the Hazard Communication section of the facility's Industrial Hygiene Manual for other training requirements.
Any temporary employees shall review and document: b,c,d,e.
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INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
6. ASBESTOS TRAINING
All personnel who work in Trichloroethylene/HCL must receive initial training. Personnel who handle asbestos must receive annual training. Consult the Texas Operations Asbestos Handbook for training requirements.
7. NOISE TRAINING
Employees at Trichloroethylene/HCL are not required to participate in the Texas Operation Hearing Conservation Program as all average personnel exposures were less than the OSHA Action Level of 50%. As there are noise levels greater than 90 dBA in the plant, training should be performed on a periodic basis (ie. every 2 years). Refer to Safety Standard 0-46 and the Hearing Conservation Manual for training requirements.
8. NEW CHEMICAL TRAINING
Per HA2COM all employees to be potentially exposed to a new chemical must be trained on the hazards of that chemical and the approved protective equipment. Signatured documentation is required at the time of this training, to include MSDS, TIME sheet, or hazard data used.
9 . HEAT STRESS TRAINING
Personnel performing jobs (eg. chemical suit in the summer) that may lead to heat stress are to be trained on heat stress avoidance procedures. This training is recommended for new employees and on a periodic basis for experienced employees. Training should be documented.
1 0. PROTECTIVE EQUIPMENT TRAINING
Per 29 CFR 1910.132 protective equipment shall be provided, used and maintained for employees with potential of exposure to environmental or process hazards. Personnel are to be trained on the proper use or applicable protective equipment upon initial assignment, after major job changes, and periodically. Consult the Texas Operations Personal Protective Equipment Program Manual for training guidelines. ..
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INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
1 2. VENTILATION SYSTEM TRAINING
Personnel that use ventilation systems (incl. hoods, dust and chemical ventilators) are to be^ trained in the use, maintenance and documentation requirements. Hood requirements are covered in Safety Ref. 7.
13. HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE
Per HAZWOPER personnel invloved in operations in RCRA Treatment, Storage, and Disposal facilities must be trained. Training must enable the employees to perform their job in a safe and healthful manner so as not to endanger themselves or others. Training topics include respiratory protection, hazard communication, health hazards training, protective equipment, safety standards/references, job procedures, RCRA, hearing conservation, eye protection, emergency procedures and unit specific rules.
All new employees must receive at least 24 hours of initial training. Current employees do not need the 24 hours of initial training if equivalency can be proved. Certificates of training must be issued to all employees. Eight hours of refresher training is required on an annual basis.
Personnel in facilities where RCRA wastes are stored less than 90 days are only affected by the emergency response portion of the HAZWOPER RCRA section. Training for those employees who must respond must occur prior to ER assignment and annually thereafter and must include:
1. elements of the ER plan 2. ER procedures 3. personal protective equipment 4. job procedures
Non-responding employees should be trained to recognize an incident and activate the ER system. The method used to demonstrate competency must be documented.
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DOW CONFIDENTIAL
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
Page 1
RESPIRATORY PROTECTION PROGRAM
1 . INTRODUCTION
Information regarding Dow respiratory protection programs is located in Safety Standard 0-45 and the Texas Operations Respiratory Protection Manual (RPM). The RPM addresses selection, use, fit testing, medical approval, training,' maintenance, redoras,' administration and recommended respirators. Responsibilities for employees, supervisors, industrial hygiene, fire departments and Occupational Health are detailed in the RPM.
2 . TYPES OF RESPIRATORS USED
Respirator Type
AOR9722 Mouthbit Scott Air Pack 2.2 SCBA with Scottoramic full face mask Scott, 5 min Escape (Scottovista mask) Elsa 5 minute escape Scottovista full face airline Scottoramic full face airline 3M Easi Care 5000 Disposable 1/2 face 3M Easi Care 5000 Disposable 1/2 face AO 5 Star 3M 8710 Dust Mask
Cartridges Filter. Canisters OVAG (R722)
NA
ISA
NA ISA NA A3 Ammonia/Methylamine OVAG; Ammonia/Methylamine
na
Sources of
Breathing Air
NA
20 min. air tank 5 min. air tank 5 min. air tank Cylinder Cylinder ISA NA NA NA
OVAG - NIOSH approved for Organic Vapors and Acid Gases
Industrial Hygiene is contacted whenever a new respirator is selected.
3. RESPIRATORY USE CATEGORIES
Job Classification Office Personnel
User Category Escape Only
Lab Personnel
Routine/Escape
Operators
Routine/Emergency Escape
Maintenance
Routine/Emergency Escape
Reap. Types Used
MP; Elsa
MP; Half Face
SCBA; Airline; Half Face MP; Half Face
Airline; Half Face MP; Half Face
Individually
Issued
MP
MP; AO 5 Star
Half Face MP; Half Face
Half Face MP; Half Face
C O N F ID E N T IA L
MP = AOR9722 Mouthbit Routine/Emergency users are fit tested and medically approved biennially.
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RESPIRATORY PROTECTION PROGRAM (CONT.)
Respirator training is conducted by:
Bespiratot-Iypa
Escape
Routine/emergency^
Trainer
Plant Representative
Plant Representative
frequency
Every 2 years Annually
Visitors, contractors and employees are required to carry an escape respirator on their person while in block process areas.
4. USE SITUATIONS Respirator Tvpe/Filter
Mouthbit Half face/OVAG Half Face/Ammonia
Chemical of Concern
CI2, Add Gases
RCL's, HCL, CI2
Ammonia
Use
Situation
Escape
Escape, equipment clearing, minor leak repair
Breaking/entering equipment associated with ammonia refrigeration unit
Full face airline SCBA Scott 5 min. Elsa
RCL's, HCL, CL2 All chemicals All Chemicals All chemicals
Breaking/entering equipment Emergency response Escape only Escape only
Filter cartridges for the mouthpiece respirator or half face respirators carried for escape purposes only should be replaced after each use or at least every six months. Filter cartridges for half face respirators used for routine work should be replaced when breathing becomes difficult, breakthrough is detected, or at least every 2 weeks.
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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RESPIRATORY PROTECTION PROGRAM (CONT.)
5 . RESPIRATOR CLEANING STATIONS
The cleaning stations are sinks located in the change rooms. Half face masks are cleaned with soap and water. Airline equipment and SCBA are sent to the fire department for cleaning after each use. Contaminated respirators and cartridges which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.
6. RESPIRATOR STORAGE
Respirator
MP Half face air purifying SCBA (30 min.) Scott 5 min. escape
Elsa Airline masks
Dust masks
Storage-Locaiioa
B-1513 Storage Bins B-1513 Storage Bins; B-1501; B-1506 Safety Cabinets B-1501; B-1506; B-1505 Control Rooms B-1501; B-1506 B-1510 Office Supply Storage Room
B-1501; B-1506; B-1513; B-1516 B-1501; B-1506 Safety Cabinets
Except for the mouthpiece respirator, all respirators must be stored in secondary containers such as respirator pouches, plastic bags or storage boxes.
INSPECTION SCHEDULE
Documentation
Paspicaior Ergqusncy By Betained-By
Half Face Airline SCBA; Scott 5 Min; Elsa
MP Dust Mask
Before each use Before each use Before each use Monthly Annually 5 year hydro Monthly Before each use
User User
User Plant Rep Fire Dept. Fire Dept. User User
none Fire Dept. none Plant Rep Fire Dept. Fire Dept. Plant Rep Plant Rep
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IHS File #B15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
RESPIRATORY PROTECTION PROGRAM (CONT.)
Page 4
8. BREATHING AIR
The breathing air source is from bottles which have been pre*checked for oxygen content and markings.
9. DOCUMENTATION
Documentation of inspections, fit testing, and training are maintained by the plant safety contact. Original signatures on training are sent to the plant industrial hygienist at B-101 for placement in the plant's 75 year compliance file. The plant superintendent and the Occupational Health Department maintain the medical approval list on file.
10. NEXT REVIEW DATE: January, 1993
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
Page 1
PERSONAL PROTECTIVE EQUIPMENT PROGRAM
1 . INTRODUCTION:
Information regarding the Texas Operations personal protective equipment (PPE) program is located in the Texas Operations PPE Program Manual. The manual addresses program administration, approval procedures, testing requirements, selection, use and maintenance, decontamination, laundering, training, records, and program evaluation. Responsibilities for employees, supervisors, Industrial hygiene, safety, purchasing, the Texas Operations Protective Equipment Team, and the Texas Operations Protective Equipment Supplier Partnership Team are detailed in the manual.
2. SELECTION:
See Table 1 for a listing of approved PPE for the Trichlor/HCL plant. PPE selection, was based upon the health and safety hazards associated with the site or job tasks. All PPE has been reviewed by the Trichlor/HCL Industrial Hygienist and Safety Director and has been approved for use by the Texas Operations Protective Equipment Team.
3. TRAINING:
Training on user responsibilities, PPE inspection, use, donning, doffing, decontamination, limitations and the location of theTrichlor/HCL PPE program is conducted for Dow employees and long-term contractors upon initial assignment and biennally thereafter. This training is documented. Visitors are informed of and provided the minimum PPE required in the Trichlor/HCL plant.
4. INSPECTION:
All PPE items must be inspected visually before, during and after use for signs of deterioration, defects, damage, etc. However, the PPE items listed below shall be inspected according to the following minimum frequency and specific test protocol:
PPE Item
Totally encapsulated suits (Maintenance activities)
Test Method Visual Inspection
Frequency -.Biannually
By Dept Rep
Chemical protective gloves (high hazard operations)
Air test method
Each use
User
Electrical rubber gloves Electrical rubber blankets
High voltage test Air test method
High voltage test
Biannually Each use
Biannually
Elec Shop User
Elec Shop
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
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PERSONAL PROTECTIVE EQUIPMENT PROGRAM (CONT.)
5. DECONTAMINATION AND DISPOSAL:
The Trichlor/HCL decontamination stations are located in the following locations:
safety showers throughout the process area.
After each use where PPE has been contaminated by hazardous substances, users of the contaminated PPE shall use one of the above listed decontamination stations and clean their PPE by rinsing with copious quantities of potable water. Before storage, the PPE is air dried . Contaminated PPE which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.
6. MAINTENANCE:
No clothing or chemical protective suits are repaired in this department. Defective or damaged equipment is discarded.
7. LAUNDERING:
General purpose clothing is laundered in a standard type washer and dryer located in B-1501 and B-1506. No personal clothing may be washed in block washers. Cotton gloves are sent to the Learning Center. Half face and mouthbit respirators are cleaned by the individual owner. Full face respirators are sent to the fire department for cleaning.
8 . STORAGE:
The following lists where PPE is stored when not in use:
a Cotton gloves in glove bin in men's change room b. North Silver Shield gloves are in laboratory drawer in B-1500 c. Low voltage gloves and flash suits in switchroom locker d. Individually issued equipment is stored in personal lockers a New respiratory equipment is stored as follows:
Full face airline in the respirator cabinet in B-101 New half face respirators in the day foreman's office Mouthbit in the safety cabinet in B-1500 f. SCBA's are located in the following locations: B-1501 in the control room B-1506 in the control room g. New PPE is stored in the Safety cabinet in B-1500
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PERSONAL PROTECTIVE EQUIPMENT PROGRAM (CONT.)
9. PROGRAM EVALUATION:
This program shall be evaluated biennally or whenever there are major job or process changes that require a re-evaluation of the PPE currently in use.
NEXT REVIEW DATE: June, 1993
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
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TABLE 1 TRICHLOR/HCL PPE INVENTORY, 1991
The following lists the approved PPE for the Trichlor/HCL plant. Trichlor written job procedures indicate when and which PPE items must be worn for specific job tasks.
A. HAND PROTECTION 1. Edmont Solvex (Vallen # 37-155 & 37-175) gloves 2. North #E214B dielectric natural rubber gloves 3. Scooba #JPS 10B Cotton Gloves 4. Fisher Scientific Vinyl Disposable (#11-384-36C)
B. FOOT AND LEG PROTECTION 1. Servus 21714, 22114, and 21629 boots 2. Servus Rainfair 9043 3. Lehigh #1149 dielectric natural rubber boots 4. Iron Age 990 Steel Toe Natural Rubber
C. EYE, FACE AND HEAD PROTECTION 1. Face Shields - Wilson # V-10-86 - Encon # SD-115A 2. Hard Hats Vallen 302 - Fibremetal E2W851 3. Sideshields - Variety (anything that is on approved list) 4. Chemical goggles - Allsafe #211-1 OR - American Optical #484B
D. BODY PROTECTION 1. Kappler Saranex coated Tyvek 2. Life-Guard Responder Hazard Suit (Protection Level A) 41450
E. RESPIRATORY PROTECTION 1. Self-Contained Breathing Apparatus Survivair 30 min. - Scott Air Pack - Scott 5 min. SCBA Pack 9881-22 (MSMS# 74694) 2. Airline Respirators Scottoramic Full Face #801548-00 (MSMS #4871) 3. Half-Mask Respirator - 3M Easi Air 5000 disposable - AO 5-Star 4. Dust Mask - 3M 8710 (MSMS #4869) 5. Escape Respirator - AO Mouthpiece R9722 with organic vapor/acid gas cartridge (MSMS #106840) - ELSA 5 min. escape SCBA
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL. B-1500
TABLE t (CONT.)
F. HEARING PROTECTION 1. Willson Sound Ban #20 (NRR*19-22) 2. E-A-R Foam Ear Plugs (NRR=29) 3. Bilsom Universal I Ear Muffs (NRR=23-25) 4. Bilsom Viking Ear Muffs #2318 (NRR=28) 5. E-A-R Ultra Fit Plugs with cord (NRR=27)
G. FALL/RESCUE PROTECTION 1. RTC 7435-PT1 Body Harness 2, RTC 8250-P6HH Lanyard
Page 5
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1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
DEPARTMENT ACTIVITIES
TRICHLOROETHYLENE PRODUCTION
Page 1
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
DEPARTMENT ACTIVITIES (CONTINUED)
ANHYDROUS HCL LIQUIFACTION PLANT
Page 2
C O N F ID E N T IA L
REDACTED
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DEPARTMENT ACTIVITIES (CONTINUED)
ANHYDROUS HCL LIQUIFACTION PLANT (CONT.)
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IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TRICHLOROETHYLENE/HCL, B-1500
DEPARTMENT ACTIVITIES (CONTINUED)
ANHYDROUS HCL LIQUIFACTION PLANT (CONT.)
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REDACTED
Trichloroethylene] Production
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R&S 153955
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MB/7-91
J FIGURE 1
IHS File #B 15-3839-91
1991-93 OCCUPATIONAL HEALTH PROGRAM TR1CHLOROETHYLENE/HCL. B-1500
JOB DESCRIPTIONS
Page 1
Production Superintendent. Assistant Superintendent. Project, Office Specialist: The probability of personnel in these job classifications experiencing a significant exposure to chemical and physical stresses in the plant is low as the majority of their time is spent in office areas.
TRICHLOROETHYLENE (66900)
Production Foreman: Coordinates the Trichloroethylene plant production activities (rates, personnel, safety, and maintenance) with the Production Engineer, Assistant Superintendent and Maintenance Foreman. Spends approximately 50% of the time in the plant area. The balance of the time is spent in office areas.
Sr. Production Chemist: Supervises the production lab and performs development work to improve analytical capabilities. Acts as the Customer Quality Service Coordinator. Exposure to chemicals is minimal due to the short period of time they are handled and the use of lab exhaust hoods.
TRICHLOR PLANT (66915)
Assistant Chemist CL A: Responsible for running routine and non-routine samples of the Trichloroethylene plant process sample points, storage tanks, HCI tank car shipments, etc. 75% of the time is spent in the lab. The balance of the time is spent in plant areas catching samples.
Production Engineer: Directly responsible for safety, production, and maintenance in the Trichloroethylene plant. 20% of time is spent in the process area with the remainder of time spent in office areas.
Sr. 1& E Technician: Repairs and troubleshoots process analytical equipment including Dp cells, pressure transmitters and other instruments. Approximately 30% of time is spent in the plant process areas with the remainder in instrument shop areas.
Chemical Aide: Responsible for all routine and non-routine sample analyses including environmental, industrial hygiene, and process. Works production to solve plant problems by doing necessary analytical work. Responsible for daily water analysis. Industrial Hygiene Monitoring are also part of the responsibilities. About 15% of the time is spent in the process areas and the balance is in the lab or office area.
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JOB DESCRIPTIONS (CONTINUED)
TRICHLOR PLANT (66915) (CONTINUED)
Control A Operator: Resonsible for the operation of the thermal chlorinator. tetras cracker, and the acid absorption columns. Duties include sfart-up, shutdown, analysis, and adjustments of operating parameters for safe and profitable operation of the units. Outside activities include sampling which takes up to 5 to 10% of each shift. Under normal operating conditions, the Control A Operator spends 95% of the time in the control room.
Control B Operator: Responsible for ensuring plant hazardous waste shipments are made in correct fashion. Spends 70% of time in the process area working with vacuum trucks, etc. with the remainder spent in office areas.
Control C Operator. PRG Control C Operator: Responsible for implementing job tasks identified by the Control A Operator as necessary for the safe, proper, and profitable operation of the unit. The Control C Operator also handles activities such as clearing equipment for maintnenance, switching pumps, opening and closing valves, and touring reas watching for problems. About 80% of time is spent in process areas.
TRICHLOR SERVICES (66930)
Foreman: Coordinates shipping and warehousing activities of the department. Supervises two operators and assures the movement and the quality of the departments products.
Sr. Parts Technician: Orders all the necessary equipment for the Trichloroethylene and HCI plants. Acts as the backup material handler for the warehouse. Ten percent of the time is spent in the plants with the remainder of the time spent in office and storage areas.
Sr. Vibration Asst.: Routinely checks all pumps and motors in the B-1500 block and assists the operators in the warehouse. 35% of the time is spent in the plants with the remainder of the time in the warehouse and office areas.
Control 0 Operator;
Assists warehouse personnel with loading and sampling activities. Approximately 80% of time is spent in the warehouse and loading facilities. The balance is spent in office or other plant areas.
Class 2 Operator: Loads ail tank cars, tank trucks and drums that leave the B-1500 block. Catches samples of all trucks, cars and drums for analysis. 90% of time is spent in the warehouse and loading facilities.
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JOB DESCRIPTIONS
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HCL PLANT (66926)
Process Supervisor; Responsible for safety, production, and maintenance in the HCI plant, warehouse and shipping area. 30% of time is spent on the plant process areas. The remainder of the time is spent In office areas.
Project Engineer (TCE & HCH: Responsible for new construction, demolition, and capital projects. 90% of time is spent in office areas with the balance of the time spent in the plant.
Control A Operator: Operates compressors, refrigeration units, and distillation columns in the production of HCI. Operates the air compressors and distribution system for plant air. These duties are performed primarily from the control room. Outside activities are mainly short-term for investigation of problems or performance of manual adjustments. Approximately 90% of time is spent in the control room and 10% is spent in the process area.
TRICHLOR MAINTENANCE (66950)
Maintenance-Foreman;
Responsible for coordinating and completing all routine maintenance of the plants. 80% of time is spent in the plant areas.
SR. I&E Technician: Repairs and troubleshoots process analytical equipment including Dp cells, pressure transmitters and other instruments. Approximately 30% of time is spent in the plant process areas with the remainder in instrument shop areas.
Sr. Electrician: Responsible for all electrical, equipment in the B-1500 block. 85% of time is spent in the plant with the remaining time is office and shop areas.
Pipefitter: Responsible for all pipe fitting jobs and pipeline maintenance. Routine jobs include working on reboilers in the Trichloroethylene plant, working on 32% HCI distribution lines, and breaking into lines to make repairs or changes. Maintenance work is done on pipelines owned by the Trichloroethylene plant but located outside the block. 90% of time is spent in the process areas with the remaining time in the shops.
Pipefitter/Welder: In addition to pipe fitting responsiblities, the Pipefitter/Welder is responsible for welding in the shop and in the plant. 75% of the time is spent in the shop and 25% of the time is spent in the plant process area.
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JOB DESCRIPTIONS
TRICHLOR MAINTENANCE (66950) (CONTINUED)
Machinist; Responsible for maintenance of ail pumps, compressors, fans, and motors in the B-1500 block. Alignment of fin-fans and motors are also part of the job. 75% of the time is spent in the shop and 25% of the time is spent in the plant process area.
iilility_Man/ContractQf; These personnel are called upon to perform and support maintenance activities in the B-1500 block. They perform pipe fitting, welding, grinding, and pipe insulating activities. 90% of the time is spent in the plant process areas with the remainder of the time in the contractor maintenance shop.
Control C Operator. PRG Control C Operator: Assists the Control A Operator. Checks and operates process compressors, transfers products and raw materials, catches and analyzes process samples, operates division wide anhydrous HCI distribution system. Approximately 80% of the time is spent in the process area and 20% is in the control room.
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Page 1
OSHA SPECIAL REGULATIONS
The Trichloroethylene/HCI is directly affected by OSHA special regulations 29 CFR 1910.1001: Asbestos, 29 CFR 1910.1028:Vinyl Chloride, and 20 CFR 1910.95: Occupational Noise Exposure. A copy of each of these standards is located in the plant's Industrial Hygiene Manual. Key elements of the standards includes:
A. Asbestos and Vinyl Chloride
1. exposure monitoring requirements 2. respiratory protection and personal protective equipment 3. medical surveillance 4. information and training
A review of the past monitoring data, the plant's respiratory protection and protective equipment policies, and Hazard Communication and training program, has confirmed Trichloroethylene/HCI to be in compliance with the requirements outlined in the Asbestos standard. To complete the requirements for Vinyl Chloride, initial training and personnel monitoring will be conducted as part of the 1991*93 Occupational Health program at Trichloroethylene/HCI
B. Noise
1. exposure monitoring requirements 2. audiometric testing requirements 3. hearing protection requirements 4. training requirements
A review of the hearing conservation program at Trichloroethylene/HCI has confirmed the plant to be in compliance with the requirements outlined in the Noise standard.
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