Document gDDer51q0RwbL8JxJRx7ma24N

AiimklMUlUl 11 KOCH KOCH RERNING COMPANY flt n s PLAINTIFF'S I EXHIBIT JKRC--10 CORPUS CBBISTI BEFI1ERY ASBESTOS MANAGEMENT PROGRAM Policy and Procedures il-1.doc/1.*41 fecobtf 14, 1988 K010206 1 IHTRODUCTIOM Asbestos Is a generic tera that applies to a group of naturally occurring, hydrated alneral silicates .that are separable into fibers. The aost coaaon fora of asbestos is known as chrysotlle which has the general aolecular foraula: 3 MgO * 2 SiOa * HaO. There are two aajor health hazards associated with long-tera exposure to airborne asbestos fibers. The first is a disease of the lungs known as Asbestosls and the second is one of several foras of cancer. In 1986, the Occupational Safety and Health Adalnlstratlon issued new, aore stringent regulations for the control of airborne asbestos dust. These new regulations are intended to protect a larger section of the work force froa the health hazards associated with asbestos dust overexposure. It is with the intention of coaplying with these regulations, and in the interest of protecting the health of KOCH Refining Coapany eaployees and their faallles, that this policy is addressed. 2 POLICY It is the policy of KOCH Refining Coapany to control occupational exposures to airborne asbestos fibers to the lowest achievable level through the use of engineering control aethods. If the lowest achievable level is in excess of governaent regulated standards or other accepted occupational exposure guidelines as aeasured by standardised aethods, then KOCH will provide appro priate personal protective equlpaent for each and every eaployee at risk of exposure to the airborne asbestos fibers. 3 ssaea This policy applies to all eaployees of KOCH Refining Coapany, KOCH Chealcal Coapany, and XOCH Industries, it`s subsidiaries and/or contractors eaployed at or otherwise perforalng work at the Corpus Christl Refinery or any of it's ancillary facilities. 4 PftQCSP.V.fig.S The following procedures shall be followed in lapleaentlng the above stated policy: 4.1 Planning requirements All lnsalatloa reaoval projects shall confora with the following planning requlreaents completely unless an eaeraencv condition exists. An eaergency condition is defined as a situation in which following these procedures would endanger life/health or cause property daaage. 4.1.1 Deteralne if project requires the reaoval of insulation 4.1.2 Identify equlpaent nuabers, piping, etc. on process drawings 11*1.doe/1.141 tecaafer 14, 1968 Pag* 1 K010207 4.1.3 lotlfy Loaa Control ai laaat tan (18) working days ia advanca of the atart of any project requiring Insulation reaoval (2t daya if ora than 81 aeters (268 linear feet) or aore than IS square aetera (168 square feet) of insulation are to be reaoved). 4.1.4 Assist Loss Control in securing representative Insulation samples for polarised light ilcroscopy analysis; including identification of saaple locations 4.1.5 After insulation saaple analysis, clearance to proceed vith Insu lation reaoval will be granted by Loss Control. Specific requireaents for the reaoval of the insulating materials will be given at this tiae. Specific requireaents aay Include but are not Halted to: * Asslgnaent of a KOCH Project Coordinator * Submission of a written plan for insulation reaoval * Asslgnaent of insulation reaoval to outside contractor * The use of specific engineering control aethods * The use of specific personal protective eqnipaent * Restricted area requireaents including entry log * Haxard coaaunication training on the hatards of asbestos * Waiver of requireaents due to the absence of asbestos 4.2 leeoval of Asbestos-containing insolation 4.2.1 Engineering Control Methods The aethods eaployed for the control of airborne asbestos dust sball be used in the following precedence: * Glove Bags * Mini-Enclosures,,. * Wet Methods and/or Chenical Encapsulants * Dry Methods and HEPA vacuums 4.2.2 Ipjpvjl. Procedures 4.2.2.1 Restricted areas for the removal of asbestos-containing insu lation shall be identified, prior to beginning work, by the use of barricade tape (or other suitable barrier) and appropriate warning signs. 4.2.2.2 All personnel entering a restricted area shall wear appropri ate personal protective equipment Including but not limited to respiratory protection, protective clothing and head coverings, eye protection, safety hats, and safe footwear. 4.2.2.3 All asbestos-containing material shall be placed in approved bags and transported to the holding area. il-l.doc/1.841 Hcaaber 14, 1968 ftp 2 K010208 4.2.2.4 HEPA vacuum cleaners shall be provided for the decontamina tion of areas and personnel contaeinated with asbestos. 4.2.2.5 All personnel entering a restricted area shall vacuum their outer clothing to remove asbestos fibers prior to leaving the area. 4.2.2.6 The deaolijlon and stripping areas shall be cleaned and decontaalnated of asbestos prior to removal of barricades and signs. 4.2.2.7 Beaoval of, only the alnlaua aaount of asbestos-containing insulation necessary for transportation to the stripping area vill be peraltted in the demolition area unless otherwise speci fied. All open, damaged, or otherwise friable asbestos-contain ing material shall be encapsulated before transporting to the stripping area. 4.2.2.8 lo smoking, chewing gum or tobacco, eating or drinking shall be permitted in restricted areas. 4.2.3 lotlflcatlon and Restricted Areas Before beginning any asbestos removal work, the appropriate process or transfer control room shall be notified of the work in progress and the restricted area identified by the use of barricade tape and appropriate signs. The barricades shall not be removed until de contamination is completed. 4.2.4 Protective clothing Protective clothing used for protection of personnel in restricted areas shall be approved by the Loss Control Department. 4.2.4.1 Protective clothing used for protection from asbestos shall consist of the following (unless otherwise stated in the specific Removal Plan):* * Coverall, Tyvek(I) or equivalent, with elastic cuffs on arms and legs * lead covering, Tyvek(l) or equivalent * Gloves, rubber or PVC * Safe footwear * Safety hat * Bye protection 4.2.5 lesplratorv protection Appropriate respiratory protection equipment shall be worn by all personnel entering or working in a restricted area unless air san- .doc/l.Ml Booster 14, 1961 Pago 3 K010209 piing shows conclusively that the airborne asbestos concentration is less than i.il fibers per illlliter of air averaged over an eight-hour tiae period per the IIOSH 74M analytical aethod. 4.2.6 Decontaalnatlon of. Personnel All personnel entering a restricted area shall follow this decon taalnatlon procedure or the procedure outlined in the specific reaoval plan. 4.2.6.1 Before leaving the restricted area, all personnel shall coapletely vacuua their outer clothing Including head-covering and respiratory protection equlpaent. 4.2.6.2 Personnel shall then proceed directly to the CHAI6E BOOSE and enter by way of the *Dlrty Boon'. go I0J BEHOVE BBSPIBATOB! 4.2.6.3 Beaove and thoroughly vash boots in the sink. 4.2.6.4 Beaove coveralls and place in the container provided. 4.2.6.5 Beaove the respirator and place In the container provided. 4.2.6.6 Proceed directly to the shover area and thoroughly sbover the entire body Including scalp. 4.2.6.7 Place bath tovels In the special container located In the Building Crafts Shop. 4.2.7 Restricted Area Cleanup and Decontaalnatlon When the reaoval of all asbestos-containing Insulation is coaplete, the area shall be Inspected by the KOCH Project Coordinator. If the area Is visually clean to his/her satisfaction, then the barri cades and signs aay be reaoved and the area returned to Operations. 4.2.8 Ai saaplino Ml Analysis Air saapllng and analysis shall be done in accordance vlth the requirements of 29 CPI 1918.1M1 and 29 CPI 1926.58. Analysis shall follow the HOSE 7498 analytical aethod (other recognised analytical aethods aay be used vlth prior approval froa KOCH Loss Control). Vorkers shall be notified of the results of personal air sampling within ten working days of receipt of the analyses. 4.3 Working vlth Ashestos/Ceaeat board and pipe 4.3.1 Whenever possible, work shall be perforned outdoors using a prop erly shielded hand-tool vacuua system. lk-l.doc/l.Ml Beceabtr 14, 1968 Pays 4 K010210 4.3.2 An approved respirator with HEPA filter or an airline respirator shall be vorn vben the shielded hand-tool systeas are used. If unshielded tools are utilised, full protective clothing and the appropriate respirator shall be vorn. 4.3.3 When the HEPA vacuum filter is filled, it shall be disposed of In a properly identified plastic bag as asbestos vaste. 4.4 Outside Contractor lequlreaents 4.4.1 Contractors shall conply with the provisions of the OSHA asbestos standards (29 CFB 1910.1881 and 29 CFI 1926.56). 4.4.2 Sestrlcted areas for the reaoval of asbestos containing insulation shall be Identified by the use of barricade tape (or other suitable barrier) and appropriate varnlng signs. 4.4.3 All personnel entering a restricted area shall vear appropriate personnel protective equipment including but not Halted to respi ratory protection, protective clothing and head coverings, eye pro tection, safety hats, and safe footvear. 4.4.4 All personnel entering a restricted area shall vear a respirator approved for use vith asbestos dnst unless air saapling data sbovs conclusively that the airborne asbestos concentration Is less than 6.1 fibers per ailliliter of air as determined by IIOSH 7488 saa pling and analysis procedures. 4.4.5 Air saapling and analysis shall be conducted In accordance vith Section 4.3.7 above. Copies of all air sampling data shall be subnltted to the KOCH Loss Control Departaent for reviev. Contrac tors shall aliov KOCH to place saapling pumps on contractor person nel and to perfora area saapling as a quality control teasure to validate the contractors saapling data. 4.4.6 The contractor shall provide shover facilities for contract per sonnel at the stripping area. KOCI shall supply sanitary vater for the shovers. 4.4.7 All asbestos-containing aaterlal shall be placed in approved bags vhich vill be provided to the contractor by KOCI. KOCI vill ar range for disposal of the bagged asbestos. 4.4.8 The contractor shall provide BEPA vacuua cleaners for the decontaalnatlon of areas contaalnated vith asbestos. 4.4.9 All personnel entering a restricted area shall vacuum their outer clothing to reaove asbestos fibers prior to leaving the area. 4.4.18 The contractor shall clean and decontaainate the deaolltlon and stripping area of asbestos before reaoval of barriers and signs. U-l.fec/l.Ml leceator 14. 1988 Pift 5 K010211 4.4.11 In the demolition arte, reeoval of only the elniiue aiount of asbestos-containing insulation necessary for transportation to the stripping area will be permitted unless otherwise specified. All open, daaaged, or otherwise friable asbestos-containing eaterlal shall be encapsulated before transporting to the stripping area. S RESPOHSIBILITIES The Project Coordinator (Engineer, Engineering Tech, Maintenance Foreaan or Supervisor, etc.) shall obtain clearance froa Loss Control as detailed above before beginning any project requiring Insulation reaoval. He/she shall also have the responsibility of insuring that the provisions of this procedure and/or those of the reaoval plan are aet. Loss Control shall obtain representative Insulation saaples and analyse then for the presence of asbestos, shall grant clearance for Insulation reaoval, shall approve the reaoval plan(s), shall specify appropriate personal protec tive equlpaent, and shall conduct the required air saapling, analysis and personnel notifications (KOCH personnel only) of saapling results. ih-1.doc/1.141 toaster II. 1961 Pigt 6 K010212