Document gaJ3zYK07O25kr8e2r3v5qE1Q

Eft-WTO Occupational Health Survey BEAUMONT WORKS POLYMER PRODUCTS DEPARTMENT HOUSTON, TEXAS REPORT NO. 1022-H MAY 1, 1981 DUP 0502256 DU 001900 "iBiiaiv i, i in....mi i,.Blitill m SUMMARY The overall rating was Good. Organization for administration of OH programs, housekeeping and facility maintenance and radiation control are excellent. Scope of information on carcinogenic and embryotoxic materials should be included in documentation of annual training. Appropriate maintenance, cleaning and laboratory chemicals should be included in the collection of MSDS's or similar documenation. The respirator program is good. It is recommended that employees who are now required to use half-mask respirators for which they have not been fit-tested be fit-tested as soon as possible. The need for a full-face escape mask for ammonia fumes should be evaluated and the breathing air systems should be brought into compliance with Engineering Standard S 1 H. Selection of gloves is fair. Permeation data should be considered with other significant factors in choosing the most appropriate glove, with special attention given to carcinogenic materials. The air monitoring program is excellent. Plant personnel should be trained on procedures to handle asbestos. Labeling of asbestosfree insulation should be considered. Welders should be trained to place the exhaust hood so the required airflow can be maintained. Spill procedures are fair and need to be upgraded. Consumption of food or beverages should not be allowed in a laboratory where carcinogens are handled. Plans to mark hearing protection zones at 87 dBA for 12-hour shifts are endorsed. DUP 0502257 DU 001901 J5M3UIE-.5 -I GENERAL The third occupational health survey of the Beaumont Works was conducted by the undersigned engineers April 6-10, 1981. Escorts during the visit included members of area supervision and the occupational health coordinator. The purpose of the survey was to evaluate occupational health programs and practices and to provide suggestions for improve ments as needed. Practices, procedures and facilities for identifying, evaluating and controlling environmental factors that may cause illness, impaired health and significant discom fort to employees were addressed. The Beaumont Works was rated Good bn a scale of Excellent, Good, Fair and Poor, with the first three being degrees of satisfactory performance. This report summarizes the observations and recommendations presented to the manager and staff at the conclusion of the survey. Details and many of the specific recommendations devel oped during the survey are not included since these were dis cussed in field observations. We would appreciate being advised within the next few months concerning the actions taken on recommendations in tnia report and vour response to any of the field observations with which you disagree. SAFETY AND FIRE PROTECTION DIVISION NDJ/RS/msh Supervisor, Occupational Health DUP 0502258 DU 001902 a m ma 1 ORGANIZATION AND ADMINISTRATION Program Administration The organization for administration of occupational health programs is excellent. The Environmental Health Committee of the Central Safety Committee is composed of representatives of each plant group and the plant industrial hygienist. Routine meetings are held monthly and the minutes are issued to members of the Central Safety Committee. Occupational health staff personnel are very knowledgeable in their areas of expertise. Extensive use has been made of ESD training courses. The plant OH coordinator is a certified industrial hygienist and the OH coordinator of the petrochemicals operation has successfully passed the first phase of certification. Communications * Communication of occupational health information is good. Employees are trained annually on the health hazards in their areas and new employees are trained as they enter the area. This training is documented with the names of the employees and the dat.es of the training. It is recommended that the scope of the information on chemicals with carcinogenic or embrvotoxic poten tial be included in the documentation. The maintenance organi zation has begun work on a program intended to eliminate defi ciencies in their training programs for occupational health. Additional personnel have been committed to the task and comple tion is scheduled for this year. Thi3 program is commended. Although plant policy was changed in late 1980 to eliminate disposable dust masks in favor of the Comfo II respirator, several members of supervision indicated that the disposable masks would be used for dusty operations and asbestos work. Some employees were noted with the disposable style of mask in their possession. It is recommended that significant communi cations of this tvoe be highlighted to assure understanding and compliance. Chemical Hazard Information This area is good. Significant progress has been made in the description of raw, intermediate and finished production mate rials in the four page Material Safety Data Sheet (MSDS) format. .- 1 DUP 0502259 DU 001903 Support materials and catalysts are also included in the collec tion. It is recommended that maintenance chemicals, industrial cleaning agents and appropriate laboratory chemicals (as described during the survey) be included in the collection of MSDS's. The Hypalon* Area prepared training sheets on carbon tetra chloride and chloroform for employee use, which omitted informa tion on the carcinogenic potential of these chemicals. It is recommended that the description of the carcinogenic potential be included in employee training material. Personal Environment Record System (PERS) The 3ite is currently entering work history data for all produc tion operators and maintenance mechanics. First line supervisions' work history is also being entered. Exposure histories will be entered during the second quarter of 1981. Medical Involvement The site is currently without a full-time physician and is using a contract physician. The previous physician had toured the plant areas, but due to his ill health the frequency had declined significantly during the past year. The nurses are able to respond to plant areas during ambulance runs but have limited knowledge of plant areas. When a new physician is hired he should be involved in the and should make periodic as appropriate become familiar with employee working conditions. The nurses should also tour periodically, with or without the physician. Sanitary conditions of lunchrooms, restrooms and change rooms should be checked by the medical staff. Contractor Operations Contractor operations as they relate to occupational health are adequate. Programs and procedures are in place to protect contractor employees from Du Pont created hazards and vice versa. Few contractor operations were going on during the survey. PROTECTIVE EQUIPMENT Respirators The respiratory protection program is good. The quantitative fit-testing equipment and program are excellent. However, there are some aspects of the program that need improvement. 2 DUP 0502260 DU 001904  Disposable Masks. While previous plant policy allowed the use of the 3M 8710 for dust, two other type3 of masks (not site approved) were brought onto the site, a mercury vapor mask and a 3M 9920 mask used by a welder. It is recommended that the disposable masks be purged from the site and not readmitted unless a fit test is provided. e Half-face Masks. When the disposable masks were removed from use, half-face Comfo II's were issued for use in those appli cations. Some employees have not been fit-tested or retested within the last year for these respirators. It is recommended that fit testing be scheduled as soon as possible for all persons required to wear respirators who have not previously been tested. The Methanol Area has placed several half-face masks with ammonia cartridges in the reformer building. These are for escape in the event of an ammonia leak from the Ammonia Area. Since ammonia is an eve irritant it is recommended that the need for a full face respirator be evaluated. Air Line Respirator. The site installs tees (Hansen Couplings) on its air line respirators for attaching escape cylinders when necessary. This arrangement is convenient and probably does not affect the degree of protection provided but, techni cally, it appears to void the NIOSH approval. Although one OSHA compliance officer who saw the arrangement considered it acceptable, other OSHA personnel may not. It is recommended that this practice be discussed with the departmental Energy and Environmental Affairs office who may want to ask for legal input. The breathing air systems should be modified to include the filter recommended in Engineering Standard S 1 H. A sion should also be provided to have the pressure adjusted correctly and blow down the air line prior to use. e Self-Contained Breathing Apparatus. There was confusion between area personnel and the safety department on their respective responsibilities for inspecting and maintaining the self-contained breathing apparatus on the plant. It is recommended that training be provided to appropriate area personnel in the proper inspection and maintenance of the equipment. DUP 0502261 DU 001905 r:aWil:MB;s |M*( ^wrri.Kiffla^agffiaiaaHWei Gloves The selection of gloves to protect personnel from contact with hazardous chemicals is fair. Permeation rates have been con sidered along with other factors in selecting gloves for handling TEL and AN. However, the site uses a number of other chemicals, some with carcinogenic potential, for which skin absorption may be a significant route of exposure, e.g., carbon tetrachloride and perchloroethylene. It is recommended that permeation data such as that developed at Haskell Laboratory be considered along with other significant factors in choosing the most appropriate clove for all hazardous chemicals which may affect the skin or may be absorbed through the skin. For the compounds with carcinogenic potential impermeable gloves should be used as dictated by the nature of the operation. EXPOSURE HAZARDS - IDENTIFICATION, EVALUATION AND CONTROL Chemicals The plant is commended for its excellent air monitoring program. Evaluation and verification of sampling and analytical methods is done by very knowledgeable plant personnel. The areas follow up where high exposure is evaluated. Basis for the evaluation is the LOGAN program as outlined in Engineering Standard S 12 T. The sampling priorities are established on basis of Engineering Standard S 11 T by knowledgeable personnel but the priority determination has not been documented. It is recommended that the evaluation be documented to facilitate review whenever a chance occurs which is likely to affect employee exposure. Although asbestos is handled infrequently by plant personnel, field observations showed some inconsistency in the knowledge about who handles asbestos and what protective equipment is required. It is recommended that all involved parties be informed on the content of the plant'3 asbestos procedure and the involvement of Du Pont employees in handling asbestos. It is recommended that new insulation be identified as asbestos-free. lln case of future removal, unnecessary and time-consuming precau tionary measures can be avoided. ______________________ Ventilation The ventilation program is good. DUP 0502262 j I DU 001906 Plans to install new laboratory hoods in the Polymer Products (PP) Laboratory (project costs $700,000) are endorsed. In the meantime, the maximum opening whereby the minimum required airflow can be obtained should be marked. The sashes should not be opened further when chemicals are handled in the hoods. All local exhaust hoods for chemical control should be monitored for airflow annually, e.g., the hood over the rubber mill in the PP Laboratory was not checked. Plans to replace the canopy hood in the water treatment laboratory of the Methanol Area are endorsed. The hood should be designed so fumes are drawn away from the operator and not through the breathing zone. _________ _ Three observations indicated that welders are not aware that the f required airflow of 100 fpra in the welding zone has to be main tained. It should be considered to post the distance, within which the required airflow can be maintained. It gives the welder a practical reminder of how close he should place the exhaust opening Emergency Procedures Spill procedures are fair and should be upgraded. Advice for protection in case of a spill is partially covered in different documents, e.g., MSOS's, emergency procedures primarily for environmental control and standard operation procedures. It is recommended that concise. readilv_accessible procedures be developed to protect people, environment and property. Based on the property of a chemical or a group of chemicals, definitions of maior/minor spills should be established. The protective equipment, type of glove, respirator, acid suit, etc. should be selected and defined. The cleanup procedure and proper disposal should be covered. The requirements for reentry, e.g., air monitoring results should be specified. Drills are helpful training tools in implementing these procedures. Housekeeping and Facility Maintenance This program is excellent. Leaks are generally contained and areas roped-off. Pood Control Pood control is good. The interiors of microwave ovens need better cleaning. Thermometers are, recommended for all refrigerators to assure that temperatures are kept at or below 45* F. 5 DUP 0502263 DU 001907 It ts recommended that the -consumption of food orbevarage nnf ho allowed in a laboratory where chemicals with carcinogenic poten tial are handled, e.g., as now practiced in the PP Laboratory. Noise Control The noise control program is good. Annual noise surveys are performed and boundaries for hearing protection are drawn at 90 dBA. Since employees work 12-hour shifts, it is planned to mark hearing protection zones at 87 dBA within 1981. This plan is endorsed. Where noise exceeds permissible limits, compliance plans have been developed. It is recommended that the rationale for the decision to 1- tiateor delay engineering controls be added" success or fs -ire of engineering controls should also be recorded. Radiation/Laser These programs are excellent. Source monitoring is in compliance with the appropriate standards. Heat Stress Several jobs have been evaluated for heat stress potential. Work/rest cycles have been established for some tasks. It is rec- ended that evaluation of current and future data be contint as planned to establish work/rest cycles where necessary. pr: report The ing items of the previous survey have not been adequa dressed; e lmt ament in documenting information to employees who handle carcinogens V Material Safety Data Sheets for certain laboratory chemicals V'm Glove selection based on permeation data Noise boundary at 87 dBA for 12-hour shift (Nordel* Area). ##### .- 6 DUP 0502264 DU 001908 jiyjfjygj BiUi m I) McClure - #42 July 9, 1981 TO: I. M. SINGER - #36 FROM: N. M. SABATELLI - #80 `Tl.TfW-V S&F SURVEY #1022-H - RESPONSE Three observations indicated that welders are not aware that the required airflow of 100 fpm in the welding zone has to be maintained. It should be considered to post the distance, within which the required airflow can be maintained. It gives the welder a practical reminder of how close he should place the exhaust opening. A total of 18 shop welding locations exist on the site. Airflow measurements have been completed at all locations to determine the proper placement of the exhaust opening to attain the required airflow of 100 fpm in the welding zone. Appropriate signs will be located at the exhaust blower on-off switches as a reminder to all welders. NMS/kp Attachment DUP 0502265 DU 001909 NMS June 4, 1981 cc: L. T. Freeland J. E. Nauss S&F SURVEY/?1022-H The following Items are primarily in your area of Interest. Will you please advise what you believe our response should be. 1. Although asbestos is handled Infrequently by plant personnel, field observations showed some Inconsistency in the knowledge about who handles asbestos and what protective equipment is required. It Is recommended that all Involved parties be informed on the content of the plant's asbestos procedure and the involvement of Du Pont employees In handling asbestos. It Is recommended that new Insulation be Identified as asbestosfree. In case of future removal, unnecessary and time-consuming precautionary measures can be avoided. 2., Three observations Indicated that welders are not aware that the required airflow of 100 fpm in the welding zone has to be main tained. It should be considered to post the distance, within which the required airflow can be maintained. It gives the welder a practical reminder of how close he should place the exhaust opening. RLM/fb DUP 0502266 DU 001910 TO^i 6 7DATE ///t FROM: L. T. FREELAND Beaumont Work* Mail Area 42 Ext. 9629 ''fyilM "iiktZ. -UnJtj) /Utfc /Uut th +tdj, in DUP 0502267 DU 001911 -3-iLa. i^Jltav0 m.jlJL /vvwjL' %-mJlli^ Qjss A-?iy /HjMI jw ClIj^^^ZT $511$ f^ ^Cu/M^rxJt/fitu> GuJ aU*-J- 4L G)W|i^ AcifcdW ^jjfalull)# (/J^&*0 tJld^'fciL* /Urw iktf/d^ G^uJ& irfyM^ &ju*> ^nC^,vJmj '^^Aott/UrclflC$$A*U. tti M^JLyttiL. DUP 0502268 DU 001912 ^dL&- |Liv 4xA*-*fcw pCr&eio5 '-0+* Jl>a^-> jj^jJQ JUj sujjk piS^riKV^ ftP }S\r-- CL. ^^i^^.4j / fry .0 ^ "t^ f^MJ+ltAjJiiJlA* M- ^**y 0+L +aa^' JL/ftoijlJL (M4^vW^,> >o3A <svJ^ AtJ^uxf A^^y AV ^ *|iJb /VWAd l^zfcu* ttl'^ ^iul uLJtSi^tLy uAw ^Wiiwfcu ,/WlUU/V^u^ ftJlJjJlfl^J) jt(^Cfe* Ij^lAlV ClvvjUW^ y J' totU J* /JUr-fij^-aJ) ^u ^jMyi^h ^^O^Ltahciv. DUP 0502269 DU 001913 S&F OCCUPATIONAL HEALTH SURVEY NO. I022-H FIELD NOTES AND PLANT RESPONSES (PROPOSED) Breathing Air a. The plant purchases compressed air fcr its breathing air svstems. Although each cylinder is checked for Os and CO content, there is -o periodic check of the other Trade D breathing air parameters. It is recorr.er.ded that the purchased breathing air be checked ceriodically fcr Trade I specificaticns. b. The breathirg air supplier fas visited several years azo to insoect his operation but no followup contacts have been made to insure that operations continue as ir.ciaily inspected. It is reccmr.erded that annual contacts be rads to assure continued acceptable operations (See Engi neering Standard 32H'. * 2~-' Response a. One trailer per year will be checked for hydrocarbon content. cure bew-n vwxAt. SHjBEIlM b. Annual, contactsAwily Safety Caoa Sheets The compilation of material Safety lata Sheets should include maintenance chemicals and industrial cleaning agents. Household cleaning azer.ts, consumer 'not industrial' paints, inks, greases, etc., need net be included in the compilation. Ir. laboratories, Material Safety Tata Sheets or other equiva lent safety monographs should be available for the followir.t chemicals used: materials U3ec in pilot plants or process development operations. materials of moderate or greater health hazard purchased in bulk quanti ties by the storeroom. teroxiiitable compounds. compounds known to cause strong skir. reactions cr irreversible eye injury and, other highly hazardous materials used on an average of mere than once per month which have an exposure Limit <10 ppm, LCsa<ppm/L hr. or LD,a <30 mg/kg (oral rat). ~ Response Mai\itenana*^hendaatep^dus1?rici2r~cl<aaninq/Cq&nts, pilrfbpUmt awiyroaess/y development ajiemipals, andjil]/materials.^tnirchabeidJin bulk cfcwrfitiebcwjjzl be Material Safetu/6aSa Sheets f^laboratory chprtfcats are na^nohmlly neca Hazards and appropriate precautions \re adequately addressed in t\e indyoic labonrbsnt procedurek^in wjinch they DUP 0502270 DU 001914 ,Mani^ itfUi ''gwgitftn m EH -2- j|^ 3--S ?3.d.i2.^icn RsccrdksSwirs The records for the dosimeter monitoring do net contain the c'jru';'v e^-osur- with tr.e exception of the exposure data for the nurses. It is recommended that the year-tc-date exposure as well as the cumulative liftdne"*Vcsur""* te recorded. It should also be considered to issue assigned cerscnal dosi meters for plant personnel which repeatedly has potential exposure like the employees which do the radiation surveys "1 Response Review of the last 10 years of radiation exposure data show that all exposures have been "M" (minimal). Adding year-to-date and cumulative lifetime exposure to the records would not provide any additional useful information. Because of the infrequent incidence of use and the very low potential for exposure, the assignment of personal dosimeters to individuals (other than the nurses) is not warranted. * --s qp ^0^53 Lsv@l- Messrs Several noise level meters and calibration sources are in use. Some comparison is made between sources calibrated by a vender ar.d others. But there is no schedule to have at least one source calibrated once a year and to have all other level reters as well as calibration sources compared with it. It is recommended that a formal schedule be introduced. Reavonse The two proprietors of the noise survey meters maintain docmentation of annual calibration. Upon return of a newly calibrated meter from the vendor, source validation is confirmed by direct comparison with the meter. Cross-checks between the three meters end the two sources have shown this practice to be satisfactory. 5-S J-6 Mclse limit Tr.e noise boundaries are sresently marked at 90 d3A. Since employees work 12-hc'ur shifts, it is agreed that plans to mark hearing protection zones at 37 oBA be implemented soon. Ho response necessary. Respirator Fit-Test With the increased emphasis by OSKA in the fourth quarter of 1980 for the fittesting of disposable respirators, the plant has elected to discontinue use of these types of" respirators, in favor of the Ccmfo II with appropriate cart ridges. *Thi3 policy has affected mechanics site-wide and selected employees (a phosphate sensitive individual in the Methanol Area). This group of employees are new using respirators for which they have not been fit-tested, although testing is due this year. It is recommended that employees not be required to wear respirators that they have not been fit-tested ar.d trained ir. the use of. Dup 050227l Response This program is underway and will be completed during the current year. DU 001915 -3- Self-Oontalr.sd preaching Apparatus The pressure of the air supply cylinder of a 20-mir.uce self-contained ,a-u---- apparacus was only ItCO psiz. is recommended chat Che cylinder be maincai-ed ir. the full condition. A full cylinder will be one in which ohe pressure gauze is the full ir.dicaoion ranee or at least within SC% of the rated tank pressure. If nonthiy regulator checks are responsible for low tank oressures, it'nay be useful to use a spare cylinder for these inspections. Response All areas have been reminded of -he need to maintain the cylinders "full. " Employee r.esslracor Cleaning The site uses a clearing solution of 303 isopropyl alcohol for daily cleaning of individually assigned respirators. Some locations have encountered crcclems when using alcohol containing solutions, which car. damage the faceoiece bv causing swelling or hardening of t.he rubber. It is recommended that -use of alcohols shculd be avoided. A convenient alternative way to do Intermediate clearing is with an aqueous oleaner/sanitizer solution, e.g., Antiseptic Tcvrelette, by Ved-Pak Corporation, ?. 0. 3ox 5^3, ?oca, W.V. 25159. Response Our experience using the 30% isopropyl alcohol has been satisfactory. We will keep in mini the availability of the Med-Pak product in event a problem should arise. Cloves ?VC gloves are used as protaction against carbon tetrachloride, chloroform. ar.d other solvents. TIC gloves have a lew breakthrough time for these solvents. Plans to evaluate tore protective gloves on basis of permeability data collected by Haskell are hignly endorsed. .Vo response necessary. Spill Procedures The area has developed some emergency procedures. Three different sheets address this item and different statements about personal protective equipment are indicated, e.g., rubber gloves, PTC gloves or'only protective equipment for carbon tetrachloride. It is recorr.er.ded that concise emergency spill proce dures be developed. 'They should contain, beside other information the exact types of crotective equipment that shculd be 'used in a spill situation. Chemicals'with similar properties can be grouped together. Sample procedures can be provided. Other'areas like Hordel, TIL need to develop similar procedures. DUP 0502272 DU 001916 Information cn Trsmlcal Hazards jgf a. Employees ere informed about the hazards of the chemicals they hard'a annually. 'This training is documented with the narr.es of t'-e =rpi ov^s a.-'4 the dates they received this information. It is recommended that the scoce of the information on chemicals with carcinogenic or embryctoxic ooter.tial be included in the documentation. o. The Chemical Cata Sheets 'used and prepared by Hypalon Area) cr. car'ccr. tetrachloride and chlorcform which serves as information basis for emrloyees do net contain information or. the carcinogenic potential of these chemicals. This infcrmaticr. should be added. Response a. The information to be covered is contained in the training instructions. Documentation by reference that the prescribed information was covered appears to be adequate. Recording the training session content on each occasion e appears redundant. b. The information sheets used by the area have been corrected. 5-12 P.esoiratcrs a. Two face pieces of Scott Air Pales had some soil cn them. It is reccrrm.er.ded that dirty respirators be cleaned when found during the monthly inspection. A dirty face piece '.as also found in the Horde1 Area. b. Breathing air stations for airline respirators are marked as such. It is recommended that the phrase 'blow out line before using mask' (Engineering Standard 31H' be added. This appears to have plantwide application. Response Both reoomended measures will be implemented. # Air-Line Respirators The air-line respirators in the Mcrdei Control Room are all similar in appearance and function. The approval designation on one of the units was by the Bureau of Mines 3K-19B-3S. This style of respirator was no longer approved for use past March 31, I960, unless modified by the manufacturer (no modification was apparent), A similar style of respirator was in 'use in the Methanol Control Room, but it carried a current approval number. Both styles of respirator use a quick disconnect unit which appears to have been fabricated cn site. An approved air supplied respirator must use components and parts, which have been'submitted to the HICSH/RSKA approval organization and approved as a 'unit, this includes vortex coolers, interchange of parts and substitution cf ether parts will void the approval. A similar quick disconnect unit is present on the 5, 7.3 and 10-minute escape respirators'. It is recommended that the ' >ir supplied respirators be inspected to assure that the entire 'unit is composed cf actroved components. In addition, the breathing air station in the Lordsl?1 ' 'entre'i Room should be properly identified see Tnrineerirg Standard SIrr . DUP 0502273 DU 001917 Res venae The outdated respirators have been replaced with standard units. Regarding the quick-discormect feature, since it is so widely used (Beaumont, Sabine River, Victoria, Haskell Lab, Corpus Christi) we believe it would be ` more appropriate for Ailmingpon Sic to initiate an inquiry in order to obtain a Corporate answer. --vfscr.-'~.es a. k coffee cup was being used bo remove ice from the ice raker. use it was placed in the ice bin /.'here the handle was in contact with the It is reccnr.ended that the handle not be placed in contact with the i: due to the cctentiai contamination of the handle and subsecuent ice contamination. b. The ioe bin is beginning to rust creating difficulties in cleaning and the potential of rust particles in the ice. It is recommended that the unit be cleaned and painted to eliminate the rusty condition. Resvonse Accepted. Fascinators Two out of five Scott Ska ?aks were filled below the full mark. It is recom mended that the air pressure of emergency respirators 'ce kept ir. the full range of the pressure gauge. The same deficiency was found at ar. escape pak in. theMethanol Area. Response See J-7. Refrigerator Refrigerators for cooling food do net contain thermometers. It is rsccnr.er.ded that ail refrigerators or. the plant be equipped with a thermometer ''net mercury bulb) to assure that the temperature be kept at or below to assure proper food storage. Response Accepted. Instrument Shoo Pans for catching mercury were installed under manometers. Various iters were stored in the pans. It is recommended that nothing be stored in them, to impair detection'and cleanup of spills. Response Accepted. DUP 0502274 DU 001918 -o- Zscace P.sscirators a. Air purifying respirators 'half-mask Ccnfc II with ammonia cartridges' rave been placed in various areas of tbs .''ethanol Area. The ''str.ar.cl Area is adjacent to the Ammonia Area. Two cf the respirators were dirty ar.d the storage bag was not sealed to provide clean, uncontsmirated storage. Scare cartridges were also stored in the box. It is recommended that the respirators be cleaned, stored properly ar.d spare cartridges stored ir. a central location 'in an er.erger.cy, an etcIcyee should not be concerned with changing cartridges). b. Since arocnia is an eye irritant, the area should evaluate the need for iul face respirators in those locations that eye irritation could prevent successful escape in an err.erger.cy situation. It is reccnr.er.ded that the need for full-face respirators be evaluated. Response a. Accepted. Hearing Protection a. .'to hearing protection is required in the Water Treatment laboratory/ but is required beyond both exits. It is recommended that signs be pcsoed at both exits to remind employees that hearing protection is required when leaving the laboratory. c. An air powered portable grinder had no indication chat hearing croteccion is required when it is operated. It is recommended that the noise level be evaluated and the tool be marked if the noise exceeds the acolicable limit. Response Accepted. Welding Exhaust The welding exhaust unit in the maintenance shop will .not effectively cover c.oe entire area of the welding table. It is recommended chat the system, te modi fied to provide effective coverage to the entire area. Response Welding will be restricted to the area which can be covered by the exhauster. DUP 0502275 DU 001919 -7- -.'_or:_".e Shed She breathing air manifold ac the chicrir.e shed is located at oh cylinder manifold area. A small chlorine leak rad been detected ar.d barricaded. ^----------------*-*J -- -J f-'a rra/-J i-*........................................................ - aw ^ * exposure to leaks dun11 -.g respirator to erection. ?.esz'Or>.33 Accepted. low 3reath.ing Air Pressure A portable breathing air cart was in use by a welder. She saute cn the lev/ pressure side of the regulator shewed ^0 psig supplied to the respirator. She gauge was corroded and r.ct responding properly. Plant procedures' call for the pressure to be set at ICO psig. Use of the lewer pressure could allow the respirator to be 'starved' for air creating a potential for the respirator to become a negative pressure device, allowing leaks of contaminated air to enter the facepiece and expose the 'user. It is recorr.er.ded chat the gauge be replaced and the regulator tagged to indicate the preper pressure. Response Accepted. Armenia Laboratory laboratory hcod effectiveness improves dramatically as sources of emission are placed behind 5 inches of the plane of the 3ash Engineerin? Standard K3U' . It is rscorr.er.ded that lines be drawn in the hoods of the Armenia lab as already done in the heeds of the adjacent labs. Response Accepted. Scill Prevention licuid waste containing acrylonitrile ia collected in a container under a laboratory hood in the Petrochem Lab. It is reccrnnended that the container be placed in a catch pan to contain spills. Response Accepted. DUP 0502276 DU 001920 -<?- Weidinz Exhausts Heeds Airflows are checked ir. 3 ir.ches cisrar.ce from rhs center of the hood tcenirss. Mo actions are required if rhe airflow reaches ICC for. ar.d r.o reachir.zs' ir~ ' ether distances are taken if it exceeds ICO fen. luring welding ir. the ?3C shoes, the center of ohs exhaust opening vas placed in greater iiscar.ce than 3 ir.ches. Since no airflow r.eas'urer.e.ot results -were posted cr the disoance was not ieterrir.ee within rhe required airflow of IOC far can be rair.tair.ed, err levees could r.cc ce sure whether rhev 'are adecuacel-' oreteener. Ic-should be considered to give a practical guidance for the welder anc cost the distance within, the required airflow can be rair.tair.ed. Asbestos Sene discrepancies exist in the opinion whether asbestos insulation, still be reroved by Du Pent employees or only by contractors. Area personnel stated that maintenance work on asbestos insulation is still done 'ey lu Pont etnplcyees. 7ne electrical shop would still use respirators which r.o fit test is performed for. Ir. the boiler house, the retaining asbestos insulation is not identified and labeled 'Engineering Standard S-T). Maintenance employees are being informed about the carcinogenicity of asbestos. It is recommended that a consistent procedure be implemented for the piano and that all Involved parties be inferred about its contents. DUP 0502277 D\J 001921 9- - e.zirx exposure A maintenance welder in the area she? had used a 3M 992C disposable resoirater for protection from zir.c oxide fumes while working on galvanized metal spoke of having suffered from metal fume fever on'or.s occasion In'the eastward ms. , _ ________ es be investigated for lu Pont capability and approoriate protective ecuipr.ent provided, if warranted. '' ' Response Tne ZnO exposure was a pre-Du Pons incident. The 3M 3920 mask has been removed from service. 3-?; Self-Contained Breathing Apparatus The pressure of two Scott Air ?aks was beicw the full scale. T!'.e straps of both facepieces were not fully extended, and the regulator Cy-cas3 valves were open to flush contaminants from the face piece. It is recc.mmer.ded that area personnel be trained to perform the monthly checks srcoerlv. Response Accepted. J-29 Ivewash Staticr. The eyewash station in the center of the nitrobenzene area did net function properly on initial operation, e.g., lew water pressure. In the third attempt . i.z functioned crcc-sriy. It is recor^r.ended that th ur.it fcs r'sp&irsd to -function Response Accepted. S--30 .'olse Control A telephone is situated in a noise zone (^90 d3A). while calling, employees have to take out their hearing protection. It should be considered to install a noise protection enclosure which allows phoning without hearing protection and without exposure to the .noise. Response Accepted. S-31 Cloves Rubber gloves are recuired in the spill procedures for on tection against several chemicals. At least three different kinds of gloves were in use v/hich were all called 1 rubber gloves.' It is reccntoended that the use r: ' gloves be reviewed or. basis of their permeability, this is already planned. Response No response necessary OUP 0502278 DU 001922 :o. 3-22 Cor.ralr.sd Breaching Accsratns <0 <0 A. Scotc Air Par: wic'r. a sraii cylinder was scored ir. a case labeled as "'C-rdruces and:. Ever, this srail cylinder was filled -;ncer the full scale'" Id isY ner.ded trad only adequate er.erssrcy equipment be provided and oersomel b chck iv prow^ply. ffegpongg Accepted. DUP 0502279 DU 001923