Document jyK3maVnDNarOoe85Rq84675N

Safe* *fficc JleatraMlw to <Nam and Location) As Listed* FROM <Nam and Location) C. W. Whaley GEN 53 (RCV.6/7- DATE January 9, 1980 cwewE-mc-^- *E. L. Tejml*^ 0. H. Miller^ W. F. Soward*' K. A. Dunn L. E. Hackfeld E. D. Luke^ D. G. Bremer C. 0. Schaefer^ C. D. Barrett, Dallas G. A. Rodenhausen, NYO SUBJECT: Employee Notification of Recent Toxicity Testing Results on Triphenyl phosphine and Trlphenyl phosphine Oxide Attached are a communique and "back-up" questions and answers for Informing 8ay City Plant and Arthur Brothers, Inc. employees of recent toxicity testing results on trlphenyl phosphine (TPP) and triphenyl phosphine oxide (TPPO). If you have any questions concerning the BCP addition to this statement, we will discuss these at a meeting to be called by Dave Bremer on Friday, January 11, 1980. CWW/cmr Attachments File: 71-2 C. W. Whaley / 005019 ROUGH DRAFT - CONFIDENTIAL TOXICITY TEST RESULTS OF TRIPHENYLPHOSPHINE AND TRIPHENYLPHOSPHINE OXIDE In 1977, you were Informed that based on toxicity studies conducted in Germany, triphenyl phosphine had been found to be neurotoxic (i.e., toxic to the nervous system) in laboratory animals. Based on these early tests, Celanese Implemented safe handling pro cedures aimed at minimizing employee exposure. Recently, we received additional toxicity test results based on studies sponsored by our American supplier of this material. In these recent studies, dogs were fed various doses of either triphenylphosphine (TPP) or Its reaction product triphenyl phosphine oxide (TPPO). In some cases, the dogs were given single doses and In other cases they were given small doses over a period of two to three weeks. Test results have confirmed the earlier German results. Both TPP and TPPO were found to affect the dogs' nervous system at the lowest dose tested. Furthermore, the TPP exposed animals suffered partial paralysis and were unable to stand for normal periods of time. These test results are of significant concern to Celanese because the "no effect level" (I.e., the dose which produces no paralysis or other neurotoxic effects) is not known. Moreover, It has not yet been determined whether Inhalation of TPP can result in neurotoxic effects. Our supplier Is presently sponsoring additional toxicity studies to answer these questions. Although there have been no known cases of TPP or TPPO Induced neurotoxicity in humans, the animal test results suggest this possibility. Therefore, we should continue to consider these materials as being highly toxic. Employee contact should be avoided. Approved personal protective equipment should be used when handling these materials. TPP Is used as a catalyst In the propanol, butanol and synthetic fatty acids processes at the BCP. TPP Is present In various streams of these processes along with Its reaction products TPPO and other phosphines. Precautions have been taken throughout the BCP to minimize employee exposure to TPP and Its reaction products. Standard Operating Procedures have been instituted for handling TPP In Traffic, Operations, Maintenance, and the Laboratory. In addition, attention was given to proper disposal of TPP containers and samples. Equipment containing TPP/TPPO In the units have been Identified by labeling as a warning to Operations 005020 Page 2 and Maintenance personnel. Where there is a potential for direct contact with TPP/TPPO, the use of personal protective equip ment is required to minimize exposure. For example, during the catalyst mixing operation, the Operators wear fresh air hoods and disposable coveralls, boots and gloves. In addition, each TPP mixing facility is equipped with a dust collection system to minimize TPP dusting. The Occupational Safety and Health Administration (OSHA) has not established a permissible exposure limit for TPP and TPPO. However, based on available animal toxicity data, Celanese believes TPP and TPPO should be considered highly toxic and any employee contact should be avoided. If employees use recommended procedures, protective equipment, and follow good Industrial hygiene practices no harmful exposure should occur. 005021 BACK-UP "QUESTIONS AND ANSWERS 1. Who is our domestic supplier of triphenylphospine? M & T Chemical Company 2. What happened when dogs were given single oral doses of triphenylphosphine? All dogs given one oral dose of 500 mg/kg (milligrams per kilogram of body weight, about one-half ounce of TPP for a 50pound dog) died within 24 hours after receiving the dose. Before death, the dogs experienced convulsions, tremors, vomiting and other signs of neurotoxicity -- an effect on the dog's nervous system. Similar neurotoxic symptoms were observed in dogs given a single oral dose of 300 mg/kg of TPP and one of the six dogs given this dose died. A single dose of 50 mg/kg did not produce observable results similar to those from higher doses. 3. Describe the test results when animals were given repeated doses of triphenylphosphine. When oral doses of 50 mg/kg of TPP were given to six dogs daily for 14 days,.the dogs became weak and were unable to stand for normal periods of time. This partial paralysis continued for two weeks after administration of TPP'was stopped. Subsequent micro scopic examination of the brain, spinal cord, and sciatic nerve of these dogs revealed evidence of neurotixic effects of the TPP. 4. Is TPP a severe eye and skin irritant? No. 5. Oescribe the test results when the dogs were given single doses of TPPO. Single oral doses of triphenyl phosphine oxide were more toxic to dogs than equivalent doses of triphenyl phosphine. All six dogs given a single oral dose of 300 mg/kg of TPPO died within 24 hours. A single oral dose of TPPO of 50 mg/kg produced convulsions but not lethality. 6. Describe the test results when dogs were given repeated doses of TPPO. Unlike TPP, repeated 50 mg/kg of TPPO for 21 days did not cause signs of paralysis. 7. Is TPPO a severe skin and eye irritant? No toxicity information is available. 005022 2- 8. What additional toxicity studies will H 4 T be conducting? H 4 T is presently sponsoring additional feeding and inhalation studies in dogs with TPP and TPPO. The objective of the studies is to determine a "no effect" level of exposure. The studies should also determine whether inhalation of the dust poses a health hazard. 9. When should the additional tests be completed? Within six months. 005023 Intenrfficc HcnraMlH -O (N<m* and vocation) As Listed* from (Nama and Location) c. W. Whaley A'1 / S~ / ---------- ----------------------- GEN S3 (RV./; OATE January 9, 1980 *E. L. Tejml 0. H. Miller W. F. Soward K. A. Dunn L. E. Hackfeld E. D. Luke D. G. Bremer C. J. Schaefer C. D. Barrett, Dallas 6. A. Rodenhausen, NYO SUBJECT: cEmployee Notification of Recent Toxicity Testing Results on Triphenyl phosphine and Triphenyl phosphine . Oxide ,,,, * Attached are a communique and "back-up" questions/nd answers for Informing Bay City Plant and Arthur Brothers/Inc. employees] of recent toxicity testing results on triphenyl phosphine (TPP) and triphenyl phosphine oxide (TPPO). If you have any questions concerning the BCP addition to this statement, we will discuss these at a meeting to be called by Dave Bremer on Friday, January 11, 1980. ] " / ^0 ^**<! + U Q, -TTP 4 / CWW/cmr Attachments File: 71-2 I: + -j j 4 ' *>> / hUr uLJmx C. W . Whaley \ 0 * b If * A" 7 ]) Ctf- L/J A ** ^ A It** f- //. -j-ff f "^4 _ Z) t.tf- * u ~b ^ j 1 *' <_ (*n *~hr\ "f~/ l/'^f* 5"f* ^ -A*-* -- d | IT J -y14 /r 4-l--^ ^ v~ / *V' .0r / // * -/ -f. 'C1 V" X//*"-L t] -6 *o' <& 0 ' 005024 ROUGH DRAFT - CONFIDENTIAL TOXICITY TEST RESULTS OF TRIPHENYLPHOSPHINE AND TRIPHENYLPHOSPHINE OXIDE In 1977, you were informed that based on toxicity studies conducted in Germany, trlphenyl phosphine had been found to be neurotoxic (i.e., toxic to the nervous system) In laboratory animals. Based on these early tests, Celanese implemented safe handling pro cedures aimed at minimizing employee exposure. Recently, we received additional toxicity test results based on studies sponsored by our American supplier of this material. In these recent studies, dogs were fed various doses of either trlphenylphosphine (TPP) or Its reaction product trlphenyl phosphine oxide (TPPO). In some cases, the dogs were given single doses and In other cases they were given small doses over a period of two to three weeks. Test results have confirmed the earlier German results. Both TPP and TPPO were found to affect the dogs' nervous system at the lowest dose tested. Furthermore, the TPP exposed animals suffered partial paralysis and were unable to stand for normal periods of time. These test results are of significant concern to Celanese because the "no effect level" (I.e., the dose which produces no paralysis or other neurotoxic effects) Is not known. Moreover, It has not yet been determined whether Inhalation of TPP can result In neurotoxic effects. Our supplier Is presently sponsoring additional toxicity studies to answer these questions. Although there have been no known cases of TPP or TPPO Induced neurotoxicity In humans, the animal test results suggest this possibility. Therefore, we should continue to consider these materials as being highly toxic. Employee contact should be avoided. Approved personal protective equipment should be used when handling these materials. TPP Is used as a catalyst In the propanol, butanol and synthetic fatty acids processes at the BCP. TPP Is present In various streams of these processes along with Its reaction products TPPO and other phosphines. Precautions have been taken throughout the BCP to minimize employee exposure to TPP and Its reaction products. Standard Operating Procedures have been Instituted for handling TPP In Traffic, Operations, Maintenance, and the Laboratory. In addition, attention was given to proper disposal of TPP containers and samples. Equipment containing TPP/TPPO In the units have been Identified by labeling as a warning to Operations 005025 Page 2 and Maintenance personnel. Where there is a potential for direct contact with TPP/TPPO, the use of personal protective equip ment is required to minimize exposure. For example, during the catalyst mixing operation, the Operators wear fresh air hoods and disposable coveralls, boots and gloves. In addition, each TPP mixing facility is equipped with a dust collection system to minimize TPP dusting. The Occupational Safety and Health Administration (OSHA) has not established a permissible exposure limit for TPP and TPPO. However, based on available animal toxicity data, Celanese believes TPP and TPPO should be considered highly toxic and any employee contact should be avoided. If employees use recommended procedures, protective equipment, and follow good industrial hygiene practices no harmful exposure should occur. a jj: ^<-- <3 ' `"J T*-* r e i *v //- J ^ *-- ^ ^ f*- 4. J** * i- ***-* 4-/ . / / ^ S/tT / + s-S-K- -f' Vk-V'-J f) +-4 7y/ >,,.// 1 k. /*<*- /s* ^^ J) i~t J~ i/y-V 4 //<///*' f ~\4 f~k, .y v-VS p* -- ?- \ <Lj r +--y*j~k 't/ V` -Tv y+) i.i J~* }inj />? ?) Tft "7 >i j'/ 005026 BACK-UP "QUESTIONS AND ANSWERS 1. Who is our domestic supplier of triphenylphospine? M & T Chemical Company 2. What happened when dogs were given single oral doses of triphenylphosphine? All dogs given one oral dose of 500 mg/kg (milligrams per kilogram of body weight, about one-half ounce of TPP for a 50pound dog) died within 24 hours after receiving the dose. Before death, the dogs experienced convulsions, tremors, vomiting and other signs of neurotoxicity -- an effect on the dog's nervous system. Similar neurotoxic symptoms were observed in dogs given a single oral dose of 300 mg/kg of TPP and one of the six dogs given this dose died. A single dose of 50 mg/kg did not produce observable results similar to those from higher doses. 3. Describe the test results when animals were given repeated doses of triphenylphosphine. When oral doses of 50 mg/kg of TPP were given to six dogs daily for 14 days,.the dogs became weak and were unable to stand for normal periods of time. This partial paralysis continued for two weeks after administration of TPP \as stopped. Subsequent micro scopic examination of the brain, spinal cord, and sciatic nerve of these dogs revealed evidence of neurotixic effects of the TPP. 4. Is TPP a severe eye and skin irritant? No. 5. Describe the test results when the dogs were given single doses of TPP0. Single oral doses of triphenyl phosphine oxide were more toxic to dogs than equivalent doses of triphenyl phosphine. All six dogs given a single oral dose of 300 mg/kg of TPP0 died within 24 hours. A single oral dose of TPP0 of 50 mg/kg produced convulsions but not lethality. 6. Oescribe the test results when dogs were given repeated doses of TPP0. Unlike TPP, repeated 50 mg/kg of TPP0 for 21 days did not cause signs of paralysis. 7. Is TPP0 a severe skin and eye irritant? No toxicity information is available. 005027 2- - 8. What additional toxicity studies will M S T be conducting? M & T is presently sponsoring additional feeding and inhalation studies in dogs with TPP and TPPO. The objective of the studies is to determine a "no effect" level of exposure. The studies should also determine whether inhalation of the dust poses a health hazard. 9. Wien should the additional tests be completed? Within six months. 005028 4 Interoffice A\eiiaoraii<liini TO (Nn< and Location) *As Listed { Vt (Nim* ana Location) v C. J. Schaefer *C. W. Whaley W. 6. Comman D. F. Ripple N. V. Smith 6. E. Organ R. W. Sanders E. M. Sullivan G. B. Durett D. K. Mastell D. G. Bremer Meeting To Discuss Additional Safeguards To Prevent TPP Exposure GEN S5 (REV.6. OATE January 25, 198 REFERENCE NO. CJS-18-80 Listed below are the action items we agreed on at the January 16, 1980 subject meeting. 1. Operations will promptly notify Purchasing of any flowability problems due to quality and of any need to change container size. This is actually current procedure and there are no problems at this time. 2. Engineering will determine the feasibility and economics of completely enclosed TPP dump systems. Operations will initiate RFS's. l 3. Operations will take action to insure respirators are cleaned after each use and stored in a clean TPP-free environment. 4. Carroll Whaley and Roy Sanders will observe sampling of new shipments of TPP and recommend an appropriate SOP and protec tive equipment fpr this activity. 5. The Laboratory will notify Operations of any changes needed (to prevent exposure) on sampling systems containing TPP. Operations will investigate the best way to clean up TPP spilled in dump areas - dump areas will be kept clean. 7. Need Process Engineering to look at dump system modifications or SOP changes to reduce organic vapor backup to TPP dump bins. 8. Joe Schaefer will check with Bob Allen on Maintenance com pliance with TPP SOP. CJS/las cc: E. L. Tejml K. A. Dunn D. H. Miller W. F. Soward C. u. Schaefer L. E. Moore C. V. McSwain R. E. Allen 6. A. Vos - Dallas 005029 Interoffice A\eiiioraiuliim TO (Nian *"<1 Locit(oo) *As Listed FROM (Nm ina korjtlnnt -- L^eTjTschaefer *C. W. Whaley W. G. Cornman D. F. Ripple^ N. V. Smith G. E. Organ R. W. Sanders E. M. Sullivan G. B. Durett D. K. Mastell 0. G. Bremer 3----- a--r-- yn H -/f- ?o DATE January 25, 198 REFERENCE NO. CJS-18-80 (ZLclU On Meeting To Discuss Additional Safeguards To Prevent TPP Exposure ~---------------Listed below are the action items we agreed on at the January 16, J, 1980 subject meeting. Operations will promptly notify Purchasing of any flowability t .Problems due to quality and of any need to change container "l * size. This is actually current procedure and there are no Kfl^B^AUXA^Yroblems at this time. fc*A. VUUL\' -J"--"'' Vn rnzJ1 Engineering will determine the feasibility and economics of completely enclosed TPP dump systems. Operations will initiate . RFS's. ^Or- Operations will take action to insure respirators are cleane#^JLi^i ^ter each use and stored in a clean TPP-free environment. /)Av*** Carroll Whaley and Roy Sanders will observe sampling of new shipments of TPP and recommend an appropriate SOP and protective equipment for this activity. The Laboratory will notify Operations of any changes needed/^ S$-> (to prevent exposure) on sampling systems containing TPP. ^ Operations will investigate the best way to clean up TPP spilled in dump areas - dump areas will be kept clean. Need Process Engineering to look at dump system modifications ^ SOP changes to reduce organic vapor backup to TPP dump N fiuL0H*8r Joe Schaefer will check with Bob Allen on Maintenance Corn wall*'. Pn % r\ ifipliance with TPP SOP. ^ a *^r9J iipite ffo CJS/las z/fC. o. Schaefer cc: E. L. Teiml L. E. Moore K. A. Dunn D. H. Miller C. V. McSwain R. E. Allen 005030 W. -F. Soward G. A. Vos - Dallas L. E. Hackfeld C. 0. Barrett - Dallas  Interoffice SXemmnm4mm TO (Nwn and Location) * As Listed FROM (Nm and Location) C. J. Schaefer -cr ~w. Whaley w. G. Cornman N. V. Smith G. E. Organ E. E. Abels H. C. Thiele P. B. Rapstine D. G. Bremer J. R. Higgins J. E. Brents GEN 53 (REV.6/ DATE May 16, 1980 REFERENCE NO. CJS-92-80 Status of Additional Safeguards To Prevent TPP Exposure On May 7, 1980, the personnel listed above met to review the status of additional safeguards (CJS-18-80) to prevent TPP exposure. Listed be low are the highlights of the meeting. 1. The SFA Unit has been experiencing flowability problems with the 225 lb M & T TPP drums. Purchasing has been notified. Bill Cornman said they will probably go to the 50 lb drums used by Area I after they use up the existing supply of 225 lb drums. Flowability of 50 lb drums is good. 2. Operations has submitted HFS's for Engineering to determine cost and feasibility of totally enclosed TPP dump systems. A sock type en closed system has been tried in SFA but is not yet satisfactory due to 1) poor hopper accessibility due to high hopper height cause by valve temporarily replacing slide gate 2) insufficient vacuum system 3) 225 lb drum flowability problems Jim Brents said the 50 lb drums would be good to standardize on for the enclosed dump systems. Jim is going to publish status report on his investigation of totally enclosed dump systems. If the sock type system in SFA Unit is not satisfactory Jim feels any alternate totally enclosed system Is going to be expensive. Carrol Whaley mentioned that the ventilation systems on the Butanol and Propanol TPP dump systems combined with the protective equipment provided adequate operator protection. However, a totally enclosed dump system might eliminate the need for some of the pro tective equipment. If an economically feasible enclosed dump system cannot be engineered the SFA ventilation system will be modified and made similar to the BuOH and Propanol systems. 3. Respirators (with few exceptions) are being cleaned after each use and stored in a clean TPP-free environment. k. Appropriate SOP not yet defined for sampling incoming shipments of TPP. This will be done by C. Whaley and E. Abels after observing sampling of next TPP shipment. 005031 cjs-92-80 Page 2 5. SOP's have been -written for sailing all stream, containing TPP in the BuOH and Propanol Units. SPA Unit vill write SOP's. 6. Rotary lock has been reinstalled on BuOH TPP dump system but Operations has not noticed significant change in vapors at dump bin. Organic vapor backup in BuOH and Propanol needs further attention - no problem in SPA Unit CJS/rg cc: E. L. Tejml D. H. Miller K. A. Dunn W. F. Sovard L. E. Kackfeld G. B. Durett L. E. Moore D. P. Ripple R. E. Allen C. R. Pennington C. V. MeSwain G. Vos - Dallas C. D. Barrett - Dallas C.^J. Schaefer 005032 Interoffice Alcmoraiidam TO (Nama and Location) As Listed FROM (Naina and Location) J. E. Brents GEN 55 (REV.6 OATE May 30, 1980 REFERENCE NO. E-375-JEB-80 C. J. Schaefer C. W. Whaley W. G. Cornman N. V. Smith P. B. Rapstine D. G. Bremer J. R. Higgins C. R. Pennington Subject: Status Report on Engineering Activities to Up-grade TPP Dump Systems Engineering efforts to obtain data on a "totally enclosed" TPP dump system have so far been unsuccessful. No vendor contacted offers such a system as such. Custom designed equipment fabricators could, in all probability, come up with such a system, but the cost would, no doubt, be in the $100M range (or more). I don't think this would be economically justified for the BuOH and PrOH units dump systems just to eliminate some of the protective equipment requirements. The SFA unit TPP dump system needs to be modified such that it Is at least equal to the BuOH and PrOH unit systems level of operator protection. This will require a complete redesign of the hopper, dust collection system, and mix tank/hopper interface block valve. RFSI1-0303 has been estimated and routed for approval to do the required work on the SFA dump system. The estimate is >37.1M capital and $1.1M expense and is based on a dust collection system Identical to Area I systems, complete re-design of hopper for height, 501b. drums, hood for dust control, etc., and a new air operated block valve that will not leak through at V-1003's Ng blanket pressure of 10 psig. If there are any questions about this status report, feel free to call me. ^ JEB/pc file: 5.5.0.0 L. Tejml H. Miller A. Dunn F. Soward E. Hackfeld B. Durett J. E. Brents L. E. Moore D. F. Ripple R. E. Allen C. V. McSwain G. Vos 0 DALLAS c. D. Barrett - DALLAS 005033 Interoffice iUeiiiommliiin TO (Nam* and Location) B. L. Fritz from (Name and Location) C. W'.:-Whaley- GEN S5 (REV.6/74 OATE August 26, 1982 REFERENCE NO. CWW-339-82 SUBJECT: Survey of TPP Mix Area Periodically, I survey the TPP mix areas to evaluate compliance with plant safety and health procedures. On August 24, 1982 I toured the SFA-TPP mix area and made the following observations: - General housekeeping is good. - The TPP dust collection system appears to be well maintained. - Improvement is needed in the maintenance and storage of respiratory protection equipment. Materials for proper cleaning and storage of respiratory protection equipment should be provided. The air hood is currently kept in a cabinet but is not stored in a plastic bag. Attached is the plant AP pertaining to the respiratory protection program. I have highlighted the areas which I feel need attention to get into com pliance. If you have any questions regarding my observations, call me at Ext. 4077. CWW/dj cc: C. J. Schaefer W. G. Cornman D. G. Bremer L. I. Wallace 005034 3AY ClTi f _a:jt IUISTRATIVE PROCEDURES Pace 1 of 8 Section VIII SAFETY Bay City do. 32 Date: 12/17/80 Respiratory Protection Program PURPOSE: This Respiratory Protection Program establishes requirements for the selection, use, inspection and maintenance of respiratory equipment within the confines of the Bay City Plant of Celanese Chemical Company, Inc. The respiratory equipment shall be used for safeguarding employees against airborne contaminants and oxygen deficient work atmospheres. This program does not apply to mine and tunnel rescue work or protection against airborne radiation. The Bay City Plant Respiratory Protection Program incorporates provisions of the General Industry Standards, 29 CFR 1910.134 (OSHA), Respiratory Protection and ANSI Z 88.2 - 1969 of American National Standard Practices for Respiratory Protection. PROCEDURES: I. Bay City Plant Management assumes the responsibility for the imple mentation and maintenance of the Respiratory Protection Program. Each employee has the responsibility to know and adhere to this policy. II. The Respiratory Protection Program shall be administered by the Respiratory Protection Program Administrator from within the Plant Safety Section. III. Facial hair and other facial features must not interfere with the facepiece-to-face seal of a respirator if plant activities may require that face-fit type respirators be worn during normal or abnormal conditions. IV. Responsibilities ^A. Owning Supervisor ]. / Shall procure, use, inspect and maintain respiratory pro tection equipment in accordance with requirements of this program. The Plant Industrial Hvoienist and Respiratory Protection Program Administrator shall determine the proper respirator selection. 005035 SAY CITY PLAN Tl ADMINISTRATIVE PROCEDURES Pace 2 of 8 Section VIII SAFETY Bay City No. 32 Date: 12/17/80 Respiratory Protection Program _____ 2. Shall ensure that inspection records are sent to Respiratory Protection Program Administrator for retention. 3. Shall ensure that a suffic'ent supply of approved respiratory protection equipment, for contaminants likely to be encountered in everyday work practices or in emergency situations, is provided and readily available. 4. Shall ensure that respirators are worn by the employees when required. 5. Shall ensure that each employee who may be required to wear a respirator receive appropriate respirator training pro vided by the Bay City Plant Safety Section. Employee y 1. Each employee shall use, inspect, clean, and maintain his/her respiratory protective equipment as instructed by his/her supervisor. C. Purchasing Section 1. Shall purchase only respirators that bear the approval of the National Institute for Occupational Safety and Health (NIQSH) and approved by the Plant Industrial Hygienist and the Respiratory Protection Program Administrator. 2. Shall require vendors that supply breathing-air cylinders and breathing-air compressors to the Bay City Plant comply with specifications for Grade "0" breathing-air as des cribed in the Compressed Gas Association^, Commodity Specification for Air, Pamphlet G-7.1, ANSI Z 86.1 - 1973. D. Safety Section 1. Shall screen employees and prospective employees who must wear respirators for physical impairments or complications which may cause difficulty in performing job functions safely. Refer to Health Monitoring Program. 005036 BAY CITY PLANT Section VIII Bay City No. 32 Date: 12/17/80 h n .* T * 'r PROCEDURES SAFETY Respiratory Protection Program Paoe 3 of 8 2. Shall provide initial and recurring training courses in Respiratory Protection for all employees that may be required to wear respirators. 3. Shall be responsible for administration of Respiratory Protection Program. E. Plant Industrial Hygienist 1. The Plant Industrial Hygienist shall periodically monitor employee exposure to airborne contaminants. Monitoring shall also be conducted following new unit start-ups or process modifications which could result in new hazards. 2. The Plant Industrial Hygienist shall be consulted for assistance in selecting appropriate respiratory protection equipment. 3. Any changes to the Respiratory Protection Program (i.e.. Administrative Procedure and S.O.P.) shall be approved by the Plant Industrial Hygienist. V. A Maintenance Program shall be contracted to perform A. Cleaning and Disinfecting of respirators in wash water with temperature of 120-140 B. Drying C. Inspection and Repair after laundering with NIOSH approved repair parts D. Leak checked E. Individually bagged VI. Ambient Hazards (Defined) A. Excessive contaminants, including gases, vapors, dusts, fumes, and mists t V_ 005037 Section VIII Eay City No. 32 Date: 12/17/80 TRATIVE PROCEDURES SAFETY Respiratory Protection Program Pace 4 of 8 B. Oxygen deficient work atmosphere C. Combination of excessive conta linants and oxygen deficiency VII. Control Measures The primary objective shall be to control Ambient Hazards by accepted engineering controls such as confinement of the operation and local exhaust ventilation. Alternate controls may include administrative changes or the substitution of less toxic materials or approved respiratory protection. Respiratory protection shall not be used as a substitute if engineering or administrative con trols are feasible and practical, except as an interim measure. RESPIRATORY PROTECTION PROGRAM: The following requirements are necessary considerations in a Respira tory Protection Program. Standard Operating Procedures (S.O.P.) will be based upon the following data: I. Selection and Procurement A. Selection shall be based upon 1. Oxygen deficient work atmosphere 2. Ambient concentration, toxicity, reactivity and irritancy of contaminants 3. Work requirements and conditions 4. Characteristics and limitations of approved respirators 5. Wearer comfort and acceptance B. Respirator shall be NIOSH approved. C. The Plant Industrial Hygienist shall determine type of respirator to be used based upon contaminant and exposure potential based on contaminant monitoring data. 005038 BAY CITY PLANT Section VIII Bay City No. 32 Date: 12/17/80 AO;iI li I STRAY! YE P P.0CEDU2ES SAFETY Respiratory Protection Program Pace 5 of 8 II. Training and Education in Proper Use of Respirators A. Instruction in the nature of the hazard B. Explanation of why other control strategies are not feasible or practical C. A discussion of the reasons for selecting this respirator for this particular use D. A discussion of the respirators capabilities and limitati ons E. Instruction and training in actual use of the respirator F. Classroom and field training to recognize and cope with emergency situations G. Special training for special use Inspection A. Employees assigned personal respirators shall inspect them before and after each use as instructed during training session. Common use respirators shall be inspected before use and shall be cleaned after each use by the individual that has worn the respirator! C. Random inspections of personal, common use, and emergency respirators will be conducted by the Safety Section and the Plant Industrial Hygienist. The Owning Units will make weekly inspections on emergency, personal, and common use respirators. Records shall be for warded by the Owning Unit Supervisor to the Safety Section for retention. E. Routine maintenance of personal respirators such as replace ment of cartridges or filters shall be performed by the owning individual. A supply of all necessary items will be kept in stock in the Warehouse. 005039 BAY CITY plant Section VIII u::i:iistrative procedures SAFETY Pane 6 of 8 Bay City No. 32 Date: 12/17/30 Respiratory Protection Program IV. Maintenance A. Emergency respirators shall be rotated through a repair and cleaning shop on a regular basis. B. Assigned or personal respirators will be sent to a maintenance and cleaning shop on a regular basis. C. All repairs will be performed by an authorized individual or repair shop. D. All repairs must be made with NIOSH approved parts. V. Fit Testing A. An employee must take and pass a qualitative leak test per formed with the appropriate respirator(s) using irritant smoke or iso-amyl acetate while simulating body movements associated with normal work activities. The employee should be issued an identical make and model of the respirator that he/she used to pass the qualitative .leak test. B. Employees required to wear face-fit type respirators will not have facial hair that would prevent the proper facepieceto-face seal of a respirator. C. Employees who are required to wear respirators shall perform a positive or negative pressure leak test before entering a con taminated atmosphere. D. Eye glasses shall not be worn under full-face respirators except where they have been properly installed in approved adapters and do not interfere with face-to-respirator seal. Employees who need corrective lens should not wear full-face respirators with out these adapters and glasses, except during emergencies. E. Contact lens shall not be worn inside the plant except for rare instances where for medical reasons an employee cannot function with regular glasses. Permission must be obtained from the Safety Section and certain conditions must be met by employee. 005040 On'. CITY PLANT Section VIII Bay City No. 32 Date: 12/17/80 A3:II N I STP.-M I ye procedures SAFETY Respiratory Protection Program Pace 7 0f 8 Storage Reusable personal respirators shall be stored in sealed plastic bags and protective containers after being properly cleaned and maintained. B. Respirators shall not be stored in areas of extreme tem. peratures. ** C. Respirators should not be stored in areas where chemicals might damage or contaminate them. VII. Routine Application A. Where respirators are required for routine use they should be individually assigned. B. The atmosphere shall be monitored before entry into confined spaces or other areas which might be subject to oxygen deficiencies or excessive concentrations of toxic contaminates. VIII. Emergency Application A. Emergency Work Situations 1. Employees must wear an air-line respirator with auxiliary air tanks, or a self-contained unit, and must be equipped with safety harness and lines, where an oxygen deficient work atmosphere exists. 2. An attendant shall be present and located such that he/she is not likely to be overcome by an event affecting the wearer. The attendant shall have the necessary equipment for an emergency rescue. 3. Communications shall be maintained between all parties present. B. Immediately Dangerous Atmospheres (normally work is not per formed in IDLH atmospheres; however, emergency situations arise where such entry may be required.) 005041 bay city ad; :i i; i strat i ve procedures Section VIII SAFETY Eay City No. 32 Respiratory Protection Program Date: 12/17/80________________________________________________ Pane 8 of 8 1. A self-contained respirator or an air-line unit with auxiliary tank must be worn where an atmosphere immedi ately dangerous to life ar.1 health (IDLH) may be expected. 2. Persons wearing air-line respirators with auxiliary tank must be equipped with safety harness and lines in atmo spheres immediately dangerous to life or health (IDLH). 3. There shall be at least two standby persons stationed outside the toxic atmosphere. They shall remain in com munication with those in the toxic atmosphere. At least one shall have the necessary self-contained breathing apparatus and equipment on hand for emergency rescue. IX. Emergency Respirators A. Adequate respiratory protection will be kept easily accessible to facilitate the safe escape of all employees from areas in which immediately dangerous to life and health (IDLH) atmo spheric contamination may occur. B. Emergency escape respirators will be of a type which is easily put on, such as an escape unit with a plastic hood. These will be kept in the immediate vicinity of work stations subject to dangerous toxic contamination. C. Respirators used for emergency re-entry will be self-contained breathing apparatus (SCBA) units required for immediately dangerous to life or health (IDLH) atmospheres. The IDLH units will be kept immediately outside areas likely to be quickly contaminated. Additional units may be kept at a central loca tion or on emergency vehicles. D. Considerations will be given during emergency planning to assure that a fully adequate supply of breathing-air tanks is available, and that adequate refilling capacity exists on plant site. 005042 Interoffice AVeiiioniiidiini TO (Niim ana Location) L. T. Pless FROM (Name and'Location) C. W. Whaley cc: C. L. D. J. J. Schaefer J. Cribb G. Bremer P. Lieck A. B. Savage J. E. Brents L. I. Wallace GEN 55 (REV.6/7a DATE August 26, 1982 REFERENCE NO. CWW-340-82 SUBJECT: Survey of TPP Mix Areas Periodically, I survey the TPP mix areas to evaluate compliance with plant safety and health procedures. Following a survey on May 26, 1982, I re commended corrective action to improve general housekeeping and comply with plant safety and health procedures. On August 25, 1982, I conducted an other survey of the TPP areas and found that little progress has been made in correcting the deficiencies. One notable improvement is the installation of new boots between the TPP dump and mix vessels which appears to have re duced leaks. Once again I recommend that corrective action be taken on the following items: Propanol - TPP Mix Area 1. General housekeeping needs improvement (dust, oil, etc. on floor). 2. Unlabeled bottles of liquid are setting in the area. 3. The dust collector catch pan is missing. The pan should be installed like the SFA design. 4. Equipment for proper cleaning and storage of respiratory protection equipment should be provided. Air hood is currently in a plastic bag lying on the floor. Butanol - TPP Mix Area 1. General housekeeping needs improvement (tape, disposable clothing, disposable boots, drum tabs, dust on the floor). 2. Equipment for proper cleaning and storage of respiratory protection equipment should be provided. Air hood is currently stored in a cabinet but is not properly cleaned and stored in a plaster bag. 3. Unlabeled bottles of liquids and solids sitting in the area. 4. Dust collector catch pan needs to be installed like SFA design. Pan currently has trash, rags, etc. inside. During the survey, I also noticed two disposable air suits on the floor in the Butanol TPP mix area. As we previously discussed I am in favor of substituting these suits for current protective equipment providing the suits are disposed of properly after each use and SOP's are updated to reflect their use. I am apposed to reusing the suits in TPP service for hygiene and health reasons. Attached are unit and plant SOP's/AP's pertaining to TPP mixing and respiratory 005043 Page 2 protection. I have highlighted the areas which I feel need attention to get into compliance. If you have any questions regarding my recommendations call me at Ext. 4077. CWW/dj U) L C. VI. Whalev 005044 * -'jrc TJ;JC C~r :r *.T'T'7 ZD THE SAFETY SUPEF'.'l SZF, IDD'JSTF.IAL 1ST, ADD CD:;IDG S'JFEF.IDTEDDEDT INVOLVED SOP for Disposal of Empty TPP Fiberpacs, Fiberpac Liners, and Disposable Protective Clothing______ Triphenylphosphine (TPP), a catalyst used in the Oxo-BuOH reactor system, is received in 50 pound fiberpacs and =3 fiberpacs of TPP are added to the reaction system once each veek. Since animal tests indi cate that TPP is a potential nerve toxin, special precautions must be taken in the handling and disposal of this material. The following procedures will be used for TPP fiberpac, fiberpac liners, and disposable protective clothing disposal. 1. After the TPP is dumped into the catalyst addition system, the fiberpac1s polyethylene liners will be secured with rubber bands. (The operator will insure that all the TPP, except for thin film of TPP powder left on the liner, is emptied from the fiberpac.) The liners should be pulled from the fiberpacs and placed in a seoarate fiberpac. 1 The disposable protective clothing will be placed in the fiberpac with the liners. 3. The lids should be secured and the empty fiberpacs placed in the special temporary' storage container placed near the base of the TPP addition system structure. 4. At least once each week. Maintenance will insure that the empty fiberpacs and used protective clothing are picked up and burned in the solid waste incinerator. The personnel picking up the empty fiberpacs should wear gloves. 5. The polyethylene liners will not be burned in the solid waste in cinerators, since burning significant quantities of TPP could re sult in smoking of the solid waste incinerator and in possibly emitting toxic fumes from the incinerator. When the container for the liners becomes full, the Shipping Supervisor should be notified and he will arrange to pick up. The liners will be temporarily stored in the chemical warehouse, along with any off-soec TPP, until off-site disposal can be arranged by the Environmental Maintenance Section. 6. For the same reason as mentioned in No. 5, no off-spec or any bulk TF? powder should be burned in the solid waste incinerator. For off-test or any bulk TPP powder needing disposal, contact the Environmental Section and they will arrange for off-plant disposal at a registered commercial solid waste disposal site. 005045 TPP Mixing Unit 100 ( Safety Notes TPP is known to be toxic and can therefore be detrimental to the health of unit personnel if proper handling precautions are not used. . Protective wearing apparel must be worn at all times while handling TPP. Protective clothing is to be used only one time and disposed of in the prescribed manner. 2. Fresh air hoods will be worn during TPP mixing. Bottled breathing air and fresh air hoods are provided and must be in use before opening TPP containers. 3. A drum lift has been provided for dumping the 220 lb. size drums. 50 lb. drums require two people to dump. 4. The dust collection system must be in service while TPP is being added to the mix tank. I. Objective To maintain a charge of TPP solution to be added to the 0X0 BuH Reactor (R-38) as needed. Sample analysis of R-38 material will determine the frequency of addition and TPP concentration required in each mix. II. Standard Operating Procedure 1. Fill V-916 to prescribed level with crude BuH from V-829 or T-4 overhead. It is desirable to use V-829 material since its tem perature will be lower, and therefore less vapor will be present prior to actual mixing. BUH vapors have a detrimental effect on the TPP dust filters, making them less effective. 2. Check V-916 for a positive nitrogen pressure to prevent oxygen contamination of V-916. Oxygen will result in TPP0 formation. 3. Start mixer (M-1320). 4. Strap TPP container in drum lift and lift into position. 5. Don protective equipment and clothing before opening TPP container. 6. Start up the dust filtering system and check for proper operation. 7. Dump prescribed lbs. of TPP into V-916. 8. Immediately following the last container being dumped, close the filtering system doors and shut down the fan. This will prevent BuH vapors from being pulled through the filters and damaging fil ter elements. ANY CHANCES TO THIS SOP MUST BE APPROVED BY THE SAFETY SUPERVISOR, INDUSTRIAL HYGIENIST. AND OWNING SUPERINTENDENT INVOLVED 005046 TPP Mixing, Unit j f Page 2 ^ g. Immediately after shutdown of the dust removal, system, operate the "kick bars" on the side of the filter case several times. This will prevent BuH vapors from dissolving TPP dust and resulting in filter inefficiency or plugging. After operating kick bars, dump the filtered TPP into the provided container. Dump collected 1PP dust into one ot the plastic liners from TPP drums and store in provided container. 11. Collect any spilled TPP from the floor and put in plastic bag de scribed in item #10. 12. When items 1 through 11 have been completed, protective clothing and fresh air hoods may be removed. a. Clean fresh air hoods with .soap,and water and store in their proper containers, (include air noses) Used protective clothing must be stored in the provided con tainer. (Located northwest corner of unit 100 mix building) 13. Heat material (TPP/BuH) in V-916 to 110F, using V-916 heater (HE-881), while continuing to agitate with mixer (M-1320). 14. Add TPP solution to R-38 per unit supervisor's instructions. 005047 BAY CITY PLANT Section VIII Bay City No. 32 Date: 12/17/80 ADMINISTRATIVE PROCEDURES SAFETY Respiratory Protection Program Pace 1 of 8 PURPOSE: This Respiratory Protection Program establishes requirements for the selection, use, inspection and maintenance of respiratory equipment within the confines of the Bay City Plant of Celanese Chemical Company, Inc. The respiratory equipment shall be used for safeguarding employees against airborne contaminants and oxygen deficient work atmospheres. This program does not apply to mine and tunnel rescue work or protection against airborne radiation. The Bay City Plant Respiratory Protection Program incorporates provisions of the General Industry Standards, 29 CFR 1910.134 (OSHA), Respiratory Protection and ANSI Z 88.2 - 1969 of American National Standard Practices for Respiratory Protection. PROCEDURES: I. Bay City Plant Management assumes the responsibility for the imple mentation and maintenance of the Respiratory Protection Program. Each employee has the responsibility to know and adhere to this policy. II. The Respiratory Protection Program shall be administered by the Respiratory Protection Program Administrator from within the Plant Safety Section. III. Facial hair and other facial features must not interfere with the facepiece-to-face seal of a respirator if plant activities may require that face-fit type respirators be worn during normal or abnormal conditions. IV. Responsibilities A. Owning Supervisor . Shall procure, use, inspect and maintain respiratory pro tection equipment in accordance witn requirements ot uns program. The Plant Industrial Hygienist and kespiratory Protection Program Administrator shall determine the proper respirator selection. 005048 bay city ADMIT; 1ST?.AT IVE PROCEDURES P = o2 2 of 8 Section VIII SAFETY Bay City Mo. 32 Date: 12/17/80 Respiratory Protection Program 2. Shall ensure that inspection records are sent to Respiratory Protection Program Administrator for retention. 3. Shall ensure that a sufficient supply of approved respiratory protection equipment, for contaminants likely to be encountered in everyday work practices or in emergency situations, is provided and readily available. 4. Shall ensure that respirators are worn by the employees when required. 5. Shall ensure that each employee who may be required to wear a respirator receive appropriate respirator training pro vided by the Bay City Plant Safety Section. Employee 1. Each employee shall use, inspect, clean, and maintain his/her /respiratory protective equipment as instructed by his/her supervisor. C. Purchasing Section 1. Shall purchase only respirators that bear the approval of the National Institute for Occupational Safety and Health (NIOSH) and approved by the Plant Industrial Hygienist and the Respiratory Protection Program Administrator. 1: Shall require vendors that supply breathing-air cylinders and breathing-air compressors to the Bay City Plant comply with specifications for Grade "D" breathing-air as des cribed in the Compressed Gas Association's, Commodity Specification for Air, Pamphlet G-7.1, ANSI Z 86.1 - 1973. D. Safety Section 1. Shall screen employees and prospective employees who must wear respirators for physical impairments or complications which may cause difficulty in performing job functions safely. Refer to Health Monitoring Program. 005049 SAY CITY PL.-M_________________ ADMINISTRATIVE PROCEDURES Section VIII SAFETY Bay City No - 32 Date: 12/17/80 Respiratory Protection Proaram Pane- 3 of 8 2. Shall provide initial and recurring training courses in Respiratory Protection for all employees that may be required to wear respirators. 3. Shall be responsible for administration of Respiratory Protection Program. Plant Industrial Hygienist The Plant Industrial Hygienist shall periodically monitor employee exposure to airborne contaminants. Monitoring shall also be conducted following new unit start-ups or process modifications which could result in new hazards. The Plant Industrial Hygienist shall be consulted for assistance in selecting appropriate respiratory protection equipment. ^3. Any changes to the Respiratory Protection Program (i.e.t Administrative Procedure and V.U.P.) shall be approved by the Plant Industrial Hygienist. V. A Maintenance Program shall be contracted to perform A. Cleaning and Disinfecting of respirators in wash water with temperature of 120-140 B. Drying C. Inspection and Repair after laundering with NIOSH approved repair parts D. Leak checked E. Individually bagged VI. Ambient Hazards (Defined) A. Excessive contaminants, including gases, vapors, dusts, fumes, and mists 005050 BAY CITY' -LANi ADI! I i ISTRAT IVE PROCEDURES Pace 4 of 8 Section VIII SAFETY Bay City No. 32 Date: 12/17/80 Respiratory Protection Program B. Oxygen deficient work atmosphere C. Combination of excessive conta linants and oxygen deficiency VII. Control Measures The primary objective shall be to control Ambient Hazards by accepted engineering controls such as confinement of the operation and local exhaust ventilation. Alternate controls may include administrative changes or the substitution of less toxic materials or approved respiratory protection. Respiratory protection shall not be used as a substitute if engineering or administrative con trols are feasible and practical, except as an interim measure. RESPIRATORY PROTECTION PROGRAM: The following requirements are necessary considerations in a Respira tory Protection Program. Standard Operating Procedures (S.O.P.) will be based upon the following data: I. Selection and Procurement A. Selection shall be based upon 1. Oxygen deficient work atmosphere 2. Ambient concentration, toxicity, reactivity and irritancy of contaminants 3. Work requirements and conditions 4. Characteristics and limitations of approved respirators 5. Wearer comfort and acceptance B. Respirator shall be NIOSH approved. C. The Plant Industrial Hygienist shall determine type of respirator to be used based upon contaminant and exposure potential based on contaminant monitoring data. 005051 BAY CITY PLANT Section VIII Bay City No. 32 Date: 12/17/80 ADM I .NI STRATI VE PROCEDURES SAFETY Respiratory Protection Program Pace 5 of 8 II. Training and Education in Proper Use of Respirators A. Instruction in the nature of the hazard B. Explanation of why other control strategies are not feasible or practical C. A discussion of the reasons for selecting this respirator for this particular use D. A discussion of the respirators capabilities and limita tions E. Instruction and training in actual use of the respirator F. Classroom and field training to recognize and cope with emergency situations G. Special training for special use III. Inspection A. Employees assigned personal respirators shall inspect them before and after each use as instructed during training session. *'"^15. Common use respirators shall be inspected before use and .shall be cleaned after each use by the individual that has worn the respirator. C. Random inspections of personal, common use, and emergency respirators will be conducted by the Safety Section and the Plant Industrial Hygienist. D. The Owning Units will make weekly inspections on emergency, personal. and common use respirators. Records shall be Torwarded by the Owning Unit Supervisor to the Safety Section for retention. E. Routine maintenance of personal respirators such as replace ment of cartridges or filters shall be performed by the owning individual. A supply of all necessary items will be kept in stock in the Warehouse. 005052 1: i1 t S:v City Mo. 32 a:e: 12/17/SO vr . s SAFETY Respiratory Protection Procram nI c- e 6 of 3 :7. Maintenance A. Emergency respirators shall be rotated through a repair and cleaning shop on a regular basis. B. Assigned or personal respirators will be sent to a maintenance and cleaning shop on a regular basis. C. All repairs will be performed by an authorized individual or repair shop. D. All repairs must be made with NIOSH approved parts. V. Fit Testing A. An employee must take and pass a qualitative leak test per formed with the appropriate respirator(s) using irritant smoke or iso-amyl acetate while simulating body movements associated with normal work activities. The employee should be issued an identical make and model of the respirator that he/she used to pass the qualitative leak test. B. Employees required to wear face-fit type respirators will not have facial hair that would prevent the proper facepieceto-face seal of a- respirator. C. Employees who are required to wear respirators shall perform a positive or negative pressure leak test before entering a con taminated atmosphere. D. Eye glasses shall not be worn under full-face respirators except where they have been properly installed in approved adapters and do not interfere with face-to-respirator seal. Employees who need corrective lens should not wear full-face respirators with out these adapters and glasses, except during emergencies. E. Contact lens shall not be worn inside the plant except for rare instances where for medical reasons an employee cannot function with regular glasses. Permission must be obtained from the Safety Section and certain conditions must be met by employee. 005053 BAY Cl' Section VIII Bay City :io. 32 Date: 12/17/80 ad;:i!JISTRATIVE ?ROCED'JRCS SAFETY Respiratory Protection Program Pane 7 of 8 l/VI. ,, Storage ^A. Reusable personal respirators shall be stored in sealed plastic bags and protective containers after being properly cleaned and maintained. B. Respirators shall not be stored in areas of extreme tem peratures. C. Respirators should not be stored in areas where chemicals might damage or contaminate them. VII. Routine Application A. Where respirators are required for routine use they should be individually assigned. B. The atmosphere shall be monitored before entry into confined spaces or other areas which might be subject to oxygen deficiencies or excessive concentrations of toxic contaminates. VIII. Emergency Application A. Emergency Work Situations 1. Employees must wear an air-line respirator with auxiliary air tanks, or a self-contained unit, and must be equipped v/ith safety harness and lines, where an oxygen deficient work atmosphere exists. 2. An attendant shall be present and located such that he/she is not likely to be overcome by an event affecting the wearer. The attendant shall have the necessary equipment for an emergency rescue. 3. Communications shall be maintained between all parties present. B. Immediately Dangerous Atmospheres (normally work is not per formed in IDLH atmospheres; however, emergency situations arise where such entry may be required.) 005054 SAV CITY PLANT Section VIII Bay City No. 32 Oate: 12/17/80 ACr*i:iISTRATIVE PROCEDURES SAFETY Respiratory Protection Program _________ Pare 8 of 8 1. A self-contained respirator or an air-line unit with auxiliary tank must be worn where an atmosphere immedi ately dangerous to life ar.1 health (IDLH) may be expected. 2. Persons wearing air-line respirators with auxiliary tank must be equipped with safety harness and lines in atmo spheres immediately dangerous to life or health (IDLH). 3. There shall be at least two standby persons stationed outside the toxic atmosphere. They shall remain in com munication with those in the toxic atmosphere. At least one shall have the necessary self-contained breathing apparatus and equipment on hand for emergency rescue. IX. Emergency Respirators A. Adequate respiratory protection will be kept easily accessible to facilitate the safe escape of all employees from areas in which immediately dangerous to life and health (IDLH) atmo spheric contamination may occur. B. Emergency escape respirators will be of a type which is easily put on, such as an escape unit with a plastic hood. These will be kept in the immediate vicinity of work stations subject to dangerous toxic contamination. C. Respirators used for emergency re-entry will be self-contained breathing apparatus (SCBA) units required for immediately dangerous to life or health (IDLH) atmospheres. The IDLH units will be kept immediately outside areas likely to be quickly contaminated. Additional units may be kept at a central loca tion or on emergency vehicles. D. Considerations will be given during emergency planning to assure that a fully adequate supply of breathing-air tanks is available, and that adequate refilling capacity exists on plant site. 005055