Document k6Rrv4Z3nmQ4Yr0qwZBZO9b5O

EXXON COMPANY, U.S.A. DEVELOPMENT OF REFINERY AND PLANT ASBESTOS CONTROL PROGRAMS OCTOBER, 1974 18-0000788 The Occupational Safety and Health Administration COSHA) established a permanent asbestos standard in July, 1972. Attached is correspondence outlining Exxon Company's development of an asbestos control program which preceded the standard, but has been modified to comply with OSHA requirements. No. 1 No. 2 No. 3 No. 4 No. 5 No. 6 2/16/72 3/28/72 9/25/72 10/16/72 11/1/72 1/15/73 EXHIBITS Letter - Mr. E. L. Burkett, Baytown Refinery Recommends the Refinery discontinue use of insulation which contains asbestos Baytown Engineering Standards, Letter No. 72-5 Baytown Engineering Standards revised to eliminate use of insulation materials con taining asbestos Headquarters Manual, Asbestos Handling Guide lines for Humble-Enjay Distributed to the field by Headquarters Industrial Hygiene Humble-Enjay Safety Regulations, No. 1, Baytown Guidelines for Handling Asbestos Minutes of OSHA Steering Committee, Baton Rouge Action taken to eliminate purchase of insulation containing asbestos Letter - Headquarters Industrial Hygiene to Headquarters Refining Advises on status of asbestos control programs at refineries. Also advises on need for Headquarters Refining management to emphasize importance of asbestos control program. JNH:cjw October 31, 1974 -l3-0Q007q9 C0220.) ijxhiDrt too. 1 . HUMBLE OIL 8: REFINING COMPANY BAYTOWN, TEXAS 77520 KtFININC DtrSTMENT ATTOWN KtUNMr ' . t. PYH WHICH. * February 16, 1972 po*t orricc vox sso FEDERAL EXPOSURE LIMITS OF ASBESTOS-INSULATION MATERIALS Mr. V. H. Schweitzer The Refinery Hygienist, Hr, W. R. Meyer, has informed -e the Labor Department's e-emeucy standares esrablis'ning oersonnel. exposure Units to asbestos dust and fibers. Attached are three notegrams from Mr. Meyer dated January 5, January 19, and February 1, 1972, giving more detailed information. Because asbestos is used in many insulation materials, this is an area of concern and one in which I have an interest as author of the Baytown Engineering Standards (BTESs) covering insulation. To date, I have reviewed the ETESs, the Refinery needs and prac tices, and available insulation materials. From this, I recomend that the' Rj.i.ne.ry., jislr.g Lr.su.lat:an, A-ghpctns-.frnp rprja 1 s are available at no higher c^sr. Tf thp fnllnvring steps are c.-^xyier? out f.. the_esposur.e of personnel to asbestos when install ing new materials will be eJJ^i.nated. 1. Mechanical Engineering Department o Remove from the BTESs those materials that contain asbestos. (Note: I am in the process of revising these standards. o Instruct design personnel to specify asbestos-free materials for special jobs if standard materials are not satisfactory. 2. Maintenance and Construction Division' o Order only those materials specified in the BTESs unless an ' asbestds-free material is specified for a special application. 3. Materials Department o Question the purchase requisitions for insulation materials that contain asbestos. Special effort will be required by each division to break old habits. This is evidenced by the fact that 35,700 pounds of an asbestos ' 13-0000790 / 002210 JPR - 2 WKC containing felt (equal to Johns-Manville's Firetard) was purchased in 1971 on a blanket order and installed in the Refinery even though it was removed from the BTESs approximately eight years ago. This probably resulted from replacing insulating materials in kind. The remaining questionable areas, though minor, are the reuse of existing pipe and block insulation and demolishing insulation systems that contain asbestos. Mr. Meyer plans to do some additional work to establish the severity of exposure for each operation; for example, handling, sawing, cutting, demolishing, and the need, if any, for equipment and procedures to meet safe levels and Labor Department standards. E. L. Burkett f / 18-0000791 p n oo i ; vJ -- J- i HUMBLE wAYHTuOfWtcNruKAtirNiNCCKdYivi.ion i cj.'iiu1 jiu . i. OIL S:' REFINING COMPANY BAYTOVN, TEXAS 77520 1 March 28, 1972 . ornci aso II BAYTOWN ENGINEERING STANDARDS I < To All Recipients of Baytown Engineering Standards The following changes will bring your Baytown Engineering Manual up to date. Insert the attached standards and remove all pages of the superseded issues. INSERT IN MANUAL Standard No. Revision Oate BTES 2-52-1.1A BTES 2-52-1.ID BTES 14-1-2.1C BTES 14-1-2.5C BTES 14-2-50.IB BTAD 16-12-1 BP 16-12-1 BTES 19-1-1.1C 1 3-72 2 3-72 1 3-72 - 1 3-72 . 1 3-72 1 3-72 3 6-70 1 3-72 REMOVE AND DISCARD Standard No. Revision Date BTES 2-52-1,1A BTES 2-52-1.ID BTES 14-1-2.1C BTES 14-1-2.5C BTES 14-2-50.IB BTAD 16-12-1 BP 16-12-1 BTES 19-1-1.1C 0 1 * 3 n-70 5-71 1-71 2-71 3-71 12-70 6-70 5-70 GENERAL NOTES BTES 2-52-1.1A - Figure 2 has been revised to require safety signs on tanks "containing volatile hydrocarbons or tanks equipped with nitrogen or natural gas blanket systems. BTES 2-52-1.ID - Several new safety signs were added. BIESJ4-1.-2JC^BTES 14-1-2.5C, and BTES 14-2-50.IB - These standards were revised_ rn p! infnatg-.insula^ioji'tpg~teria 1 s containing' asFestn?.___Lp_ugn.t . Qf'lhn haw-rSHpral.^rply rnnr.prn'ir.'g.lppr^'nnne-l pxpasurp t.n asbestos, -there i<: nnf suffir-'pnt. prnnnnir ir.rpntii'f'--fnr pnrrhasing ins.nlafinri .,3iAlP- rials containing asbestos. BTAD 16-12-1 - Paragraph 9.1 of this standard was deleted to reflect accep tance *oF~Paragraph 9.1 of the Basic Practice. BTES 19-1-1.1C - This standard was revised to give material specification consistent with Managements' recent decision to paint onsite equipment blue instead cf gray. JBT:bmc 4 t 0. B. Tucker 13-0000732 oU n `0'? .JL > Tito following ore oreoi of good sofcty practice which are now covered by Federal regulations. Those not already in our Safety Procedures book will ultimately become port of our permanent safety rules. These should now be given special emphasis in our normal work practices. October 16, 1972 NO. 1 GUIDELINES FOR HANDLING AfPEETON MATERIALS ii The inhalation of asbestos dust may be injurious to the health of our employees The following guidelines should be followed to minimize this exposure when asbestos materials have to be handled. Some examples of exposure are: . Installation of asbestos insulation.* . Hand sawing or cutting asbestos insulation.*"* . Removal (rip-off) of asbestos insulation.** . Cleanup operations involving asbestos materials. . Sawing or cutting cement asbestos materials (Transite, Marinitc, etc.). The procedures to bo followed when handling materials that contain asbestos are: I 1. Install signs to show- asbestos dust may be present, (jobs of significant size and duration only.) These signs can be obtained from Mo. 1 tool room. 2. Schedule work to minimize number of people in area. All personnel whose presence is not required shall be restricted from the immediate area unless they arc protected with approved <inol-uce respirators. 3. All personnel working in the area shall wear approved single-use respirators (Symbol Ho. 77700-090). These respirators shall be discarded at the end of the day or at the end of the job, whichever is the shorter period. | If. Employee should a3 far as practicable stand upwind from source of asbestos dust to minimize accumulation of dust on clothing. 5. Remove fibers and dust from clothing using a vacuum cleaner before removing respirators. Change coveralls as necessary. 6. Perform work in such a manner as to minimize exposure. (a) Installation work " 13-0000793 1) Precut and score asbestos, whenever possible, using bond saw with C02212 duct collector. When poonible this should be done at a location remote from other work. . 2) Pick up broken insulation and scraps immediately and place in plastic bags. Dampen asbestos to minimize generation of dust. (b) Removal of asbestos 1) Clip wiring on bands bolding jacket. 2) Remove jacket. 3) Remove insulation in pieces as large as practical. Cut or break carefully to minimize dusting. When practical dampen insulation to reduce dusting. U) Place all material in plastic bags (Stores Symbol I.'o. 18103-003) for disposal. Where practical place drop cloths under work area to retain broken materials (i.e., on tower platforms, etc., where material otherwise could be spread over several levels). 5) Area should be cleaned up prior to .lunch break and at end of shift. Dampen asbestos to minimize generation of dust. (c) When insulation materials are removed to do mechanical work and are replaced at end of job, ure asbestos-free materials for the replace ment . (d) Do net spray asbestos materials.' Do not use materials containinn asbestos if sul "prestos-free materials arc available. The Baytown Refinery engineering specifications and purchase specifications have been changed to specify materials that are "asbestos-free." If a nonstandard material is required for a special job, asbestos-free material should be specified on the requisition. All insulation supplied as kits such as L'xomet should be assumed to be asbestos unless the kit is labeled asbestos-free. All existing high-temperature insulation should be assumed to be asbestos or to contain asbestos as a binder. o,]92U \J 13-0000794 CAiilOi-t 3 MINUTES OF OSHA STIT.KTNC COMMITTEE HCETINO WO. 36 November 1. 1972 - Baton Rouge F. S. Venable covered our current position on dealing with hazardous materials. . * -Both Humble and Enjny Mechanical Divisions will instigate further action to reemphasize the problem of handling asbestos containing materials. Technical will contact Purchasing to get a positive statement in all con tract r which will p-ohibit the use of high asbestos coi-tcnt materials. * F. S. Venable will begin working with Mechanical to develop noire level data for certain tools. The Committee began selecting items to be part of the sixth Humble - Enjay Safety Regulations Bulletin. 1. No loose combustible material, empty or full drums or barrels, shall be permitted within the diked area of a tank while it is in service. 2. Machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by the moving point of operation, nip points, flying chips and sperks.' The remaining items needed to complete the 6ixth bulletin will be chosen at the next OSHA Steering Committee meeting. RRDomier,Jr. :msn November 15, 1972 C0-221o ,8-0000^ January 15, ;1D73 C. B. Moore Hq. Refining Rood 3621 Rat Refinery Programs for Handling-Asbestos . Charles; In reply to your recent question. Attached is a safe handling guide sheot from Baton Rouge Refinery. The Baytown program was given as a model in the asbestos guide, navwnv has a similar program, Billings and Benicia have less formalized programs and seem to depend more on Contractors to follow safe practices. Bayway, Baton Rouge and Baytown supervise the Asbestos practices through the OSIIA Steering Committees. Their chief concerns are that Exxon employees follow the regulations whilo doing small Jobs in the units. These Jobs night be done by insulators, mechanics, laborers and/or operators. The big jobs are generally done by Contractors. Housekeeping and disposal of the scraps are practices needing close supervision. Theso refineries have been held back in the substitution of all non-asl>cGtos insulation by not having available unlimited amounts of suitable replacements. As sho-.vn by the attached Johtin-Manvlllo Company's technical sheet, this situation is improving.' ' Although each location in the past has been following its own standard, the- three large refineries have had the same basic policies. If cither Billing or Benicia have established a safe asbestos policy we have not seen it. IJJQJSojtlning^aancncjii_Hre_JtQ^raphR8izcL-thQ_ImpDrAn^ oX^iiQiiY.l3^j^iialplDg^hcir-j^XPxg-^-9_PRti_lbpn_Qj fpxc.ing_t.fip BQL_jrcgulatarx_pxiiciices, this would assura-ihgxP-Should. bo. no citation from violations. JWII/ra Attachment* James W. Hammond 13-0000736