Document mLY1aMOkwV9yy5Nz2zVG7qX4

ij1 .. ....." "TM" ..... ENVIRONMENTAL SURVEY CAP CO Ragland Plant ! February 4-5, 1976 t i ...................... . ............................. -- * A i 1 i J { ASARCO ALV 0000407 ENVIRONMENTAL SURVEY CAP CO Ragland Plant February 4-5, 1976 Prepared by: J. P. Sieverson Environmental Specialist Department of Environmental Sciences ASARCO Incorporated Salt Lake City, Utah Report Date: May 11, 1976 Distributions JRCarpenter AEAlpine MJMessel DHSoutar KWNelson AJGillespie,Jr./JPStetson RCBeckstead EHHaug/WTSweat Dr.CHHine MOVarner J ASARCO ALV 0000408 Environmental Survey CAPCO Ragland Plant February 2-4, 1976 TABLE OF CONTENTS Page Executive Summary ..................................... .......................... I. Operating Conditions ........................................ II. Sampling Procedures .............................................. III. Sample Results A. Air 1. Asbestos Samples a. Employees ..................................... b. Stationary Samples .... 2. Dust and Fume Samples .... 3. Ventilation Measurements ... B. Noise 1. Sound Level Measurements ... 2. Personal Noise Exposures ... IV. Comments............................................................ 9 V. Recommendations .......................................................... VI. Summary of OSHA Requirements for an Acceptable Respirator Program ..................... VII. Photographs....................................................... 15 ii 1 1 2 4 4 5 5 6 12 14 -i- J ASARCO ALV 0000409 -11 Environmental Survey CAP CO Ragland Plant February 4-5, 1976 EXECUTIVE SUMMARY A new ventilation system was installed since the last environmental survey. Most employee exposures have been significantly reduced and housekeeping has improved. How ever, the air samples show that the batch mixing operator is exposed to asbestos concentrations exceeding the current OSHA ceiling concentration (which is never to be exceeded). Ventilation must be improved in this area. Total particu late concentrations exceed the OSHA standard around the pipe machine shot blaster. Plans to enclose and ventilate this area should be made. The employee working around the baghouse and scrap grinder is exposed to asbestos concentrations exceeding the future OSHA 8-hour TWA of 2.0 fibers/cc. A major process change is recommended. From an indus trial hygiene standpoint, the wet mill should be replaced with a dry mill. Extensive noise measurements show that many employees are exposed to excessive sound levels. A more extensive study of employee noise exposures and related noise sources by D.O.E.S. and/or a noise consultant is needed. The Ragland Plant should have a full-time safety man. The existing solid waste dump should be converted to a solitary-landfill operation. Scavenging by local residents should be stopped with appropriate fencing and posting. Records and file material for a number of environmental topics are requested. J ASARCO ALV 0000410 ENVIRONMENTAL SURVEY REPORT CAPCO. Ragland Plant February 4-5, 1976 I. OPERATING CONDITIONS Operating conditions were normal during the survey. This is the first survey since installation of an entirely new ventilation system. II. SAMPLING PROCEDURES A. Air: 1. Individual samples for asbestos fiber analysis were collected with M.S.A. personal monitoring pumps? equipped with open-face Millipore filters (0.8 micron pore size). The asbestos fibers were counted using a Zeiss phase-contrast microscope, according to methods specified in the NIOSH criteria document. 2. Individual samples for dust and fume analysis were collected with M.S.A. personal monitoring devices equipped with closed-face (plastic cover in place and inlet plug removed) Millipore filters (0.8 micron pore size), and analyzed for lead, cadmium, and iron by atomic absorption spectrophotometry. Total particulate.content was found by weighing filters before and after exposure. Free silica was determined by using the modified Talvitie method, as recommended by NIOSH. 3. Ventilation measurements were made with an Alnor Velometer, Series 6000-P. B. Noise: 1. Sound level measurements were taken with a BeoC 2205 Sound Level Meter using the "A" scale and "slow" response setting. The meter was calibrated with a standard noise source before and after each set of measurements. J ASARCO ALV 0000411 -2- 2. Personal noise exposure data were collected using DuPont Permissible Audio Dosimeters, Model D-100, which measure noise exposures in terms of the present 90 dBA OSHA standard. A DuPont Audio Dosimeter Readout (Model R150) was utilized to decode each dosimeter memory cell and produce a reading as a percentage of the current 90 dBA standard. The calibration of each dosimeter was checked daily using a DuPont Audio Dosimeter Calibrator. III. A. Air: 1. Asbestos Samples a. Employees Department Kollergang Wet Mill Employee Name J.Jones (resp.worn when charging) Job or Operation Batch Mixer 1976 Date 3/4 3/5 Sampling Time (Min.) 25 69 Asbestos Concentration (fibers >5y long per cc air) 14. (1) 2.6 (2) J.Looney Batch Mixer 3/4 83 (resp.worn when charging) 8. Pipe Machine J.Noah (no resp.worn) Machine Tender 3/4 78 0.3 J.Woods (no resp.worn) Tray Loader 3/5 65 0.1 C.Byers (no resp.worn) Tray Unloading 3/4 105 0.2 Pipe Finishing Line A.Gray (no resp.worn) B.St.John (no resp.worn) Pipe Lathe Operator Hydrotester 3/4 104 3/4 101 1.2 <3) 0.03 C.Johnson Flextester 3/4 99 (no resp.worn) (used hand- grinder on 2-3 pipes) 0.4 M.Bunt (no resp.worn) Load Unitizing 3/4 74 0.3 ! ASARCO ALV 0000412 1. Asbestos Samples - Employees (cont.) Department Lathes Saw Scrap Grinding Employee Name J.Nix (no resp.worn) H.Phillips (no resp.worn) A. Kay (no resp.worn) W.Nobles (no resp.worn) C.Wolfe (resp.worn) G.Bollinger (resp.worn) T.L. Davis (resp.worn) Job or Operation M0A Lathe 1976 Date 3/4 M0A Lathe 3/4 Coupling Cut-off 3/4 Large Coupling Lathe 3/4 Cut-off Saw Operator 3/4 Cut-off saw Helper 3/4 Scrap Grinder 3/4 3/5 Samp ling Time (Min.) 98 91 100 100 89 85 30 74 -3- Asbestos Concentration (fibers >5y long per cc air) 0.08 0.07 - 0.2 0.08 0.7 1(32) 0.3 2.0 t3) 2.7 <25 Footnotes: (1) Exceeds current OSHA standard for asbestos: 8-hour Time-Weighted Average (TWA) -- 5 fibers/cc air Ceiling Concentration = 10 fibers/cc air (2) Exceeds future OSHA standard for asbestos (effective July 1, 1976): 8-hour TWA Ceiling Con'n. = 2.0 fibers/cc = 10 fibers/cc (3) Exceeds proposed OSHA standard for asbestos: 8-hour TWA Ceiling Conc'n. = 0.5 fibers/cc = 5.0 fibers/cc J ASARCO ALV 0000413 1. Asbestos Samples (cont.) b. Stationary Samples Location_________________ fjh - middle of bench Foremens' Office Main Office 1976 Date 3/5 3/5 3/5 Sampling Time (Min.) 254 225 710 -4- Asbestos Concentration (fibers > 5 M long per cc air) 0.03 0.09 None Found 2. Dust and Fume Samples - Employees Employee Name Job or Operation 1976 Date Samp ling Time (Min.) Analysis Cone'n. (mg/m3) W.Mostella (resp.worn) Pipe Machine Shot Blaster 3/4 71 Iron Oxides Total Part. 4.8 10. n Free Silica = 1.9% OSHA DUST LIMIT = 7.6 (based on free silica content) V.Baffron Welder 3/5 223 Iron Oxides (no resp.worn) (mild steel) Total Part. 0.7 2.5 Lead < 0.02 Cadmium < 0.004 Footnote: * (1) Exceeds OSHA 8-hour time-weighted average exposure. OSHA LIMIT: Total Particulate (no free silica content) = 15.0 mg/m3 Total Particulate (based on free silica content) = 30 mg/m3 Iron Oxide Fume = 10 mg/m3 % Si02+z ' Lead = 0.20 mg/m3 Cadmium (fume) = 0.10 mg/m3 ASARCO ALV 0000414. Ventilation Measurements Location Batch Mixing - charging hood Pipe Finishing Lathe - hood on hydro- testing side - top hood on flex testing side - bottom pick-up on flex testing side Cut-off Saw - operator's inspection port - side opening Average Face Velocity (feet per minute) <50 400-600 400 200 400 250 Noise Measurements: 1. Sound Level Measurements Area Location Pipe Machine Stripping operator's position Opposite stripping position - with compressed air venting Pipe Finishing Line Finishing lathe - lathe off - lathe on Flextesting area - lathe off - lathe on Sound Level (dBA) 88 OSHA Permissible Noise Exposure Duration per Day (Hrs./Min.) 8/0 86 8/0 92-94 6/0-4/36 88 8/0 96 3/30 89 8/0 96 3/30 ASARCO ALV 00004-15 1. Sound Level Measurements (cont.) Area______ Location Sound Level (dBA) Lathes Large coupling lathe - lathe off - lathe on 88-92 94-98 Small coupling lathe - lathe off - lathe on 90 98-103 Baghouse Area In driveway Near screw conveyor 90 98-100 Saws Wood saw - operating but not cutting - cutting 95 99-102 Mobile Equipment Erickson autoclave charger - idle ` - accelerated in neutral 74 92-96 -6- OSHA Permissible Noise Exposure Duration per Day (Hrs./Min.) 8/0-6/0 4/36-2/40' 8/0 2/40-1/20 8/0 2/40-2/0 4/0 2/18-1/30 8/0 6/0-3/30 2. Personal Noise Exoosures Employee Name Job 1976 Date Samp ling Time (Min.) (2) 8-Hour Dosimeter^ Adjusted Readout Readout (% exposure' (% exposure) Sound*35 Level Exceeded 115 dBA? J.Jones Batch Mixer 3/4 213 112 252 (4) Yes J.Looney Batch Mixer 3/5 260 3/5 372 121 16 223 (4} 2i (6) Yes No L.Tramell Kollander 3/5 258 45 84<5) Yes G.Ford Machine Tender 3/4 212 52 118(5) No' ` 3/5 261 90 166(1> Yes J ASARCO ALV 0000416 -7 2. Personal Noise Exposures (cont.) Employee Name Job 1976 Date Samp ling Time (Min.) Dosimeter^ Readout (% exposure) 8-Hour{2) Adjusted Readout (% exposure) Sound(35 Level Exceeded 115 dBA? J.Noah Machine Tender 3/4 350 144 197(4) Yes N.Edge Tray Loader Helper 3/5 258 37 69 No J.R.Davis J.Bagwell H.Woods A.Gray Tray Loader Helper 3/5 255 Stripper Operator 3/4 197 Pipe Finishing 3/4 Lathe Operator 203 Pipe Finishing 3/4 Lathe Operator 344 24 59 70 146 45 144 (4) 166<4> 204 (4} No Yes Yes Yes J.Nix MOA Lathe 3/4 366 65 85 Yes H.Phillips MOA Lathe 3/4 363 27 36 No W. Echols B.Kay H.O'Donnell Large Coupling 3/4 Lathe Small Coupling 3/4 Lathe Cut-off Saw Operator 3/4 230 225 216 36 62 63 75 132 (5) 140(4) No Yes Yes C.Wolfe D "ay J *.Davis Cut-off Saw Operator 3/4 345 Wood Saw Operator 3/5 237 Scrap Grinder 3/4 215 45 73(7) 16 ^ 63 Yes 148{4,7> Yes 36<5> No 3/5 269 71 127(5J No C.Foreman Driver of Erickson Auto clave Charger 3/4 369 55 72 No J.St.John Hyster Driver 3/4 Finishing Line 368 28 37 No ] ASARCO ALV 0000417 -8 Footnotes for Personal Noise Exposures: (1) Readout based on elapsed sampling time. (2) The 8-hour adjusted readout is an extrapolation of the original dosimeter reading. This extrapolation assumes that the employee will be exposed to the same noise level during the remainder of the shift when the dosimeter is not worn. (3) The OSHA noise standard does not allow employees to be exposed to sound levels greater than 115 dBA. However, experience to date shows that most dosimeter measurements greater than 115 dBA are the result of employee mischief, i.e. shouting into the microphone of the dosimeter. Therefore, these data must be interpreted cautiously. (4) Dosimeter readouts greater than 100% indicate a violation', of the OSHA noise standard. However, the accuracy of the dosimeters (as specified by A.N.S.I. SI.4 - 1971) is 2 dBA which translates to an upper confidence limit of 133%. Therefore, only readings greater than 133% are a positive violation of the OSHA noise standard. (5) Readings from 75% - 133% fall within the dosimeter calibration limits and may be violations of the OSHA standard. (6) . These sartples were taken with a dosimeter that malfunctioned and was repaired at a later date. Thus, the reported readout value is probably erroneous. (7) The DuPont Model R150 Readout Unit malfunctioned when processing this result. Therefore, the reported value may be lower than the actual value. J ASARCO ALV 0000418 -9- IV. COMMENTS A. OSHA: 1. Asbestos The plant operated sporadically in 1975, but an entirely new ventilation system was installed. The new system consists of two baghouses operating in parallel. The capacity is 26,000 acfm at 17" H2O pressure drop with an approximate air-to-cloth ratio of 2:1. Since the last environmental survey (November 1974), most employee exposures have been significantly reduced following installation of the new ventilation system. . The new ventilation system did not include the batch mixing area. Therefore, the asbestos exposures have not been changed and the batch mixers still receive exposures in excess of the OSHA ceiling concentration (10 fibers/cc), which is "never to be exceeded." The air velocity measurements show that the fan for the hood over the bag breaking area is ineffective and should be replaced as soon as possible, or the hood should be connected to the new ventilation system. The Kollergang wet mill was observed to be quite messy, with wet asbestos covering equipment and the floor. There are plans to replace the wet mill with a dry mill such as that used at Van Buren. From an industrial hygiene' standpoint, this replacement would be desirable and should receive a high priority. The future OSHA standard of 2 fibers/cc (effective July 1, 1976) would be violated in the scrap grinding area. The scrap grinder (J.L.Davis) works around the baghouses (which is in the same area as the batch mixer). One source of exposure was observed to be fugitive emissions caused by allowing asbestos baghouse waste to drop from a screw conveyor into an open skip. The plant manager has plans to attach large plastic bags on the end of the screw conveyrr. This idea should be implemented as soon as possible. Fugitive emissions were also observed from cracks in a bin near the baghouses. The maintenance depart ment should repair these leaks. Respirator use by employees has been much improved since the last survey. The plant uses two respirators: 1. The 3-M No. 8710 Disposable 2. The Welsh No. 7170 Disposable I ASARCO ALV 00004-19 -10 A summary of OSHA requirements for an acceptable respirator program is included with this report. Plant personnel should review these requirements to assure compliance. More information is available from D.O.E.S., if needed. The installation of the new ventilation system has also enhanced housekeeping around the plant. Accumulations of asbestos fibers were markedly reduced, especially around the lathes. However, housekeeping is still sub-standard and needs further improvement. Employees still take their clothing home for laundering. An in-plant laundry should be constructed to prevent any future liability over alleged family exposures. All hand-operated or power-operated tools should be provided with local exhaust ventilation. This would primarily apply to the hand grinder used on the pipe finishing line. 2. Dust: The employee working around the pipe machine shot blaster is exposed to an excessive concentration of total particulate matter (based on the free silica content). Plans should be made to enclose and ventilate the shot blasting area, if feasible. Employees in the area should continue to wear respirators until engineering controls are installed. 3. Noise: The audio dosimeter results show that many employes are exposed to excessive sound levels, specifically: a. Batch mixer b. Pipe machine tender c. Pipe machine stripper d. Pipe lathe operator e. Small coupling lathe operator f. Cut-off saw g. Wood saw h. Scrap grinder These employees should wear hearing protection until suitable engineering controls can be evaluated and installed. Specific information about ear plugs and/or muffs is available from D.O.E.S. ! ASARCO ALV 00004-20 -11- The primary noise sources were not identified during the survey. However, the noise source around the pipe machine is probably compressed air venting. The noise source for lathe operators is probably the sound associated with cutting pipe. Engineering controls for this particular application may not be feasible. The cut-off saw and wood saw could be insulated to reduce noise levels. A more extensive study of employee noise exposures and related noise sources by D.O.E.S. and/or a noise consultant is needed. CAPCO management should consult with D.O.E.S. personnel for more specific information. The Ragland Plant owns and operates a Beltone manual audio meter and IAC Testing booth. The audiometer is calibrated annually. The noise measurements reinforce the need for pre-employment and annual audiograms for all employees at the Ragland Plant. Since Asarco acquired the CAPCO Plants, audiograms have not been reviewed regularly. This situation should be resolved by contacting the Asarco Medical Director: Dr. C. H. Hine P. 0. Box 7604 Rincon Annex San Francisco California 94120 The present location of the audiometric booth is questionable because the booth is located in the guard room where numerous trucks park or move back and forth outside. The ambient noise levels could exceed the maximum recommended ambient levels for the design of the booth. A consultant should be contacted to evaluate this situation and conduct an electric ear calibration of the booth and audiometer. Relocation of the booth to a quieter area may be necessary. 4. The Laboratory The lab still uses a kitchen-type hood mounted over the sink. This hood should be replaced with a laboratory-type hood. The Corning Atomic Absorption Instrument is still not vented. 5. Safety This plant shares a safety man with the Van Buren Plant in Arkansas. This system does not work. The Ragland Plant should employ a full-time safety man. B. Water Treatment: The plant succeeded in rebuilding its water pollution control system in the last year. All process waste water is now re circulated. J ASARCO ALV 0000421 -12- C. Solid Waste: Solid waste, such as pipe and waste asbestos, is still disposed of in a large ravine west of the plant site. This operation should be converted to a sanitary landfill. Scavenging by local residents still occurs at the dump. This area must be fenced and posted to keep out unauthorized personnel. The abandoned dumping area north of the employee parking lot still needs to be covered; and the land should be reclaimed, if at all possible. D. Records and File Information: This Department does not have a historical file of corres pondence and sampling results in relation to the environ mental regulations (air, water, solid waste, and occupa tional health) faced by the Ragland Plant. A request for this information was sent to S.D. Weaver on October 31, 1974. No information has been received to date. Records and file material for the following subjects are requested: 1. State laws and standards. 2. Correspondence from State Departments. 3. Correspondence to State Departments. 4. Correspondence from the Environmental Protection Agency. 5. Correspondence to the Environmental Protection Agency. 6. Correspondence from OSHA. 7. Correspondence to OSHA. 8. OSHA Citations. 9. Plant environmental sampling correspondence. 10. Interoffice memos per environmental subjects. 11. Miscellaneous per environmental subjects. This Department would also appreciate receiving copies of future correspondence concerning environmental topics. V. RECOMMENDATIONS A. The ventilation system for the batch mixing area must be improved to reduce asbestos fiber concentrations, which are currently in excess of the OSHA ceiling concentration. B. It would be desirable to replace the Kollergang wet mill with a dry mill, as used at Van Buren. C. Fugitive emissions around the baghouses and scrap grinding area should be eliminated, as discussed in the comments section. D. The respirator program should be reviewed to assure compliance with OSHA requirements. I ASARCO ALV 0000422 -13- E. Housekeeping has improved since 1974 but is still sub standard. More work is needed. F. An in-plant laundry should be constructed. G. The handgrinders used on the finishing line should be ventilated. H. Plans should be made to enclose and ventilate the shot blasting area, if feasible. Respirators should be worn * by employees in this area. I. Employees working in the noisy areas, as described in the comments section, should wear hearing protection until suitable engineering controls can be evaluated and installed. J. A more extensive study of employee noise exposures and related noise sources is needed. K. Employee audiograms should be reviewed regularly. The Asarco Medical Director should be contacted. L. A consultant should be contacted to evaluate the location of the audiometric testing booth and conduct an electric ear calibration of the equipment. M. The kitchen-type hood in the laboratory should be replaced. N. The Ragland Plant should employ a full-time safety man. O. The dump should be converted to a sanitary landfill. P. Scavenging in the dump must be stopped by fencing and posting the area. Q. The abandoned dumping area should be covered, and the land reclaimed, if possible. R. Historical information about environmental topics is requested. JPS/bj s Enel. James P. Sieverson Environmental Specialist ASARCO ALV 0000423 V SUMMARY OF OSHA REQUIREMENTS FOR AN ACCEPTABLE RESPIRATOR PROGRAM -14- 1. Written standard operating procedures governing the selection and use of respirators shall be established. 2. Respirators shall be selected on the basis of hazards to which the worker is exposed. 3. The user shall be instructed and trained in the proper use of respirators and their limitations. 4. Where practicable/ the respirators should be. assigned to indi vidual workers for their exclusive use. 5. Respirators shall be regularly cleaned and disinfected. ' Those issued for the exclusive use of one worker should be cleaned after each day's use, or more often if -necessary. Those used by more than one worker shall be thoroughly cleaned and disin fected after each use. 6. Respirators shall be stored in a convenient. Clean, and sanitary location. 7. Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Respirators for emergency use such as self-contained devices shall be thoroughly inspected at least once a month and after each use. 8. Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained. 9. There shall be regular inspection and evaluation to determine the continued effectiveness of the program. 10. Persons should not be assigned to tasks requiring use of respir ators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's lexical status should be reviewed periodically (for instance, annually). 11. Approved or accepted respirators shall used when they are available. The respirator furnished shall provide adequate respiratory protection against the particular hazard for which it is designed in accordance with standards established by competent authorities. FROM: CFR 1910.134 Federal Register Volume 37 No. 202 Wednesday, October 18, 1972. J ASARCO ALV 0000424. PHOTO GRAPHS -15- } Overall view of the Ragland Plant as seen from the waste disposal area. The storage bins in the background belong to an ad joining cement plant. The drag-out conveyor, part of the water pollution control system, was being repaired after freezing-up during the survey. The Ragland Plant recirculates all process waste water. iI ASARCO ALV 00004-25