Document mmpznEmNKEovDLpy4oRV8bzR4

SM-32 (REV. 5*78) Shell Oil Company Interoffice Memorandum OCTOBER 19, 1988 dte-buiA C 5 PLAINTIFF'S EXHIBIT S1I-297S FROM: STAFF INDUSTRIAL HYGIENIST, PRODUCTS HEALTH & SAFETY TO: SEE ATTACHED DISTRIBUTION LIST SUBJECT: INITIAL MONITORING REQUIRED UNDER AMENDMENT TO ASBESTOS STANDARD On September 14, 1988, OSHA amended its Asbestos standards 1910.1001 and 1926.58 to incorporate an Excursion Limit of 1.0 fiber per cubic centi meter of air (1 f/cc) as averaged over a sampling period of thirty minutes. This amendment requires initial monitoring to be completed by 12/13/88. During a teleconference call between Head Office and several locations held on October 11, 1988, it was agreed that a mechanism should be estab lished to facilitate the sharing of initial monitoring data between loca tions. A summary of the data submitted would be summarized by the end of 1988. While this data may not be readily useful to demonstrate OSHA com pliance, it will aid in assessing the need for additional monitoring and study. The purpose of this memorandum is to outline a strategy for accomplishing this initial monitoring data according to a standardized sampling protocol. All locations are requested to implement this procedure as soon as reason ably possible. Locations who depend on asbestos contractors should request that they pro vide this monitoring data to Shell for review by December 10th. Addition ally, where contractors are typically used for asbestos work, locations should verify Shell employees do not perform infrequent incidental tasks which would result in exposure to asbestos. MONITORING REQUIREMENTS AND CONSIDERATIONS OSHA Requirements 1926.58(f)(l)(iii) "Representative 30 minute short term employee exposures shall be determined on the basis of one or more samples representing 30 minute exposures associated with operations that are most likely to pro duce exposures above the excursion limit for employees in each work area." BJT8829102 ABS-060739 LAM 031315 2 An equivalent provision exists for brake repair operations under 1910.1001 (d)(2). OSHA's intent is further explained on pg. 35621 of the Summary and Explanation: "Short-term monitoring is required whenever asbestos concen tration will not be uniform throughout the workday and where high concen trations of asbestos reasonably may be expected to be released or created in excess of the EL." Recorrcnended Implementation Steps and Suggested Completion Dates 1. Each location should begin now to identify those job categories on site where exposure to asbestos could foreseeably occur, e.g. brake repair, operations performing incidental maintenance, col lection of bulk insulation samples, insulation removal or distur bance, etc. This list should not necessarily be limited to those jobs previouslymonitored. 2. By November 1st: Document these jobs and tasks on the form provided (Attachment 1). This form represents the Initial Monitoring Study Plan. The form should be used to prioritize the sampling to be done and infers the rational used in meeting the OSHA requirement. 3. No later than November 4th: Submit a copy of the study plan to P. J. Snyder who will redi stribute a copy of all of the locations' plans to the field by November 11th for information sharing purposes. This summary will represent Shells initial listing of tasks of interest. 4. By December 13th: Collect/obtain the required short term (30 min.) monitoring data for the identified tasks (where feasible and where oppor tunities exist) and document the results on the form provided (Attachment 2). An equivalent summary (or sampling forms) may be submitted instead of Attachment 2 if the required informa tion is included.A minimum of one representative sample should be collected for each task identified. Note that one or more weeks will be required for sample analysis. 5. Supplement the short term monitoring conducted with TWA moni toring collected since March 14, 1988, which reveals eight-hour exposures below .06 f/cc (equivalent to the 30 minute EL). In clude this information on Attachment 2 if a specific type of work can be identified as being included. 6. By December 16th: Head Office will provide a summary of the monitoring conducted. This summary will be used to 1) identify additional monitoring needs (throughout Shell), and 2) to assess the need for periodic monitoring. BJT8829102 ABS-060740 LAM 031316 3 Sampling Methodology and Duration of Monitoring 1. 30 minutes should be targeted as the minimum sampling duration. Tasks will frequently be much shorter or much longer than this. For tasks of interest which require a shorter period of time, leave the pump on for the entire 30 minutes. For tasks which are longer than 30 minutes, change out the cassette at 30 minutes. 2. Flow rate of 0.5-2.5 LPM. That means a maximum flow rate of 2.5 LPM for a 30 minute excursion sample which is a maximum air volume of 75 liters. Lower flow rates and volumes should be used only in heavy dust to avoid overloading the filter. If filter darkens or loose dust is seen in cassette, a second sam ple with a lower flow rate/volume should be taken. 3. Sample with a 25mm MCE filter with a conductive cowl, open face, in the breathing zone. Send 102 blank filters, with a minimum of two blanks, back to the lab with each set of samples. 4. Ship filter samples in a rigid container well packed to avoid rattling around which might dislodge fibers. Do not use packing, such as expanded polystyrene, which can develop an electrostatic charge. 5. Calibrate sampling pump before and after each use with a repre sentative filter in line. Either Jerry Ransdell or 1 may be contacted regarding this. Philip J. Snyder PJS:bjd cc: A. D. Ditmar A. Gauthreaux A. J. Landry 0. D. Long D. H. Morman W. F. Nail C. F. Phillips J. D. Ransdell J. L. Rivard BJT8829102 ABS-060741 LAM 031317 DISTRIBUTION LIST MANUFACTURING LOCATIONS ANACORTES REFINERY L.F. Kennedy F.J. King D.D.Smart BELPRE CHEMICAL PLANT D. C. Andrews M. W. Hershman DEER PARK MANUFACTURING COMPLEX W. B. Austin E. M. Hawthrone GEISMAR CHEMICAL PLANT L. M. Burright T. L. Rodeheaver MARTINEZ MANUFACTURING COMPLEX A. C. Dreier M. B. Leeds NORCO MANUFACTURING COMPLEX E. L. Martin A. K. Menard ODESSA REFINERY ' S- C. Hendricksen WILMINGTON MANUFACTURING COMPLEX S. V. Sever R. A. Turner WOOD RIVER MANUFACTURING COMPLEX W. M.Cunningham R. C. Newell PRODUCTS DISTRIBUTION LOCATIONS SEWAREN PLANT D. E. Eitel WILLBRIDGE PLANT C. Goetze BJT8829102 4 ABS-060742 LAM 031318 TASKS SELECTED FOR MONITORING Location Reporting: Date Submitted: ATTACHMENT 1 INITIAL MONITORING STUDY PLAN TYPICAL TWA ASBESTOS EXPOSURE LEVEL* O-.l . 1-.2 .2+ POTENTIAL FOR EXPOSURE ABOVE EL** HIGH LOW * Check appropriate column. ** Based on current data and knowledge. BJT8829102 ABS-060743 LAM 031319 . cn c r-- 4-> J- o QJ Q. 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