Document mxpZNwDYwv5qJqrXOXnzgX7d

Page 1 THE ROLE OF INDUSTRIAL HYGIENE AT LHC 3 Protection of the worker is the main concern when assessing the Industrial Hygiene program here at LHC 3. In order to protect the worker, recognition of potential problems and their possible solutions is required. Exposure to benzene, 1,3 butadiene, the coldness of propylene, the heat of steam, and the high noise areas are some of the potential problems which exist. LHC 3 is designed to operate under a guideline of 1 ppm benzene on a time weighted average. LHC 3 has a system of area air monitors for benzene and toluene. This system alarms whenever the benzene concentration exceeds 8 ppm. The daily monitor printouts are reviewed by the Safety Monitor and any reading of .5 ppm (STEL) is reported to the block Safety Operator and the block I. H. Contact. Data indicates that the levels of benzene exposure on a normal day to day operation schedule are well below the TLV and PEL as shown by the data collected on pages 5, 6 and 7. LHC 3 has a continuing educational program to train personnel in the latest information on hazards and their proper handling. A data base of worker exposure has been gathered by the Industrial Hygiene Contact at LHC 3. This is especially true in the benzene area due to the new Benzene Standard which went into effect on December 10, 1987. This data helps in determining the level of respiratory and other protection needed when working in a benzene area. There are twelve (12) different job assignment classifications at LHC 3. The average degree of exposure for each class and the number of persons in each class is as follows: 1. Office/Clerical (2) - Negligible 2. Extended Day Operations (5) - Moderate 3. Shift Supervisors (6) - Low 4. Operation Specialists (34) - Low 5. Senior Operation Specialists (31) - Moderate 6. Operation Technician (1) - Moderate 7. Chemists (7) - Moderate 8. Mfg. (12) - Low 9. Mfg. Mgr., Sup. Dir. (4) - Negligible 10. Material Controllers (2) - Negligible 11. Maintenance Contractors (13) - Low 12. Instrumentation (8) - Low tx Page 2 JOB CLASSIFICATION DESCRIPTIONS OFFICE/CLERICAL : The secretaries perform clerical tasks including monthly reports, scheduling of travel arrangements, typing of correspondence and all around office duties which take up 100% of their time. This time is spent in their respective offices or the PC room. Their exposure potential to plant chemicals or physical stress is negligible. EXTENDED DAY OPERATIONS: This group consists of coordinators and planners who schedule and sometimes carry out work performed in the field. The overall exposure potential is moderate. 1. Mechanical Operator - Oversees repairs of all rotating equipment. 2. Furnace Operator - Oversees scheduled maintenance of furnaces involving tube repair, brick replacement and instrumentation. 3. Utilities Operators - Oversee the periodic maintenance on safety relief devices, steam traps, refrigeration equipment and water treating equipment. 4. Job Planner - Schedules the maintenance and project jobs to be done in the field by pipefitters, welders, boilermakers, ironworkers millwrights, insulators and painters. SHIFT SUPERVISORS: They supervise the day to day operation of the plant and track the performance of the people on their shift. Seventy percent of their time is spent in their offices working on training, job planning, performance evaluation, time cards and vacation planning. The remaining time is spent in the plant. Their potential exposure to chemicals and noise is low. OPERATION SPECIALISTS: Their main duties consist of running the plant from the control panel consoles in the main control room on twelve hour shifts for three out of four weeks during a month. During one week they may be out in the plant while working an eight hour maintenance shift. Their potential exposure to chemicals and noise is low. SENIOR OPERATION SPECIALISTS: The majority of their twelve hour day is spent in the plant performing scheduled checks on equipment and making any adjustments felt necessary by the inside operation specialist. They will also prepare systems and equipment for work which will be performed by contract workers. From time to time, they will work on equipment themselves. Their potential exposure to chemicals and noise is moderate. l -41 i i i i M t 1 Page 3 OPERATION TECHNICIAN: This operator handles the tank car loading for the plant. Host of his eight hour day is spent outside and his potential exposure to chemicals and noise is moderate. CHEMISTS: Their twelve hour day is spent running samples in the lab. These are mostly water and process liquid and vapor samples. Lab hoods and localized exhaust vents are stationed throughout their work area to minimize their potential exposure to chemicals which is moderate. TECHNICAL MANUFACTURERS: The plant engineers participate in directing the operations and improvements in particular plant processes. They spent five to ten percent of their time in the plant with the remainder being spent in the control room or their offices. Their potential exposure to chemicals and noise is low. MANUFACTURING MANAGERS AND SUPERINTENDENT: This group consists of the production supervisors in each area and the plant superintendent. A large part of their time is spent dealing with the economics of supply and demand for the plant's products and feed stock. They take an adminstrative role. Their potential exposure to chemicals and noise is negligible. MATERIAL CONTROLLERS: Their time is spent in their office and warehouse area overseeing the stocking of spare parts, securing of items needed by the engineers, and day to day supplies needed to keep the plant in operation. Their potential exposure to chemicals and noise is negligible. MAINTENANCE CONTRACTORS: This group consists of welders, pipefitters, boilermakers, millwrights laborers, painters and insulators who do the majority of the manual and physical labor performed in the plant. Their potential exposure to chemicals and noise is low. INSTRUMENTATION: This group performs the installation, maintenance and modification of all instrumentation in the plant. About eighty percent of their eight hour day is spent in the plant with the remaining time spent in their shop. Their potential exposure to chemicals and noise is low DO c.:.!v ;'W ' ' Hi <r ^!! m j K riui* j. , u i', LHC 3 - Louisiana Division Page DATE 13-JAN-88 TIHE 07:43143 REPORT * 55 AX1030 (ST 1-10) TAG DATA UNITS DESCRIPTION AX 1 AX 2 0.0033 PPM 0,0081 PPM BENZENE IN CONTROL ROOM AIR TOLUENE IN CONTROL ROOM AIR AX 3 AX 4 0.0029 PPM 0.0017 PPM BENZENE IN LAB AIR TOLUENE IN LAB AIR AX 5 AX 6 0,0032 PPM 0.0058 PPM BENZENE IN COMPUTER DEV. ROOM TOLUENE IN COMPUTER DEV. ROOM AX 7 AX 8 0,0060 PPM 0.0048 PPM BENZENE AT P-18/S/P-19/S TOLUENE AT P-18'S/P-19'5 AX 9 AX 10 0,0015 PPM 0.0063 PPM BENZENE AT P-10'S TOLUENE AT P-10'S AX 11 AX 12 0.0073 PPM 0.0104 PPM BENZENE AT AH-S TOLUENE AT AH-8 AX 13 AX 14 0,0013 PPM 0.0053 PPM BENZENE AT P-23'S TOLUENE AT P-23'5 AX 15 AX 16 0.0035 PPM 0,0077 PPM BENZENE AT AH-9 TOLUENE AT AH-9 AX 17 AX 18 0,0014 PPM 0.0071 PPM BENZENE AT P-55 C/D TOLUENE AT P-55 C/D AX 19 AX 20 0,0026 PPM 0.0079 PPM BENZENE AT P-55 A/B TOLUENE AT P-55 A/B ALARMS if <ECF> REP ENTER THE REPORT NUMBER 56 ht 1 C\ . i . i * LHC 3 - Louisiana Division Page 6 DATE 13-JAN-B8 TIME 07*43:53 REPORT # 56 AX4014 (ST 1-10) TAG DATA UNITS DESCRIPTION ALARMS AX 21 AX 22 AX 23 AX 24 0.0027 PPM 0.0054 PPM 0.3219 PPM 0.1305 PPM BENZENE AT AH-15 TOLUENE AT AH-15 BENZENE AT AH-17 TOLUENE AT AH-17 AX 25 AX 26 0.0075 PPM 0.0122 PPM BENZENE AT P-521 A/B TOLUENE AT P-521 A/B AX 27 AX 28 AX 29 AX 30 0.0137 PPM 0.0025 PPM 0.0015 PPM 0.0016 PPM BENZENE AT BENZENE PROD TOLUENE AT BENZENE PROD BENZENE AT CLAY BEDS TOLUENE AT CLAY BEDS AX 31 AX 32 AX 33 AX 34 0.0162 PPM 0.0161 PPM 0.0592 PPM 0.0070 PPM BENZENE AT K-551 TOLUENE AT K-551 BENZENE AT E-536 TOLUENE AT E-536 AX 35 AX 3 6 0.0000 PPM 0.0081 PPM BENZENE AT P-510G TOLUENE AT P-51OG AX 37 AX 38 AX 39 AX 40 0.0019 PPM 0.0101 PPM 0.0000 PPM 0.0092 PPM BENZENE AT S-594 TOLUENE AT S-594 BENZENE AT P-570 TOLUENE AT P-570 3 <EGF> REP ENTER THE REPORT NUMBER i 57 H A h l>y|U iUr( LHC 3 - Louisiana Division t'age 7 BATE 13-JAN-SS AX4015 (ST 1-10) TIME 07M4:i4 REPORT * 57 TAG ' AX AX 41 42 * AX AX 43 44 AX 45 AX 46 : ax AX 47 43 AX AX 49 50 AX 51 AX 52 ' AX AX 53 54 ' AX AX 55 56 AX 57 AX 58 ` AX AX 59 60 data units description 0.0453 PPH 0.1593 PPM BENZENE AT P-501 A/B TOLUENE AT P-501 A/B 0.0634 PPM 0.1381 PPH 0.0513 PPM 0.1558 PPM BENZENE AT AH-18 Tolilfene P AT AH-18 '* BENZENE AT P-520 A/B TOLUENE AT P-520 A/B 0.0579 PPM 0.1665 PPM BENZENE AT P-540 A/B TOLUENE AT P-540 A/B 0.0432 PPM 0.1047 PPM BENZENE AT P-540 E/F TOLUENE AT P-540 E/F 0.0816 PPM 0.1969 PPM BENZENE AT B-534 TOLUENE AT D - 5 3 4 0.0621 PPM 0.1390 PPM BENZENE AT P-530 C/D TOLUENE AT P-530 C/D 0.0493 PPM 0.1773 PPM 0.0300 PPM 0.1620 PPM BENZENE AT P-510 A/B TOLUENE AT P-510 A/B BENZENE at' P-500 C/D TOLUENE AT P-500 C/D 0.0435 PPM 0.1526 PPM BENZ. AT WASTE H2 0 PIT TOL. AT WASTE H20 PIT ALARMS >(? <E0F> > Df; LHC 3 ACCOMPLISHMENTS IN 1987 Page 8 INDUSTRIAL HYGIENE TRAINING Tank Farm and LHC 3 operations and maintenance personnel were trained in the consequences of overexposure to the block's hazardous chemicals. Hearing protection requirements and the monitoring program were reviewed. "Right to Know", Mouth bit, half faced dual cartridge respirator, 5 minute escape pack, and Scott Air Pack training was performed. Block personnel were informed that yearly respirator fit testing and documentation would begin in 1988. HAZARD COMMUNICATION STANDARD The requirments of the OSHA Hazard Communication Standard were reviewed with all plant personnel. A written program meeting the requirements of the OSHA Hazard Communication Standard was utilized. The reference manual contains policy statements, a hazardous chemical listing, a vessel content listing, and MSD sheets for chemicals found in the block. The standard, its effects on plant personnel, and the location and types of reference material was reviewed. FORMATION OF BLOCK ENVIRONMENTAL COMMITTEE In June of 1987, an Environmental Committee to address both environmental and industrial hygiene problems and their solutions was formed at LHC 3. The committee is open to all interested Dow block personnel. A computer program to track environmental and industrial hygiene suggestions was implemented. TANK SEAL PROBLEM The floating roof seal on the process water storage tank (T-1660) was studied and sample coupons of sealant material were placed in the tank to determine the best method of repair. Venting hydrocarbons which contaminated the tank may pose an odor and exposure problem. The tank will have to be taken out of service and cleaned before the seals can be replaced. This work is scheduled for the first half of 1988. NOISE REDUCTION AND MONITORING The yearly noise level survey of LHC 3 was performed. A summary of the noise surveys for the past three years is included. No new noise reduction plans were initiated in 1987 although some new hearing protection muffs with an improved NRR were tried and adopted for use not only in the block but division wide. DO Cf,\Vr LHC 3 NOISE SURVEY - Louisiana Division 1986 1987 Page 9 1988 INSIDE CONTROL ROOM 65 EAST OF CONTROL RM. 81 N.E. OF CONTROL RM. 88 WAREHOUSE 73 WEST OF V-1400A 98 WEST OF T-1200 75 WEST OF T-1210 83 BETWEEN T-1200 T-1210 73 D-531 DECK 83 WEST OF E-531 87 BZ Rx DECK 82 BX RX GROUND 86 NORTH OF R-500F 82 NORTH OF D-580 FIN FAN DECK COOPER DECK 88 91 94 S.W. OF CT-1000 85 N.W. OF CT-1000 85 SOUTH OF C3H6 STORAGE 88 SPARE PARTS YARD 83 S.E. OF MOTOR CONTROL CENTER 92 S.E. OF C-54 87 EAST OF C-55 87 S.E. OF C-150'S 83 EAST OF C-52 108 SOUTH OF R-lA 79 S.W. OF D-130 95 K-71 GROUND . 98-114 K-71 DECK 102-109 K-120 GROUND 98-112 K-120 DECK 99-108 SOUTH OF E-9'S 92 EAST OF C-3 * 92 SUPERHEATER DECK (NOT VENTING) 96-102 HPSH DECK VENTING ---- LPSH DECK VENTING 98-102 FURNACE WALKWAY 89-92 WEST OF B-3 102 S.E. OF B-3 85 S.E. OF B-1B ` 81 E-1230 MUFFLER 114 72 81 89 74 89 88 72 81 80 82-86 82-102 84 89 88-93 89-93 87 84 88 81 85 91 86 86 101 78 95 106-115 101-111 99-112 101-112 86 95 96-104 ___ 96-102 89-93 108 85 82 119 74 84 92 74 91 82 87 79 86 88 86 88 96 98 90 91 85 86 86 81 91 88 86 91 92 84 102 116 109 116 112 92 ,92 104 92 106 85 82 96 ALL NOISE LEVELS ARE GIVEN IN DECIBLES. DIVISION POLICY REQUIRES THE USE OF HEARING PROTECTION IN AREAS WITH A DECIBLE RATING OF 85 OR MORE. NEW BENZENE STANDARD Page 10 In October of 1987, the new Benzene Standard which went into effect on December 10, 1987 was reviewed with the Louisiana Division Industrial Hygienist. Dow and contract personnel were informed of the new guidelines. More benzene monitoring was done using 3M 3500 organic vapor badges to give us a better idea of how to deal with routine and non-routine potential benzene exposure situtations. Special warning signs and caution tape were ordered to use in these situtations. Results of some of the monitoring are included in this report on pages 12 and 13. Training of personnel and its documentation was carried out. 1,3 BUTADIENE MONITORING Due to the high vapor pressure (low boiling point) of 1,3 butadiene, it was found advisable to start using the 3M 3520 organic vapor badges with a back up section to assure proper monitoring results in areas where 1,3 butadiene was known to be present. Results of some of the monitoring are included in this report on page 11. CITRIKLEEN REACTIVE CHEMICALS STUDY In December of 1987, a reactive chemicals study involving a new heavy duty cleaner-degreaser known as CITRIKLEEN was begun to determine if it would be a suitable substitute for chlorothene which was widely used in the block. In January of 1988, CITRIKLEEN use was begun at LHC 3. I February 5 1988. C-55 AREA: SWINGING SPECTACLE BLINDS AND PREPARING SYSTEM FOR MAINTENANCE On November 18* 1987* the C-55 column was prepared for maintenance. Monitoring was performed on the contract and operations personnel involved. The results were as follows DOW PERSONNEL TIME (TWA) PPMI- EXPOSURE BENZENE BUTADIENE Tom Hunt (Resp) 140 min. 3. 0 1. 5 CONTRACT PERSONNEL Ronnie Sagona Jim Marino Jerry Dubois Randy Pitre (Resp) Alvin Brown (B. Air) Gerald Taylor (Resp) Rip Theriot (B. Air) 180 min. 120 min. 90 min. 140 min. 140 min. 140 min. 140 min. .2 .' . 4 .4 4. 0 .12. 3 & 13. 0 .7 .2 .. 4 10 11. 3 .4 9. 1 The two contract personnel with the highest readings were involved in swinging the spectacle blinds to isolate the column. Breathing air was worn by these two in anticipation of the high levels of beniene and butatiene that were present. The two contract personnel who wore respirators did so in anticipation of some exposure potenti 1 but not at the higher levels. The Dow person was'involved in various tasks in getting the system ready for the contract personnel. The results of this monitoring indicate that the proper procedures are being followed in preparing this system for maintenance. Data previously gathered had provided information in determining what levels of protection would be worn by the various people involved. Dane L. D'Armond Industrial Hygiene Contact LHC 3 T-1702A SAMPLING & GAUGING AND T-1704C SAMPLING Page 12 T-1702A it a benzene holding tank located in Block 210 which it routinely templed and gauged. 3M badge monitoring mat performed on the sampling and gauging whieh took place on November 26 19S7 and December 6# 1987. The results were as follows: . DOW PERSONNEL TIME BENZENE (TWA) PPM EXPOSURE Carl Williams Carl Williams 13 min. 13 min. .60 (11-26-87) 3.8 (12-6-87) T-1704C is a butadiene holding tank located in Block 110 which is routinely sampled. 3M badge monitoring was performed on the sampling which took place on November 26* 1987. The results were as follows: DOW PERSONNEL TIME BUTADIENE (TWA) PPM EXPOSURE Carl Williams 15 min. 20.2 (11-26-87) The results of these samples indicated that respirators need to be worn while gauging and sampling of these tanks is carried out. Follow up monitoring is being done in these same jobs to determine if respirators will continue to be worn or if any other action is warranted. Dane L. D'Armond Industrial Hygieni Contact LHC 3 DC February 5. 1988. Page 13 BENZENE AND 1.3 BUTADIENE SAMPLE COLLECTION AND LAB ANALYSES On December 1st end 2nd. 1987. monitoring uai done using 3M 3300 Sedges on persons who collected end ren the analyses on benzene in Block 68. The outside SQT's collected the benzene samples in their normal way utilizing sampling devices which had been installed to keep exposure potential to a minimum. Monitoring was also done while the outside SOT's collected the ethylene samples which contain 1.3 butadiene. The lab personnel injected the samples into the analyzers using safe work practices which are a part of normal operations. The results were as follows: DOW PERSONNEL Buster Danehower Keith Graves Keith Graves Keith Graves Keith Graves Randy Looney Linda Johnson (Lab) Lab Office Johnny Davis Frank Auster Frank Auster Frank Auster Lynn Viator (Lab) Lynn Viator (Lab) TIME 15 min. 21 min. 21 min. 22 min. 23 min. 13 min. 15 min. 15 min. 13 min. 6 min. 24 min. 22 min. 23 min. 20 min. (TWA) PPM EXPOSURE BENZENE BUTADIENE 1.7 .4 .4 3. 2 .4 1. 2 1. 2 1. 2 2. 0 4. 5 *MDL 1. 0 .9 4. 5 53. 0 377. 0 18. 0 15. 8 2. 7 3. 9 MkDL stands for Method Determination Limited -- Bz ,001 mg/ml One of the lab persons had a 4. 3 ppm benzene reading while running the lab sample. This is close to the STEL limit of 5 ppm for a 15 minute TWA. Follow up monitoring on this lab procedure will be done. The outside SOT's were within the STEL limit of 5 ppm for a 15 minute TNA sampling period fcr benzene. Due to the high levels of 1.3 butadiene monitored while the samples were being collected, the outside SOT's WILL BE REQUIRED to wear half-face dual cartridge respirators when performing this task until further badge monit-oring can be done. The personnel involved in this monitoring will be informed of the results and proper follow up action will be performed. Dane L. D'Armond Industrial Hygiene Contact LHC 3 Page 14 FUTURE INDUSTRIAL HYGIENE PLANS FOR LHC 3 LHC 3 will continue to inform its plant personnel on the consequences of exposure to chemicals in the block and provide the necessary reference material. New and better training material will be utilized as it becomes available. More exposure monitoring will be done in the areas of gauging and tank sampling as well as routine process sample catching and lab analysis of these samples. Yearly respirator fit testing and documentation will be performed in the block. A review of our protective clothing policy will be done and changes will be forthcoming if warranted. The way in which process systems are prepared for maintenance will be reviewed to see if potential exposure levels can be reduced. An audit of our floating roof tanks will be carried out to stay abreast of potential exposure problems that may arise from faulty seals or support legs. The fugitive emission program will continue in established areas of the plant as well as new areas as they come on line. Routine cleaning of warehouse areas containing asbestos gaskets will be implemented and documented. wNrTnvN'TT A 1 5 ig8s LHC 3 C4 C5 C6 C7 BEN. TOL. ETH. BEN. XYLENE STYRENE CO.S+ DCPD HEAVIES C 505 C6 C7 BEN. TOL. ETH. BEN. XYLENE STYRENE C9+ C6 C7 BEN. TOL. ETH. BEN. XYLENE STYRENE C9+ DCPD HEAVIES -H > ; T> rv i -i