Document p8Ox1ya4a4L1pZwK0YN06q8D

PLAINTIFF8 exhibit SH-2970 FEBRUARY 13, 1989 FROM: W.E. WOOD JR. TO: ALL MAINTENANCE ELECTRICANS AND ELECTRICAL S.E.T.'S SUBJECT: Recommended Guidelines For Removal Of Asbestos Gaskets From Holophane Light Fixtures A945551 Unit no.02454. See Complex Procedure S 1.02 Minor Task The below list of material will be needed to do this job GLOVE BAG (JVA23A) contact A.C.T. Member DUCT-TAPE folio 90777 REPLACEMENT GASKET SPRAY ENCAPSULANT APS or contact A.A.T. Member DAMP PAPER HANDTOWELS APPROVED RESPIRATOR PUTTY-KNIFE 1-1/4 IN. folio 4340-000088 ` PLASTIC ASBESTOS . CONTAINING MATERIAL BAG folio 90680 We recommend the following steps be taken to assure the proper engineering controls needed for these asbestos gaskets located in these light fixtures: . 1. obtain work permit. 2. secure power to light fixture. 3. install glove bag containing putty knife, encapsulant and damp handtowels, over fixture. 4. remove globe and light bulb and wipe inside of globe. 5. remove rivets holding gasket in place. 6. clean and spray gasket surface. 7. reinstall globe 8. remove glove bag and tape bag closed. 9. remove globe and install new gasket and bulb. 10.install globe, and place asbestos free sticker on or as close to fixture as possible. The above recommendation is for gasket replacement and was reviewed by the ASBESTOS CONTROL TEAM. ' The other option would be disposal of the entire fixture intact. W.E. WOOD JR. ELECTRICAL S.E.T.'COMPLEX 2766 5-141 ABS-060720 LAM 031296 i SAFETY ANALYSIS WORKSHEET plant Shell WRMCtitle of job operation Asbestos gaskets replacement in light fixtures department/unit Complex wide date February 21. 1989 personal protective equipment ^ ra^or ^h ^EPA filter. Complex Procedure SI.02, SEQUENCE OF BASIC JOB STEPS POTENTIAL ACCIDENTS OR HAZARDS RECOMMENDED SAFE JOB PROCEDURE Bitik clt* jab down lav bnk niti that i*|t *Iiii it dear first. what la 4mi mil and m m, Yoo cm da tlu by (1) observing the lob, (2) discussing li with tb* operavt, fj) Graving on your Im*I4| of cbo lob. or (41 a combination of oik ihm. Record the fob ingi in ihcir normal order of occnroncc. 0* acrib* what i< done, nor tb* detoils *1 how it is don*. Uanolly three or font words or* sufficient o describe *ocb |*b step. For esamplc: Tbc |ob of "replacing s light bulb'* breaks dorrs into bo sic steps os fetlova 1. Bring ond aermp loddoc 2. Ascend ladder 3. Remove ligbl glob* 4. Replace light bulb 3. Replace light globe 6. Descend ladder 7. Reaver sad ssorc ladder Mobs the |ob steps neither too floo or too brood. They should sound natural. Ash yourself lor each rob step what accidents could occor v the man doing the fob aiep. Get yonc Mswera by either (1) observing ib* job, (2) discussing it with otbota, (3) recalling past accidents, or (4) a combinstioo of all dire*. Ask: Caa be be struck by or contocred by anything? Can be strike agaiast or contact any thing! Can bo be canght in, on, or between aaytfuag! Caa ha fall! Caa be strata nr evetesett himsnif? Can be b* eaposed to gas, fumes, radiation, etc.! Record potential accident* by combining non of fbo accident type abbreviations below with the agent of contact. For eiample, **stiuck by i cronebook" is to corded "SR-craa* hook**. Number cock potential accident. SB - Struck by CB - Contacted by CO - Caught oa CB - Caught between CV - Contact with SO - Strain - nveretartinn If you pceiet, etplaln baiatds aad potential accident! note fully. Draw a line indicate whero the entries for oao iob step end and the near begtm For each potential accident, ask yonrsetl what etacriy should the wan do or not do to avoid the accident. Get your aaawera by either (1) observing tb* Job lot leads. (2) discussing the lob with others wb* ary espedeeced thsteta. (3) draw ing on youl own okporienc*. ec 14! a combination oi all tbreo. Describe specific precautions la concrete detail. Give each recommaaded procautioa the same number as was given the potential accident (center caluma) to which it applies. Avoid generalities Ilk* "Be alert**, **8e careful**, sod **Take caution". Use alavie do or doa*l statements, e.g. "Lack out main power swueft* "Sr sod dear of lift before signalling", or ''Check wrench grip before netting full force**. If necessary, esplata how as well as what to do. Amooot of detail Is o matter of ladgomeai Also, question the basic |ob metbnd. I* thvrv an vntttely different way to do the fob hu Is bettet and salt! If a repair at servics iab, can aoythiag be dona to increase the life nf the lab. Review job with operator Identify light fixtures On - Review Complex Procedure SI.02, when obtaining permit. containing asbestos gaskets, "Minor Task"and what type of engineering controls you will Turn off 1ights to be Hot lamps may mel.t plastic be using. worked on. glove bag. Install glove bag con- Falling off ladder. taining putty knife, damp hand towels, and Encapsulant, over light with fixture and secure with duct tape. Use correct size ladder and position correctly. Dmove globe and lamp. Remove rivets holding gasket. fConfinvo on flavor#o Sid) ---------------------------------------------------------------------------------- ABS-060721 LAM 031297  PAGE 2 - JOB SAFETY ANALYSIS WORKSHEET SEQUENCE OF BASIC JOB STEPS POTENTIAL ACCIDENTS OR HAZARDS RECOMMENDED SAFE JOB PROCEDURE an and spray gasket surface with Encapsulant. Use putty knife to remove any gasket material that may be stuck to gasket surface. Wipe out inside of globe with damp towels. Fibers may have fallen inside of globe. Reinstall qlobe. . Remove qlove bao. Keep baq taped close when not in use. Spray old gasket with Encapsulant to prevent fiber release when installini h - baq on next fixture. ve qlove and install replacement qasket and 1 amD. Install globe and place asbestos-free sticker on fixture. * - Asbestos-free sticker must be blue with white letters. . ARR_nRn799 LAM 031298 SHELL WOOD RIVER MANUFACTURING COMPLEX HANDLING AND DISPOSAL OF ASBESTOS INSULATION PAGE 8 OF 11 -v COMPLEX PROCEDURE BOOK I, S 1.02 LATEST ISSUE 2/88 . B. Large-scale, long-duration jobs will require the use of an approved respirator, disposable Tyvek coveralls, head covering, gloves, and protective footwear. Also provided will be any clothing worn beneath the Tyvek suits including socks, underwear and coveralls. Non-disposable clothing will be placed in a properly labeled bag and sent to Purchasing for laundering. Xj Personnel and area monitoring is required daily until it has been established that levels are below the action level. VI. MINOR TASKS A. Minor tasks will include those jobs where control procedures are used to maintain exposures consistently below the action level of O.lf/cc. Minor tasks will not require the use of disposable protective clothing, banner tape or sign posting. However, minor tasks will mandate the use of an approved respirator (Section III, H) unless engineering controls are provided which reduce the asbestos fiber concentration below the action level. Some examples of minor tasks are: Brake shoe replacement. Clutch replacement. Picking up and bagging pieces of transite. Removing asbestos-containing gaskets and valve packing. Cutting of asbestos-containing gasket material. Taking samples of insulation (Section III, B). -Removal of non-friable "firetard" may be considered minor tasks after a review by a competent person and the Health and Safety Department. B. Also, where practical, minor tasks will require cleanup of the area using a HEPA vacuum. VII. EPA NOTIFICATION REQUIREMENTS - A. .IEPA notification is required for each job as follows: 1. More than 160 square feet of asbestos-containing insulation removal from a vessel, or; 2. More than 260 linear feet of asbestos-containing insulation removal from piping. COMP PROC S 1.02 ABS-060723 LAM 031299