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C3-173 0.4-4i OFFICIAL FILE COPY *. *urw O "cm^ CJ.L. I_l --uc SA-- cs. _ 110 16 TO C. X. Gellenbeck 2larch 4, 1975 R. P. Medlin E. D. Keiper E. W. Collins ?. J. Reilly ASBESTOS HANDLING REQUIREMENTS Attached are 50 copies of the "Asbestos Handling Requirements" for distribution andduse within the refinery. This final draft has incorporated the comments of Operations and Engineering where possible. Employee Handbook. CM, Qi?; ^ i" RWMasters:eh Attachments J. L. Wescoat 054: 44722s ASBESTOS HANDLING REQUIREMENTS MAR /, 1975 INTRODUCTION Based on the rales and regulations promulgated under OSKA and by the EPA, all handling of asbestos bearing material requires special atten tion. This guide is intended to provide process and mechanical supervisors with a summary of the actions which must be taken when employees are working in an area where asbestos bearing insulation is being removed and handled. wnwT7 fcrinvA* u/"-H** As of August 29, 1972, the Purchasing Department was instructed that all future purchases of insulating material must be asbestos free. It is difficult to differentiate, by appearance, between asbestos bearing and asbestos free insulation. To establish a guideline, friable insulating materials installed prior to January 1, 1973 will be considered to contain asbestos fibers and will be treated according to the following requirements. If the material can be positively identified as being asbestos free, the full requirements which follow need not apply. The following list indicates those items which contain asbestos that are not considered to present a health hazard. These items are approved for use in the refinery without special handling precautions: Woven asbestos covered thermocouple lead wires Solid sheet asbestos gaskets Spiral wound asbestos packed gaskets Asbestos gloves Asbestos welding blankets Graphite or teflon impregnated woven asbestos packing Any asbestos bearing materials, presently on hand or contemplated for purchase, that is not in the above list must be reviewed with a representative of the Safety Department and the Industrial Hygiene Department to determine if its use would require any special personal protective measures. REQUIREMENTS The following requirements are based on OSHA and EPA rules and upon 054! 447229 2 three Industrial Hygiene Investigations conducted in the Beaumont and Paulsboro Refineries. They are intended to cover routine jobs where old insulation is removed; large jobs where demolition is involved may require additional precautions. l.a. The plant representative involved in a job which will require the removal of asbestos bearing thermal insulation must notify a Safety Department Foreman to inform him of the nature of the intended work. nuC4 o iuai*j. <aXe<a.a cue ismuveu iui. ilibuct; oxuu Ox uaoc mcodi. cr& Sonorayi the method of removal is important. If the method of removal may generate significant airborne fibers, the pre cautions which follow must be observed. The worker cutting the area for inspection must wear an air purifying respirator re gardless of the method of removal. 2. The plant representative must obtain sufficient respirators, caution signs, caution tags (see figure l), heavy plastic bags, and safety tape to complete the job in accordance with the following requirements. These items are available from the Safety Storeroom. 3. Asbestos bearing material is best handled in a wet condition. It must be wetted to keep moist during the removal and handling period whenever possible. k. In congested areas and in process units a safety tape barrier shall be installed to isolate the area where insulation is being removed. It is recommended that the safety tape be located 25 feet from the work area. Tape barriers are not required when small groups are working in isolated areas where other personnel are not likely to become involved. 5. All workers inside the area marked by safety tape must wear air purifying respirators as well as those workers actually handling the material. Respirators must be worn regardless of barricade or wetting practice. 6. Caution signs must be posted at all approaches to the area. 05458 447230 3 in which asbestos type insulation is being handled. 7* Employees who, according to a medical examination, cannot function normally with a respirator device shall not be assigned to work requiring a respirator. 8. All removed insulation shall be carefully placed in the plastic bags available from the Safety Department. When, full, the bags shall be sealed and the caution tags attached in a readily visible location. 9. Piping and other equipment covered with asbestos insulation must not be dropped or thrown from buildings or structures. It should be carefully lowered to the ground. When jacketing has been removed from piping the insulation must be wetted before lowering. 10. The EPA must be notified at least 20 days before starting "demolition'' work on asbestos covered piping and equipment. Routine maintenance and repair work is not to be considered as demolition and does not require notification. Examples of demolition which would require EPA notification are: Demolition of TCC-i, or major physical changes of a structure which bears asbestos insulation. The unit responsible for initiating demolition work must contact the Conservation Engineering Section at least 30 days before demolition activities are initiated so that they may forward the rea.uired notification to the EPA. 11. Sealed containers of asbestos scrap may be taken to the sanitary land fill area where it is buried. A plant representative must notify the Conservation Engineering Section before having the scrap hauled to the land fill area. 12. On jobs performed by contractors, it is the contractor's responsibility to conduct the job in accordance with the OSHA and EPA rules and regulations. The Mobil Contact or Con struction Inspector should insure that the contractor is aware of his obligations to conform with these regulations. The contractor will provide his own signs, ~ags, bags, and barricade tape, etc. 05459 447231 CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM ___________________ ___________ FIGURE 1. 447232 Mobil safety operating procedures HAHDLI1KS AS3KST0S--C0WTAI1IIHC MATS8IAL March 4, 1975 Revised Hovember 11, 1985 iirntoDucTioH This procedure is intended to provide guidelines for tha safa handling of asbastos and/or asbastos--containing materials so that personnel involvad in tha handling oparation or in tha araa of tha work will not ba axposad to asbastos flbars. MATERIAL IDgHTIFTCATIOM Insulating aatarial and othar rurpacted asbestos-containing materials (transits siding, ate.) bsing removed should ba eonsidarad as containing asbastos flbars unless: a. All of tha aatarial in quastion has spaclfic manufacturer's marking denoting that it is "asbastos frea or b. Snginaering drawings or othar signed and datad documents verify that equipment is covered with "asbestos frea" material (only 1972 and latar installations will ba acceptable under this item), or c. Qualitative analysis of at least 2 samples of tha material confirms it is "asbastos free.." These analyses must ba recorded on signed documents. Material must not ba reinstalled unless proven to ba asbestos-free by one of tha above methods. MATSBIAL AHALYSIS Bulk samples of insulation should ba placed in a sealed plastic bag and tagged to indicate: data, location. The requestor should fill out tha Asbastos Sample Data Sheet (copy attached) and bring it to tha Industrial Hygiene Office. A qualitative test will ba conducted, documented and signed. Tha results will be given as "positive" or "negative." When requesting analysis, tha following should ba observed: a. For scheduled projects, submit samples at least four (4) days in advance. b. For unscheduled/emergency projects, the bulk samples should be submitted at least three (3) hours in advance. 0233S Page 1 of b 05461 447233 Mobil safety operaung procedures HANDLING ASBESTOS-CONTAINING MATERIAL (cont'd) APPROVED ASBESTOS--CONTAINING MATKRTAf-5! The following asbestos-containing items are approved for use in the refinery without special handling precautions: Woven asbestos--covered thermocouple lead wires Solid sheet asbestos gaskets Spiral-wound asbeatos-packad gaskets Asbestos gloves Asbestos welding blankets Graphita- or teflon-impregnated woven asbestos packing Any asbestos-bearing materials presently on hand or contemplated for purchase that are not in the above list oust be reviewed with a representative of the Safety Department to determine: (1) if they are permissible and/or (2) if their use would require any special personal protective measures. tha urine Personnel involved in the handling of asbestos-containing materials oust be trained in: a. The potential health hazards of asbestos fibers. b. The procedure for safely handling asbestos-containing materials. c. The proper use and limitations of respirators. JOB REQUIREMENTS following are the requirements for all jobs where asbestos-containing material is removed (large demolition jobs may require additional precautions): 1. The job supervisor will arrange for sufficient respirators, protective clothing, caution signs, caution tags, heavy plastic bags, and barrier tape to complete the job in accordance with the following requirements. These items are available from the Safety Storeroom. 2. A safety tape barrier shall be installed to isolate the area where material is being removed. The tape should encircle approximately a SO-foot radius around the work site. Signs shall be installed on thi3 barrier to alert personnel to a potential exposure to asbestos. The signs will reed: ASBESTOS DUST HAZARD AVOID BREATHING DUST WEAR ASSIGNED PROTECTIVE EQUIPMENT DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO YOUR HEALTH 02S8E-2 Page 2 of 6 054c2 447234 Mobil safety operating procedures KAMOLIHC ASBKSTOS-COMTAIMXMG MATERIAL (cont'd) 3. Any parson who enters tha safety tape barrier araa oust wear a HIOSH-epproved dust respirator as a minimum precaution. Temporary or summer-hire employees should not ba assigned to work insids this barriar. A. Employees Involvad in tha removal oparation oust ba equipped with a IOSH-approvad, singla usa, disposabla dust raspirator. Employees also saiat waar glovaa, eovaralls, shoa covars, and a haad covering ovar hard hats. Glovaa, eovaralls, shoa covars, and haad covars should ba of tha singla-usa, disposabla typa. Tha clothing must ba removed and placed in tha spprovad disposal bags batons eating and bafora laaving tha wort araa for any reason. Tha dust raspirator should ba removed last and placed in this bag also. 5. All asbestos-containing materials oust ba thoroughly watted with water bafora removal to prevent dust dispersion. It should ba wetted initially and kspt wet during tha entire removal and handling operation. In extraordinary cases, where watting is not possible, an alternate procedure may ba developed by tha job supervisor, tha proprietor and tha Safety foreman. 6. A suitable and effective means of containment, such as a.disposable plastic sheet placed under and/or around tha wort area, should ba used to prevent tha dispersion and ground settling of fibers so that their subsequent release to the atmosphere in a dry form does not occur. This plastic sheet should also be placed in an approved disposal bag at tha end of each work period. 7. Asbestos-containing material should be handled carefully so as not to disperse fibers into tha air. Materials should not be dropped or thrown down. 3. Piping and other equipment covered with asbestos-containing material must not be dropped or thrown from buildings or structures. It should be carefully lowered to the ground. When jacketing has been removed from piping, tha insulation must ba watted before lowering. 9. Where power tool3 such as abrasive wheels, drills, etc., are being used to remove insulation, all such tools must ba provided with local exhaust ventilation to capture asbestos dust as it is generated. 0Z38S-3 Page 3 of 6 Q5463 447235 MODI! safety operaring procedures HAITDLIMC AS8CST0S--COMTAXiniiG MATERIAL (cont'd) 10. Waste asbestos-containing material and other debris must immediately be placed in approved disposal bags, saalad and affixed with cautionary tags. Broken or torn bags oust be double-bagged to pravant leakage. Tba cautionary tag will raad: CAUTI0H Contains Aabastos Fibers Avoid Craating Dust Braathing Asbastos Dust May Causa Sarious Bodily Hara 11. Upon cotsplation of tba work aacb day, tha work araa stall ba complataly claanad of asbastos to minimize potantial axposura, including flushing with watar, vacuuming or othar sppropriata maans. 12. Tba baggad wasta material is to ba ramovad daily from tha work araa and deposited in tha idantifled asbastos disposal containar located near tha rafinary landfill. Disposal of wasta asbestos-containing material is not permitted in tha refinery landfill. All such waste is disposed of off-site at an approved wasta disposal facility. 13. Asbastos- and non-asbastos-containing materials must ba disposed of in accordance with the Dumpground Solid Vasts Disposal Procedure. This procedure basically requires that a Refinery Landfill Ticket, BR-1172, ba provided to tha truck driver for presentation to tba guard at tha dumpground for each load of wasta. Tha individual authorizing tha ticket is responsible for' ensuring that documentation of material identification, as specified on page 1 of this procedure, is readily available and can ba provided upon request. 14. Bags must ba handled, transported, and placed in the disposal containar carefully to prevent bag rupture. Broken or torn bags oust ba immediately rabaggad by tha disposer. Broken bags constitute a potantial asbastos exposure requiring tha same personnel protective equipment designated in itam 4, pegs 2, until rabagging is completed. TRANSITS Transits may contain up to 40* asbestos, and mu3t be treated as an asbestos-containing material in accordance with the above job requirements. However, if it can be removed without sawing, drilling or otherwise creating dust, tha following exceptions are permitted: 1. Where plastic sheeting can ba used to isolate removal operations from othar building operations, such as during tha removal of exterior wall panels, the 50-foot perimeter may ba reduced on tha building occupant side. 0288E--4 Page 4 of 6 05464 447236 Mobil safety operating procedures HAMDLZMCr ASBSSTOS-COHTAIinMG MATKHIAI. (cant'd) 2. A dedicated dumpster, with doors or hatches to provide coop1st* enclosure, may be used instead of Individual plastic bags.. Transits panels oust bs carefully placed, intact, in the dumpster as they are removed from the structure. If necessary to reduce the size of panels to fit into the dumpster, the panels can be laid on plastic sheeting on the ground, wetted, and broken to proper size. ogwocmoir amp rsitovattoh The Texas Air Control Board (TAGS) suet be notified in writing prior to Initiating work involving asbestos removal as follows: 1. The plant proprietor responsible for initiating work involving asbestos removal must advise the Conservation Section of the magnitude and type (demolition or renovation) of work as soon as passible or preferably 30 days prior to commencement of the activity. This will allow time to review the need for notification and, when necessary, to work with contractor representatives to insure that the necessary TAC3 notifications have been submitted. 2. For contracted asbestos renovation or demolition, it is the contractor's responsibility to make the required notifications. The contractor must be able to provide documentation that notification has been made upon request by a Mobil representative. For work performed by Mobil, the Conservation Section will make any required notifications. 3. For any asbestos removal that involves the wrecking or removal of any load-supporting structural member (demolition), a written notification is required as follows: a. For scheduled projects where the amount of asbestos is at least 260 linear feet or at least 160 square feet, notify at least 10 days before demolition. b. For scheduled projects where the amount of asbestos is less than 260 linear feet or less than 160 square feet, notify at least 20 days before demolition. c. For projects being demolished under an order of a state or local governmental agency, notify as early as possible before demolition. 1288S-S Page 5 of 6 05465 447237 safety operating procedures KAHDLISC ASBESTOS--COIfTAIVIlfG MATERIAL (continued) *. For asbestos removal that involves the altering (renovation) of a facility component (any pipe, duct, boiler, tank, raactor, turbine, furnace, or structural member), but not demolition, a written notification is required as follows: a. For individual non-seheduled projects over a period of one year where the total amount of asbestos is predicted to be at least 260 linear feet or at least 160 square feet, notify as early as possible before renovation. b. For emergency renovation where the amount of asbestos is at least 260 linear feet or at least 160 square feet, notify as early as possible before renovation. COWTRACT JOBS On jobs performed by contractors, it is the contractor's responsibility to conduct the job in accordance with this procedure, except that the contractor will provide his own signs, tags, bags, plastic sheets, barricade tape, personal protective equipment, etc. The Mobil job representative will ensure that the contractor is aware of his obligation to conform with this procedure. 02885-6 Page 6 of 6 05466 447238 -------------- IPW^ampla Vo. PW.-Sub 3asuit Date-IMD Submitted by(a) Data(b) Data Raquastad(c) Plant/Unitld) Sampla Location/Idantifiar Brief Description!*) SBESTOS SAMPLA DATA SHEET 8/8S Skatch(f) Iron Asbnatoal I Yas I Analysis by: Data: I Ho Princatoa TSL: Yes/lfo Data: Rasults: Hota: Parson*(a) requastins analysis naad to fill out columns (a) thru <). 05467 447239 ni ^ u ro J. L. Wescoat INTEROFFICE CORRESPONDENCE oate September 10, 1973 c.c. R. D. Drew - New York J. D. Reicnel - New York L. V. Cooley - Dallas R. P. Madlin E. D. Keiper J. K. Stewart j. L rvcSCwAT 40 CFR. 61 EPA REGULATIONS HAZARDOUS AIR POLLUTANTS Your September 7 letter transmitted an Asbestos Handling Guide in which Section 10 outlined certain requirements presumed co be encumbent upon the refinery in order to comply with the subject EPA regulation. Specific reference is made to Section 61.22 (d) which sets forth notification requirements and procedures to be used under certain circumstances of demolition. The subsection applies to "Any owner or operator of a demolition operation Mr. Cooley of OGC - Dallas concurred in by Mr. Hewitt OGC - New York has rendered the opinion that the refinery does not constitute the owner or operator of a demolition operation. This regulation, therefore, does not apply to refinery activities and Section 10 of your Asbestos Handling Guide should be deleted. The above is in reference only to the subject EPA regulation, and should not be used in any way affecting your implementation of any OSHA requirements deemed applicable. E. T. GELLENBECK RGS/im 05468 447240