Document r6qoZroOE2rQ31eZ68aewDD7q

PLAINTIFF'S EXHIBIT i i- Nw York* How York* 10017* Jtuo 29* 1972 INOWgTRlA^HTOIgNg SURVEY PU<3*T SOUND RSyiNXRT Mm9*Ansm* Mr. D.H. Mortoft AueotUi, Woofetogtott Attacked to fbo roport of tk iado*trial feygiaa* oorvOf ebadoctod ftfc yooc plftat n Moy I 0a 10* 1972* Vo Ion boo* wftttiof tor dot* from ebomlcftl ftappllftrft which ho otUl ootboo* roeolrod. K mmaundittoH eorortog Hum* materials oro aaoded tor will bo tat to oopftrofo roport. If you boro **j qanfcionft* ploftftb lot mo know* JFL-AFQ cc: FPYjr DMM JAD JPI* R. T. RICHARDS WA-TEX 000033 Industrial Hygiene Survey Anecortes ftflurf,Pa|t8oaad Rut Atteett*!, Washington May 8-10, 1*72 By: James P. Lieata,Industrial Hygienist Texaco be,, Health Division Haw York* Haw York SUMMARY Asbestos containing materials are befog wed lor pipe insolation and each we should bo discontinuod. Paint spray work fo dune fo the warehouse #3 building without adequate enuwt ventilation or proper electrical fixture* approved lor uao fo a hasardou* location. The mixing ahad located at foe water cooling tower doea not have adequate exhauet ventilation to remove the chromate duet evolvedwhea dumping begs Into the mixing hopper* The advent drum rack outeide foe paint chop ia net equipped with the proper electrical grounding to handle a static charga build-up. The tetraethyl lead tank car unloading baildfog it not equipped with a flow alarm or eight-glare on the overflow tank* Mercury waa found behind the teat panel ia the instrument room. The plot plana of the high noiae arena do not show the 90 dBA contour on .foe plana. A calibration kit ahonld ho parchaaod for the MSA combustible gaa indicator. INDUSTRIAL HYOIBKE SURVEY On May 8,9> and 10th, 1972 a survey of foe Anacortea Refinery waa made to aaalat local management fo updating some plant operations to. comply with the Federal Occupational Health and Safety Act of 1970* The following recommendations are a result of this survey. Some additional information eoncorning Magnus 94XX-K and Bata Dlanodic 939 has still not boon received from the manufacturer and recommendations covering these will he handled fo a separate report if needed. RECOMMENDATIONS 1. Asbestos uasage ia befog strictly controlled under OSHA regulations. The most practical alternative is to perform insulation work fo the refinery, with mon-asbeato# containing insulation materials. The present stock of asbestos cement in 100 lb. begs should be discarded since theee are non-asbestos types readily available. All insulation which has been done with asbestos should be indicated on plant operation diagrams to enable employee to fodhsw OSHA regulations during WA-TEX 00Q034 I -2- uptlv or ntpiunamt at iom Him la ft* Iota**. All specifications for mv installation* should prohibit ft* tu of **b*ito* containing materials for insulation* 1. 2* Paint spray work bolag porformod ia warehouse building 13 hoald b* discontinued until m adequately ventilated paiat spray booth of euffieient siaa cam b installed. AMtttaftf all eloctries! ilataraa ia ft* room shonld bo apdatod to ft* approved typo for hasardens locations, Claaa 1 as datailod ia paragraph If10.322-1910324 HBA regulations. 3* Tha mixing shad loeatod J^p irator cooling tower should have aa adequate exhaust system iastalledr'to rsmoveeny dust evolved during the damping of Bets OlaaodU #939 into the mixing hopper. The operator wears a U.S. Bureau of Mines approved respiretort goggles and other protective clothing but the dost still contacts many exposed areas of bis skin. This water treating chemical cantatas 49% chromates. The lighting inside this shed shoold also be improved by the addttion of another light fixture over the mlxiag hopper. 4. The solvent dram reck outside the paint shop should be provided with proper beading wire end grounding to prevent a static charge build-up unspecified in 08HA regaletione paragraph 1910* 104* S* The tetraethyl lead tank car unloading pump hones building is equipped with n task to eolleet eny overflow ia the event of n malfunction. This tank should be equipped with a flow alarm system or sight-glass to alert operators when this situation has occurred* 4. The interior of the instrument rowan tent panel should be checked periodically* with a magnlfing glass and flashlight, for droplets of mercury. Any mercury noted should he vacuum removed using n special collecting flask attachment equipped with a h'gh velocity pick-up tube. The attachment will have to be fabricated in your laboratory as they are not commercially available. A side arsaoVacuum flask, rubber haae and a glass rod for a pick-up tube should be used.. The incoming air should bubble through water in the flaak to collect the mercery* 7. The installation diagrams ussd for noise plot plans do not show the 90 dBA contour on the drawing* The present yellow outlines shown era the concrett pad edges in most eases and not the actual 90 dBA contour. 3. A calibration kit for your Mina Safety Appliance (MSA) combustible gas indicator should bo purchased to insure the unit is working properly prior to use. Tests for combustible vapors should be made prior to any tank or confined epece entry. ! WA-TEX 000035 -3 DISCUSSION The storage araa for insulating material Hat rosy poor honsokeeping aad controls for iibrntoi coatalaing materials, The asbestos "fins" comaat is dispensed with a scoop from a 100 lb sack which is torn open* The floors wore covered with asbestos fibers aad pieces of brekea preformed pipe laselation. Browns are ased to dry sweep this area. No respitfitgy protectioa is worn byythe employes involved la the asbestos cemeat rnfadiatfoperatlon. The Federal Occupational Health and Safety Act regulations ca asbestos were changed on December 7, 1971 through publication of an Emergency Standard amendment. The threshold limit value for asbestos is presently. 9 fibers longer than S microns per roUltMfe* of air. A special study committee, which was formed under the U. 8, Dept, ef Labor, has now recommended that the limit for asbestos bo farther rodeoed to 2 fibers longer than 9 microns per milliliter of air, Sven if ell fotoro insulation work is performed with asbestos-free materials ths oxistiag asbsstos containing insolation will confine# to caaso problems. AU linos presently covered with asbestos should bo indicated on piping plans so when it comes time to remove or repair each insulation the proper employe protective moasaros can be taken. The safe work procedures for asbestos include tkedSdlowing; 1. All power driven or mechanical catting equipment moat bo provided with adequate local exhaust ventilation. (ANSI Standard Z9* 2-1971). 2. U. S. Bureau of Minos approved respirators, air supplied or self-contained breathing apparatus must be worn where dust levels exceed the Threshold Limit Values. 3. All dost must bo remeyed by vacuum cleaning methods. 4. AU waste material must he collected and disposed of in sealed bags or containers. 5. Warning signs must be posted as specified In the proposed standards if adopted. Compliance with these regulations will be very difficult and dd&grsatly to the labor cost. Zt is, therefore, important to document the exact present location of att asbestos insulation which will be subject to these regulations, as woU as installing only non-asbsstos typos in the future. A copy of the WA-TEX 000036 . . r -4- Emergency ud Proposed standards U attached for yoar information. Also attached m d*t* sheet* for n esbeetos free cement. The other items diseussed ere covered la the recommendation* listed ebore* There is on* additional item under recommendation #7 concerning the noise contours. The question of spacing of warning signs at the 90 dBA eontou line was raised* No specific distance between signs are mentioned in the "Guidelines to the Dept, of Labor Occupational Noise Standards*4 or In the OSH. regolations. I would suggest Act each contour be inspected to dstcemln* if a warning sign is visible to anyone approaching along normal routes* Additional signs mny be needed st sou# points whore items block presently posted eigne. Eech noise source should be treated individually. Additional items which were checked during my plant surrey were the open surfhee tanks in the machine shop, holler house end laboratory. The hot water bath tanks in th* lab and th* tank in th* boiler house do not present s haserd as defined by the GSHA Item 1910.94 (d) (plOSIS). The tank in th* mad shbO i* head to dean metal parts and contains a solution of Magnus 94XX-K whi druScUKlabel status is a medium strength alkali mixture* I have written to th* manufacturer for detailed information and will writ* specific recommendations operation, if aoodod. whoa file data i* received. X would like to thank Mr. D. H. Morton and hie staff for th* cooperation and assistance 1 received during my visit to the Anaeortes refinery. JPL-AFG Atts. J.P. L1CATA WA-TEX 000037