Document rXBXyq79jgDzBGQ5RKK36Vqr

WKS-tn (*-r; IT /. <*//*-*> SHELL OIL CC ANY SHELL CHEMIC t COMPANY DEER PARK MANUFACTURING COMPLEX 7i" . ,, g. TO D. 0. CHRISMER DATE DECEMBER 1, 1975 FROM j. D. RANSDELL PLAINTIFF'S EXHIBIT SH-1666 SUBJECT RESPIRABLE DUST MONITORING DURING SANDBLASTING A-lr sampling was conducted October 6 and 8 to measure sandblaster's exposure to respirable dust. The purpose of these measurements was to check the effectiveness of the Cesco supplied-air respirators. The results showed that the Cesco air-supplied hood significantly reduces exposure. Al though the Cesco hood provides more protection than the previously used hood, eight-hour time-weighted average exposures are very near and could at times exceed the permissable limit. SCOPE The survey was limited to the measurement of respirable dust concentrations inside the Cesco hood as sandblasters worked in the sandblast yard. DESCRIPTION OF OPERATION Sandblasting is done in an open yard located on the north edge of the Refinery adjacent to the Houston Ship Channel. A storage building is located near the middle of the yard and is also used as shelter for lunch and breaks. The west side of the yard is used for blasting larger pieces of equipment while smaller pieces are blasted on the east side. A course sand, Clemtex No. 3, and a fine sand, Clemtex No. 5, are used for blasting. However, inspection of the sand on the survey days showed that the No. 3 sand was finer than usual, probably because an incorrect grade of sand had been delivered. The sandblaster usually moves in and around the pieces of equipment being blasted so he is unable to always be upwind of the blasting. Sand blasting is sporadic throughout the day, but typically less than four hours per day per man. HEALTH STANDARD The OSHA eight-hour time-weighted average (TWA) exposure limit for respirable dust containing free silica is determined by the following formula: 3 10 mg/m %Si02+2 DPMC-00749 LAM 007241 D. 0. CHRISMER 2 Since the limit is a function of the free silica content, the limit will vary from 0.1 mg/m3 for 100% free silica dust to 5 mg/m^ for dusts without free silica. The limit was set in order to prevent a pulmonary fibrotic condition called silicosis from chronic exposure. SAMPLING/ANALYTICAL PROCEDURES Breathing zone samples for respirable dust were collected by attaching at the worker's waist a sampling pump (either a MSA Model G or a Bendix C-115 or Bendix Unico Micronair) connected by plastic tubing to a MSA, Type FWS-B, 5.0 micron pore size, 37 mm PVC filter which was preceeded by a 10 mm nylon cyclone. The filter-cyclone assembly was pinned to the shirt collar, underneath the sandblasting hood. The air was sampled at 1.8 liters per minute. Pumps were calibrated in the morning before sampling and the flow rate rechecked that afternoon after sampling. The weight of the dust on the filters and the percent silica content of the dust were determined at the Bellair Research Center. Per cent silica determinations were done by x-ray diffraction using NI0SH method P & CAM No. 109. FINDINGS Free silica analysis was attempted and the results are reported In Table 2. Because the dust loading on the filters was so low, the free silica determinations have a large analytical error. As a result, the data are best interpreted by comparing them with the results of a similar survey done in September 1974. The main difference between the surveys was the protective hood being tested. Table 1 shows that exposure to total respirable dust was less than in September 1974. While actually sandblasting, the average ex posure was 0.42 mg/m^ compared to an average of 2.34 mg/m3 in 1974. The nearly six-fold reduction is primarily due to the better protection afforded by the Cesco air-supplied hoods. Ordinarily, the worker sandblasts much less than eight hours so his 8-hour TWA would be less than 0.42 mg/m^. Only one measurement was made for the 8-hour exposure, with the result being 0.094 mg/m^ when blasting 31% of the workday. The average of six long-term measurements in 1974 is between 3 and 4 times this measurement and workers averaged sandblasting only 12% of the time. Although, one measurement for 8-hour exposure is hardly adequate for precise determinations of such variable exposure, it does reinforce the conclusion that substantial red'udLiuu "iTT ` exposure has been achieved. DPMC-00750 LAM 007242 D. 0. CHRISMER 3 TABLE 1. COMPARISON OF THE OCTOBER 1975 SURVEY RESULTS WITH THE SEPTEMBER 1974 SURVEY RESULTS SAMPLES MEASURING EXPOSURE . . WHILE SANDBLASTING Survey Date Protective Hood 9/4-19/74 Me Donald 10/6-8/75 Cesco^ No. of Samples 4 4 Fraction of Survey Approximately Time Spent Sand 100 blasting (%) (2) Range of Results (mg/m3) 1.95 - 2.62 Average of^^ Results (mg/m ) 2.34 Approximately 100 0.18 - 0.78 0.42 Range of Free Silica Content (%) Average Free Silica Content (%) Range of 0SHAv(3)' Limit (mg/m3) Average 0SHA(v3)7 Limit (mg/m3) 27.6 - 100 78 0.10 - 0.27 0.15 (4) (4) Q) (5) SAMPLES MEASURING 8-H0UR AVERAGE EXPOSURE 9/4-19/74 Me Donald 10/6-8/75 Co esco CD 61 Average of 12 31 0.196 - 0.438 0.31 28.6 - 89.4 - 0.094 (4) 56 (4) 0.11 - 0.35 0.22 (5) (5) (1) NIOSH tested and certified. (2) Results are expressed as milligrams of total respirable dust per cubic meter of air (3) Eight-hour time-weighted average exposure limit in milligrams of total respirable dust per cubic meter of air (4) Insufficient dust was collected on filters to permit accurate determination of free silica. (5) Exposure limit could not be calculated since free silica content was uncertain. DPMC-00751 LAM 007243 D. 0. CHRISMER 4 Since equipment and sand type did not change between surveys, the free silica*`content of the respirable dust samples would not be expected to differ significantly between surveys. Therefore, the OSHA limits calculated as applicable to the 1974 findings would approximate the limits for the 1975 measurements. In 1974 the OSHA 8-hour TWA limit ranged from 0.11 to 0.35 mg/m^ for the long-term samples and averaged 0.22 mg/m^. The only long-term measurement in October 1975 was 0.094 mg/m^ which would be below the limit for 100% free silica dust (limit of 0.1 mg/m^). The table below shows the predicted 8-hour TWA on the basis of 0.42 mg/m^ exposure while sandblasting and zero exposure when not sandblasting. Time Actually Sandblasting 1 hour 2 hours 3 hours 4 hours 5 hours 8 hours Precent of Workday Spent Sandblasting 12.5 25 37.5 50 . 62.5 100 8-hour TWA 3 0.05 mg/m 0.11 mg/m^ 0.16 mg/m^ 0.21 mg/m^ 0.26 mg/m^ 0.42 mg/tP The estimates of full day exposure on this basis is crude, but it does indicate that exposure to the sandblaster is below the limit when sandblasting for less than two hours during the day. Sandblasting for two to four hours causes exposures very near the exposure limit and sandblasting for more than four hours of the workday could result in overexposure. CONCLUSIONS The NI0SH certified Cesco air-supplied hood is a significant improvement over the hood used during the September 1974 survey. The use of the Cesco hood resulted in approximately a six-fold reduction in exposure. However, the eight-hour time-weighted average exposures are still very near and could at times exceed the permissable exposure limit. RECOMMENDATIONS The following items recommended in order to insure that employee exposure is less than the OSHA limit. '* 1. Increase the effectiveness of the respiratory protection program by: a. requiring the sandblasters to use the Cesco supplied-air hoods, even though these hoods are bulkier and heavier than previous ones. b. instituting a regular inspection and maintenance of equipment by the foreman or a designated individual. c. cleaning and storing equipment in a relatively dust-free area. DPMC-00752 LAM 007244 D. 0. CHRISMER 5 ^ ^ A copy of OSHA Standard CRF 1910./34 Respiratory Protection is attached. 2. A finer sand than No. 3 was being used because of a delivery mixup. Since the finer sand can result in a higher fraction of respirable dust, stricter control in the selection and receipt of sand would reduce this occurrence. 3. Regular monthly monitoring for the next four months is advisable for sandblasters in the yard. Initial measurements should be made during sandblasting in vessels to determine the effectiveness of the protective hoods. 4. The feasibility of installing a turntable for blasting small pieces of equipment should be evaluated from an operational point of view. A turntable will allow the operator to stay upwind of his work and thereby minimize his exposure. 5. Both Martinez and the Norco plant have recently tried substitutes for sand. Martinez is trying a 35 mesh "kleen Blast" material and Norco is trying a material called "Stan-Blast". Both products are low in free silica and I will contact each location for more information. JDR:gew cc - R. L. Bryan W. H. Probst F. G. Reitz J. L. Rivard ' DPMC-00753 LAM 007245 TABLE 2 . OCTOBER 1975 RESPIRABLE DUST MONITORING RESULTS AT REFINERY SANDBLAST YARD (1) The a n a ly s is was perform ed near the a n a ly tic a l m ethod's lim it o f s e n s itiv ity . 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(a> Permissible practice. (1) In the control of those occupational diseases caused by breathing air contaminated vtth harmful dusts, fogs, fumes, mists, (ases, smokes, sprays, or vapors, the pri mary objective shall be to prevent at mospheric contamination. This shall be accomplished as far as feasible by ac cepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being In stituted. appropriate respirators shall be used pursuant to the following require ments. (2) Respirators shall be provided by the eihployer when such equipment is necessary to protect the health of the employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the .blishment and maintenance of a res. atory protective program which shall Include the requirements outlined in paragraph <b) of this section. (3) The employee shall use the pro vided respiratory protection in accord ance with instructions and training received. (b) Requirements for a minimal ac ceptable program. <1) Written standard operating procedures governing the se lection and use of respirators shall be established. (2) Respirators shall be selected on the basis, of hazards to which the worker is exposed.. (3) The user shall be instructed and trained in the proper use of respirators and their limitations. (4) Where practicable, the respirators should be assigned to individual workers for their exclusive use. (5) Respirators shall be regularly cleaned and disinfected. Those issued for `he exclusive use of one worker should be aned after each day's use, or more witen if necessary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. (6) Respirators shall be stored in a convenient, clean, and sanitary location. (7) Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Res pirators for emergency use such as selfcontained devices shall be thoroughly inspected at least once a month and after each use. (8) Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained. (9) There shall be regular inspection and evaluation to determine the con tinued effectiveness of the program. (10) Persons should not be assigned to tasks requiring use of respirators un less it has been determined that they are Physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed National Standard Method of Marking periodically (for instance, annually) : Portable Compressed Gas Containers to (11) Approved or accepted respirators Identify the Material Contained. Z48.1- shall be used when they are available. 1954; Federal Specification BB-A-1034a. The respirator furnished shall provide June 21. 1968. Air. Compressed for adequate respiratory protection against Breathing Purposes: or Interim Federal the particular hazard for which it is Specification GG-B-00675b, April 27. designed in accordance with standards 1965, Breathing Apparatus, Self-Con established by competent authorities. The tained. VS. Department of Interior. Bureau of (e) Use of respirators. (1) Standard Mines, and the US. Department of Agri procedures shall be developed for respi culture are recognized as such authori rator use. These should include all infor ties. Although respirators listed by the mation and guidance necessary for their VS. Department of Agriculture continue proper selection, use. and care. Possible to be acceptable for protection against emergency and routine uses of respira specified pesticides, the UjS. Department tors should be anticipated and planned of the Interior. Bureau of Mines, is the for. agency now responsible for testing and (2) The correct respirator shall be approving pesticide respirators. specified for each job. The respirator (c) Selection of respirators. Proper type is usually specified in the work pro selection of respirators shall be made ac cedures by a qualified Individual super cording to the guidance of American vising the respiratory protective program. National Standard Practices for Respira The individual Issuing them shall be tory Protection ZS8.2-1969. adequately instructed to Insure that the (d) Air quality. (1) Compressed air. correct respirator is issued. Each respira compressed oxygen, liquid air. and liquid tor permanently assigned to an indi oxygen used for respiration shall be of vidual should be durably marked to in high purity. Oxygen shall meet the re dicate to whom it was assigned. This quirements of the United States Pharma mark shall not afTect the respirator per copoeia for medical or breathing oxygen. formance in any way. The date of issu Breathing air shall meet at least the re ance should be recorded. quirements of the specification for Grade (3) Written procedures shall be pre D breathing air as described in Com pared covering safe use of respirators in pressed Gas Association Commodity dangerous atmospheres that might be Specification G-7.1-1966. Compressed encountered in normal operations or in oxygen shall not be used in supplied-alr emergencies. Personnel shall be familiar respirators or in open circuit self- with these procedures and the available contained breathing apparatus that have respirators. previously used compressed air. Oxygen (i) In areas where the wearer, with must never be used with ah' line failure of the respirator, could be over respirators. come by a toxic or oxygen-deficient (2) Breathing air may be supplied to atmosphere, at least one additional man respirators from cylinders or air shall be present. Communications (visual, compressors. voice, or signal line) shall be maintained (i) Cylinders shall be tested and main between both or all individuals present tained as prescribed in the Shipping Planning shall be such that one individ Container Specification Regulations of ual will be unaffected by any likely inci the Department of Transportation (49 dent and have the proper rescue equip CFR Part 178). ment to be able to assist the other(s) in (ii) The compressor for supplying air case of emergency. shall be equipped with necessary safety - (ii) When self-contained breathing and standby devices. A breathing air- apparatus or hose masks with blowers type compressor shall be used. Compres are used in atmospheres immediately sors shall be constructed and situated dangerous to life or health, standby men so as to avoid entry of contaminated air must be present with suitable rescue into the system and suitable in-line air equipment purifying sorbent beds and filters in (iii) Persons using air line respirators stalled to further assure breathing air in atmospheres Immediately hazardous quality. A receiver of sufficient capacity to life or health shall be equipped with to enable the respirator wearer to escape safety harnesses and safety lines tor lift from a contaminated atmosphere in ing or removing persons from hazardous event of compressor failure, and alarms atmospheres or other and equivalent to indicate compressor failure and over provisions for the rescue of persons from heating shall be installed in the system. hazardous atmospheres shall be used. A If an oil-lubricated compressor is used, standby man or men with suitable self- it shall have a high-temperature or car contained breathing apparatus shall be bon monoxide alarm, or both. If only a at the nearest fresh air base for emer high-temperature alarm Is used, the air gency rescue. from the compressor shall be frequently (4) Respiratory protection Is no bet tested for carbon monoxide to insure ter than the respirator in use, even that it meets the specifications in sub- though it Is worn conscientiously. Fre paragraph (1) of this paragraph. quent random inspections shall be con (3) Air line couplings shall be incom ducted by a qualified individual to as patible with outlets for other gas sys sure that respirators arc properly se tems to prevent Inadvertent servicing of lected, used, cleaned, and maintained. air line respirators with nonresplrable (5) For safe use of any respirator, it gases or oxygen. Is essential that the user be properly in (4) Breathing gas containers shall be structed in its selection, use, and main marked in accordance with American tenance. Both supervisors and workers FEOERAl REGISTER, VOL. 39. NO. 125--THURSOAY, JUNE 77, 1974 DPMC-00755 LAM 007247 23672 RULES AND REGULATIONS shall be so Instructed by competent per (11) Self-contained breathing appara Instructions usually mounted inside the sons. Training shall provide the men an tus shall be inspected monthly. Air and carrying case lid. opportunity to handle the respirator, oxygen cylinders shall be fully charged <g) Identification of gas mask canis have it fitted properly, test itsTace-piece- according to the manufacturer's instruc ters. (1) The primary means of identify to-lacc seal, wear It in normal air for tions. It shall be determined that the ing a gas mask canister shall be by means a long familiarity period, and, finally, regulator and warning devices function of properly worded labels. The secondary to wear it in a test atmosphere. properly. means of identifying a gas mask canister (i) Every respirator wearer shall re (iii) Respirator Inspection shall in shall be by a color code. ceive fitting instructions including dem clude a check of the tightness of con (2) All who issue or use gas masks foil onstrations and practice in how the res nections and the condition of the face- ing within the scope of this section shall pirator should be worn, how to adjust it, piece. headbands, valves, connecting see that all gas mask canisters purchased and how to determine if it fits properly. tube, and canisters. Rubber or elastomer or used by them are properly labeled and Respirators shall not be worn when con parts shall be inspected for pliability colored in accordance with these require ditions prevent a good face seal. Such and signs of deterioration. Stretching ments before they are placed in service conditions may be a growth of beard, and manipulating rubber or elastomer and that the labels and colors are prop sideburns, a skull cap that projects under parts with a massaging action will keep erly maintained at all times thereafter the facepiece, or temple pieces on glasses. them pliable and flexible and prevent until the canisters have completely Also, the absence of one or both dentures them from taking a set during storage. served their purpose. can seriously affect the fit of a facepiece. (lv) A record shall be kept of inspec (3) On each canister shall appear in The worker's diligence in observing these tion dates and findings for respirators bold letters the following: factors shall be evaluated by periodic maintained for emergency use. <D-- check. To assure proper protection, the facepiece fit shall be checked by the wearer each time he puts on the respira tor. This may be done by following the (3) Routinely used respirators shall be collected, cleaned, and disinfected as frequently as necessary to Insure that proper protection Is provided for the Canister for (Name for atmospheric contaminant) or Type N Gas Mask Canister manufacturer's facepiece fitting instruc wearer. Each worker should be briefed (ii) In addition, essentially the fol tions. (ii) Providing respiratory protection on the cleaning procedure and be assured that he will always receive a clean and lowing wording shall appear beneath the appropriate phrase on the canister for individuals wearing corrective glasses disinfected respirator. Such assurances label: "For respiratory protection in at is a serious problem. A proper seal cannot are of greatest significance when respira mospheres containing not more than be established if the temple bars of eye tors are not individually assigned to percent by volume of glasses extend through the sealing edge of the full facepiece. As a temporary measure, glasses with short temple bars or without temple bars may be taped to the wearer's head. Wearing of contact lenses in contaminated atmospheres with a respirator shall not be allowed. Sys tems have been developed for mounting corrective lenses inside full facepieces. When a workman must wear corrective lenses as part of the facepiece, the facepiece and lenses shall be fitted by quali fied individuals to provide good vision, comfort, and a gas-tight seal. Oil) If corrective spectacles or goggles are required, they shall be worn so as not to affect the fit of the facepiece. Proper selection of equipment will mini mize or avoid this problem. (f) Maintenance and care of respira tors. (1)A program for maintenance and care of respirators shall be adjusted to the type of plant, working conditions, and hazards involved, and shall include the following basic services: (1) Inspection for defects (including a leak check), (ii) Cleaning and disinfecting. (iii) Repair, (lv> Storage Equipment shall be properly maintained to retain its original effectiveness. (2) (i) All respirators shall be in spected routinely before and after each workers. Respirators maintained for emergency use shall be cleaned and dis infected after each use. (4) Replacement or repairs shall be done only by experienced persons with parts designed for the respirator. No attempt shall be made to replace com ponents or to make adjustment or re pairs beyond the manufacturer's recom mendations. Reducing or admission valves or regulators shall be returned to the manufacturer or to a trained technician for adjustment or repair. (5) (1) After inspection, cleaning, and necessary repair, respirators shall be stored to protect against dust, sun light. heat, extreme cold, excessive moisture, or damaging chemicals. Res pirators placed at stations and work areas for emergency use should be quickly accessible at all times and should be stored in compartments built for the purpose. The compartments should be clearly marked. Routinely used respirators, such as dust respira tors, may be placed in plastic bags. Res pirators should not be stored in such places as lockers or tool boxes unless they are in carrying cases or cartons. (ii) Respirators should be packed or stored so that the facepiece and exhala tion valve will rest in a normal position and function will not be impaired by the elastomer setting in an abnormal (Name of atmospheric contaminant) (iii) All of the markings specified above should be placed on the most conspicuous surface or surfaces of the canister. (4) Canisters having a special highefficiency filter for protection' against radionuclides and other highly toxic par ticulates shall be labeled with a state ment of the type and degree of protec tion afforded by the filter. The label shall be affixed to the neck end of. or to the gray stripe which is around and near the top of, the canister. The degree of protection shall be marked as the per cent of penetration of the canister by a 0.3-micron-diameter dioctyl phthalate (DOP) smoke at a flow rate of 8S liters per minute. (5) Each canister shall have a label warning that gas masks should be used only In atmospheres containing suffi cient oxygen to support life (at least 16 percent by volume), since gas mask canisters are only designed to neutralize or remove contaminants from the air. (6) Each gas mask canister shall be painted a distinctive color or combina tion of colors indicated in Table 1-1. All colors used shall be such that they are clearly identifiable by the user and clearly distinguishable from one another. The color coating used shall offer a high degree of resistance to chipping, scaling, peeling, blistering, fading, and the effects use. A respirator that is not routinely position. of the ordinary atmospheres to which used but is kept ready for emergency (iii) Instructions for proper storage they may be exposed under normal con use shall be inspected after each use of emergency respirators, such as gas ditions of storage and use. Appropri and at least monthly to assure that it is masks and self-contained breathing ately colored pressure sensitive tape In satisfactory working condition. apparatus, are found in "use and care" may be used for the stripes. FEDERAL REGISTER, VOL 39, NO. 125--THURSDAY, JUNE 27, 1974 DPMC-00756 LAM 007248 -r LAM 007249 DPMC-00758 lam 007250 DPMC-00759 LAM 007251 LAM 007252 LAM 007253 LAM 007254 . 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