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United States Department of the Interior BUREAU OF MINES Denver Federal Center, Building 20 Denver, Colorado 80225 PLAINTIFFS EXHIBIT UC-1289 Health and Safety Technical Support Center January 28, 1972 Mr. F.H. Larrison, Resident Calidria Asbestos Plant Union Carbide Corporation Mining and Metals Division Box K King City, CA. 93930 Manager ucc - cal!o.-.:a KIN= *:ty. Dear Mr. Larrison: Enclosed is a report covering the asbestos dust (health) survey of October 4-6, 1971. Thank you and members of your staff for cooperation during-* the survey. Sincerely, Glen W. Sutton Chief, Denver Technical Support Center cc: R.J. Kronkhyte, Maintenance Supt. and Safety Engineer UNITED STATES DEPARTMENT OF IHE INTERIOR BUREAU OF MINES HEALTH AND SAFETY TECHNICAL SUPPORT HEALTH STUDY (ASBESTOS DUST) CALIDRIA ASBESTOS PLANT KING CITY OPERATION UNION CARBIDE CORPORATION KING CITY, MONTEREY COUNTY, CALIFORNIA October 4-6, 1971 By Walter Bank, Mining Engineer Amin N. Alameddin, Mining Engineer Kenneth L. High, Mining Engineer i-'i 'ii< z-x 'L /rf y Tcil 4J,ja it . S^vv- e>/ - ;; . -4c .. - 9 - DENVER TECHNICAL SUPPORT CENTER Mr. Glen W. Sutton Chief Originating Office S. Bureau of Mines, Health and Safety Technical Support Center Denver Federal Center, Building 55 Denver, Colorado ..80225 A . 795 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF MINES v Mine: Calidria Asbestos Plant Company: Union Carbide Corp. Mining and Metals Div. Operated by: same as above I.D. No: 40013-00-04-027 Underground ___ Open Cut __ Survey by: Walter Bank, Amin Alameddin, and Ken High Location: King City, Monterey County, California Survey dates: October 4-6, 1971 DISTRIBUTION: Company officials: F.H. Larrison, Resident Manager (3) R.J. Kronkhyte, Maintenance Supt. and. Safety Engineer Assistant Director--Health and Safety Technical Support (2) Assistant Director--Metal and Nonmetal Mine Health and Safety ( Originating office: Technical Support Center, Denver, CO. (2) State agencies: California Div. of Industrial Safety Dept, of Industrial Relations 455 Golden Gate Ave. San Francisco, CA. 94102 Attn: Walter Van Sandt (1), Edward Davies District Manager: Allan Look, Alameda, CA. Subdistrict Mgr: Howard Poland, Alameda, CA. * (1) Other: Ernie Piersol, Safety Director (2) Mining and Metals Division Union Carbide Corp. P.0. Box 1049, Grand Junction, CO. 81501 A ;795; Identification No. 40013-00-04-027 INTRODUCTION This report is based on a study made pursuant to Section 5 of the Federal Metal and Nonmetal Mine Safety Act (80 Stat. 772, P.L. 89-577, 30 U.S.C. 721-740). The report supplements the Health and Safety Report dated September 20, 1971 pre pared by J.L. Weddle of the Bureau's Alameda, California office. GENERAL INFORMATION The Calidria Asbestos Plant, Ring City operation of the Union Carbide Corporation, Mining and Metals Division, is located about 5 miles southerly from King City on Wild Horse Road about one mile from its interchange on U.S. Highway 101. The mailing address is Box K, King City, California. Mr. F.H. Larrison was Resident Manager and R.J. Kronkhyte was Mainte nance Superintendent and Safety Engineer. Mr. Larrison * accompanied the investigators during part of this study, and visual observations and provisional recommendations were discussed with him at the end of the sampling campaign. . Total mill employment consisted of 50 men as of October 5, 1971, the date of the survey. Production crews worked three 8-hour shifts, 5 days a week, and maintenance and distribution crews worked the day shift. There were 16 salaried employees. The mill went into production in 1963. The plant uses a wet milling process for the chrysotile asbestos and produces four types of material. The standard grade is bagged and shipped in perforated multiwall paper bags of 50 pounds (pellets), 40 pounds (open fiber) and 30 pounds (open fiber) capacity. The Super Standard is ground finer and is bagged in 30-pound bags. The High Purity asbestos, used for paper manufacture, is bagged into 50, 40, and 30-pound bags. The Resin Grade (a specialty product) is bagged in 10-pound bags provided with plastic outer sheaths. The product is transported by truck or- by the Southern Pacific Railroad; however, it is never shipped in bulk. The asbestos is shipped to many points throughout the United States and overseas. Estimated pro duction for 1971 is 20,000 tons, and the life expectancy of the operation is indefinite. The following structures are located on the property: 1. The mill, which is a metal building of 14,400 sq. feet. 2. A wooden office and laboratory building of 1,320 sq. feet. 3. A two-story metal warehouse-office-shop building of 2,400 sq. feet. A i 795O 4. A metal, open-sided product storage shed of 10,960 sq. feet. 5. A rubberized-cloth inflatable building of 6,426 square feet. An ore stockpile, estimated to contain about 35 ,000 tons , was located across the roadway. Ore was delive red to the stockpile by a 25-ton capacity truck and traile r, dumped on top the stockpile, and pushed by a bulldozer to blend the ore and to provide a more level surface or roadway for the ore truck. A front-end loader with a 2 1/2 -yard capacity bucket trammed ore from the stockpile to the lo ading point which leads to the COM bin - the start of the o re processing. A tailings pile, estimated at 15,000 tons, was immediately adjacent to the ore stockpile, Product recovery was 50 percent the 50 percent wet tailings was stacked by means of an in dined belt conveyor. When the waste pile becomes too large and overflows onto the roadway, the waste pile is cut down to size and the waste is hauled to a nearby ravine by a means of self-loading paddle wheel scraper. While the dust survey was in process, M. Walter A. Van Sandt, Industrial Hygiene Engineer and Mr. Ed Davies, Safety Engineer of the California Department of Industrial Relations visited the operation, discussed our sampling techniques, collected several samples for record purposes, and furnished the writers with information on this and other asbestos plants. DESCRIPTION OF STUDY Asb es tos airborne dus t is plant of this ch aract er. demons tr ated to cause the and lung cancer. the overriding he alth hazard in a Airborne asbes tos dus t has be en pneumoconiosis ca lied asbes to sis All cont rol meas ures applicable to miner al dus t control can be used for airb orne asbestos; however, the more hazard ous n,nat ure o f asbest os re quires more stringe nt adhe rence to goo d con trol pra cti ce s. At the Calidria mi the foil owing con ditions and p racti ces were noted: 1. The s tockpil e was kept wet most of the time . the o re contains 20 p ercent moisture. Repor tedly 2. Prev ailing w inds are from the north. an d bl ow the s tockpil e-cre ated dus t away from the mill. 2 A : 795C 3. The front-end loader, normally used for tramming ore from the stockpile to the ore bin, was- provided with an enclosed cab with blower attachment. The spare front-end loader (used during the survey) was not provided with an enclosed cab. 4. Offices were enclosed and isolated from dust-producing operations. 5. The asbestos processing was a wet operation. 6. Production of a pellet prior to drying decreased dust creation and dissemination in the later packaging and shipping operations. 7. Housekeeping was a continuous process. Outside areas were cleaned as needed. Vet areas in the mill were washed down at least once a shift. Dry areas were swept with a push-broom and the sweepings from the bagging and palletizing areas went back into the circuit. 8. Both the Standard and High Grade processing systems were provided with dust collectors. 9. A dust collector system was being installed in con junction with the bagger; the incomplete system was used currently to vacuum employees clothing. 10 . USBM-app rove d res: pi r ato rs were wo rn by (a) the doze r ope rator ; (b) the b agger ope rat or; (c) the palletize r operator; and (d) the front -end loade r op erator. 11. The assay office was ai r-c onditioned and provid ed with fil tered air. A fume hoo d w as availab le. A vacuum cleaner was used to clean the ben ch and other equipment. 12. The account! ng and o the r o ffices we re air-condi tioned and provided with filtered air. All offices were swept regularly. 13. In the electrical shop, compressed air jets were used to clean equipment. This cannot be considered a good-housekeeping practice. 14. An engineering surveillance program was maintained. A monthly sampling program was carried out by a resident laboratory technician who sampled seven locations using a Unijet pump and Millipore filters. Mr. Paul W. McDaniels, Industrial Hygiene Engineer for Union Carbide Corporation, reportedly visits the plant twice a year to check the program and to make pertinent recommendations. 3 A . 795 15. A medical surveillance program was reported In effect. The reported program Included a pre-employment physical examination followed by an examination every three years until age 40; thereafter, an annual physical examination Is provided. During the survey sampling, the weather was clear and dry with a slight wind blowing intermittently. At noon, the temperature was about 90 degrees and the humidity was about 13 percent. The effectiveness of the control measures will be dis cussed later in this report. Sixty-six samples were collected. Of these, two Nuclepore samples were submitted to Dr. Phillip DeNee, Safety Research Center, Bruceton, Pennsylvania for evaluation. Results of his work will not be included in his report. A settled dust sample and a sample of the purified product, collected from the filter press, were submitted to the Field Health Group analytical laboratory; results of these afialyses are included in Appendix I. Sixty-two airborne asbestos dust samples were collected on membrane filters using pumps calibrated, at the mill office to pull 1.4 liters per minute of air; these samples were counted in the Denver Field Health Group laboratory at approximately 460 magnification with phase contrast illumination according to the method established by the U.S. Public Health Service. Full-shift exposure samples were collected of three individuals who were exposed presumably to high asbestos dust concentrations sufficient samples were collected of other representative individuals or of locations where men worked to indicate the dust exposure levels. DISCUSSION AND RESULTS In 1967, the published TLV 1/ was 5 mppcf (millions of par ticles per cubic foot of air) for asbestos-bearing dusts when collected conventionally with the impinger or midget impinger and counted conventionally with the standardized light-field counting method. The number concentration represented the visible fragments (small) of asbestos fibers plus the many associated mineral dust particles. In 1968, the published "Notice of Intended Changes" proposed that (1) the 5 mppcf be reduced to 2 mppcf; and (2) an alternative figure of 12 fibers/ml (fibers per milliliter) greater than 5 microns in length be adopted -- this figure 1/ Threshold Limit Values for 1967, Recommended and Intended Changes; American Conference of Governmental Industrial Hygienists, 1967. t 4 A i 7 9 5 '"N o was to be based on the membrane filter method at 430X phase contrast magnification. The above two proposed changes were retained in 1969; in 1970 the published proposed changes (1) dispensed entirely with the impinger sampling method and its number concen tration figure; and (2) recommended that the alternative value be changed from 12 fibers/ml greater than 5 microns in length to 5 fibers/ml greater than 5 microns in length. In 1971, the "Notice of Intended Changes" retained the 1970 proposal, and specified the membrane filter method at 400-450X magnification phase contrast illumination. Also, an excursion limit not to exceed 10 flbers/ml may be per mitted for 15-minute periods each hour up to five times daily. For purposes of this health study, it is believed that the 1971 proposed TLV figure and sampling method provides the best indication of the asbestos dust health hazard. This, value has also been accepted by the U.S. Department of Labor and on December 7 an emergency standard of 5 fibers/ml was published in the Federal Register. Therefore, the pro posed 5 fibers/ml (on a time-weighted basis) is used as the threshold limit value. Fiber concentration and pertinent data for the individual airborne dust samples are listed in Appendix II. Fiber con centration data are summarized in Figures 1, 2, and 3. Figure 1 summarizes the time-weighted exposures of three men. The bagger operator was exposed to eight times the TLV and had a one-hour exposure of 12 times the TLV figure. The palletizer operator, working nearby, was exposed to 6 times the TLV and also had a one-hour exposure of 12 times the TLV figure. Both men were provided with U.S. Bureau of Mines approved respirators which they wore when working in obviously dusty atmospheres. The exhaust system at the bagging operation was inadequate to control the spillage and dust emission, and as the newlyfilled perforated multi-wall bags were conveyed to the palletizer, dusty air seeped from the bag's pores and con tributed to the asbestos dust load of the ambient air. When bags broke during the bagging operation, the exhaust system at floor level failed to capture the spillage; sweeping the dust spillage to the floor launder contributed to the dust load in the air. As previously mentioned, an additional dust-collecting system was in process of installation at this area. 5 A .795J The exhaust system at the top of the palletizer admittedly was not working properly and required repairs. When broken, bags were dropped to the floor beneath the palletizer, and subsequently the bags and asbestos were removed. The foreman's time-weighted exposure was 7.6 fibers/ml with one sample recording a one-hour exposure of four times the TLV figure. The foreman made his rounds unaccompanied by the man collecting samples. The source of the dust con tributing to the foreman's exposure is considered (provisionally) to be the general mill atmosphere. Other workers' airborne asbestos dust exposures were obtained on a when-sampled basis. As shown in Figure 2, the exposures of the mechanic, the bagger of the resin-grade asbestos, and the filter-press operator were within acceptable limits when sampled; the exposure (arithmetic average) of the loader operator was six times the TLV figure with a one-hour ex posure of eleven times the TLV figure. A number of working areas were sampled to assist in evaluating the workers' exposures; the airborne asbestos fiber concen trations are summarized in Figure 3. Mine yard "general atmosphere" samples collected during the greater part of the workday suggest that wind dispersal from the ore stockpile or tailings pile was not a significant factor in the workers' samples collected in the mill. Sut it is recognized that at times the wind direction and velocity may become significant factors in contributing to a hazardous dust environment. Low asbestos fiber concentrations were obtained in the accounting office, the main (upper floor) office, the welding shop, and the assay office. The roll mill area of the mill had an arithmetic average concentration of 8.0 fibers/ml. The high concentration of 17 fibers/ml of sample B-105 indicates a need for better dust control.measures at this "wet" operation. The cause of this high concentration was not apparent. The foreman's office sample results yielded an arithmetic average of 7.5 fibers/ml with a high concentration in sample B-23 of 11 fibers noted between 1:38 and 2:38 p.m. The office door opened to an area partitioned from the dusty bagging and palletizing area, so the specific cause of these concentrations was not obvious. The dust concentrations are provisionally attributed to the ambient air dust load and the dust from the workers' clothing during the time they occupied the office. 6 A .7 93,'' The electric shop area sample results yielded an arithmetic average of 3.2 fibers/ml. This concentration is attributed largely to sample 8-103 which was collected during a period when a compressed-air jet was used for cleaning some electri cal equipment. CONCLUSIONS AND RECOMMENDATIONS The time-weighted exposures of the bagger and palletizer operator were very high. Although considerable effort has been made to control dust in the mill, air sampling revealed that the air quality is not satisfactory and must be improved. Engineering methods, such as, but not limited to the following re commendationsshall be used to meet the exposure limits prescribed in the standard. 1. Enclosure of operations to prevent spillage and dispersion of material shall, where feasible, be utilized. The bagger area should be enclosed, and if properly designed and operated, can protect the bagger and reduce the dust loa<f of the ambient air. The dust control system being installed should be completed. * 2. Enclosures, hoods, and other devices to contain and collect material, especially airborne dust shall be maintained under negative pressure through the use of local exhaust ventila tion . 3. The air collected by the local exhaust ventilation system shall be cleaned through the use of adequate, well main tained bag collectors, or other devices equally efficient, and the filtered air shall be discharged outside the work area and not be recirculated. 4. Vacuum cleaning shall be used rather than manual sweeping or blowing with compressed air. 5. The dust collection devices and system must be maintained and utilized in a manner that will result in its operating in an effective manner. If the dust control system should fail, operations should be suspended until repairs are completed and the system is capable of maintaining dust concentrations below the standard. 6. Encapsulate the filled bags with plastic bags in the same way the resin-grade asbestos bags are handled. 7 A ' 7 9 3 I To diminish the exposure of the loader operator, the following recommendations are made: 1. Keep the stockpile wet. 2. Provide an enclosed cab with filtered air on the loaders; the-spare loader in use during the survey did not have such a cab . 3. Improve the housekeeping in the Immediate area. For example, the concrete ramp leading to the conveyor system was hidden beneath spilled ore. The use of respirators in the work area shall not be con sidered as a substitute for engineering controls and their continued use over prolonged periods shall not be permitted. However, to protect the workers prior to the application of engineering controls which result in exposures and/or con centrations below the standard, respiratory protective de vices shall be provided, maintained and their use required. The respiratory protection program shall include adequate* training and supervision of employees in the testing of respiratory protective devices for fit before their use. The employees shall be required to test his respiratory protective device before each use in order to insure a proper fit. Respiratory protective devices to be used shall be limited to the following: 1. For an atmosphere containing not more than 25 fibers/ml greater than 5 microns in length over an 8-hour average or more than 50 fibers/ml over any period of 15 minutes, a reusable or single-use filter type respirator, operating with negative pressure during the inhalation phase of breathing, approved by the Bureau of Mines under Schedule 21 shall be used. B 2. For an atmosphere containing not more than 250 fibers/ml greater than 5 microns in length over an 8-hour average or more than 500 fibers/ml over any period of 15 minutes, a powered filter positive pressure respirator approved by the Bureau of Mines under Schedule 21 B shall be used. The tailings pile, when dried, is an obvious source of air borne dust during windy conditions. Keeping the tailings pile wet continuously and removing it to a more distant lo cation will minimize dust conditions in the mill, shop, and office areas; however, other measures must be taken to mini mize its impact on the community environment. 8 A .7952 A sbestos F ib e r C o n c e n tra tio n s in M ill, Tim e-W eighted E xposures z o O Asbestos Fibers/ml, >5 Microns in Length 'Hll- i CO UlV/iOVO\vlJOOOOVOVOI-* 30 Cn S3 aa -U----i-O----C----/-i-O-----U---i--O----V---/--i-O----V---/--i-----O----U-----i-O----U-----i-O----U-----i-O-----C----n---O-----U----i-O- o. A CO Bagger operator f00 N> Ul VO U> Palletizer operator N> U> ro * u> Foreman t- H O H* H* "d o a o CO A a Hor Ai a 3" O O. < At-* c A A ;7-9S3 A;796; Asbestos Fibers/ml, >5 microns in Length A rith m e tic F ig u r e 2 . A s b e s to s Fi b e r C o n c e n tr a tio n E x p o s u re s I n M i l l -- On a W h e n -S a m p le d B a s is z o F ig u re 3. Asbestos F ib e r C o n c e n tra tio n s , v a rio u s lo c a tio n s Asbestos Fibers/ml-, >5 microns in length zo z o oHn H H N N) U V-n O Vn O \jx CO CD T93 H* CD CO Lower office, accounting O Upper office, main I u r Electrical shop ,. JS . "VO Welding shop 3 KO lo e* o t-1 o 01 >*F < rr (t> 3* 1 3 CD <0 0(0D rHe- ! 03Q" .I ' ` , * A ; 79So APPENDIX I Mineral Analyses Sample No. B-902 B-904 Description Percent Free Silica Filter-press product 0 Settled dust near COM bin 4 Remarks Diffractometer scan showed broad lines identified as being from serpentine 1/ Same 1/ Additional mineral and elemental information will be added to this report when available. A i 7963 03 He Bo h 00 O M H B x> m Pk A d o H 44 CO Ik 0) & o "*>-- c o H 4-1 CO o o a o m CM i-k vO en on cn CM CM m m PH m un -4 9 00 e 00 40 pH c 00 nN H e 00 Xi 00 <H 4J pH c CO o cM c0 -H 00 n pH 0) # u 00 4-1 00 co 00 pH a V H o 00 lO o 00 pH co Ch N 0) 3 CO v CO CO pH O 03 S -a C 00 0) o A a. S k M * o Ik e> 0k H o 0k 0k 0k hi M u Q. Ik N 43 u M M M o CM o o pi CO o O O O a o H o o o U o0Oo3 H pH *H ai 1--1 0) a pH pH pH pH d M Xi CM 00 CM pH co CM CM CM CM CO U 00 pH 01 H o pH a pH CO 01 pH pH pH pH iH CM pH,, uo pH BQu pH pH pH pH U X X Vi XX X XpH pH H CO pH pH pH pH PH 0 00 CM CO vO m 00 pH r-4 i-k CN co -3 v) cn 01 01 00 u ud d 00 d H 0 CO d a 0N 0 d 00 -H d 00 tH 00 00 01 d <-> 0) c 4J 4J h a 44 H a> cd H d 00 hi d 00 f--1 00 00 H oo a> H 00 --1 00 00 CO CO BL CO co co co CO B 0 43 o B 43 a A 43 N0 ik 03 0k 0k 0 0k k 0k a 0k 0k M hi Ik M M M M 3 M u 0 O 0 o o CM O 0 O O d O o cu 0 O o o pH 0 u o o CO o 0 3 pH CO i-H iH pH pH 00 pH pH 0) pH pH d CM t4 <4H kk J* CM kk CM CM iH CM CM CO s U B a ai pH iH i-H o pH pH pH pH pH i--4 pH <0 iH r4 CM pH 0 pH pH 0 pH pH U Xpi H X tX4 H XpH pi X pH pH X co 44 & (-1 MV Ma X aa> io-i a z CChd 0k *< k4 <D N tt) Pk oJ o *4- rn cn m VO o o B o| cn 4- cn cn m c> m o o-H 00 on pH PH CO vO o oH w| pH pH pH pH pH pH ec d H rk 441 a Ik o CTJ 00 cn cn VO o B a o cn ^4 cn cn cn cn a 44] 00 co ON pH cs cn *0* C/3 co| o o o pH pH pH pH pH o 00 pi o 00 <* o cn ^4- cn cn cn o o00 ON pH CM cn 4* sO o o pH pH pH' pH pH pH vO pH ON o 00 <r <* o cn -S' 4* cn cn cn o00 00 o\ pH PH cn o o o pH pH pH pH 0) cd m Q o 01 ao 5 Z pH 4" fwrt 11 o cn p*h <r p1H p1H pH1 P1H P1H CO 00 CQ OQ OQ CQ 00 CO CQ m o pH 00 ph m 11 11PH in oo pH pH pH PH PH ii || || OQ 03 OQ OQ OQ OQ OQ A . 7967 a 03 1 1 03 1 03 03 11 03 I 03 1 o11s os 11 03 03 1 03 r 03 03 11 03 03 03 00 03 03 03 03 11 03 1 cn 03 PP PP P O N3 N) OO ro O Pp to to P to PP to to P to PP to N3 P P to to to P P NO O' oo "*4 o O' to U Z o 3 d ON P in X* W 'vj On IH X* U to P o O p o PP P P P OO O OO "S* Ln in Ut in in *** `"V* """S* **o PP P pM P o a in CD rr -sj CD P PP PO to to ON In O NO to u> PP LO to Oo ON x* P O in O PP in X* Oo to to P Uo3 to PP X- U X* X* ON in P to x* u PP X* 13 u 10 Po P to to m PPPPPoo in X* 13 to O vO vO O O o O m X* o P u> On ON 10 NO VO O W CO 03 rr 03 P 13 03 a n o rr P 3 JO PP to P P o M I-* O* UJ P to PP On in P x* PP in X* P 13 PP in x P 10 P P P P PP O On in X* U to o VO o VO I! to to to Ui O O O O o X* X* X* 10 u to O O o o o in X* o ON in 13 (s> O' X* to to to On in 13 P O in P O 10 ON ON to NO 00 p H* of 03 P p oo z A rt rt CL 00 3* o**1 Ch o H A 3* (9 A A P H 3 H o *H 3 H* O 9 -3P H rt 3 rt wa a A rt p A to H* rr 3 N> oo O rt 00 an rt p p rr CL A O A 0 1 o aa a rHt> rt 3 O 3 CO CO Z 03 p H- 3 3 os h- A A A H* 3 < 03 03 <0 CO CO 03 o p p H* ar O* H* o o 03 < < rr 9 ro A 3 H* OM H* Hi A A CL V in O' U3 -*o CO CO z p 03 H* 3 3 O H* A A T3 H- 03 03 CO CO *T3 Hi H* 03 p A H IT IT 0) ft O O CD A < < * H AA CO *0 NH A CD CO p >i A P V OO S3 in 13 o in CD CO o 03 03 3 3 3 o rt A A n CO A H* 03 P CL CO CO A OS p p N3 a* cr H* oo M << AA H* w rr H P 3 9 H- 3 OO in N3 o p* M CO CO z 03 03 p 99pp A Anp Aw 03 P P CO CO -< A p p 9 CD cr o* P P o o CO 3 <<o A A OO oP a CL AA p 3* rr P H- 00 O OO 3P CD 3 < oo os P* p N N3 *> vO CO CD z pp p 331p AAAp T3 p 03 p CO (0 P < n 03 por p 3" rt P o O o A. << Q. <T> A 7T P O OS rt NP rr p o a3 oO po o P CD CO CD CO CD 09 CO 03 03 p p p 03 p > CO 3 9 3 3 3 3 3 H cr AAAA AAAoA c CO 03 CO 03 CO P CO p CO P CD 03 CD 03 09 3 rr CL o CO CD p p 03 p p p 0> a* IT O- cr 3* 3* o* 13 o O o o O O o 09 P < < < < < < < N 03 A ro A ro A (0 A 3 rr V 3 P ?r P 3 * 00 u> u> K9 in o 1*3 in in X* U u> in P VO 00 o o p rr P O 9 o o (D rt P rr t-L o 3 V rtl in P o* 9A P rt o CD rt o3 PM CO >*3 3 W Z O M A V7963 03 pH e ao Vi a Cl Vi H a a A i-t m Cx A O o\ A A U ON co VO rH co pH c o H M-4 MM o U CuO 03 o 01 a o e a 01 0) a> 2E VI a > o >> oo 4) U3 x> A g Vi H a CO a Q Oa vM VM u a 03 co iJ CO .o A a CO a *G H V 0) a) 01 o H 60 E 6 S H <0 (0 si X CD a) a -fl- o a- NO o pH . o CM oooo 4) H o o. eo A -H o vw e at u> i <0 o A "a H a v at at u 09 v 0) 03 a at at at e ME 1-1 CO X 03 CO A Vi (0 00 e T3 o at S at 9 VI > 03 o -a a H A v< at a l-i at . at a s at at at c 00 B H at s at CM r** O' pH pH pH o o a 4J CO r-1 a Vi at c at 00 at A >> oO AA &aA CO pH at A AA >> CO at A 03 S s 03 A A <AA f--I m cm H -H O k 00 G 4J e. 3 O a u A m O E A VI UA H <Vf H <vt A o Vi A V4 C AAA 3 oo e o CO J 03 A E A A On o On CO o CO CM pH On CO O' o o H CO i-i 0c) A 00 * a* o JS 03 03 09 > > oO pH oA Xi 03 CO <0 O H 03 0) U o CO <0 uB u VI 0) 03 0) A e e pH CO CO W 03 CO oo o a 4J CO CO Vi a' e A 00 . 03 03 A>> Cl O O H pO O co co VM O CO CO CO co Vi A 0) 03 aE 6 a cO CO S3 03 03 e o APPENDIX I I Oe -th*. A Si VO s CO 1-1 <\l r** 00 O co CO o CO VO 00 aCM 00 o m VO m CM O o m m vO ps. H H pH ON o pH O m o> CM m mm o pH < O o m vO oO fH CM CO < m pH pH pH o pH CM oH W1 pH fH fH H pH H H H iH pH o pH pH pH pH pH pH pH pH OC e i-i t-4 VI a Vi EA O m A VI rH rsi 00 00 co co CO CM co O CO O 00 CM O o vO m CM U- VO P^ iH H pH 00 ON O o 00 CM in mm ON o < o ON m VO oO o pH CO O' m fH pH pH ON o pH o o o o oCO CO pH H tH H i-H iH pH -H O pH pH pH pH pH pH H fH pH iH pH pH pH A Pn. PN. r** r** VI # Am 1*1 m m m m m a o oooo o o rH pH pH iH pH pH pH A H pH m CM vO vO O CM Pv CM cn 00 <r ON CO a. o m ON co vO O O O O O O pH O o fH o o pH o o rH E z pH pH CM CM CM CM CM CM iH pH pH pH pH pH pH pH pH pH pH pH A 1 1 1 1 1 1 1 11 1t 1 1 V) CQ CQ CQ CQ CQ CQ CQ 00 CQ CQ CQ CQ CQ CQ CQ CQ CQ CQ CQ CQ A ; 7963 APPENDIX I I 00 c f> o g o CO I-' o m 00 a o o o u H fl e .O H LO IM A CO cM o 0) c u 0) (0 00 m a o * a o M Q4) >> oo MM e 0) CO CO o oCoOOcoCOcn a u o H g 8 u ii HOSE 0) . CO CO 3 co co c o u a M U CO a) a l-c o 0) H M O J 0) o4 g o] H H s| OC e H H jj| a Ml g a| (0 Mil CO co| CM *3* cn i-h CM 3" CM iH CM CM < m iH H CM CM *3* cn <* t-H rH V co m Q o a --I ao 6 25 a} C/i m l CQ r*. co rH i-* -H II ea cq A ; 7 9 7C January 18, 1972 Hr* Frank Varrsa Senior Safety lagiaeer State of Californio Sept, of Industrial Belotiooo .'irizon of Industrial Safety 255C Mariposa St., Boon k06$ -"rfmo, Californio 93721 Sear Mr* barrenr As required in your Aeeident Prevention Eeport of 11-30-71, the tagging operator baa been provided, and ia required to wear, an air supplied hood unit while performing the datieo of hia 3b* The other operator in the pallatiaer area, hao been supplied with a 21-B rated cartridge type res pirator. The teo operatera are rotated during the shift so that neithor operator epanda full ties in the cartridge respirator* Our cospany Industrial Sygiensst, Mr* P* V* Xa2aaiels, baa checked the air supplied hood unit under operating conditions aad has determined that the hood internal otsoaphere is leos than TLV. Very truly yours. Floyd K. Larrloon, Jr. Manager, King City Operations /elg cc: E. A. Pieraall 5. J. Kronkhyte A i 797 i