Document ykqjYmMmz5o9o56EKKjn0w7jr

Interoffice Communication To Distribution From Date Ronald E. Thompson January 15, 1986 JHfc... WG3. Subject PROPOSED OSHA RULE ON BENZENE rsj FILE----------- Attached is a summary on OSKA's benzene proposal that was prepared by API. Also attached is Mary Ann Chance's memorandum of December 26th on the same subject. My primary concern relates to who in Conoco will be covered thereby triggering the initial monitoring requirements. The areas apparently excluded ares1 2 3 4 1. Production 2. Distribution operations downstream of the truck racks at product terminals. 3. Truck racks with vapor recovery equipment (Larry Clynch advises that Conoco has 29). 4. Normal pipeline operations for both products and crude. The areas apparently Included are: 1. Truck racks without vapor recovery (Larry advises there are 6). 2. Refining operations where there are streams with in excess of 0.5% benzene. 3. Other areas where liquid mixtures with more than 0.5% benzene might be present or used, (barge operations, solvents, etc.) The areas at question (at least to me) include: 1. Work operations around gasoline stored in floating roof tanks (does this constitute a sealed container?) 2. Work operations around crude tankage. Terry Waltrip advises that some crudes exceed 0.5% benzene and many exceed 0.1%. Since many crude tanks are cone roof, this could include a larger number of people (i.e. gaugers, deliverymen, etc.). SAL 000000979 5 (1) Urinary phenol. (2) If urinary phenol is 3 months. 75 mg/1/ CBC after 4. Special exams a. Criteria: (1) Hemoglobin <14 grams percent for males or <12 grams percent for females; and hematocrit <38 for males of <34 for females/ and/or these indices show "a persistent downward trend" which "cannot be explained for other medical reasons". (2) (3) Thormbocyte count >15% below the most recent value or is <140/000/mnr . Leukocyte count is <4/000/mm3 or there is an "abnormal" differential count. b. Procedures: (1) If criteria are met, repeat CBC within 2 weeks. (2) If criteria persist/ refer worker to a hematologist or internist/ and worker is temporarily removed frbm workplace exposure. (3) After special exam/ the physician must determin whether to allow the worker to return to exposure/ in consultation with hematologist/internist. E. Methods of Compliance [para, (f)/ (g)] 1. Engineering and work practice controls required except: a'. Where the employer can establish they are not "feasible"/ "such as" maintenance/ repair/ vessel cleaning/ or other operations where such controls "are infeasible because exposures are intermittent in nature and limited in duration". b. Where "benzene is present in a workplace" 30 days per year. SAL 000000980 Medical Survellance [para, (i)] 1. Timing a. Initial exams within 60 days of effective date. b. Previous exams within 6 months of the effective date of the final standard are grandfathered. c. Repeat exams every 6 months. ^ 2. Coverage 4. Workers exposed >_AL 30 or more days per year. b. Workers exposed ^PEL 10 or more days per year. c. Worker formerly exposed to _> ppm for 30 or more days in any prior year by current employer. d. For workers exposed to an "emergency" (an "unexpected significant release"). 3. Elements a. Initial exam: (1) Detailed occupational history. (2) Complete physical examination. (3) CBC and additional tests "as necessary in the opinion of the examining physician". (4) Pulmonary function test and chest x-ray for workers required to wear respirators 30 days per year. b. Repeat exams: (1) Brief history. * (2) CBC and additional test " as necessary". / (3) For respirator wearers/ pulmonary function tests every 3 years and chest x-rays every 5 years. c. Emergency exams: SAL 0000009^2 2. Bulk terminals and plants that use vapor control (balance or recovery) systems. */ 3. Intact containers and pipelines. */ 4. Work operations where the only exposure is from liquids containing 0.5% (0.1% after 5 years) or less benzene by volume. 5. Oil and gas drilling/ production and servicing. C. Monitoring [para (e)] 1. Timing a. Initial monitoring within 0 days of effective date of final standard. **/ b. Monitoring within 1 year prior to the * publication date of final standard is -I , grandfathered. 2. Scope a. For Initial monitoring/ at least 1 sample is required- for each shift of each job classification in each work area. b. For repeat monitoring/ single-shift monitoring permitted if employer shows other shifts are "equivalent". 3. Frequency a. Semiannually if exposures are > PEL. b. Annually if exposure are > AL but < PEL. c. None if exposures are < AL. d. Can reduce frequency (e.g./ a to b/ or b to c) based on two consecutive measurements at least 7 , days apart. e. Redetermination required for any change that "may result in new or additional exposures" and after a spill has been cleaned up. / The emergency and hazard communication provisions apply to bulk storage facilities and to containers/pipelines involving liquids with more than 0.1% benzene. **/ The effective date is 90 days after publication of the final standard in the Federal Register. SAL 000000982 2 4. OSHA concludes that this risk is significant, and that reducing the PEL to 1 ppm would achieve a significant risk reduction. OSHA adds that, "if it were feasible, OSHA would seek to reduce" the risk remaining under a 1 ppm standard (which OSHA estimtes to be 5-16 deaths per 1,000 workers for a 45-year vorklife); however, this is caveated by statements acknowledging that certain employer actions, such as holding average exposures below 0.5 ppm and implementation of medical surveillance provisions, will reduce the risk below the levels predicted by the risk assessment models [pp. 135-137]. C. Feasibility 1. OSHA concludes that a 1 ppm standard is tech nologically feasible [pp. 148-157], and suggests that a 0.5 ppm PEL may be feasible in refining, chemical, coke, and wholesale gasoline marketing industries [pp. 150, 153, 179]. 2. OSHA also concludes that a 1 ppm PEL would produce no significant economic impacts [pp. 164-70]. 3. OSHA estimates the annualized costs of the proposed standard to be $29 million [p. 159], and that it will prevent 822 deaths over a 50 year period [pp. 144-148]. II. PROVISIONS A. Exposure Limits and Triggers [para (c), (h) ] 1. PEL: 1.0 ppm (8. hr. TWA). 2. No STEL is proposed, however comments will be considered on the merits of inclusion. 3. Action Level (AL): 0.5 ppm (8 hr. TWA}. 4. Ppssible utilization of company data to help assess compliance with the standard if and when OSHA . measurement indicates, non-compliance. 5. Eye contact "prevention" and dermal contact "limits" are delected although protective equipment provisions are included. B. Scope: all workplaces involving "occupational exposures to benzene" except for the following [para (a)]: 1. Gasoline marketing downstream of bulk terminals and bulk plants. SAL 000000983 3S? SUMMARY OF OSHA'S DECEMBER 2, 1965 BENZENE PROPOSAL This outline summarizes the key factual findings contained in OSHA's benzene proposal and its major provisions. I. FINDINGS A. Health 1. Benzene has been shown to be associated with the following disorders in humans [pp. 23-24]: a. myelogenous leukemia and its variants: b. acute and chronic lymphatic leukemia; c. multiple myeloma; d. aplastic anemia and various cytopenias. 2. Benzene has been shown to produce non-lymphohematopoietic cancer in animals; this risk has not been adequately evaluated in humans [p. 24]; OSHA refers to this risk as "suggestive" [pp. 24, 75]. 3. Benzene causes chromosomal damage in humans below 10 ppm [pp. 25, 62 - 67]. 4. Benzene causes hematotoxic and immune system effects in animals at around 10 ppm [pp. 77-79]. 5. Benzene can be absorbed through the skin in significant amounts (e.g. equivalent to an 8-hour inhalation exposure of 1 ppm for a tire-builder) [pp. 80-83]. B. Risk Assessment 1. OSpA examines leukemia only, and says that the "total disease risk" may therefore be underestimated Cpp. 85-86], 2. OSHA finds the linear dose-response model "most reasonsable" based on chromosome and subchronic blood studies [p. 88]. 3. OSHA's "preliminary preferred estimate" is 44 to 152 deaths per 1,000 workers exposed to 10 ppm for a 45-year working life (the White, Infante & Chu (1982) assessment) [p. 134JT SAL 000000984 assessment. However, as just discussed, OSHA expects the action leveF, industrial hygiene and medical surveillance provisions to reduce risk substantially below those predicted by the mathematical models, though the additional reduction cannot be quantified. OSHA preliminarily concludes that its proposed benzene standard will protect employees and that employers who fulfill the provisions of the standard will be taking reasonable steps to protect their employees from the hazards of benzene. Indeed many employers have already reduced exposures of employees to below those of the proposed standard." The second area is the cost and operation disruption that could potentially result from the myriad of individually small, but cumulatively significant monitoring, control, surveillance and compliance requirements included in the standard. These two areas are the focus of ongoing efforts within API in developing our response to this proposed standard. We must try to bolster the agency's position in those areas where we believe they have acted reasonably as well as try to change those areas where they have not. Efforts will also be made to support the elimination of the STEL, and to support the use of company monitoring data in assessing compliance. As a result of the changes made in this proposal from the last OSHA draft of February 1985, the overall impact of the proposed standard is less than previously expected. This assumes the STEL provision is not incorporated, and that the more flexible use of company data to determine average compliance with the PEL is incorporated into the standard, in general only relatively minor problems have been found with medical surveillance and ancillary provisions of the standard. Cost and operation disruption estimates stemming from control and compliance provisions of the standard are still being determined, but do not appear to be as high or as onerous as anticipated. Attached is a more detailed description of the standard. SAL oooo9as Benzene OSHA Standard Update An occupational standard for benzene was proposed by OSHA on December 2, 1985. This proposal exhibits significant positive changes from earlier OSHA positions that reflect incorporation industry concerns. Major provisions of the standard include: of o A Permissable Exposure Limit (PEL) of 1 ppm 8 hour TWA. o An Action Level of 0.5 /ppm J hour TWA. *U\ o An assqrtment of monitoring, medical surveillance, and compliance provisions that, with minor exceptions, are compatible with industry interests. Exempted from the standard are gasoline marketing establishments downstream of bulk terminals and plants, bulk terminals and plants that use vapor control systems, intact containers and pipelines, aad^work operations with exposures only f containing (0.5%\or less benzenefEy^volume -finTfafter 5 Potentially positive changes from the original draft proposal include: o Elimination of a Short Term Exposure Limit (STEL). However a STEL is still under consideration and comments on the merits of including an STEL in the standard have been requested by OSHA. o The possible utilization of company data to help assess compliance if and when OSHA monitoring indicates non-compliance. Options include requiring two separate OSHA measurements that indicate non-compliance with the PEL if adequate company monitoring data indicates compliance, or using the average of at least five 8 hour TWA company measurements to rebuke an exceedance measured by OSHA in the same work area. These provisions are not yet included in the proposed standard, but are entered into the preamble for comment and consideration. o Deletion of eye contact "prevention" and dermal contact "limits" from the standard. Protective equipment requirements are included however. The OSHA propdsal contains two areas that still require additional attention in developing API comments. First is the residual risk at 1 ppm which is characterized in the following passage: "Finally, OSHA preliminary concludes that the proposed standard is carrying out Congressional Intent within the limits of feasibility and does not attempt to reduce insignificant risks. Under both the Congressional intent and the Supreme Court's guidance, OSHA would, if it "were feasible, seek to reduce the level of risk estimated to remain at 1 ppm by the riJTc SAL 000000986 3. Work operations around other liquids that might contain some amount of benzene (condensate# natural gasoline). I am scheduled to attend a meeting of API's General Committee on Health and Environment on January 21, 1986. The API's response to the OSHA proposal is an agenda item. I will advise if anything new comes out of this meeting. E. Thompson RET/kk Attachment cc: J. R. Bender W. D. Broddle M. A. Chance L. F. Clynch E. L. DeWhitt T. G. Waltrip SAL 000000987 SUBJECT: MEMO February 27, 1978 Benzene in Air, Compliance to Federal Regulation, Title 29, Part 1910, Section 1910.1028 Benzene, Technical Services Laboratory, Refining, Ponca City, Oklahoma 1. Initial Monitoring All work areas within the Technical Services Laboratory have been monitored for employee exposure to benzene. No area exceeded or met the action level of 0.5 ppm benzene for an eight-hour time weighted average. For those areas where the airborne concentrations of benzene was suspected to be the highest for short periods of time, 15 minute samples were obtained. None of these measurements reached the ceiling limit of 5 ppm benzene for a 15 minute time weighted average. All employees have been notified in writing of their individual exposure measurements. Specific locations and results are tabulated below: 1.1 X-ray Laboratory, November 3, 1977, 0.08 ppm benzene on an eight-hour time weighted average. X-ray Laboratory, February 23, 1978, 0.83 ppm benzene for a 15 minute time weighted average, during the analyses of sulfur in gasolines. 1.2 North Analytical Laboratory, November 4, 1977, 0.12 ppm benzene on an eight-hour time weighted average. North Analytical Laboratory, February 22, 1978, 1.44 ppm benzene for a 15 minute time weighted average, during the analyses of mercaptans in gasoline. 1.3 South Analytical Laboratory, November 8, 1977, 0.07 ppm benzene on an eight-hour time weighted average. South Analytical Laboratory, February 24, 1978, 0.32 ppm benzene for a 15 minute time weighted average, during the blending of unleaded gasolines for lead determinations. * .1,4 Gas Laboratory, November 2, 1977, 0.05 ppm benzene on an eight-hour time weighted average. Gas Laboratory, February 22, 1978, 0.25 ppm for a 15 minute time weighted average, during the preparation of reformate for analysis. SAL 000000988 HF'"' Conti nuea February 27, 1978 Page 2 2. Compliance Program No written compliance program is required because all exposure measurements are below the action level. However, engineering control and work practices will be maintained to insure that no employee is exposed to benzene levels at or in excess of those minimums as set by the regulations. These controls and work practices are listed below: 2.1 Engineering controls: All ventilating systems, exhaust hoods, sewer drains and vacuum systems will be maintained in good operational order. In any event, when any of v the aforementioned is inoperable, a suitable sign noting that It is in operable will be -installed, measures will be taken to return it to opera tional condition as expedient as practical* and steps will be taken to insure that no increase In benzene exposure will result from this inopera tion. 2.2 Work practices: All work that requires handling of benzene will be done in an exhaust hood. In special cases where only small quantities of substances that contain small concentrations of benzene are handled and the ventilation system has proven by prior testing that exposure levels will not exceed % the action level, will these substances be allowed to be handled outside a hooded area. These special cases are to be determined by the super visor. All containers that contain benzene will be properly sealed and kept in a well-ventilated area. All disposal of benzene will be done in an exhaust hood, either into the exhaust hood sink or into suitable containers for subsequent controlled disposal. In special cases where only small quantities of substances that contain small concentrations of benzene are to be disposed of and the venti lation system has proven by prior^testing that exposure levels will not ex ceed the action level, will these substances be allowed to be disposed of into open sinks. These special cases are to be determined by the supervisor Gloves, aprons, face masks and other suitable protective equipment are to be used to prevent any skin and eye contact with substances that contain benzene. SAL 000000989 - MEMf> Continued February 27, 1978 Page 3 2.3 Medical surveillance: No medical surveillance is required because all exposure measurements are below the action level. 2.4 Regulated areas: There will be no regulated areas in the Technical Services Laboratories. The only areas where concentrated benzene may be used is in exhaust hoods Any area where concentrated benzene is stored will be clearly marked with a sign noting 'Danger - Benzene' 'Cancer Hazard'. Senior Technologist Technical Services, Laboratory, Refining SAL 000000990 I CONTINENTAL OIL COMPANY PONCA CITY. OKLAHOMA REFINING TECHNICAL SERVICES LABORATORY LABORATORY NO.: CHARGE: SUBJECT: B-17-78 Gen. 49 Analysis of Benzene in Air - All Refineries Pit.: PC Gen. File: A010.1 /924 Date: 2-6-78 DISCUSSION: This report includes all data reported in Laboratory Report G-15-77 "Analysis of Benzene in Air - All Refineries" dated July 6, 1977, and all subsequent like data to date January 31, 1978. All together there have been 511 samples analyzed. Summation per refinery is as follows, see attached data for details. Billings Refinery - 22 samples, 0 exceeded TLV Denver Refinery - 18 samples, 0 exceeded TLV Humber Refinery - 30 samples, 7 exceeded TLV Lake Charles Refinery - 96 samples, 1 exceeded TLV Paramount Refinery - 73 samples, 16 exceeded TLV Ponca City Refinery - 228 samples, 0 exceeded TLV Wrenshall Refinery - 35 samples, 0 exceeded TLV Technical Services Laboratory, 9 samples, 0 exceeded TLV DATA: Attached REFERENCE: Laboratory Report G-15-77, Analysis of Benzene in Air-All Refineries, dated 7-6-77. Senior Technologist bp 7 cc: D. A. Kuhn-O0RR6B` -KCH-TEC-F SAL 000000991 l^'iUKAI UK f INU , o- w - / o jruary 6, 1978 Attachment, Page 1 BILLINGS REFINERY 15 Minute Sample Date 6-6-77 Location Transport Truck Loading Rack Benzene, DDm 1.14 BILLINGS REFINERY 8 Hour Sample Date Location Benzene, ppm 6-6-77 Combination Unit Gas Recovery Area 0.03 6-8-77 Combination Unit Crude and Vacuum Area , 0.02 6-8-77 Condensate Unit- Sampling Area 0.03 6-9-77 Combination Unit-Sampling Area 0.03 6-9-77 Condensate Unit - Samplinq Area 0.03 6-10-77 Condensate Unit Area 0.02 6-10-77 Combination Unit Reformer Desulfurizer Area 0.03 6-13-77 Train Loading Rack 0.07 6-13-77 Train Loading Rack 0.06 6-14-77 Pumo Mechanic in Comb-Unit Gas Recovery Area 0.01 6-14-77 Slop Trap and Tank Farm 0.05 6-15-77 Tank Farm - Gauger 0.07 6-15-77 Pump Mechanic - All areas of the Plant 0.01 6-16-77 Pipefitter - All areas of Operating Units 0.01 6-16-77 Pipefitter - All areas of Operatinq Units 0.01 6-22-77 Instrument Man - All areas of Operating Units 0.02 6-22-77 Insulator - Carpenter - All areas of Operating1 Units 0.02 6-23-77 Electrician - All areas of Operating Units 0.02 BILLINGS REFINERY CONTROL LABORATORY 3 hour samples Date * Location 6-3-77 Distillation and Gasoline Blending Counter 6-3-77 Distillation Counter 6-6-77 Knock Engine Room Benzene, ppm 0.14 0.25 0.06 SAL 000000992 1 r-WATDRY NO. : H- 1 /-/H Ft-.uary 6, 1978 Attachment, Page 3 HUMBER REFINERY Date Location 10-21-77 Cooling Tower Area (P589) 10-21-77 Cooling Tower Area (P576) 10-21-77 Aromatics CR End Area (589) 10-21-77 Top of Fire Hose Rack in Front of T532 Area' 10-21-77 Electrical Station in Front of T532 Area 10-26-77 Hot Oil Blowdown Pond Area 10-26-77 ADA Unit (AE Unit Shutdown) 10-27-77 HDA Unit (AE Unit Shutdown) 10-28-77 HDA Unit (AE Unit Shutdown) 10-28-77 Blowdown Pond 10-28-77 Main Control Laboratory (Benzene Testing) 11-21-77 HDA Unit Operator #1 11-21-77 11-22-77 AE Unit Operator #1 Control Laboratory (Benzene Testing) 11-22-77 HDA Unit Operator #2 11-22-77 11-22-77 AE Unit Operator #2 Control Laboratory (General Duties) 11-23-77 Control Laboratory (Benzene Testing) 11-23-77 11-23-77 Control Laboratory (General Duties) HDA Operator #3 11-23-77 AEU Operator #3 11-24-77 Control Laboratory (Bottle Wash Room) 11-24-77 AEU Operator #4 11-25-77 Control Laboratory (Bottle Wash Room) 11-25-77 AEU Operator #5 11-25-77 HDA Operator #4 11-25-77 Control Laboratory (Gas Chrom. Lab.) 11-24-77 Control Laboratory (Benzene Testing) 11-28-77 AEU Operator #6 11-28-77 Reformer Operator #1 8 Hour Sample Benzene, ppm 0.13 3.84 1.68 0.45 0.72 0.20 0.82 0.32 0.95 0.44 2.27 0.08 1.00 2.92 0.29 0.19 0.26 1.10 1.01 0.17 0.43 1.80 0.23 0.36 0.18 0.42 0.22 0.63 0.10 0.06 SAL 000000993 / LA^ORATURV NU.: B-W-/8 F. uary 6, 1978 Attachment, Page 2 ( DENVER REFINERY Date 6-21-77 6-22-77 Location No. 2 Tester Work Area, Control Lab. Pump House & Tank Farm Area 6-21-77 6-22-77 6-23-77 6-28-77 7-5-77 7-6-77 7-6-77 7-7-77 7-19-77 7-19-77 7-20-77 7-26-77 8-1-77 8-16-77 8-17-77 8-25-77 Loading Rack Control Laboratory Area Pump House Cat Poly Unit Reformer Area FCC Unit Area Crude Unit Area * Boiler House Area Process Engineering Area Control Laboratory Area Office Bldg. Instrumentman Area & Activities Warehouse Machine Shop Area Insulator - Carpenter Area Pump Mechanic 15 Minute Sample Benzene, ppm 0.17 <0.01 i 8 Hour Sample 0.18 <0.01 0.02 0.01 <0.01 0.01 <0.01 <0.01 0.03 0.05 0.04 0.02 0.02 0.02 0.01 0.11 s,Al- ooooo 099^ ,*/0 .l , Page 5 LAKE CHARLES REFINERV (Continued) Date 7-18-77 7-18-77 7-18-77 7-21-77 7-21-77 7-21-77 7-28-77 7-28-77 8-1-77 8-1-77 3-5-77 8-5-77 8-16-77 8-16-77 8-19-77 8-19-77 8-22-77 8-22-77 8-26-77 8-26-77 8-30-77 8-30-77 8-3.0-77 9-1-77 * 9-1-77 9-1-77 9-6-77 9-6-77 9-6-77 9-8-77 9-8-77 9-3-77 Location Product Fractionation (1st Controlman) Product Fractionation (Operator) Product Fractionation (Foreman) Loading Dock (Foreman) Loading Dock (Operator) Loadinq Dock (1st Loader) Coker (Foreman) Coker (Outside Man) Carpenter (1st) Carpenter (Foreman) Electrician (1st) Electrician (Foreman) Instrumentman (1st) Instrumentman (Foreman) Painter-Insulator (1st) Machinist (Inside) Pipefitter (1st) Pipefitter (Foreman) Machinist (Outside) Machinist (Outside) Welder (1st) Welder (1st) Welder (Foreman) Janitor Tool Repairman Utility Helper Heavy Equip. Operator Light Truck Operator Heavy Truck Operator Guard Firemarshall Nurse 8 Hour Sample Benzene, ppm 0.01 <0.01 0.01 0.03 0.02 0.03 <0.01 0.02 0.01 <0.01 0.01 0.01 0.01 <0.01 0.01 0.02 0.01 <0.01 0.03 0.02 <0.01 0.01 <0.01 0.07 0.02 0.03 0.01 0.03 0.01 0.03 <0.01 . <0.01 SAL 000000995 L^UKAIUKY NO. : ti- I /-/ii F- uary 6, 1978 Attachment, Page 4 ! LAKE CHARLES REFINERY Date 6-29-77 6-29-77 6-29-77 6-29-77 Location No. 1 Reformer Area No. 2 Reformer Area No. 2 CTU Area Product Fractionation Unit LAKE CHARLES REFINERY Date Location 6-15-77 East Tank Farm and Pump House 6-15-77 Alkylation Unit Area 6-15-77 Thermo Unit Area 6-20-77 No. 2 Unit, Product Fractionation 6-20-77 No. 2 Crude Unit Area 6-23-77 No. 2 Reformer Area 6-23-77 Coker Unit Area 6-23-77 No. 1 Reformer Area 6-27-77 Tank Farm and Crude Area 6-27-77 Tank Farm and West Tank Farm 6-27-77 Tank Farm and Run Down Area 6-30-77 TCC Unit Area 6-30-77 TCC Unit Area 6-30-77 TCC Unit Area 7-5-77 7-5-77 ' Reformer (Foreman) Reformer (Operator) 7-5-77 Reformer (Trap Man) 7-7-77 Pump House (Foreman) 7-7-77 7-7-77 Pump House (Operator) Pump House (Blender) 7-11-77 Combination Unit (Foreman) s 7-11-77 Combination Unit (Operator) 7-11-77 Combination Unit (1st Controlman) 7-15-77 Power Plant (Treater) 7-15-77 Power Plant (Fireman) 7-15-77 Power Plant (Operator) 15 Minute Sample Benzene, ppm 0.07 0.01 0.08 0.06 \ 8 Hour Sample Benzene, ppm 0.10 0.09 0.06 0.03 0.19 0.01 0.01 0.02 0.02 0.02 0.02 0.03 0.04 0.03 0.04 0.05 0.07 0.01 0.01 0.03 <0.01 0.01 0.05 0.02 0.02 0.01 SAL 000000996 * l^UKAflJKY NU . ; Li- I /-/U i ruary fa, 19/8 Attachment, Page 7 LAKE CHARLES REFINERY CONTROL LABORATORY(continued) Oate 6-14-77 6-14-77 6-20-77 9-19-77 9-19-77 9-19-77 Location Gas Chromatograph Laboratory Gravity Table Knock Engine Laboratory Senior Chemist Assist. Chief Chemist First Tester 8 Hour Sample Benzene, ppm 0.14 T0.62 0.45 0.22 0.22 0.41 SAL 000000997 '-- BORATORY NO.: B-17-78 . *=bruary 6, 1978 Attachment, Page 6 LAKE CHARLES REFINERY (Continued) Date Location 9-12-77 Inspector 9-12-77 Inspector 9-12-77 Shift Foreman 9-15-77 Environmental Eng. 9-15-77 Process Ena., TCC. #2 CTU. Cat Polv 9-15-77 Process Eng., Reformer, Power Pit. 9-21-77 Construction Foreman 9-21-77 Planner 9-21-77 Planner 9-23-77__________ Zone Foreman_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 9-23-77 Safety Supervisor 9-23-77 Fire Marshall 9-30-77 Planner 9-30-77 Senior Analyst 9-30-77 Traininq Supervisor 10-3-77 Mechanical Eng. 10-3-77 Contract Construction Foreman LAKE CHARLES REFINERY CONTROL LABORATORY Date Location 6-13-77 Gravity Table 6-13-77 Gas Chromatograph Laboratory 6-14-77 Chemist Work Area 6-29-77 Knock Engine Laboratory C-30-77 Distillation Table 6-30-77 Chemist Wash Area 11-14-77 Filling Laboratory Truck With Gasoline LAKE CHARLES REFINERY CONTROL LABORATORY Date Location 6-13-77 Gravity Table 6-13-77 Gas Chromatograph Laboratory 6-13-77 Knock Engine Laboratory 6-14-77 Knock Engine Laboratory 8 Hour Sample Benzene, ppm 0.01 0.03 0.02 <0.01 <0.01 <0.01 1.38 <0.01 0.01 <0.01 0.01 0.09 0.04 0.02 0.04 0.01 0.02 15 Minute Sample Benzene, ppm 1.02 0.08 0.52 0.01 0.54 0.03 0.18 8 Hour Sample Benzene, ppm 0.54 0.06 0.30 0.24 SAL 0000099g Attachment, Page 9 PARAMOUNT REFINERY (Continued) Date 8-9-77 8-19-77 8-19-77 8-22-77 8-22-77 8-23-77 9-12-77 9-15-77 9-20-77 9-20-77 9-22-77 9-22-77 10-28-77 10-28-77 10-28-77 10-31-77 11-7-77 11-7-77 11-8-77 11-8-77 11-9-77 11-9-77 11-10-77 11-10-77 11-17-77 12-20-77 12-20-77 1-16-77 1-16-77 1-17-77 1-17-77 1-17-77 1-17-77 1-18-77 Location No. 1 CTU Operator Research Laboratory Research Laboratory No. 1 and 2 CTU Operator No. 1 and 2 CTU Operator ' No. 1 and 2 CTU Operator No. 2 CTU (Area for Lt. Naphtha Sampling) Lt. Naphtha HgO Drop Out Vacuum Unit No. 1 CTU (Area for Lt. Naphtha Samplinq) No. 1 CTU Operator No. 2 CTU (Hvy Naphtha Sampling Area) Control Laboratory (Lt. Oil Testing) Control Laboratory (Lt. Oil Testing) Control Laboratory (Lt. Oil Testing) Control Laboratory (Lt. Oil Testing) No. 1 & 2 CTU Operator * No. J & 2 CTU Operator No. 1 & 2 CTU Operator No. 1 & 2 CTU Operator Reformer Operator Reformer Operator Pumper Research Laboratory Research Laboratory Naphtha Unloading (Bz., Tol. & Xyl.Unloading) Naphtha Unloading (Bz.} Tol. & Xyl. Unloading) Naphtha Unloading (Bz., Tol. & Xyl. Unloading) Naphtha Unloading (Bz., Tol.'& Xyl. Unloading) Naphtha Unloadinq (Bz., Tol. & Xyl. Unloadinq) Naphtha Unloading (Bz., Tol. & Xyl. Unloading) Naphtha Unloading (Bz., Tol. & Xyl. Unloading) Naphtha Unloading (Bz., Tol. & Xyl. Unloading) Naphtha Unloading (100* away from activities) 8 Hour Sample Benzene, ppm 0.04 0.02 0.03 0.13 0.10 1.50 0.53 0.10 0.15 0.09 0.03 0.03 0.07 (4 hours) 0.33 (4 hours) 0.59 (4 hours) 0.12 (4 hours) 0.01 0.06 0.09 0.06 0.01 0.01 0.02 0.01 0.02 0.84 (1 hour) 1.13 (1 hour) 14.7 (1.5 hours) 11.6 (1.5 hours) 6.1 (1 hr. & 10 2.78 (1 hr. & 10 13.3 (1.5 hours) 12.3 (1.5 hour^ 2.60 (1 hr & 15 i SAL 000000999 r ORATORY NO.: B-17-73 Fepruary 6, 1978 Attachment, Page 8 PARAMOUNT REFINERY 15 Minute Sample Date 7-1-77 7-1-77 7-1-77 8-8-77 Location Reformer Keystop Loading Rack Control Laboratory * Gauge Hatch of TK 25003 (Lt. Naph. Storage Tk) Apparently sampled right in hatch opening , Benzene, ppm 0.04 0.04 0.24 16.4 (Not applicab PARAMOUNT REFINERY Date 6-22-77 Location Control Lab (Light Oil Tester) 6-23-77 6-28-77 Control Lab (Chemist) Key Stop Loading Rack 6-28-77 Instrument Man 6-29-77 6-29-77 Pump Shop Air Blowing Plant 6-30-77 Crude Unit, Operator 6-30-77 Safety Office 7-1-77 Control Lab (Chemist) 7-6-77 PumDinq Dept. 7-6-77 Reformer, Operator 7-7-77 Electricians 7-7-77 Pumping Dept. 7-8-77 Crude Unit, Operator 7-8-77 Welder 7-19-77 Reformer Trainee 7-19-77 Maint. Repairman 7-20-77 HDS Unit Operations Supt. 7-20-77 Pumping Dept. Supervisor 7-21-77 Pumper Trainee 7-21-77 Emulsion Operator , 7-22-77 Reformer Operator 7-22-77 Crude Unit Operator 7-27-77 No. 1 and 2 CTU Operator 7-27-77 Pumper Operator 8-9-77 No. 1 CTU Operator 8 Hour Sample Benzene, ppm 0.47 0.21 0.02 <0.01 0.31 0.01 0.07 0.01 0.57 2.66 0.15 0.19 0.19 7.49 0.17 0.03 0.02 0.02 0.01 0.01 0.02 0.02 0.12 2.20 0.01 0.07 SAL OOOOOIOOO