Document zdM4NEgJGdOmBxj1mZkDeB9yz

PLAINTIFF'S EXHIBIT DOW-1802 SOM] CINf / 25*73 DOW CHEMICAL U S A . -, I ><I OiViSKJN mtlMOllT. l(Mt T7MI :;,1.----------- rOK VSt- OK DOW EMI'I.OVEKS ONLY environmental health report EVALUATION OF EMPLOYEE EXPOSURES TO ASBESTOS AT CHLORINE PLANT SERVICES A-1000 AND A-700 'at A10-2416 r:t November 3, 1983 4U'h3I E- P. Whatlev A. J . Tolbert 3*ft __AJ/ir*' Monitoring was conducted from Fcbruary-Octobcr, 1983. at Chlorine Plant Services, A-1000 and A-700, to evaluate employee exposures to asbestos. With the exception c.f slurry preparation at A-1030, all employee excursion and time-weighted a/erage exposures to asbestos were within acceptable levels. Because o tne ventilation system (and better exposure control) at A-702, it is recommended that all slurry be prcpareJ at this facility, if possible. Alternatively, similar engineering controls should be installed at the A-1030 location. Employees should be informed of the results of this survey, and the informing documented. eeLisoois bbs Diinbwio*t S. F. Edquist, A-1230 R. E. Flake, B-101 L. E. Harvey, A-1003 E. C. Kotis, A-1003 H. McNair. A-1230 File (2) AN L. W . Rampy - 1702 Midland R. R . Lanqner - 2030 Midland M. G . Swank-1803, Midland * F. 0. Axe - Pittsburg J. E. LcBoau- 1303, Midlam * C. C. Halphen - Plaquemine * C. L. Meier - Strongsville A. F. Pollock - Sarnia R. M. Croyle - 474 Midland F. H. Br inlich - Tulsa UNIT O* TmC DOW rHIMlCAC COM*ANT File A10-2416 2 November 3, I'J: ST008 4734 I NTPODUCT I ON' A survey was conducted from February - October, 198J, at Chlorine Plant Services, A-1000 and A-700, to evaluate employ o exposures to asbestos. PROCESS 4 JOB DESCRIPTION'S See Appendix C MONITORING METHODOLOGY Asbestos samples were collected by A. J. Tolbert of Chlorine Plant Services. The samples were collected on cross-hatched cellulose acetate filters (Millipore MAWG 03700), using Bcndix BOX-44 air sampling pumps to draw approximately two liters per minute of air across the filters. The pumps were calibrated before and after use with a calibrated Gilmont rotameter, S/N B397B. Sampling times ranged from IS minutos to 7 hours, depending on the Job or area being monitored. Analyses were j*crformed at Analytical Services, B-1225. The samples were prepared by placing a section of filter on a microscope slide containing a few drops of clearing solution (dimethylphthalatc, diethyloxalate, and millipore filter), covering, and warming the slide slightly to aid dissolution of the sample filter. The fibers were then counted using optical microscopy. EVALUATION CRITERIA Industrial hygiene guides (IIIG's) are concentrations of air borne substances to which nearly all employees may be repeatedly exposed throughout a working lifetime without adverse effect. They arc based on industrial handling experience and on experimental animal toxicological studies. IHG's do not represent fine lines between safe and dangerous exposures; rather they are intended for use as guides for evaluating occupational exposures and for plant design. For asbestos fibers, IHG's are expressed as the number of asbestos fibers per cubic centimeter of air ( fibers/cmJ) . Ar. asbestos fiber is defined as a particle greater than or equal to 5 microns in length. Most IHG's are expressed as time-weighted avoraqc (TW,\) concentrations for 8-12 hour work days and 40 hour work weeks. For many substances, higher excursion levels arc allowed for specified time limits, provided that the TWA limits are not exceeded. I v A1C-2416 3 November J, 108 3 EVALUAT ION CRITERIA (continued) The IMG's for asbestos differ, depending on the typo of fiber. The IMG's for the types of asbestos used at Chlorine I'l.int Services are as follows: . Industrial Hymer.c Guide (fibers/cnJ) Type Asbestos________________________ 8-hour Excursion Chrysutxlc (white asbestos) Crocidolitc (blue asbestos/ 2.0 0.2 10.0 1.0 Mixture (751 white, 253 blue)* 0.6 3.0 * Since both types of asbestos fibers exhibit similar consequences of overexposure, it is necessary to consider their combined effects when evaluating monitoring results. A sample calculation for determining the mixture IHG is shown in Appendix 0. Effective November 4, 1983 , the Occupational Safety and 'lealth Administration (OSHA) set an Emergency Temporary Standard for asbestos, limiting employee 8 hour time-weighted average exposures to 0.5 asbestos fibers/cmJ of air. All future monitoring results should be evaluated against this standard. RESULTS AND DISCUSSION Estimated employee 8 hour time-weighted average (TWA) exposures to asbestos are calculated in Table 1, on the basis o: employee time distributions and the summarized asbestos monitoring results shown in Table 2. The 8 hour TWA exposure levels for the Class I and Class II Operators were found to be within acceptable levels, with the exception of the exposure to the Class II Operator on days slurry was prepared at A-1030 (an infrequent job performed on an "as-needed" basis). The average 3 hour exposure to the Class (I Operator on slurry preparation days at A-1030 was 0.8 fibers/on . or approximately 1 1/3 times the IMG of 0.6 fibers/eni . All other 8 hour average exposures to employees at Chlorine Plant Services were 0.1 fibors/cm or less. Summarized asbestos monitoring results are shown in Table 2. with inidividual personnel and area monitoring results given in Appendices A and irrespectively. Only one of the six job procedures monitored, making asbestos slurry at A-1030, resulted in (potential) employee exposures to asbestos m excess of acceptable levels (respiratory protection is required). oa*# o! OO t; #'iUr ' < C/1 *1 *r-( e-. R r! 9CL18001S rile Aio-2iio 4 Nover.ocr 3, 1983 RESULTS AND 31SCLSS IQ': (cor.: trued ) The average employee exposures to asbestos while preparing slurry at A-1030 was <1.5 fibers 'em , approximately twice the excursion 1HG of 3 fiber/cm'. The next hiur.est employee excursion exposures occurred during slurry preparation at j A-702, with average (potential) exposures o: 1.5 iibers/ca , or one-half of the excursion IHC. All other.excursion and TWA exposures to employees were 0.3 fiber/cm or less, well within acceptable levels. All area levels of asbestos measured under normal operatin': conditions averaged 0.03 fibcrs/ccr or less, or 5 or less of the IHC.. co:cc:.csioss a.vd i?rcommc a'PAt i oms Employee 8 hour TWA exposures to asbestos at Chlorine riant Services were within acceptable levels,with the exception of the Class II Operators' exposures on days slurry was prepared at A-1030. Similarly, all employee excursion exposures to asbestos verc within acceptable levels, except for the slurrypreparation job at A-1010. Ml area concentrations of asbestos were well within allowed levels. It is recommended that slurry preparation at A-1030 bo dis continued. if possible, and all slurry be prepared at t:;c A-702 facility. Alternatively, engineering controls should bo installed at A-1030 to reduce potential cmplcvco exposures to asbestos. The ventilation system at A-702 has reduced employee exposures to approximately one-fourth of those at tho A-1030 facility, which has no ventilation system. I:. the interim, employees should continue to wear approved respiratory protection when performing this procedure at A-1030 until monitoring shows that tho potential cxjxtsure levels have been reduced to less than 3 fiber/cm . While employee exposures to asbestos were within allowed levels during slurry preparation at A-702, it is recommended that required use of respiratory protection tc continued, since the potential exists for much higher exposures in the event of an equipment malfunction or process upset. In the interest of kccpina employee exposures to asbestos as low as is pract ic-tulo, it is also recommended that employees continue to wear respira tory protection fer those job3 and areas where it is currently utilized. Employees should be informed of t.-.e results of tins survey, the potential effects of overexposure to asbestos, methods of exposure control, and the proper care and use of protective equipment. Tins informing should be documented. > ! ] i , j ! bbs TAHI.K 1 CIIUIK1SK C*\NT M.KVICCS, A- 1001) ANIl A-70II -k s t im u k d K.'in.nYr.i: b ihi :k avi i w :i . i.x m s ik r.s i u ash i.stos ST0084737 r ile AlO-.'ilfc APrCNDtX A CHLORINE PUNT SERVICES, A -1 0 00 AND A - 700 1BBJ ASBESTOS PERSONNEL MONITORING RESULTS r; v. Z s. 2: 5A < **'. * ^ r ,s- ^ -- j ^ S* ^^ ^C 1 icu- Hur;; m f* ** -- 85 <a i eT witS*St XX X*"** * O ? r ^ ~ J "* n n pm m rIi ^I ^I ^ ^ ^ t-slei--txm*tC --li l*M-*t-- xC...x-.t..x-.*..xT....xZ...x--...xz -Xi XcI X--* "t *x** 7c. 1w < 2 Iz Xcw. V > w; / Ui Ui at. 2 O5 nN *jT 9^* t ** v* *** C* -- -- S* uj j I ST008 U738 i F ill- A10-2UA APPENDIX A (c o n i tm iv d ) r illllH IK K PLANT SEKVICF.S. A-1C100 AND A -7 0 0 ST0084739 F l i c A 1 0 -2 4 11, CIIL0K IKK PI.ANT ASPIPKKVNI1I HI SX . R A -lltD O 1 A-7lX ASBISTOS AKKA IK 'S IIO K IN I. KI SH. I S - I "IH lilU 'i .i|pf*irvJ i i 'iit jr .h u iu l I ( (...... I c;:LC?i::;i; plant s: p-.vrss and JO.'i 3i:scaIPTIOns Chlorine Plant Services provides a variety of service functions for the chlorine plants. Major services arc as fellows: Asf.e.v.bl i and disr.jr. tl inq cells -- A-1020, A-1022 Preparing asbestos slurry -- A-702, A-1030(back-up) Drawin: diaphraqr.a with asbestos slurry----- A-702, A-1022 (back-up) Rinsirv; oil off cathodes with 101 NaOl!----- A-1000 Seal back o: ATCs (anode terminal cells) with Dorakanc ar.d sand------- A-1000 Transport cells an>! cell parts within ar.d out of the Texas Division ST00847** c ci;: i.' \. I ;mctl) ( plai.t dCRViciii Job a*. Chlorine Plant Services are or.united (it: general, by tit;; l:r.g .ius ijnscr.: . Class I Oper.it*.r -- A-7G2, A-70I (Acct. 5022) In eerieral, rotate.i weekly among 3 juLa: "Board C:.-.rator" - spends 90-95. of tine at control board for ope*sting equipment to .sake slurry and for drawing vat - samples asbestos slurry: - bulk slurry after a batch is prepared - vat slurry at beginning and end of "draw" - analyzes samples for percent solids and "free.ncss" ST0084742 "Front Operator" - nukes asbestos slurry once/day (2 employees): - one leads bags of asbestos (12) onto elevator, using :crk truck (downstairs) * other o.v.ljvi-c opens Lags and pours contents into ru:-::nu tank, seals empty bails in plastic i>a.:. a::u puls m asbestos dumpster (wejrs d ispesable coveralls and dust mask) - straightens pockets on undrawn diaphragms (cat.1:. to line up wit;-, raker in drawing vat - pumps Kyr.ar, Triton, Anti foam, 4 slurry into vat - loads k unloads cathodes from vat (using crane) - oversees operation of drawing vat - unbolts "draw pan" and puts cathodes in bonding even - washes down vat area daily "Pack Operator" - woiuhs bare ar.d bonded cathodes - unloads bonding even - uses impact wrench to remove sti ::or, ibars : re::; craw.-, and bonded cathoe.s (sprays with keros.no to kcei a sues tos "dust" to a nin:::.:m - measures thickness of bonded asbestos on cathodes ' 1 5 is mutes/ cathode, 4 tir.es/day) - performs m:seeli.mcwus fork truck work - cleans build me with sweeper a couple o: tir.es/week. File A:o-.-lh r ( :*;* t U--> :;u w t } Class T! 0:.or.v.:r A-1022, A-1030 (Acct. 5023) - assembles chlorine cells: - clear.* e.ic. s iscrape rust off copper clips' - colls by dropping cathodes into coil body - rur.r air permeability tests er. colls - puts cell putty and rubber arour.d edges, gluing with small anount of epoxy restr. - >-10 days/seric* of cells - S3 projections are to build 1 series (60 celis)/l-2 months - disassembles chlorine cells (a series at a time) which are removed from service in chlorine plants - removes cathodes fron bodies, salvageable ones are sort to Cathode Cleaning Facility at OCD - salvageable bodies go to houisiar.a Division - as back up for A-702, prepares asbestos slurry in mix room, A-1030 - opens and dumps bags of asbestos in mixing tank - disposes of empty bags in asbestos dc.mpstc: - seals back of anode terminal cells (A7C) with Dcrakane/ sand mixture - ' steps: nix and pour Dcrakanc into ATC, add sanJ when Dcrakanc is tacky - takes about 8 hours, employee exposure time is 2-3 hours - 2 - 3 times/year Class It Fork Truck Operator - Shipping t Receiving (Acet 5020) - uses :'crk truck to transport goods around ar.d between A-700 and A-100C blocks - unloads asbestos bags from railcars into A-701 -warehouse ar.d transports asbestos to A-1030 slurry room as needed Crane Operator Cab -- A-I022 (Acct. 5023) - operates overhead crane in assembling ("stabbing") and disassembling cells Chief Material Hand linn Technicians - Shipp:.-..: and deceiving ( Acei. So2o) - use trucks to transport goods to ar.d from chlw: ;.ne plants. Cathode Cleanina facility, etc. I ; ! 1 ST0084743 ST0084744 nic api,i.:::i|x :i c.i.a:..-,T1S. IliC'S 10k SIML'KF.S 01 ASi'.KSIoS--------EXAMPLE rViT ASBESTOS Clirywi i ;. C foe llo 11 i c is >:i:-7iHK ;* JS ini: fs nono J.l) l llior/en'* l)..' llKr/cn1 IHC for =i.\;urc froot ion l/jjij. | 1..................................................................... ......... .. * iroeli..-, ,1(< 1 IHC lor r.iMuro 0.0 : il'ir.V of jlr