RESEARCH
T R
ANGLE
N S T I T U T E
RTI/1736/2-03S
Draft April 1979
Final July 1980
COMPARISON OF OSHA'S EXISTING AND ERA'S POTENTIAL
REGULATIONS FOR COKE OVEN BATTERIES
by
C. C. Allen, M. R. Branscome, D. W. Coy,
and W. L. Klotz
Research Triangle Institute
P. 0. Box 12194
Research Triangle Park, N. C. 27709
EPA Contract No. 68-02-3056
Project Officer
Lee Beck
Industrial Studies Branch
Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
Prepared for
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27709
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DISCLAIMER
This report has been reviewed by the Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, and approved for
publication. Approval does not signify that the contents necessarily
reflect the views and policies of the U.S. Environmental Protection Agency,
nor does mention of trade names or commercial products constitute endorse-
ment or recommendation for use.
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TABLE OF CONTENTS
Figures
Tables
1.0
2.0
3.0
4.0
5.0
6.0
EXECUTIVE SUMMARY
CONCLUSIONS
RATIONALE FOR CONCLUSION NUMBER 1
INTRODUCTION
PERSONAL EXPOSURE AND EMISSIONS INSPECTION DATA
DATA DISCUSSION
Battery Compliance with OSHA and EPA Regulations
Relationships Between Worker Functions and Exposure
Relationship Between Emissions and Worker Exposure
Role of OSHA Regulations in the Achievement of EPA's
Tentative Emission Limits
APPENDIXES
A REPUBLIC STEEL PLANT NO. 1 INSPECTION DATA
B CF&I INSPECTION DATA
C CLAIRTON INSPECTION DATA
D OSHA REGULATIONS
Page
iv
v
1
4
5
7
11
20
20
24
29
40
43
47
56
68
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FIGURES
Figure Page
1 Schematic of the side of a coke oven. 26
2 The relationship between the charging emissions and worker
exposure in the larry car, Republic Steel Co. 31
3 The relationship between percent leaking doors and average
lidman exposure on ten coke batteries 33
4 The relationship between the percent leaking doors and
bench worker exposure. 34
5 Maximum worker exposure at various emission levels from
coke oven doors. 35
6 The relationship between total particulate collected and
the benzene soluble fraction of the particulate in the
tar chaser personal exposure of CF&I. 36
IV
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TABLES
Table Page
1 Comparison of OSHA and EPA on Control of Coke Oven
Emissions 8
2 Battery Construction Data 16
3 Summary of Occupational Models for a Nonlinear Regression
Analysis 18
4 The Relative Stringency of OSHA and EPA Potential Standards
for the Control of Coke Oven Door Emissions 22
5 Relative Stringency of OSHA and EPA Standards for the
Control of Percent Leaking Lids 22
6 Relative Stringency of OSHA and EPA Standards for the
Control of Percent Leaking Offtakes 23
7 Relative Stringency of EPA and OSHA Regulations in Con-
trolling Charging Emissions 24
8 Select Comparison of Ambient Exposure and Time Weighted
Average 27
9 Worker Exposure on a Coke Battery Over Four Days 27
10 Emissions from Coke Oven Doors 28
11 A Comparison of Coke Oven Battery Performance with Emission
and Exposure Criteria for Ten Batteries 30
12 Averages of Time Weighted Worker Exposure and Emissions
at the Republic Steel .Plant 38
13 Averages of Worker Exposure and Emissions at the Clairton
Plant 38
14 Correlation Coefficients Among Variables at Republic Steel 39
15 Correlation Coefficients Among Variables at Clairton 39
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1.0 EXECUTIVE SUMMARY
This report analyzes the differences between the existing Occupational
Safety and Health Administration (OSHA) and tentative Environmental Protec-
tion Agency (EPA) limits for coke oven emissions in order to assess their
effects on worker exposure, visible emissions, and ambient concentrations.
It is concluded that (1) the OSHA standards as currently enforced do not
provide as much control of emissions to the atmosphere as would be provided
by EPA's tentative emission limits and (2) efforts to achieve the EPA
limits may pose some problems for achievement of OSHA's worker exposure
limit. The basis for this conclusion and other potential conflicts between
the two regulatory strategies are summarized below.
Inspections of 10 batteries at three coke plants were performed by
OSHA and EPA (concurrently at four of these batteries). Data from these
inspections were compiled to assess relative stringency by comparing the
visible emission measurements of EPA with worker exposure levels and cita-
tions for lack of mandated controls from OSHA. The methods used for this
comparison included a regression analysis relating emissions to the level
of worker exposure and a direct comparison between sources exceeding the
EPA tentative limits and citations issued by OSHA for those sources. The
potential effect of OSHA's mandated equipment controls on the level of
visible emissions was also examined.
The regression analysis of the inspection data demonstrated a direct
relationship between charging emissions and worker exposure. Other rela-
tionships between worker exposure and emissions were complex and may have
significant interactions. For example, the door cleaner at Republic Steel
(Cleveland, Ohio) experienced higher exposure levels on batteries with
lower emissions, whereas other workers recorded a lower exposure level
where emissions were better controlled. Some of the highest worker exposure
levels were recorded at Clairton's Battery 19 which had the lowest emission
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levels in that group. Worker efforts to decrease emissions may result in
higher exposure, or a concerted effort to control one emission source may
increase the effect of another source. This analysis demonstrates how the
level of worker exposure and level of emissions may be mutually exclusive
in some cases.
The OSHA limit of 150 |jg/m3 for personal exposure to coke oven emis-
sions was examined further. Personal exposure is not a measure of emissions
to the environment, nor does its enforcement assure a low level of emissions.
This measurement is a time-weighted concentration measured for each worker
and is affected by the time the worker is on the battery, ambient conditions
such as wind velocity and direction, exposure time in localized areas of
high concentrations, the use of larry cars or work stations with filtered
air supplies, and the worker job function. The measurement itself is
accurate, but it is plagued by poor precision or reproducibility. Several
sets of measurements on the same battery within the same worker classifica-
tion show a standard deviation that is greater than the average of the
measurements. This variability and the fact that OSHA requires that the
highest measured value be below its standard suggest that emission control
systems that are substantially different from those in present use may have
to be developed to meet the personal exposure limit at all times. For
these reasons, this limit is insufficient for accurately detecting, measur-
ing, or controlling emissions to the environment. However, the limit
provides a measure of worker protection.
The OSHA regulation requiring equipment and work practice controls was
also examined with respect to emission levels at the 10 inspected batteries.
The data show that the EPA tentative emission limit for leaking doors (5
percent) is more stringent than OSHA's equipment and work practice require-
ments as judged by the results of OSHA enforcement. OSHA violations requir-
ing the repair, replacement, and adjustment of doors were issued for four
batteries with greater than 13 percent leaking doors; violations were not
issued for five batteries with 6 to 13 percent leaking doors except for
citations for lack of written maintenance procedures.
A similar case existed with leaking offtakes (5 percent). Seven of
the 10 batteries were in violation of the EPA limit, but OSHA violations
were issued for only the five worst batteries with 15 to 38 percent leaking
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offtakes. The EPA tentative limit for leaking lids (2 percent) also appears
to be more stringent than current OSHA requirements. Six of the 10 batteries
inspected would not have met the EPA limit, but leaking lids were cited by
OSHA at only two plants with 7.0 and 8.6 percent leakage rates.
A comparison of the EPA and OSHA data on charging emissions showed
that five of nine batteries did not meet the EPA tentative limits for
charging. Three of these five were cited by OSHA. In addition, OSHA cited
three of the four batteries that did meet the EPA tentative limit for
reasons that included no mechanical gooseneck cleaning and lack of luting
on charging lids. This comparison revealed the subjectivity involved in
the OSHA regulations, the lack of uniform enforcement among different
batteries, and the general absence of objective criteria for determining
the levels of emissions to the atmosphere. Citation for lack of written
maintenance programs was not considered a door citation that relates direct-
ly to observed visible emissions. The citation for lack of repair, replace-
ment, and adjustment of oven doors was used in other cases and was taken to
reflect observed visible emissions.
The OSHA regulations are designed to limit worker exposure by mandat-
ing equipment controls and detailed operating procedures. Although these
regulations would provide for control of emissions in theory, several
inherent shortcomings make this approach inadequate for environmental
protection. These shortcomings include no performance specification for
the control equipment, no numerical enforcement limit for emissions, and
only subjective interpretation of the adequacy of written work procedures,
repair, and maintenance. The lack of performance criteria and the difficult
nature of uniform application will likely result in different levels of
emissions enforced at different batteries.
Thus, EPA sets no standards for worker exposure, the use of respirators,
filtered air supply, medical records, hygiene, or employee information and
training. These requirements are enforced by OSHA and are necessary to
protect the worker. In developing coke oven regulations, EPA should make
clear that its goal is different from" OSHA1s; OSHA's goal is to eliminate
health hazards in the work place, while EPA's is to do the same in the
nonoccupational environment.
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2.0 CONCLUSIONS
1. The OSHA standards as currently enforced do not provide as much control
of emissions to the atmosphere as would be provided by EPA's tentative
emission limits.
2. Efforts to achieve the EPA limits may pose some problems for achieve-
ment of OSHA's worker exposure limit.
3. EPA's tentative emission limits and OSHA's current regulations have
significant differences in both objectives and requirements.
4. The variability in the personal exposure data indicates that substan-
tially different coke oven emission control systems may have to be
developed to provide the level of worker protection required by the
OSHA regulations. The level of public health protection which would
be provided by these undetermined control systems is unknown.
5. Measurement of personal exposure is an inappropriate measure of visible
emissions, since it depends upon worker practice, wind conditions, the
use of filtered air cabs, and other factors.
6. Additional joint inspection programs by EPA and OSHA would be useful
to more clearly define the complex interaction among emissions, worker
exposure, and emission control techniques. An expanded data base
would be necessary to define the effects of battery age, plant-to-plant
variability, work practices, and other factors which may prove useful
in recommending preferred control strategies. However, the length of
time necessary to plan, perform, and analyze the results of joint
inspections is so long (at least 4 months) that significant improve-
ment of the data base is a long term project.
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3.0 RATIONALE FOR CONCLUSION NUMBER 1
For the existing OSHA regulations to adequately protect the public
health, it must be presumed that enforcement of the OSHA engineering con-
trols will achieve the level of emissions allowed under tentative EPA
emission limits. Likewise because the only numerical limit provided by
the OSHA regulations is for personal exposure to benzene soluble particulate
matter, it must be presumed that these measurements are acceptable measures
of emissions from the various sources. That neither of the above presump-
tions are correct is demonstrated by data in this report. Based on inspec-
tions of 10 batteries, current enforcement of OSHA engineering controls
does not produce equivalent or fewer emissions than the tentative EPA
limits, as the following shows.
EPA tentative Level at which
limit OSHA citation is issued
Leaking doors 5% 13%
Leaking lids 2% 7%
Leaking offtakes 5% 14%
Charging 11 seconds Citation at 7 seconds,
none at 17 seconds
Personal exposure levels are not acceptable indicators of emission levels
because exposure levels may be reduced through the use of air conditioned
or filtered air larry car cabs and similar standby pulpits that have no
effect on emission levels. Wind conditions and worker practice may also
increase or decrease personal exposure with no similar change produced in
emission levels. Further, some correlations presented in this report show
a negative correlation between worker exposure levels and emission levels,
i.e., personal exposure levels may increase as emission levels decrease.
For the tentative EPA emission limits to protect worker health as well
as public health it must be presumed that worker personal exposure levels
decrease with decreasing emissions levels. That this presumption is not
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always correct is evidenced by data in Tables 12 and 13. These tables show
that batteries with the lowest emission levels had some workers with higher
personal exposure levels than the same workers on other batteries with much
higher emission levels. The correlations that predict higher personal
exposure levels for lower emission levels, i.e., negative correlations,
also suggest that the above presumption is not correct. Further, it should
be remembered that no EPA standard would address the reduction of worker
exposure through the use of respirators or filtered air supply. There
would also be no provisions for monitoring worker health or providing
workers with exposure information and training requirements.
Considering the above factors, it can be concluded that the OSHA
standard as currently enforced does not provide the control of emissions to
the atmosphere provided by the EPA tentative limits. Further, efforts to
attain the EPA tentative limits may make compliance with the OSHA personal
exposure limit more difficult.
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4.0 INTRODUCTION
Coke oven batteries are typically part of complex steelmaking facil-
ities with large labor forces; therefore, they are located near urban
centers. Because of the hazardous nature of coke plant emissions, both the
coke plant workers and the populations downwind of the coke plant battery
are endangered.
Due to the significant endangerment of the coke plant worker's health,
OSHA has regulated those aspects of coke plant operations which influence
worker health through exposure to the benzene soluble fraction of total
particulate matter (BSFTPM). However, some coke oven emission sources are
not regulated by this OSHA standard. The by-product plant, quench towers,
dry coal preheater stacks, and battery stacks are outside the regulatory
standard; therefore, they are not considered in this report.
This report discusses some salient aspects of the OSHA regulations,
particularly with respect to current EPA programs to develop emission
limits for the coke ovens. Of primary concern is the relative environmental
stringency of the two programs, since the implementation of EPA regulations
could restrict the applicability of the OSHA rules or result in regulatory
duplication.
To reduce employee exposure, the OSHA regulations require a coke plant
to institute engineering and work practice controls. Additional require-
ments are filtered air equipment, written compliance plans, respiratory
protection, protective clothing and equipment, hygiene facilities and
practices, medical surveillance, employee information and training, signs,
labels, record keeping, and monitoring observations.
EPA's regulatory approach is generally to specify levels of performance
required to protect the public health and permit the employer to develop
practices, implement new process controls, and modify processes so that the
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public health is protected. The planned EPA limits for coke plant emissions
follows this general, principle: acceptable levels of emissions are identi-
fied, and the employer is permitted to meet these limits with any method
convenient to him.
Both OSHA and EPA agree that coke oven emissions should be minimized
to the greatest practical degree. Table 1 is presented in a simplistic
form to demonstrate the different approaches of the two organizations on
this issue.
TABLE 1. COMPARISON OF OSHA AND EPA ON CONTROL OF COKE OVEN EMISSIONS
OSHA
EPA
Objective
Standard
Monitoring
Specific equip-
ment and work
practice re-
quired
Protect the worker.
Engineering and work
practice controls. Limit
the worker exposure.
Check for engineering
and work practice controls.
Measure the worker
exposure.
Yes
Protect the health of
persons living near
coke plants.
Numerical emission
limits.
Measure the relative
quantity of emissions.
No; source may use
any control tech-
nique to meet emis-
sion limits.
Table 1 shows that OSHA regulations and tentative EPA limits develop
independently and without duplication although some of the same equipment
and work practices are necessary to meet the standards. The engineering
and work practice controls are required even if the permissable exposure
limit (PEL) is met without them.
The standard recognizes that an employer may raise the defense of
infeasibility as to the individual control items for a particular coke
battery. (The employer is not required to use engineering controls or work
practices if he can establish that such controls are not feasible.) Factors
such as levels of personal exposure, design problems, life of the battery,
8
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and efforts to implement control are explicitly recognized in the rules as
relevant in establishing that a control is infeasible. Because of the
importance of personal exposure in potentially influencing control require-
ments, factors which can influence personal exposures are discussed in
Sections 6 and 7.
Of primary importance to~ the consideration of the aspects of dual
regulation is the protection of public health provided by the OSHA stand-
ards. Information which characterizes both the ambient emission of pollut-
ants and worker exposure to those pollutants is available from 10 coke
batteries. Although there are some definite limitations to the available
data, the information is used where possible to indicate trends and causal
relationships in the following areas:
1. The relative stringency of the two regulatory strategies,
2. The relationship between worker exposure and emissions, and
3. Projection of the public health protection provided when the
OSHA regulations are met.
A joint team of OSHA and EPA personnel inspected four coke batteries
at Republic Steel's Plant No. 1, Cleveland, Ohio, in September 1978. EPA's
objective in this joint inspection was to assess OSHA inspection procedures
relative to their own and analyze results of the inspection to determine
which of the two agency standards may prove the more stringent. The initial
analysis by EPA, as verbally communicated to the Research Triangle Institute
(RTI) by personnel who are knowledgeable in the area of coke oven emissions,
showed that a clear-cut determination of relative stringency was not provid-
ed by the Republic Steel inspection. Since such a determination is desira-
ble to provide the information necessary to institute policy decisions for
emission standards development, information reported from the joint inspec-
tion was analyzed further along with data from inspections at six other
batteries.
Inspections at the CF&I plant, Pueblo, Colorado, were conducted from
July 26-30, 1977, by EPA and from May 3-5, 1977, and July 12-14, 1977, by
OSHA. More violations were recorded by both agencies at CF&I than at
Republic Steel. This difference and the time separation of the inspections
limit comparative data interpretation. Additional data taken at the U.S.
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Steel Clairton plant, Clai'rton, Pennsylvania, also with a separation in
time between EPA and OSHA inspections, were similarly examined. The EPA
inspection was performed between August 22-31, 1978. The OSHA inspection
was performed between November 16 and December 1, 1978.
A statistical treatment of these data indicated significant effects in
relationships between personal exposure and emissions. These effects were
used to develop conclusions about worker protection and emissions. The
joint inspection data indicated that meeting the EPA tentative limits will
not adequately protect the workers. The converse that current enforcement
of the OSHA regulations will not adequately protect the environment was
also indicated. These aspects of dual regulation of coke oven batteries
are also discussed.
10
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5.0 PERSONAL EXPOSURE AND EMISSIONS INSPECTION DATA
DISCUSSION OF OSHA INSPECTION PRACTICE
OSHA inspections performed at Republic Steel's Plant No. 1, Cleveland,
Ohio, and the CF&I plant, Pueblo, Colorado, have been reviewed with regard
to trip reports, inspection guidelines, OSHA Forms IB (field inspection
report forms), and citations issued to determine actual inspection practices.
Personal exposure data and potential citations were also reviewed for the
U.S. Steel, Clairton, Pennsylvania, plant inspection.
Considerations involved in the OSHA inspection procedure at Republic
Steel were indicated by Earl Gregory, Team Leader from the OSHA Cleveland
Office, in a draft narrative description which was not generally accessible
because of potential confidentiality of process detail. It is noted here
only that as part of the OSHA procedure, battery construction features were
duly recorded, e.g.,
1. Design and location of aspirator steam nozzles,
2. Type of door seals and door construction,
3. Means of implementation of stage charging, and
4. Number of pushes observed, oven capacities, oven pressure,
coking time and temperature, and battery layout with site
description.
However, these features will vary from plant to plant.
Other features of the OSHA inspection procedure relevant to battery
emissions are provided by a coke oven inspection checklist prepared by the
Cleveland Office.
1. Monitoring results taken on a quarterly basis are to be made
available for employee personal exposures.
11
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2. Engineering controls are designated to include:
a. Stage, sequential, or pipeline charging,
b. A double collection main or jumper pipe system,
c. Adequate aspiration to remove gases during charging (a
recommended steam pressure range is given),
d. Mechanical volumetric controls on each Tarry car,
e. Coal vibrators, pneumatic shells, and stainless steel
liners to speed coal flow,
f. Larry car drop sleeves and slide gates to contain the
oven gases,
g. Mechanized gooseneck and standpipe cleaners,
h. Air seal (i.e. "smoke boot") on pusher machine leveler
bar,
i. Roof carbon cutters or a compressed air system on the
pusher ram to remove roof carbon,
j. Pressure control system for main pressure, and
k. Chuck door gaskets.
3. Work practices concerned with inspection, maintenance, and
operation of the above controls are also examined.
General guidelines for enforcement have been compiled in OSHA Program
Directive 300-10 to all regional administrators and area directors. However,
this directive provides no specificity with respect to emissions measurement
or control.
At the CF&I plant, essentially the same considerations were involved
with considerable emphasis placed upon maintenance and work practices.
Uniformly in the two inspections, visible emissions were utilized as an
indicator of inadequate maintenance and implementation of required work
practices or inadequate charging controls.
OSHA inspections are presently conducted by a team of personnel famil-
iar with coke battery procedures and selected for each inspection. Approx-
imately one-half of the batteries in the United States have been inspected
by OSHA (March 1979). Inspections are presently prioritized on the basis
of complaints received. Should these be exhausted, self-monitoring results
12
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for personal exposure and compliance schedules would dictate the necessity
of inspection.
The OSHA inspector may interview workers in private, a valuable tool
in assessing battery performance. This factor may reflect past battery
operating practices, giving an accurate picture of plant operation and
maintenance, including details of specific equipment or work practice
problems. Review of worker medical records is also a major aspect of the
inspection procedure.
The OSHA regulation for coke oven batteries is detailed in Appendix D.
Review of the OSHA inspection guidelines as described above indicate that
the full scope of the regulation is intended to be enforced through inspec-
tion. Selected sections of the OSHA Regulation CFR 1910.1029 are summarized,
as they may apply to emissions, as follows. Section designations for the
regulation are also shown.
(a) Scope. This section is taken to apply generally to employee
exposure to coke oven emissions.
(c) Permissable Exposure Limit. The PEL requires exposure of no
employee to coke oven emissions at 8-hour average concen-
trations of greater than 150 ug/m3 benzene soluble fraction
total particulate matter (BSFTPM).
(d) Regulated Areas. The coke oven battery, wharf, and screening
station are regulated areas. Beehive ovens are also regulated.
(e) Monitoring Program. Measurements must be obtained by the
employer which are representative of each employee's exposure
over an 8-hour period. Samples must be taken for at least
7 hours, with at least one sample during each shift for each
battery and each job classification. This sampling must be
done at least quarterly.
(e)(4) The method of measurement must have an accuracy of +35
percent at the 95 percent confidence level for concentrations
of >150 ug/m3 BSFTPM.
(f) Methods of compliance. Existing batteries must install the
controls detailed above for the inspection checklist no
later than January 20, 1980, unless they can be shown not to
be feasible.
Engineering controls and work practices required in addition to the
above are:
13
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Ready access to door repair facilities.
(c) An adequate number of spare doors must be available.
(e) Heat shields on door machines.
(a) Written inspection and cleaning procedures for
each battery including:
Prompt and effective repair or .replacement of all
engineering controls.
Inspection and cleaning of goosenecks and standpipes
prior to each charge.
Inspection for roof carbon buildup.
Inspection of steam aspiration system.
Inspection and cleaning, if necessary, of steam
nozzles and liquor sprays.
Inspection of standpipe caps prior to each charge.
Inspection of charging holes and lids, and luting
of standpipes and lids where necessary.
(b) Establishment of a written charging procedure.
Detailed procedural requirements are specified in
this section.
(jj) Coking. Establishment of a written procedure for
the coking cycle is required. It must be imple-
mented for the control of emissions during coking.
Minimum requirements are given.
(jjj) Pushing. A detailed written procedure for each
battery must be implemented to control emissions
during pushing. Minimum requirements are given.
(jv) Maintenance and repair. A detailed written proce-
dure for maintenance and repair established for
the effective control of coke oven emissions is
required. Elements of this procedure are given
explicitly.
!4)(j) Filtered air. Positive pressure, temperature
controlled filtered air is required for larry car,
pusher machine, door machine, and quench car cabs.
(jj) Standby pulpits. Required on battery topside,
wharf, and screening station.
14
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DISCUSSION OF EPA INSPECTION PROCEDURE
At present, EPA inspection involves exclusively an evaluation of visi-
ble emissions. These emissions are assessed quantitatively by a trained
observer utilizing prescribed procedures. These procedures have been
developed for use for charging emissions, topside emissions, and door
leakage. The inspection procedure is straightforward, requiring relatively
few personnel, and provides immediate results. The inspection may continue
through the day or extend over a period of several days. Ambient conditions,
e.g., wind speed and atmospheric condition, are recorded.
DESCRIPTION AND SIGNIFICANCE OF DATA
Data relating to inspections by EPA and OSHA at Republic Steel's Plant
No. 1, CF&I, and Clairton, are summarized in Appendixes A, 8, and C, accord-
ing to the visible emissions (VE) and personal exposures (PE), respectively.
Construction features of the batteries are summarized in Table 2. Personal
exposure is indicated as both concentration measured and time weighted
average (TWA) as utilized by OSHA. TWA is calculated as measured concen-
tration divided by 8 hours and multiplied by the period of exposure. Area
samples, in addition to PE samples, were taken by OSHA at each of the three
plants, but the area samples at Clairton applied only to lunchrooms and
offices.
Correlations may exist between a worker's occupational PE and measure-
ments of VE. For this reason a regression analysis was performed utilizing
average values at each of the 10 batteries investigated for VE and PE
classed according to occupation. The VE averages covered a period of
3 days at Republic Steel, 4 days at CF&I, and 4 to 9 days at Clairton. The
OSHA PE averages were measured for 1 day at Republic Steel, 4 days at CF&I,
and 2 days at Clairton. There was a time separation of about 1 week for
EPA and OSHA inspections at CF&I. Data were also included for an OSHA
inspection performed 2 months earlier. The time separation of the inspec-
tions performed at Clairton was about 3 months. Making a comparison on the
basis of these data required the assumption that battery characteristics
are essentially unchanged over a 2 to 3 month period.
There is very little information about pushing emissions. For this
source of emissions, OSHA's regulation only attempts to minimize the frequency
of green pushes.
15
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TABLE 2. BATTERY CONSTRUCTION DATA
Company
Plant
Manufacturer
Battery No.
No. Ovens Per Battery
Dates: Initial Operation
Major Rehabilitation
Partial Rehabilitation
Oven Height Meters
Feet
Charging Holes No. M ,
Dia. J™s
No. Collecting Mains
Standpipe, inside dia. pg'frs
Lid Lifters
Gooseneck Cleaner
Charging Control
Pushing Control
Larry Car Feeder
U.S. Steel
Clairton
Koppers
7,8,9
64
1918
1954
3.61
11 '10"
4
14"
2
0.330
13"
Manual
Manual
Stage
Charging
None
Gravity
U.S. Steel
Glalrton
Koppers-
Becker
19
87
1927
1976-77
1951
4.32
14'2"
4
14"
2
0.330
13"
Manual
Manual
Stage
Charging
None
Gravity
Republic
No.l
Cleveland
Koppers
1
51
1976
3.81
12'6"
3
16"
2
0.356
14"
Magnetic
None
Stage
Charging
Koppers
One Spot
Car
Screw
Republic
No.l
Cleveland
Koppers
2,3,4
51
1957-58
1973
3.86
12'8"
3
16"
2
0.356
14"
Magnetic
None
Stage
Charging
Koppers
One Spot
Car on #2
Not yet
on 3 & 4
Screw
CF&I
Pueblo
Koppers
B&C
67-47
1930
4.01
13'2"
4
16"
2
0.330
13"
Magnetic
Hydraulic
Stage
Charging
None
Screw
CF&I
Pueblo
Koppers
0
31
1918
1960
1975
4.01
13'2"
4
16"
2
0.330
13"
Magnetic
Hydraulic
Stage
Charging
None
Screw
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Any general conclusions reached on the basis of the limited data
available should be tempered by the following qualifications.
1. Average ambient conditions may not be reflected in a sampling
period of only 1 week, e.g., wind conditions would be subject
to more variation than would thus be represented. Different
wind conditions may result in different personal exposures.
2. Worker practices may not be uniform between plants. The
workers are not likely to remain in one area for the sampling
period. At any one plant, time spent in an area of high
concentration may override the usual occupational exposure.
3. Engineering controls will vary among plants. Some occupa-
tions may have their PE arbitrarily lowered by means of air
conditioned cabs and standby pulpits.
4. Plant construction features vary among plants. These fea-
tures may significantly alter the characteristic occupational
exposure.
Although correlations found are not extrapolated in this report, the
following should be considered in any such extrapolations.
1. It must be assumed that installation of OSHA required con-
trols and work practices would not greatly alter the nature
of the correlation.
2. There may be interactions among the variables; however, cor-
rections can be made with additional data.
Interpolation will not require these assumptions.
Results of the regression analysis are given in Table 3. These were
obtained by means of a step regression procedure for models correlating
personal exposures with visible emission measurements of charging (s/charge),
doors (percent leaking doors), lids (percent leaking lids), and offtakes
(percent leaking offtakes). A linear model
PE = BO + B (Char9e) + B2 (doors) + BS (lids) + B4 (offtakes)
and a nonlinear model,
PE = BO + Bl (Char9e)2 + B2 (doors)2'5 + BS (lids)2'5 + B4 (offtakes)2'5
were investigated. The nonlinear functions were suggested by models devel-
oped in connection with earlier work. The nonlinear model proved superior
in reducing error to the linear model and is the only one discussed herein.
The B-, i=l-4, are the regression coefficients and indicate the contribution
17
-------
TABLE 3. SUMMARY OF OCCUPATIONAL .MODELS FOR A NONLINEAR STEP REGRESSION ANALYSIS
CO
Model
Cokeside Door Machine Operator
PE = 322 - 0.370 (Lid)2'5
Pushside Door Machine Operator
PE = 344 + 0.0919 (Charge)2
Lldman
PE = 316 + 0.0999 (Doors)2'5
Tarchaser
PE = 1774 - 0.279 (Doors)2'5
Larry Car Operator
PE = 157 + 0.0111 (Charge)2
+ 0.0322 (Doors)2'5 + 0.0214 (Offtakes)2'5
Pusher
PE = 94.0 + 0.0123 (Charge)2
+ 0.0159 (Doors)2
Regression
Coefficient
-0.370 -
0.0919
•0.0999
-0.279 -
0.0111
0.0322
0.0214
0.0123
0.0159
Lid
- Charge
- Doors
Doors
- Charge
- Doors
- Offtakes
- Charge
- Doors
Relative
Standard Error
of Regression
Coefficient
±55%
±81%
±19%
±89%
±45%
±32%
±35%
±37%
±50%
Significance1
Level
Q.90
0.75
0.9993
0.70
0.9290
0.9794
0.969
0.9703
0.9147
r «2 -i
R'Correlation 1
Coefficient for]
|_ Regression J
0.267
0.159
0.783
0.135
0.935
0.709
^Significance level is the probability that the model would be in error if the variable were omitted from the model.
-------
of each source to the observed personal exposure. Their significance
levels are calculated for each of the visible emission sources.
The nonlinear regression indicates that charging emissions increase
the exposure of the battery workers. This increase with an increase in
visible emissions is expected. The larry car operators' exposure also
increases with increasing emissions from doors and offtakes in the nonlinear
model. Occasionally, however, a decrease in emissions correlates with an
increase in exposure. This situation may occur because worker zeal in
reducing visible emissions increases personal exposure, as discussed for
door cleaners and tar chasers in Section 7. Charging emissions significant-
ly increase the exposure of all the workers examined in the regression,
with the exception of the coke side door machine operator and the tar
chaser. None of the intercepts were negative here, and the model indicates
a possibility that the OSHA exposure standard could be met, with zero
emissions, for the push side door machine operator and the pusher, but the
topside workers and the coke side workers would not meet the exposure
standards with zero emissions from the four sources considered.
19
-------
6.0 DATA DISCUSSION
BATTERY COMPLIANCE WITH OSHA AND EPA REGULATIONS
At the time of this report (March 1979), citations or potential cita-
tions have been listed by OSHA for the plants previously described. These
citations have been reviewed for Republic Steel Plant No. 1, the CF&I
plant, and U.S. Steel, Clairton and none of the batteries were compliant
with the OSHA standard. At both Republic Steel and CF&I, numerous citations
were issued for lack of required maintenance procedures and work practices,
together with leaks from sources such as chuck doors, coke oven doors,
standpipes, lids, and damper boxes. The Republic Steel violations for
absence of engineering controls included:
1. Devices such as coal vibrators, pneumatic shells, or stain-
less steel liners to speed coal flow,
2. Mechanized gooseneck and standpipe cleaners,
3. Chuck door gaskets,
4. Positive pressure, temperature controlled filtered air for
the larry car, pusher, and door machines.
Similar violations at CF&I included:
1. Standby pulpits at the topside of Batteries B, C, and D, the
North and South wharves, and the screening station,
2. Positive pressure, temperature controlled filtered air for
the door machines, push machines, and larry cars,
3. Available spare doors, and
4. A mechanized gooseneck cleaner on one of the larry cars.
With regard to the EPA standard, one battery, No. 19 at Clairton,
seemed to fall essentially within the prescribed limits for visible emis-
20
-------
sions. Battery No. 1 at Republic Steel may be considered close, but it is
outside these limits. All other batteries exhibited significantly greater
emissions than permitted by potential EPA emission limits. The tentative
EPA emission limits are as follows:
1. Eleven seconds average visible charging emission over eight
consecutive charges,
2. No more than 5 percent leaking coke oven doors,
3. No more than 2 percent leaking lids,
4. No more than 5 percent leaking offtakes, and
5. No leaking collecting mains.
One primary method of determining the relative stringency of the OSHA
regulations and the tentative EPA limits is to evaluate the various emission
sources with respect to their compliance with the OSHA standards or the
tentative EPA limits. Although determining conformity with the tentative
EPA limits is a straightforward process, determining compliance with the
OSHA regulations is complicated and subjective even with a listing and
explanation of the OSHA criteria. This difficulty is caused by the absence
of a numerical emission standard, and citations for emissions must be
indirect and involve the absence of specific work practices which may or
may not cause these emissions. For example, the absence of a written plan
for the door repairs does not directly cause door emissions, but can contrib-
ute indirectly to the problem.
The potential for exceeding EPA limits and the OSHA violations for
repair, replacement, and adjustment of oven doors is compared in Table 4.
Two of the listed installations at CF&I were not cited by OSHA for failure
to maintain a continuous seal, but were cited lack of programs and proce-
dures to prevent leakage. It is easily seen that the EPA tentative limits
are more stringent than the OSHA requirements. Substantially greater rates
of emissions are expected from the current enforcement of OSHA requirements
than from potential EPA enforcement.
The violations from the prospective EPA limits and the OSHA rules for
leaking charging lids are presented in Table 5. There were only two bat-
teries in the test which were cited for leaking lids, although half of the
batteries had unacceptable lid emissions. The EPA limits were also more
21
-------
TABLE 4. THE RELATIVE STRINGENCY OF OSHA AND EPA POTENTIAL STANDARDS
FOR THE CONTROL OF COKE OVEN DOOR EMISSIONS
Violation
Battery
U.S. Steel, 19
CF&I, C&D
U.S. Steel, 9
CF&I, B
U.S. Steel , 8
U.S. Steel, 7
Republic, I
Republic, 2
Republic, 3
Republic, 4
Percent
leaking doors
4.1
6.7
9.6
12
12.3
12.7
14.7
18.2
24.5
36
EPA
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
OSHA
f(3)(ii)(b)a
No
Yes
No
Yes
No
No
Yes
Yes
Yes
Yes
Repair, replacement, and adjustment of oven doors to provide a continuous
metal-to-metal seal.
TABLE 5. RELATIVE STRINGENCY OF OSHA AND EPA STANDARDS FOR
THE CONTROL OF PERCENT LEAKING LIDS
Battery
Clairton,
Clairton,
Clairton,
Clairton,
Republic,
Republic,
Republic,
CF&I, B
Republic,
CF&I, C&D
8
19
7
9
3
1
4
2
Percent
leaking lids
0.3
0.4
0.9
0.9
2.1
2.6
5.0
7.0
8.0
8.6
EPA
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Violation
OSHA Regulation
No
No
No
No
No
No
No
Yes f(3)(iv)(a)a
No
Yes f(3)(iv)(a)a
f(3)(iv)(e)
Inspect and repair lids, prevent miscellaneous topside leaks.
22
-------
TABLE 6. RELATIVE STRINGENCY OF OSHA AND EPA STANDARDS FOR
THE CONTROL OF PERCENT LEAKING OFFTAKES
Percent
Violation
Battery leaking offtakes EPA
Clairton,
Clairton,
Clairton,
Clairton,
Republic,
CF&I, B
CF&I, C&D
Republic,
Republic,
Republic,
19
9
8
7
1
3
2
14
2.5
4.3
4.4
6.3
10.6
15
30
30
34
38
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
OSHA
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Regulation
f(3)(iv)(a)a
f(3)(iv)(a)a
f(3)(iv)(c)b
f(3)(i)(a)c
f(3)(i)(a)c
f(3)(i)(a)c
f(3)(iv)(e)d
f(3)(iv)(a) inspect and repair goosenecks and standpipes.
3f(3)(iv)(c) inspect and repair damper system, aspirator system, and col-
lector system.
"f(3)(i)(a) written inspection procedure.
f(3)(iv)(e) prevention of miscellaneous fugitive topside emissions.
stringent for leaking offtakes (Table 6). The OSHA citations followed the
same trend that was observed with door leaks: the permissible estimated
emissions were 10 times greater with the OSHA standards. Different regu-
lations were cited for these excessive emissions at the two plants in
violation of the OSHA standards.
Half of the batteries were in violation of the tentative EPA limits
for charging emissions (Table 7). However, the relative stringency of the
two standards is indeterminate for charging emissions. Three batteries
with acceptable EPA charging control were cited for OSHA violations, but
two batteries with unacceptable EPA charging emissions were not cited by
OSHA. All of the batteries with very poor charging emission control were
cited for violations by OSHA.
23
-------
TABLE 7. RELATIVE STRINGENCY OF EPA AND OSHA REGULATIONS IN
CONTROLLING CHARGING EMISSIONS
Battery
Clairton,
CF&I, B
Republic,
Clairton,
Clairton,
Clairton,
Republic,
Republic,
Republic,
19
1
7
8
9
3
4
2
Average emis-
sions (sec)
5.0
5.2
7.0
10.5
12
17
54
61
78
Violation
EPA
No
No
No
No
Yes
Yes
Yes
Yes
Yes
OSHA Regulation
No
No
Yes f(3)(i)(b)(3)(vii)a
f(2)(i)(e)b
No
No
No
Yes f(3)(i)(b)(3)(vii)a
f(2)(i)(e)b
Yes f(3)(i)(b)(e)(vii)a
Yes f(3)(i)(b)(3)(vii)a
f(2)(i)(e)b
f(3)(i)(b)(3)(vii) lack of luting on charging lids while aspirating.
)f(2)(i)(e) charging equipment.
To summarize the major results of the joint inspections, violations of
the OSHA personal exposure limits were recorded at every battery although
essentially Clairton1s Battery 19 did not exceed the tentative EPA limits.
This measurement indicates that the OSHA personal exposure standard was not
met even on a battery with emissions meeting the tentative EPA limits, and
the OSHA violations for engineering and work practice controls were gen-
erally less stringent than the EPA tentative emission limits.
RELATIONSHIPS BETWEEN WORKER FUNCTIONS AND EXPOSURE
The OSHA regulations require attainment of the permissible worker ex-
posure limit of 150 ug/m3 of benzene soluble matter as an eight hour time
weighted average. However, a number of factors can influence this time
averaged exposure. The preamble to the OSHA regulations recognize this fact
when they state that "area samples are generally not as direct a measure of
employee exposure as are personal breathing zone samples." Also, personal
employee exposures are not a direct measure of the magnitude of coke plant
emissions to the atmosphere.
24
-------
The two major areas of difference between battery emissions and worker
exposure are in exposure time and localized concentrations. From Figure 1,
it can be illustrated how the concentration to which a worker is exposed
can vary dramatically depending upon the work area. A man working at the
center of the topside of the battery would be expected to catch some of the
door leak emissions which are carried by the wind across the battery top.
Door emissions tend to travel vertically because they are hot and of lower
density than the ambient air. The area concentrations of the coke oven
door emissions on the battery top is a strong function of the wind condi-
tions, since the wind disperses these fumes across the battery top. Workers
such as tar chasers who are expected to spend a portion of the time at the
edge of the battery top could conceivably be exposed to more of the door
leak fumes than the other battery workers. It should be noted that in the
CF&I OSHA inspection, the tar chasers were exposed to higher levels of
pollution than the other employees. The larry car operator is exposed to
the charging emissions much more than the other workers on the battery
topside. His personal exposure data could be an indication of success in
controlling charging emissions; however, the use of filtered air larry car
cabs could conceivably result in low personal exposure data while at the
same time permitting unacceptable charging emissions.
The time spent by the worker on the battery is a significant factor
because the 8-hour exposure data can be substantially reduced if the worker
is only on the battery for a fraction of the time. Table 8 indicates
typical differences seen for personal exposure and time weighted averages.
The time weighted average which is reported for enforcement purposes may
vary substantially from the actual exposure concentration, but this is not
always the case. The majority of coke plant workers have a time weighted
average that is very similar to the actual exposure concentration. It
should also be emphasized that not only is the time weighted average poten-
tially different from the exposure concentrations, but also the exposure
concentrations will be markedly different from the concentrations in the
actual emission plumes.
One primary concern in estimating the pollution potential of any
source is the precision of the measurement. The time weighted exposure of
25
-------
CTI
EMISSION SOURCES
A END DOORS
B CHARGING LIDS
C LEAKING PIPES
ASCENSION PIPE
COLLECTION MAIN
TOP SIDE
CHARGING PORT
PUSHER-SIDE BENCH
END DOOR
COKE-SIDE BENCH
Figure 1. Schematic of the side of a coke oven.
-------
TABLE 8. SELECT COMPARISON OF AMBIENT EXPOSURE AND
TIME WEIGHTED AVERAGE
S-12
G-2
C-4
G-4
G-15
C-3
C-15
C-16
C-17
G-16
G-17
Number
Push side bench helper
South hot car
Larry car
Tar chaser
Lidman
Lidman
Pusher
North hot car
Bench helper coke side
Larry car
Wharf man
Exposure
(ug/m3)
160
90
480
310
290
290
170
30
870
540
140
Time
weighted average
(ug/m3)
80
50
320
210
120
200
110
10
330
330
30
the workers is a reasonably accurate measurement since it only has 21 per-
cent error. However, the precision of this measurement is of some concern.
This precision is a measure of the reproducibility of the data from day to
day or among different workers. The standard deviation is a common measure
of this reproducibility. The standard deviation of the time weighted
exposure is often greater than the measurements themselves (Table 9).
TABLE 9. WORKER EXPOSURE ON A COKE BATTERY OVER FOUR DAYS
Relative
Time weighted exposure Average standard
Functions (ug/m3) (ug/m3) deviation
Tar chaser (B)
Tar chaser (C&D)
Push side bench
helper (B)
Lidman (B)
100, 980, 620, 210
2,160; 10,500; 760; 890
520, 80, 40, 0
310, 120, 230, 20
477
3,580
128
170
0.84
1.30
1.73
0.75
The relative standard deviation is defined as the ratio of the standard
deviation to the average of the variable.
27
-------
TABLE 10. EMISSIONS FROM COKE OVEN DOORS
Average percent Relative standard
Battery leaking doors deviation
B 11.95 0.31
C&D 6.7 0.64
aThe relative standard deviation is defined as the ratio of the standard
deviation to the average of the variable.
This comparison is in sharp contrast to the more direct measurement of the
coke plant emissions by standards such as percent leaking doors. It is
felt that direct visible emissions measurements would consistently exhibit
greater precision because of inherent analytical limitations and ambient
condition variability affecting PEL measurements. In Table 10 it is easily
seen that the emissions from coke oven doors are more precise as indicated
by the percent leaking doors measurement.
There is a substantial difference in principle behind the application
of the two different types of data sets. The tentative EPA limits are
based upon average quantities such as percent leaking doors, percent leaking
lids and pipes, and cumulative charging times. The OSHA regulation is
based on the maximum datum in the data set: each worker must meet the
standard. Considering the apparent imprecision of worker exposure data,
the OSHA standard will be much more difficult to meet than the tentative
EPA limit. For example, if a normal distribution may be assumed for the
worker exposure, and the standard deviation of the exposures is approx-
imately as large as the average, then even if the average exposure could be
reduced to one-half the standard, more than 15 percent of the workers would
be in violation of the standard, and a battery with 10 workers would be in
violation more than 75 percent of the time.
The personal exposure of some of the workers will be reduced under the
OSHA regulations by the use of equipment changes such as filtered air cabs.
Since the current personal exposure data from these workers will not accu-
rately represent the situation after some of these OSHA requirements are
met, separate classifications are used in this report for coke oven workers:
28
-------
Type I, whose personal exposure will be substantially reduced by equipment
changes, and Type II, whose exposure will not be substantially reduced by
equipment changes, independent of corresponding reductions in ambient
emissions. Type I includes workers who will be protected by filtered,
air-conditioned cabs. Table 11 indicates separate OSHA violations for each
of the two categories, recognizing the possible changes in exposure levels
caused by regulated changes. Battery 19 at the Clairton plant was the only
battery in general compliance with the tentative EPA limits. However, it
was in violation of the OSHA standards. The average worker exposure on
Battery 19 was 230 ug/m3 with a standard deviation of 175 ug/m3. Table 11
shows that both the average worker exposure and the maximum worker exposure
was worse on Battery 19 than on Republic Steel Battery 1, which was in
significant violation of the EPA criteria. The majority of the batteries
which were in violation of the EPA criteria actually have lower OSHA Class II
maximum exposures than Battery 19. Possible explanations for this apparent
anomaly will be considered in the next section, because lowering worker
exposure must accompany reductions in emissions if the OSHA program is to
be successful in protecting both the worker and the environment.
RELATIONSHIP BETWEEN EMISSIONS AND WORKER EXPOSURE
Topside workers are exposed to battery emissions such as charging
emissions, leaking doors, lids, and standpipes. Of the different coke oven
emissions, the most significant are those from charging operations and door
leaks. At a Republic Steel battery, exposure of the operator of the larry
car increased with charging emissions as shown in Figure 2. OSHA has
extensive equipment and procedural requirements for charging emissions
control, but has no standards to control emissions other than a requirement
for the repair of defective equipment to prevent miscellaneous topside
emissions. Filtered air larry cars will be provided to reduce the oper-
ators' personal exposure from charging emissions but no reduction of battery
emissions will result from this. It is unclear what levels of charging
emissions will be tolerated by OSHA.
The influence of leaking coke oven doors on lidman exposure is signif-
icant. As the percent leaking doors is reduced, the lidman exposure is
correspondingly reduced, down to approximately 12 percent leaking doors
29
-------
TABLE 11. A COMPARISON OF COKE OVEN BATTERY PERFORMANCE NITH EMISSION AND EXPOSURE CRITERIA FOR TEN BATTERIES
Percent Leaking
00
o
All Workers ,
Class ExP°sure - vgW
Clairton
CF&I
Republic
EPA Standard
Average
Std. Dev.
Battery
7
8
9
19
B
C&D
1
2
3
4
Doors
PLD*
12.7
12.3
9.6
4.1
11.9
6.7
14.7
18.2
24.5
36
5.0
15.2
10.1
Lids
PLLt
0.9
0.3
0.9
0.4
7.8
9.7
2.6
8.0
2.1
5
2.0
3.76
3.4
Offtakes
PLO*
6.3
4.4
4.3
2.5
15.4
9
10.6
34
30
38
5.0
17.9
14.4
Charging
(sec)
10.5
12
17
5
5
?
7.0
78
54
61
11.0
26.6
28.8
Exposure
Max
2,700
2,700
2,700
740
980
10,500
345
435
2,900
976
II
Max
490
310
330
740
520
750
252
435
846
976
Avg.
478
331
389
230
200
868
164
256
517
303
Std. Dev.
731
582
673
175
214
2,140
105
134
811
299
*PLD = Percent leaking doors.
tPLL = Percent leaking lids.
fPLO = Percent leaking offtakes.
-------
lOOOr EXPOSURE =4.5 (SECONDS)-I- 177
CORRELATION COEF 0.849
AREA CONCENTRATION IN LARRY CAR
WORKER EXPOSURE IN LARRY CAR
to
o»
or
s
cr
500
UJ
tr
D
X
LU
100
20 40 60 80
SECONDS OF CHARGING EMISSIONS
100
Figure 2. The relationship between the charging emissions and worker
exposure in the Tarry car, Republic Steel Co.
31
-------
(Figure 3). Additional reductions in door emissions did not reduce the
lidman exposure levels, and the personal exposure actually seemed to in-
crease for the two batteries with the most effective door emission controls.
Figure 4 presents individual exposure data for door cleaners and bench
helpers. The data indicate that personal exposure is essentially indepen-
dent of the level of control obtained. More bench workers were tested,
however, for the batteries with the more effective door control. Because
of the imprecision of the exposure data, a number of workers with excessive
amounts of exposure were identified on those batteries with effective door
control and relatively large numbers of bench workers. Adding more workers
to keep the doors from leaking apparently increases the probability of an
OSHA violation.
Considering these results, it is useful to speculate on some of the
reasons for these data trends. One hypothesis is that rigorous emission
control may be obtained by conscientious work practices, and that increased
attention to work practices could increase worker exposure. Batteries
which have rigorous maintenance programs could be expected to have greater
worker exposure from the emission plumes. When the maximum exposure is
plotted against the percent leaking doors for the 10 batteries investi-
gated, an apparent minimum exposure was observed at 13 percent leaking
doors (Figure 5). On batteries with more than 13 percent leaking doors,
increasing door leakage correlated with increased lidman exposure. For
batteries with violations and with less than 13 percent leaking doors,
almost all the maximum exposure was for door cleaners. These results
strongly indicate that reducing emissions does not necessarily reduce
worker exposure.
To emphasize the importance of work practice on emissions control, the
severity of the OSHA violations, and the danger to the health of the worker,
the function of a tar chaser will be discussed as an example. Both the
total particulate and benzene soluble fraction were reported for tar chasers
on the CF&I batteries. Figure 6 indicates a significant trend where the
benzene soluble fraction of the particulate increases as worker exposure
increases. The limiting value at low exposure levels (0.27) is similar to
the benzene soluble fraction of exposure of lidmen (0.33).
32
-------
IO
<
Q
1000
900
800
S2
^ 700
UJ
fl 600
»
ui
3 500
(O
2
X 400
-------
UJ
3
UJ
£
LU
*"~
UJ
11
O o*
Q. 4.
X
UJ
^
o
(O
or
Ul
o_
UJ
z
u
or
£
lOOOp
900
800
700
600
500
400
300
200
100
"\
\
\
\
T
\
\
\
• »
^.^
A . ^w
»^
• ^*— -.^..^ MAXIMUM OSHA VIOLATION
0 ' .
• • •
•^ ^^
_ ^
0
* 1 •*• •
^ ^h
• 1 .. ! 1 1
10 20 30
PERCENT LEAKING DOORS
40
Figure 4. The relationship between the percent leaking doors and bench worker
exposure.
34
-------
1000
900
800
tu
§ 600h
en
2
2 500h
or
in
GC 400-
300
x
< 200
100
• DOOR CLEANER
o LIOMAN
OSHA STANDARD
10 20
PERCENT LEAKING DOORS
30
40
Figure 5.
Maximum worker exposure at various emission levels
from coke oven doors.
35
-------
CO
en
.9
.6
3
t.
_
CO
UJ
z
UJ n
N .2
Z
UJ
CD
.1
EXPOSURE : 0.031 (T.P.) + 0.271
CORRELATION COEF. 0.736
€>
I
5000
TOTAL PARTICULATE
10,000
3
15,000
Figure 6.
The relationship between total participate collected and the benzene soluble fraction of
the particulate in the tar chaser personal exposure of CF&I.
-------
The benzene soluble fraction of the participate at high tar chaser
exposure is similar to the benzene soluble fraction of tar, based on plant
data. This similarity is not unexpected, because the job function may
require exposure to oven fumes containing coke tar. The tar chaser personal
exposure appears to be directly a function of how conscientiously he works.
The tar chasers' duties involve cleaning the collection main and removal
of tar deposits at the ascension pipe connection to the collection main so
that the oven gases may escape to the main and not leak to the atmosphere
from the door seals, oven lids, or standpipes. With 70 percent signifi-
cance, the tar chasers' exposures were greater when the doors leaked less.
There was no significance to the tar chasers' exposure from other sources
of emissions. This example illustrates the complexity of the factors
involved in protecting both the worker and the environment.
To more clearly define the complex factors in the relationships between
visible emissions and worker exposure, a detailed analysis of correlations
among the variables was developed for the batteries at the Republic Steel
and U.S. Steel plants. The data were examined separately for significant
correlations at each plant to determine the potential for plant-to-plant
variability, as well as the relationships between emissions and worker
exposure.
The average worker exposure and visible emission data are presented in
Tables 12 and 13. The correlation coefficients calculated from these data
are presented in Tables 14 and 15. Only those correlations for which there
is a greater than 90 percent confidence will be discussed here.
The door cleaners, larry car operators, and lidmen were all positively
correlated. Reducing the exposure of one of these workers would tend to be
related to a reduction in exposure of the other members of that group. The
coke door machine operator, however, was negatively correlated with the
other worker functions. When the exposure of the other workers was less,
his exposure was greater. Similar negative correlations between worker
functions were observed at Clairton, with negative correlations between
lidmen and machine workers (99.7 percent confidence) as well as larry car
operators and the average topside workers (98 percent confidence). These
data indicate that the variables which determine worker exposure cannot be
simply controlled to reduce all of the worker's exposure.
37
-------
TABLE 12. AVERAGES OF TIME WEIGHTED WORKER EXPOSURE AND
EMISSIONS AT THE REPUBLIC STEEL PLANT
Variable
Door cleaner
Larry car operator
Lidman
Coke door machine
workers
Side workers
Top workers
Machine workers
Doors
Lids
Offtakes
Charging
TABLE
Variable
Pusher machine
workers
Larry car operator
Lidman
Top workers
Side workers
Machine workers
Door cleaners
Doors
Lids
Offtakes
1
169
241
252
345
216
259
166
14
2
10
7
2
290
404
435
296
291
273
221
.7 18
.6 8
.6 34
.0 78
13. AVERAGES
EMISSIONS AT
7
100
170
350
220
370
145
490
12
0
6
8
143
180
210
190
170
273
200
.7 12
.9 0
.3 4
Battery
3
356
490
846
210
312
396
218
24.5
.0 2.1
30
54
4
356
575
976
189
356
429
182
36
5
38
61
Units
[jg/m3, TWA
|jg/m3, TWA
(jg/m3, TWA
|jg/m3, TWA
jjg/m3, TWA
(jg/m3, TWA
pg/m3, TWA
Percent leaking
doors
Percent leaking
lids
Percent leaking
offtakes
Charging,
seconds
OF WORKER EXPOSURE AND
THE CLAIRTON PLANT
Battery
9
' 165
180
280
208
287
217
270
.3 9.6
.3 4.3
.4 17
19
117.5
125
372
290
277
117
275
4.1
2.5
5.0
Units
ng/m3, TWA
Mg/m3, TWA
|jg/m3, TWA
Hg/m3, TWA
|jg/m3, TWA
|jg/m3, TWA
(jg/m3, TWA
Percent leaking
doors
Percent leaking
lids
Charging,
seconds
38
-------
TABLE 14. CORRELATION COEFFICIENTS AMONG VARIABLES AT REPUBLIC STEEL
Emission source
Worker function
Door cleaner
Larry car operator
Lidman
Coke door machine
operator
Side workers
Top workers
Machine workers
Larry car operator
Lidman
Coke door machine
operator
Doors
0.79
Q.91
0.93
-0.91
0.91
0.93
-0.03
Door
cleaner
0.96
0.92
-0.94
Lids
0.14
0.17
-0.11
0.08
0.26
-0.24
0.39
Larry car
operator
0.96
-0.97
TABLE 15. CORRELATION COEFFICIENTS AMONG
Offtakes
0.90
0.90
0.75
-0.78
0.94
0.64
0.58
VARIABLES AT
Charging
0.77
0.71
0.49
-0.54
0.75
0.36
0.77
Lidman
-0.998
CLAIRTON
Emission source
Worker function
Pusher machine
operator
Larry car operator
Lidman
Door cleaners
Top workers
Side workers
Machine workers
Doors
+0.03
+0.885
-0.556
+0.30
-0.90
+0.00
+0.58
Lids
-0.09
+0.16
+0.50
+0.70
+0.01
+0.88
-0.43
Offtakes
-0.28
+0.68
-0.12
+0.70
-0.64
0.46
+0.15
Charging
+0.74
+0.88
-0.61
-0.12
-0.81
-0.08
+0.68
The leaking offtakes at Republic Steel were correlated with increased
door cleaner exposure (90 percent) and larry car operator exposure (90 per-
cent). There was no significant effect of leaking offtakes on the worker
39
-------
exposure at Clairton. Leaking lids were also not a significant factor in
worker exposure at Clairton.
Leaking doors increased both the larry car operator's exposure (91 per-
cent confidence) and the lidman's exposure (93 percent confidence) at
Republic Steel, but decreased the coke door machine operator exposure
(91 percent confidence). The opposite effect was observed at Clairton:
the average topside worker exposure was reduced by increased leaking doors
(90 percent confidence).
These results demonstrate that reducing emissions does not necessarily
reduce worker exposure, and in some circumstances it is accompanied by an
increase in worker exposure, that is, negative correlation coefficients.
Whenever an emission source and a worker exposure is negatively correlated,
reducing the emissions and reducing the exposure are mutually exclusive:
either the surrounding population may be protected or the worker may be
protected, but not both. Because of the potential for negative correla-
tions, personal exposure is an unacceptable indicator of emissions.
ROLE OF OSHA REGULATIONS IN THE ACHIEVEMENT OF ERA'S TENTATIVE
EMISSION LIMITS
This section will discuss industry's ability to comply with the OSHA
standards and the potential effect of this compliance on the level of
atmospheric emissions. The data analyzed in this investigation show that
the industry has thus far demonstrated an inability to meet the OSHA stand-
ards and must deal with a subjective interpretation of some of the regula-
tions. The citations issued include (1) exceeding the maximum worker
exposure level, (2) lack of detailed written procedures (for which minimum
standards are not specified), (3) inspection and prompt, effective mainte-
nance and repair (no specific standards), (4) mandated engineering controls
not used (a choice of equipment controls is provided, and standards of
equipment performance are not specified), and (5) adjustment or replacement
of doors to prevent leaks (no emission standard). The industry can comply
with work practices, maintenance and repair requirements, and use of option-
al equipment, but only through a subjective determination of adequacy and
without assurance that the worker exposure level will be met.
There is a flexibility that is built into the determination of standard
violation that may result in nonuniform application of the OSHA standards
40
-------
on a site-specific basis. This application would lead to a variation of
emission levels at different sites or at different batteries at the same
site. This flexibility is manifested in (1) the previously mentioned lack
of specificity for procedures, inspection, maintenance, and repair, (2) man-
dated equipment controls, but with options, (3) no standard of performance
for the equipment, and (4) options designated only to decrease worker
exposure with no decrease in emissions. For example, to meet the charging
requirements a company may use stage charging, sequential charging, or
enclosed (e.g., pipeline) charging if this is subjectively determined to be
adequate. Emissions will vary depending on which of these techniques is
chosen. Adequate aspiration during charging is required, but the amount of
emissions will be determined by the interpretation of "adequate."
An individual company has the option of attempting to demonstrate the
infeasibility of required controls through arguments of design or technical
problems, remaining life of the battery, and previous efforts to implement
controls. The level of emissions at that company may then be determined by
its success in defending its interpretation of "infeasible."
The industry may meet the specific requirements of the standard without
effecting a decrease in emissions. Worker exposure levels may be decreased
by the use of filtered air supply for equipment cabs and work stations,
increase in the number of workers, or decrease in work hours (since a time
weighted concentration is used). These changes would result in isolating
the employee or limiting exposure time rather than in eliminating emissions
at their source.
For an extreme case, the OSHA standards do not prohibit collecting
coke oven door emissions and discharging them at a remote point. This
practice would reduce worker exposure but could potentially increase emis-
sions to the environment and adjacent population, even if directed through
air pollution control equipment.
Some other factors that may help industry comply with the OSHA regula-
tions without protecting the environment are wind conditions and worker
avoidance of emission sources. If the OSHA inspection is on a windy day,
or in an area with constant air movement, emissions may be readily dispersed.
Therefore, worker exposure levels could be lower with no corresponding
decrease in emissions. Also, workers may be instructed to avoid areas
41
-------
where there are leaks and effectively lower exposure levels. Both of these
situations will aid in industry compliance with OSHA standards. The possi-
bility of subjective and nonspecific requirements, compliance through
personal protective equipment and control of work habits points out the
need for an emissions standard.
42
-------
APPENDIX A
REPUBLIC STEEL PLANT #1
INSPECTION DATA
43
-------
EPA INSPECTION DATA
1
Visible Emissions Data • Republic Steel, Cleveland, Ohio Coke Plant No. 1
September 13-20, 1973
Total NunSer of: Ovens 51
Doors 102
Hds 153
Offtakes 102
Battery 1
Charging
sec
Run
Offtakes Run f>
" " '23.0
0.5
5.5
4.0
6.0
2.0
5.5
§ non-consec
non-consec
. " " "
'Average' 5.9 sec/ch
Battery 2 Charging
(29.5) non-consec
(1.5) non-consec
62 sec
119 •
07
o /
165
81 .
196 .
(355) rr.alfuntlon
212
Total "S22"
Average 132 sec/ch
Battery 3 Charging 10.5 sec
10.5
31
Total GOT
Average 22.7 scc/ch
. •
1 1.3
2 2.6
3 JJt
Avcra'gc iT/5i
L1ds Run tf
1 8.5
2 7.2
3 4.6
4 7.8
5 0.7
Average b.tfft
L1ds Run %
1 3.3
2 2.6
3 0.7.
Avcrage 27?
1
2
3__
Average
5.9
15.7
8.8
TO*
Offtakes Run i.
i
2
3
4
5_
Average
31.4
23.4
36.3
20.4
30.4
•STTBK
Offtakes Run %
Mains Run
1 .
2
3
Average 2TJ
Mains Run
Mains Run $
'Data taken by EPA (OAQPS-ESEDO-EMB, office division branch) representative.
Doors .Run
1 .
2_
Average
Doors Run
1
2
3 .
4 .
Average
17.2
14.5
T579H
18.7
18.6
14.7
24.7
Doors Run 5J
1
2
3
Average
3
2
0
T
• I • • •
rcj^icncj
1
2
...3
. Average
40.2
21.6
25.5
-217T .
1 1
2 0
Average oTf
1
2
Average
25
12
~w
.5
.4
To"
-------
Visible Emissions Data
September 18-20, 1978
EPA INSPECTION DATA1
Republic Steel, Cleveland, Ohio Coke Plant Mo. 1
Total Number of: Ovens 51
Doors 102
Lids 153
Offtakes 102
Battery 1
tn
Battery 2
Battery 3
Battery 4
Charging
Total
Average
Charging
Total
Average
Charging
Total
Average
Charging
Average
8.0 sec
12.0
3.0
6.0
23.0
1.0
4.0
57.0
8.1 sec/ch
67.0
16.0
72.0
155.0
51.8
30.0
37.0
192.0
259.0
86.1
61.0
61.0
Lids Run %
1 3.9
2 2.6
Average 3.2
Lids Run %
1 8.5
Lids Run %
1 2.0
Lids Run %
1 4.6
Offtakes Run %
1 10.8
2 10.8
Average 10.8
Offtakes Run %
1 37.3
Offtakes Run %
1 30.4
Offtakes Run %
1 38.2
Doors Run
1
2
Average
Doors Run
1
Doors Run
1
Doors Run
1
%
14.7
11.8
13.2
%
16.7
%
29.4
%
36.3
1
Data taken by Regional Office representative
-------
TABLE A-l. REPUBLIC STEEL^PLANT #1 OSHA INSPECTION DATA FOR PERSONAL
EXPOSURE (ug/nT BSTPM)
Date Position
9/18-20/78 Door Machine Op.-CS
Door Machine Op. -PS
Door Cleaner-PS
Larry Car Area
Millwright Helper
Lidman
Pusher Machine Op.
Tar Chaser
Lidman
Patcher
Patcher Helper
Larry Car Area
Door Cleaner
Door Cleaner
Door Machine Op.
Pusher Car Op.
Larry Car Op.
Larry Car Op.
Door Machine Op.-CS
Lidman
Door Machine Op.
Larry Car Op.
Larry Car Area
Door Cleaner
Patcher
Patcher Helper
Door Machine Op.-CS
Lidman
Lunch Room Area
Door Repair Area
Battery
1
1
1
1
1
1
1 & 2
1 & 2
2
2
1 & 2
2
2
2
2
2 & 3
2 & 3
3
3
3
3
3 & 4
3 & 4
3 & 4
3 & 4
3 & 4
4
4
Concentration
(yg/m3 BSFTPM)
387
148
190
173
31
271
24
323
480
124
152
472
450
186
434
238
436
254
230
894
3312
672
513
401
48
140
215
1031
219 & 73
55
TWA
(pg/m3 BSFTPM)
345
133
169
153
27
252
21
284
435
108
132
419
411
169
488
217
404
241
210
846
2990
575
451
356
41
124
189
976
68
46
46
-------
APPENDIX B
CF&I INSPECTION DATA
47
-------
EPA INSPECTION DATA
VISIBLE EMISSIONS FROM CHARGING CF&I PLANT, BATTERY B
July 28, 1977
July 30. 1977
I -
Jven
ri
a
i
f*
57
T
"i9
1'"
__
1
^1 9
i
•
A2^B
!zP
'^ii
•
<2^P
M. -.
Duration of visible
emissions by observer,
seconds.
. . I - J 2
10
2
10
7
10
2
7
4
. 4 5
15 12
I
9
5
14
6
5
4
4
.
6
8
3
_
'
,
8
5
10
4
3
15
5
8
4.
4
20
8
5
17
4
4 : 3
6
4
5
8
0 ' 0
3 8
3
6
4
4
3
6
6
10
5
. t _
4 I 3
- ..
Oven
No.
B15?
C15
A17
B17 •
C17
A19
B19
C19
A21~
B21
A23f .
B23
A8
B8
C8
A10
BIO
CIO
A12
Duration
emission
ac
l 1
of visible
5 by observer,
conds.
? Y
i
4
2
2
1 '
6
2
3
1 1
3 4
3
2
1
5
8
6
5
5
6
5
2
5
9
6
i
i
i
3
3
2
5
5
.2
3
1
0
9
4
4
4
4
t
5
5
9
6 '
Oven
Mo.
B2V'
C2
A4
B4
- C4':' •
A6
B6
C6
A8
B8
C8
A10
2 .. 6
. 5
4 .
4
1
5
6
3
1
3 6
7 '6
10 - 13
i
Duration of visible -
emissions by observer,
,_ seconds.. . . ~
1 ._ 1. ._.2 .
!
4
4
6
5
7
3
5
5
2
11
8
3
i
'
1
6
9
4
8
5
6
3
2
2
8
.1
0
6
6
3
6
3
5
2
1
2
7
i
•
i
'•
t
\
*
\ ,
Mean = 4
Mean = 4
48
-------
EPA INSPECTION DATA
VISIBLE EMISSIONS FROM CHARGING CF&I PLANT, BATTERY B
July 26, 1977
July 27, 1977
Oven
No.
C2
A4 -
B4
C4
A6
B6
-C6
A8
B8
C8
A10
BIO
CIO
A12
'B12
A22
B22
Al
Bl
Cl
'
.
Duration of visible
emissions by observer,
cnf-rmrfc
.. JL_J
I
3
3
4
" 2. .
8
5
9
2 ! 4
4 •
7
3
6
3
7
3
7
2
7
5
7
6
3
4 i
4
7
6
4
9
6
9
r
2
2
• 10
9
6
11
3
3
|
4
6.
7
2
4
7
3
5
5
5
2
2
1
Oven
Mn
liU .
^
C12
B12
B14
C14
A16 •
B16
CIS
A18
B18
CIS
A20
B20
A22'
! 6 A9
6
9
7
1
i
6 ; n
3 ! 2
•• • i
•
I f
J
..
•
;
I
I
r
•
•
B9
C9
All
Bll
Cll
A13
!
i
i
i
i
i
;
Duration of visible
emissions by observer,
5Prnnrf<; - ..
1 |
_.._ ^
1
•
3 1
4
6
5
8 ! 11
15 ! - 8
' 3 j 4
2 i 2
1
5
2
3
3
-o-
3
19
. 7
8
5
6
9
5
3
3
2.
2.
4
i
1
0
20
3
1
5
9
10
1
3
2
1
1
1
1
2
25
5 1 6
1 5
! 4
6
.12
5
6
6 ! 11
8:5
4 ! 7
t .
! i
! i
•
t
|
I
1
1 t
i
l_i. .1 -
I
'
Mean = 5
t-'ean =
49
-------
CF&I EPA INSPECTION DATA
DOOR LEAKS
Date Time Started
Battery B 7-26-77 0741
0838
0936
1042
1136
1357
1456
1542
1640
7-27-77 0740
0847
0950
1046
1243
1340
1446
1543
7-28-77 0745
0842
0945
1045
1330
1436
1535
7-29-77 0725
0826
0926
1026
1422
7-30-77 0720
0821
0926
1020
Average
% Leaking Doors
7.7
7.7
7.7
9.2
6.9
15.4
12.3
7.7
10.8
11.5
13.1
16.2
15.4
8.5
13.8
15.4
16.2
15.4
18.5
16.2
9.2
7.7
13.8
11.5
13.1
10.8
9.2
6.9
10.8
9.2
10.0
13.8
21.5
11.9
No. of Doors
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
130
50
-------
CF&I EPA INSPECTION DATA
DOOR LEAKS (con'd.)
Date Time Started
Batteries 7-26-77 0720
C & D 0820
0921
1030
1125
1336
1437
1529
1628
7-27-77 0725
0830
0932
1030
1230
1328
1430
1530
1630
7-28-77 0724
0825
0925
1025
1315
1419
1515
7-29-77 0743
0841
0943
1047
1411 "
7-30-77 0736
0831
0920
1028
% Leaking Doors
5.8
3.8
5.2
8.2
6.0
11.2
17.2
3.7
5.2
3.1
4.5
11.9
15.7
4.5
4.5
11.2'
6.0
3.7
4.5
5.1
8.3
10.3
5.8
9.6
3.8
3.2
3.8
1.9
2.6
3.2
7.4
4.3
4.3
19.1
No. of Doors
156
156
134
134
134
134
134
134
134
134
134
134
134
134
134
134
134
134
156
156
156
156
156
156
156
156
156
156
156
156
94
94
94
94
Average 6.7
51
-------
CF&I EPA INSPECTION DATA
TOPSIDE VISIBLE EMISSIONS
Date
Battery 7-26-77
B
7-27-77
7-29-77
7-30-77
Average
Batteries 7-26-77
C & D
7-27-77
7-29-77
7-30-77
Average
Time
Started
0800
0951
1149
1357
0908
0907
0143
0805
0758
0845
1057
1341
1446
1555
0800
1402
1107
0413
0905
0807
0954
Leaking Lids
4.6
19.6
23.1
6.5
6.5
4.2
2.6
2.7
0.4
7.8
12.4
18.3
11.9
6.7
16.8
5.2
10.1
8.0
6.1
5.8
4.9
—
9.7
%
Leaking Offtakes
16.8
16.8
20.8
15.4
13.8
14.6
10.8
16.9
13.1
15.4
15.4
31.3
19.9
31.4
42.9
33.6
23.9
26.1
7.7
12.8
27.6
55.6
58.5
30.9
Leaking Mains
0
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
52
-------
CF&I OSHA INSPECTION DATA
PERSONAL EXPOSURES (yg/m3 BSFTPM)
B
Battery
Occupation
Pusher
Door Machine
Bench Helper,
c-s
Bench Helper,
P-S
Larry Car Op.
Date
7-12-77
7-13-77
7-14-77
5-3-77
Average
7-12-77
7-13-77
7-14-77
5-3-77
Average
7-12-77
7-13-77
7-14-77
5-3-77
Average
7-]2-77
7-13-77
7-14-77
5-3-77
Average
7-12-77
7-13-77
7-14-77
5-3-77
Average
C & D
Batteries
Personal Exposure Personal Exposure
(yg/m3 BSFTPM) (yg/m3 BSFTPM)
Cone. TWA Cone. TWA
160
40.
-------
CF&I OSHA INSPECTION DATA
PERSONAL EXPOSURES (yg/m3 BSFTPM) (cont'd.)
B
Battery
Occupation Date
Tar Chaser 7-12-77
7-13-77
7-14-77
5-3-77
Average
Lidman 7-12-77
7-13-77
7-14-77
5-3-77
Average
Personal Exposure
(yg/m3 BSFTPM)
Cone. TWA
100
1000
620
310
70
420
370
140
290
230
290
80
233
100
980
620
210
478
310
120
230
20
170
C & D
Batteries
Personal Exposure
(ug/m3 BSFTPM)
Cone. TWA
(D Battery) 770
(C Battery) 23,000
3,320
(D Battery) 890
(C Battery) 5,150
590
5,620
430
380
-------
CF&I OSHA INSPECTION DATA
AREA SAMPLES
Area Date Concentration
(ug/m3 BSFTPM)
Push Car #1 5-5-77 TOO
7-13-77 40
Average 70
Push Car #2 7-12-77 20
7-13-77 0.0
Average 10
Push Car #3 5-5-77 30
7-12-77 70
7-13-77 100
Average 100
(Overall Push Car Average) (60)
Door Machine #2 5-4-77 130
7-12-77 0.0
7-13-77 70
Average 67
Door Machine #3 7-12-77 70
7-13-77 120
Average 95
(Overall Door Machine Average) (81)
Larry Car #1 7-12-77 ]30
Average 130
Larry Car #2 5-4-77 200
7-12-77 180
Average 190
(Overall Larry Car Average) (160)
Other area samples taken at north and south hot cars, B & C & D battery launch
rooms, door repair area, office, cellar, receiving room, and north and south
wharf, range from 0.0-130 ug/m3 BSO.
55
-------
APPENDIX C
CLAIRTON INSPECTION DATA
56
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY INSPECTION DATA
CHARGING EMISSIONS DATA >a Of. OPACITY
FOUP CONSECUTIVE CHANGES
U. S. STEFU CORPORATION
CLMKTON. PFNNSYLVANJA ? .
8ATTEHY 07
cn
DATE
08-22-78
08-24-70
08-29-78
08-31-78
TIME OF CHAHOE
1031 --1025
1037 — 1040
1100—1104
1115—1119
1139 — 1143
11SO — 1154
1212— 121*
852™ 855
905 — 909
9/.0 — 952
1003 — 1006
1059 — 1102
936— 942
1018 — 1025
1029 — 1035
lllft— 1127
1131 — 1138
923 — 927
933 — 936
9/,6 — 951
1000 — 1005
10?9 — 1034
1040 — 1044
1054 — 1059
1107—1110
OVEN
A06
P06
A04
R08
A10
BIO
A12
A28
4?H
A30
B.HO
HOI
HIS
A17
R17
A19
R19
A12
HI?
A14
HI t,
A16
Rlf.
AIR
nia
CHARGE »SEO
?iO.
15.
25.
13.
29.
19.
10.
7.
15.
7.
0.
Q.
22.
62.
34.
36.
21.
3S.
29.
34.
13.
52.
27.
43.
32.
SUM (SEC)
73.
82.
86.
71.
65.
51.
39.
37.
39.
46.
101.
127.
154.
153. '
126.
121.
119.
111.
12«.
126.
135.
154.
MEAN (SEC)
18.
?0. .
21.
18.
16.
13.
• 10.
9.
10.
11.
25.
32.
38.
38.
31.
TO.
30.
?.n.
32.
31.
34.
3H.
-------
U.S. ENVIRONMENTAL PHOTECT JON AGENCY INSPECTION DATA
CHARGING EMISSIONS DATA > = 0% OPACITY
FOUP CONSECUTIVE CHARGES
U. S. STFEL CORPORATION
CLAIRTON, PFNNSYLV4NIA '
BATTERY 0* !
en
00
DATE
08-22-78
08-23-78
Oa-24-78
08-29-78
08-31-7fl
TIME OF CHARGE
lOOfl— 1012
1049—1053
1127 — 1130
1202—1206
929 — 9~33
1007 — 1012
1050 — 10'JS
904— 90H
921 — 924
947— V5?
1002— 100S
1025— 102fl
1045 — 104W
1126—1127
913— 917
1009 — 1013
1110 — 1114
900 — 904
911 — 91S
950— 954
1016 — 1020
1056 — 1100
OVEN
«06
• ROH
P10
ru?
Alf.
AlB
A20
A2H
»>30
A30
B15
P01
C01
A01
AJ5
A17
A19
A12
F<12
A14
A16
Alft
CHARGE (SEC)
vS.
15.
.¥•£?.•
.16.
17.
•20.
21.
10.
7.
13.
26.
4'.
17.
ft.
34.
999.
7.
35.
2R.
16.
35.
19.
SUM (SEC)
5".
70.
75.
74.
6fl.
50.
51.
56.
50.
60.
55.
61.
. 999.
999.
999.
990.
H«S.
114.
9fl.
MEAN (SEC)
1'..
18.
19.
IH.
17.
14.
13.
14.
13.
15.
14.
1ft.
999.
999.
999.
999.
21.
20.
24.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY . INSPECTION DATA
CHARRING EMISSIONS DATA >= 0* OPACITY
FOUR CONSECUTIVE CHARGES
U. S. STFEL CORPORATION
CLAIRTON. PENNSYLVANIA
BATTERY 09 '
On
CO
DATE
08-23-78
08-24-70
08-29-78
08-31-78
TIME OF CHARGE
913— 917
942— 945
. 955 — 1000
1022 — 102/,
1037—1042
1109—1113
1120 — 1125
R47— 850
919— 923
932-- 93*
101R — 1021 .
. 103ft — 104D
111H — 1122
950— 954
1000 — 1004
1043—1047
1054 — 1057
917 — 921
939— 944
1003 — lOOh
1016—1021
1032 — 103H
1046—1051
1112— lllft
1121 — 1125
OVEN
H16
AIR
HI 8
A20
H20
A22
K22
R2fl
A30
H30
A01
M01
C01
A17
H17
A19
R19
A14
«14
A16
Hlft
AJR
H1R
A20
»20
CHARfiE (SEC)
!
27;.
9.
?(}•
12.
IS.
ft.
13.
20.
9.
ft.
9.
3.
11.
13.
fl.
13.
6.
11.
999.
30.
22.
14.
24.
32.
29.
SUM («?F.C>
ftn.
5ft.
53.
4ft.
54.
4R.
41.
44.
27.
29.
3ft.
35.
45.
40.
3ft.
999.
990.
«99.
999.
90.
92.
99.
MEAN (SEC)
17.
14.
13.
11.
13.
12.
12.
11.
7.
7.
9.
9.
11.
10.
10.
999.
999.
999.
999.
23.
23.
25.
-------
U.S. ENVIRONMENTAL PROTECTION AOENCY
INSPECTION DATA
CHARRING EMISSIONS DATA ><
FOUP CONSECUTIVE CHARGES
U. S. STEFL CORPORATION
CLATHTON. PENNSYLVANIA
IUTTEWY 19
0* OPACITY
en
o
DATE
08-23-78
OS-25-78
08-28-78
08-29-78
0«-30-78
TIME OF CHARGE
854-- H«59
90ft — 91 1
92* — 930
930 — 941
950— 21
C21
A 23
H23
R20
C?0.
A22
H22
C22
A24
H24
C24
P2ft
C26
A?fl
K?f»
C?fl
A01
C28
A01
HOI
COl
A03
no 3
ro3
A05
no 5
r.o5
A07
C17 '
M9
Ml O
Cl«
A21
H21
C21
A23
H?3
C?.T
CHARGE (SEC)
3.i}
4."
7. it
19..
4,!
4.
19.
21.
3.
4.
7.
A.
15.
«.
8.
5.
5.
10.
999.
990.
999.
999.
999.
999.
12.
8.
a.
5..
9.
5.
23.
12.
9.
8.
8.
7.
4.
1.
25.
12.
14.
1 H.
?*.
fl.
n.
SUM (SEC)
33.
34 .
34.
4 f. .
4<\.
47.
47.
35.
22.
34.
3«.
39.
3ft.
26.
2*.
999.
900.
990.
999.
999.
999.
999.
099.
999.
33.
30.
27.
42.
40.
40.
52.
37.
32.
27.
20.
37.
42. '
52.
50.
5ft.
54.
/. n .
MEAN (SEC)
«.
o.
0.
n.
12.
12.
12.
9.
ft.
0.
10.
10.
9.
7.
7.
909.
909.
999.
999.
999.
999.
099.
999.
999.
H.
8.
•7.
10.
12.
12.
13.
9.
8.
7.
r>.
9.
10.
13.
15.
14.
n.
1 1
-------
(continued)
08-31-78
903— 911
924— 930
938— 943
1000
1023
1037
1050
-110?
1109 — 11 13
IIZI — IIZS
1131—1136
1007 —
1018 —
1033 —
1043—
A04
H04
C04
A06
H06
C06
A0«
ROfl
con
A10
01 0
CIO
15.
6.
4.
1.
3.
fl.
a;
s.
a.
1.
4.
66.
64.
14.
16.
14.
1«.
23.
16.
in.
19.
16.
16.
15.
7.
4.
4.
4.
5.
6.
4.
5.
-------
ENVIRONMENTAL PROTECTION AGENCY INSPECTION DATA
cn
ro
U. S. STEEL CORPORATION
CLAIRTON WORKS
DOOH OBSERVATIONS
STOP
TIME
1600
142J
0210
094B
0448
0252
0456
1145
AV6
10.0
BATTERY 07
64 OVENS
% CS
noons
9.4 -
14.1
10.9
10.9
9.4
7.B
9.4
7.8
% PS ,
DOORS
(I/SIDE)
7.H
31.2
21.9
14.1
10.9
15.6
9.4
12.5
% PS
;DOORS
.<2/SIDE)
4.7
IS. 6
10.9
7.0
7.0
9.4
4.7
7.0
%
CHUCK
DOORS
1.6
17.2
0.0
6.2
4.7
7.B
4.7
10.9
* TOTAL
DOORS
(2/OVFN)
n.6
22.7
16.4
1?.S
10.2
11.7
9.4
10.2
* TOTAL
OOORS
(3/OVEN)
6.2
1H.I
10.9
fl.3
7.fl
a. 9
6.?
7.3
% OVENS
WITH
LEAKING
OOORS
15.6
37. S
211. 1
23.4
17.2
21.9
IB. 7
IB. 7
OATF
OH-22-7B
On-23,-7B
OH-P4-7B
nn-?5-7H
on-?n-7«
OB-29-7B
Ofl-10-78
09-01-78
15.4
ft. 3
6.6
12.7
U.9
ZZ.7
BATTERY OA
64 OVFNS
STOP
TIME
1554
1440
0227
1000
0438
0245
0451
1140
* CS
OOORS
10.9
14.1
9.4
14.1
9.4
10.9
7.0.
10.9
% PS
OOOWS
(1/SIOt)
6.2
34.4
20.3
12.5
12. S
9.4
6.2
7.B
% PS
OOOPS
<2/SIOE>
3.1
17.2
10.2
W.6
6.2
6.2
3.1
3.9
*
CHUCK
OOORS
4.7
14.1
4.7
6.2
1.6
3.1
3.1
3.1
* TOTAL
OOOUS
(?/OVEN)
«.6
24.2
14. n
13.3
10.9
10.2
7.0
9.4
% TOTAL
OOORS
(3/OVEN)
5.7
16.1
9.«
10.4
7.3
7. ft
4.7
6.2
» OVENS
WITH
LEAK INK
>, DOOMS
17.2
42.?
?3.4
23.4
15.6
15.6
14.1
IB. 7
OATF
OA-22-78
Oft-?4-7fl
nn-?5-7B
Oft-29-7fl
0«-30-7fl
09-01-7B
AVti
10.9
1J.7
7.3
5.1
12.3
21.3
-------
ENVIHONMENTAL PROTECTION AfiENCY INSPECTION DATA
U. S. STEEL CORPORATION
CLAIRTON WORKS
OOOH OBSERVATIONS
BATTERY 09
64 OVFNS
STOP
TIME
1542
. 1456
0230
1012
0431
0235
0447
«** 1136
AVG
*
CS
DOOMS
6.2
7. ft
9.4
7. ft
7. ft
9.4
6.2
4.7
7.4
* PS
DOORS
* PS
DOORS
(I/SIDE) (2/SIDE)
14.1
10.9
7.8
12.5
17.2
7. ft
12.5
10.9
11.7
7.0
5.5
3.9
7.0
fl.6
3.9
7.0
5.5
6.1
*
CHUCK
OOORS
7
4
1
6
9
4
6
6
5
HATTF'HY
STOI>
TIME
1547
132H
0137
0920
0319
0306
0245
0320
0912
* CS
ooous
4.
3.
5.
2.
5.
5.
2.
2.
2.
6
4
7
3
7
7
3
3
3
% PS
DOOKS
( I/SIDE)
6.4
1.1
5.7
2.3
4.6
3.4
6.7
3.4
5.7
« PS
DOORS
(2/SIOE)
4.0
.6
2.9
1.1
2.9
1.7
2.9
1.7 '
?t\
• ~
<*
CHUCK
DOOMS
2.3
1.1
1.1
2.. 3
3.4
2.3
1.1
0.0
4.6
.0
.7
.6
.2
.4
.7
.2
.2
.9
19
*
* TOTAL * TOTAL
DOORS OOOHS
(2/OVEN) (3/OVEN)
10
9
ft
10
12
fl
9
7
g
.2
.4
.6
.2
.5
.6
.4
.8
.6
6.n
6.2
5.7
7.3
8.3
5.7
6.H
5.2
6.5
* OVENS
WITH
LEAKING
DOORS
17.?
17.2
15.6
1ft. 7
21.9
17.2
17.2
15.6
17.6
DATE
Oft-22-7fl
on-p3-7fi
nn-?4-7H
OR-25-7H
Ofl-?ft-78
Ofl-29-78
Oft-30-7ft
09-01-7R
fl7 OVFNS
TOTAL
OOOHS
(2/OVEN)
5.7
?. 3
5.7
2.3
5.?
4.6
4.0
2.9
4.0
% TOTAL
DOORS
(3/OVEN)
4.
1.
3.
1.
3.
3.
2.
1.
2.
2
5
ft
5
0
1
7
9
7
* OVENS
WITH
LEAKlNfi
DOORS
11.5
.4.6
10.3
4.6
9.2
a.o
Q.O
4.6
a.o
OATF
Oft-2?-7fl
Ofl-23-7fl
nn-24-7»»
0»l-?5-7ft
OH-2B-7H
OH-?9-7fl
Ofl-30-7«
Oft-31-78
09-01-7H
AVG
3.ft
4.3
2.3
2.0
4.1
2.R
7.7
-------
." :: TOPSIDE EMISSIONS DATA
U. S. STEFL CORPORATION
CLAIRTON WORKS
BATTERY 7
BATTERY 8
OFFTAKE
BATTERY 9
OFFTAKE
STOP
TIME
0425
140U
0245
1007
0245
0307
OS03
0945
AVERAGE
OFFTAKE
»> TOT * SIG
LEAKS LFAKS
4.7
10.2
3.1
5.5
3.1
1.1
14.1
7.0
6.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
f,
LIOS
.4
i.2
.4
.4
.4
.8
2.0
1.6
.9
STOP
TIME
0415
1419
0256
1018
0252
0259
0319
0220
0958
AVERAGE
* TOT
LEAKS
4.7
5.5
1.6
2.3
4.7
3.9
7.8
4.7
4.7
4.4
% SIG
LEAKS
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
%
LIOS
0.0
0.0
0.0
.4
0.0
.8
.4 ;
.8 ,
.4 '•
.3
STOP
TIME
0408
1430
0310
1027
0257
0305
0325
0227
1007
AVERAGE
% TOT
LEAKS
3.9
8.6
5.5
1.6
1.6
1.6
3.1
10.9
2.3
4.3
* SIG
LF.AKS
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
0.0
0.0
%
LIOS
DATE
1.6
0.0 08-2?-7fl
0.0 08-23-78
0.0 08-24-78
1.2 08-25-78
.8 08-28-78
1.6 08-30-78
2.0 08-31-78
.8 09-01-78
.9
-------
TOPSIDE EMISSIONS DATA
U. S. STfF.L CORPORATION
CLAIHTON WORKS
BATTFRY 19
en
STOP
TIME
0451
0930
0123
0822
0214
0137
$127
0131
0806
OFFTAKE
X TOT * SIfi
LEAKS LEAKS
0.0
2.3
1.1
4.0
4.0
3.4
2.9
1.7
2.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
ft
LIDS
0.0
0.0
1.1
.3
.6
0.0
0.0
1.1
.9
OATE
08-22-78
08-33-78
08-24-78
OB-2«i-7B
Ofl-2fl-7B
OB-29-7W
08-30-7B
08-31-78
09-01-78
AVERAGE
2.5
0.0
.4
-------
CLAIRTON OSHA INSPECTION DATA
PERSONAL EXPOSURE (ug/m3 BSFTPM)
November 16-December 1, 1978
Occupation
Operator-Push
Operator-Door
Operator- Larry
Door Cleaner,
Battery
Machine 7 & 8
8 & 9
19
Average
Machine 7 & 8
8 & 9
19
Average
Car 7 & 8
8 & 9
19
Average
Push-Side 7
8
9
19
Average
Coke- side 7
8
9
19
Concentration
(yg/m3 BSFTPM)
100
100
280
70
100
50
117
910
130
440
150
130
230
332
180
160
180
120
130
158
350
230
360
240
630
362
540
90
250
260
340
296
TWA
._.Cyg/m3, BSFTPM)
260
260
810
390
463
66
-------
CLAIRTON OSHA INSPECTION DATA
PERSONAL EXPOSURE (pg/m3 BSFTPM)
November 16-December 1, 1978 (con'd.)
Occupation Battery Concentration TWA
(yg/m3 BSFTPM) . (yg/m3 BSFTPM).
Lidman
Tar chaser
7
8
8
9
19
(new man- train ing)
Average
7, 8, & 9
19
400
400
260
320
150
130
820
520
375
2,700
310
-
740
470
605
1,505
67
-------
APPENDIX D
68
-------
•167S4
RULES AND REGULATIONS
purpose of this provision is to ensure
that records are preserved for the req-
uisite retention period.
In requiring the records to be trans-
mitted by registered mail to the Director,
where there is no successor employer, the
final standard follows the proposed
standard. The Advisory Committee re-
port did not address the issue.
An industry participant, objecting to
the requirement of transmittal by reg-
istered mail only, argued that an em-
ployer should have a right to select the
best means of shipment, especially where
the volume of records varies widely. But
the purpose of requiring transmittal by
registered mail only is to ensure that the
records will be received.
To relax the requirements with regard
to the means of shipment would lower
the degree of accountability to which
the employer is held and would increase
the possibility that the records would
not be handled with due care.
The proposed standard contained re-
quirements for recordkeeping of me-
chanical ventilation measurements, and
rosters. The substantive requirements to
make these measurements and to keep a
roster no longer exist, hence the require-
ments to keep the corresponding records
have been deleted from the standard.
The proposed standard and the Advi-
sory Committee report included require-
ments to keep records of respirator usage
and employee training. The standard
does not include these requirements.
Both the respiratory protection program
and all materials relating to the em-
ployee information and training program
must be provided upon request to the
Secretary and the Director. Since the
main purpose of requirements to keep the
records in these areas is enforcement,
OSHA believes that this goal will be
served by having such information avail-
able upon request.
N. Observation of monitoring. Section
8(c) (3) of the Act requires that employ-
ers provide employees or their repre-
sentatives with the opportunity to ob-
serve monitoring of employee exposures
to toxic materials or harmful physical
agents. In accordance with this section,
the standard contains provisions for
such observation. To ensure that this
right is meaningful, observers would be
entitled to an explanation of the meas-
urement procedure, to observe all steps
related to the measurement procedure,
and to record the results obtained.
The observer, whether an employee or
designated representative, must be pro-
vided with, and is required to use, any
personal protective devices required to
be worn by employees working in the
area that is being monitored, and must
comply with all other applicable safety
and health procedures.
(O) Effective date. In order to ensure
that affected employers and employees
will be informed of the existence of the
provisions of this standard, and that
employers are given an opportunity to
familiarize themselves and their em-
ployers are given an opportunity to
familiarize themselves and their em-
ployees with the existence of the new re-
quirements, pu:-yu;:;-;t to section 6'b'>i'4)
of the Act, the effective date of this
standard will be delayed ninety days
until January; 1977. Both the proposed
standard (Ex. la. p. 32281) and the Ad-
visory Committee Report 'Ex. 3, p. 70)
provided for a delayed effective date of
-thirty days from the date of promulga-
tion, although they did include start-up
dates which, in effect, extended the
effective date beyond the thirty day pe-
riod for various portions of the regula-
tion. However, OSHA has decided that,
in view of the highly technical nature of
the standard, and for the reasons stated
above, a ninety cay delay of the effective
date is appropriate.
(P) Appendices. The two appendices
included with the regulation are not in-
tended to create any additional obliga-
tions not otherwise imposed or to detract
from any existing obligation.
Accordingly, pursuant to sections 6(b)
and 8fc) of the Occupational Safety and
Health Act of 1970 <84 Stat. 1593. 1599,
29 U.S.C. 655, 657), Secretary of Labor's
Order No. 8-76 (41 FR 25059), and 29
CFR Part 1911, Part 1910 of Title 29,
Code of Federal Regulations is hereby
amended by adding a new § 1910.1029 as
set forth below.
Signed at Washington, D.C., this 19th
day of October 1976.
MORTON CORN,
Assistant Secretary of Labor.
Section 1910.1029 is added to Title 29,
Part 1910 as set forth below: • / '
§ 1910.1029 Coke oven emissions.
(a) Scope and application. This sec-
tion applies to the control of employee
exposure to coke oven emissions, except
that this section shall not apply to work-
ing conditions with regard to which
other Federal agencies exercise statu-
tory authority to prescribe or enforce
standards affecting occupational safety
and health.
(b) Definitions. For the purpose of this
section: "Authorized person" means any
person specifically authorized by the
employer whose duties require the per-
son to enter a regulated area, or any
person" entering such an area as a desig-
nated representative of employees for
the purpose of exercising the opportu-
nity to observe monitoring and measur-
ing procedures under paragraph 'n) of
this section.
"Beehive oven" means a coke oven in
which the products of carbonization
other than coke are not recovered, but
are released into the ambient air.
"Coke oven" means a retort in which
coke is produced by the destructive dis-
tillation or carbonization of coal.
"Coke oven battery" means a structure
containing a number of slot-type coke
ovens.
"Coke over, emissions" means the ben-
zene-soluble fraction of total ^articulate
matter present during, the destructive
distillation or carbonization of coal for
the production of coke.
"Director" means the Director, Na-
tional Institute for Occupational Safety
and Health, U.S. Department of Health,
Education, and Welfare, or his or he-
cesignee.
"Emergency" means any occurrence
such as, but not limited to, equipment
failure which is likely to, or does, result
in any massive release of coke oven emis-
sions.
'"Existing coke oven battery" means a
battery in operation or under construc-
tion on January 20, 1977, and which is
, not rehabilitated.
"Rehabilitated coke oven batters-
means a battery which is rebuilt, over-
hauled, renovated, or restored such as
from the pad up, after January 20. 1977.
"Secretary" means the Secretary" of
Labor, U.S. Department of Labor, or his
or her designee.
"Stage charging" means a procedure
by which a predetermined volume of coal
in each larry car hopper is introduced
into an oven such that no more than
two hoppers are discharging simultane-
ously.
"Sequential charging" means a proce-
dure, usually automatically timed, by
which a predetermined volume of coal in
each larry car hopper is introduced into
an oven such that no more than two
hoppers commence or finish discharging
simultaneously although, at some point,
all hoppers are discharging simultane-
ously.
"Pipeline charging" means any ap-
paratus used to introduce coal into an
oven which uses a pipe or duct perma-
nently mounted onto an oven and
through which coa! is charged.
. "Green push'' means coke which when
removed from the oven results in emis-
sions due to the presence of unvolatilized
coal.
(c) Permissible exposure limit. The
employer shall assure that no employee
is exposed to coke oven emissions at con-
centrations greated than 150 micrograms
per cubic meter of air (150 ug/m3). aver-
aged over any 8-hour period.
id) Regulated areas. (1) The employer
shall establish regulated areas and shall
limit access to them to authorized per-
sons.
(2) The.employer shall establish the
following as regulated areas:
The beehive oven and its machin-
ery.
i'e) Exposure monitoring and measure-
ment— (1) Monitoring program, li'i Each
employer who has a place of employ-
ment where coke oven emissions are pres-
ent shall monitor employees employed
in the regulated area to measure their
exposure to coke oven emissions.
iii» The employer shall obtain meas-
urements which are representative of
each employee's exposure to coke oven
emissions over an eight-hour period. All
measurements shall determine exposure
without regard to the use of respiratory
protection.
'iii) The employer shall collect full-
shift (for at least seven continuous
hours) personal samples, including at
least one sample during each shift for
each battery and each job classification
FEDERAL REGISTER, VOL 41, M9. 206—FRIDAY, OCTOBER 22, 1976
69
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RULES AND REGULATIONS
46785
\vithin the regulated areas including at
least the following job classifications:
(ai Liciman;
'b> Tar chaser;
(c) Larry car operator;
Heater;
(i) Quenching car operator;
(j) Pusher machine operator;
(fc) Screening station operator;
(Z) Wharfman;
(.ml Oven patcher;
(n) Oven repairman;
(o) Spellman; and
(p) Maintenance personnel.
(iv) The employer shall repeat the
monitoring and measurements required
by this paragraph (e) (1) at least every
three months.
(2) Redetermination. Whenever there
has been a production, process, or con-
trol change which may result in new or
additional exposure to coke oven emis-
sions, or whenever the employer has any
other reason to suspect an increase in
employee exposure, the erhployer shall
repeat the monitoring and measurements
required by paragraph (e)(l) of this
section for those employees affected by
such change or increase.
(3) Employee notification. Engineering controls, (i) Charg-
ing. The employer shall equip and oper-
ate existing coke oven batteries w:ith all
of the following engineering controls to
control coke oven emissions during
charging operations:
fa> One of the following methods of
charging:
U) Stage charging as described in par-
agraph (f) <3(i) (b) of this section; or,
(2) Sequential charging as described
in paragraph (f) (3) (i) Mechanical volumetric controls on
each larry car hopper to provide the
proper amount of coal to be charged
through each charging hole so that the
tunnel head wi 11 be sufficient to permit
the g-ases to move from the oven into the
collector mains;
(el Devices to facilitate the rapid and
continuous flow of coal into the oven be-
ing charged, such as stainless steel liners,
coal vibrators or pneumatic shells;
(/) Individually operated larry car
drop sleeves and slide gates designed and
maintained so that the gases are effec-
tively removed from the oven into the
collector mains;
(g) Mechanized gooseneck and stand-
pipe cleaners;
(ft) Air seals on the pusher machine
leveler bars to control air infiltration
during charging; and
(i) Roof carbon cutters or a compress-
ed air system or both on the pusher ma-
chine rams to remove roof carbon.
(ii) Coking. The employer shall equip
and operate existing coke oven batteries
with all of the following engineering con-
trols to control coke oven emissions dur-
ing coking operations:
(a) A pressure control system on each
batten' to obtain uniform collector main
pressure ;
(b"i Ready access to door repair facili-
ties capable of prompt and efficient re-
pair of doors, door sealing edges and all
door parts;
'c) An adequate number of spare doors
available for replacement purposes;
(d) Chuck door gaskets to control
chuck door emissions until such door is
repaired, or replaced; and
(e) Heat shields on door machines.
FEDERAL REGISTER, VOL. 41. NO. 206—FRIDAY, OCTOBER 22, 1976
70
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-J67S6
RULES AND REGULATION'S
(3) Work practice controls, (i)
Charging. The employer shall operate
existing coke oven batteries with all of
the following work practices to control
coke oven emissions during the charging
operation:
(a) Establishment and implementation
of a detailed, written inspection and
cleaning procedure for each battery con-
sisting of at least the following elements:
(1) Prompt and effective repair or re-
placement of all engineering controls;
(2) Inspection and cleaning of goose-
necks and standpipes prior to each
charge to a specified minimum diameter
sufficient to effectively move the evolved
gases from the oven to the collector
mains;
(3) Inspection for roof carbon build-up
prior to each charge and removal of roof
carbon as necessary to provide an ade-
quate gas channel so that the gases are
effectively moved from the oven into the
collector mains:
(4) Inspection of the steam aspiration
system prior to each charge so that suffi-
cient pressure and volume is maintained
to effectively move the gases from the
oven to the collector mains;
(5) Inspection of steam nozzles and
liquor sprays prior "to each charge and
cleaning as necessary so that the steam
nozzles and liquor sprays are clean;
(6) Inspection of star.dpipe caps prior
to each charge and cleaning and luting
or both as necessary so that the gases are
effectively moved from the oven to the
collector mains; and
17) Inspection of charging holes and
lids for cracks, warpage and other de-
fects prior to each charge and removal
of carbon to prevent emissions, and
application of luting material to stand-
pipe and charging hole lids where neces-
sary to obtain a proper seal.
(b) Establishment and implementa-
tion of a detailed written charging pro-
cedure, designed and operated to elim-
inate emissions during charging for each
battery, consisting of at least the follow-
ing elements:
(1) Larry car hoppers filled with coal
to a predetermined level in accordance
with the mechanical volumetric controls
required under paragraph (f) (2) (i) (d)
of this section so as to maintain a suffi-
cient gas passage in the oven to be
charged:
(2) The larry car aligned over the
oven to be charged, so that the drop
sleeves fit tightly over the charging holes;
and
(3) The oven charged in accordance
with the following sequence of require-
ments:
d) The aspiration system turned on;
(ii) Coal charged through the outer-
most hoppers, either individually or to-
gether, depending on the capacity of the
aspiration system to collect the gases
involved;
(iii) The charging holes used under
paragraph (f) (3) (i) (b)<3> (::) of this
section relidded or otherwise sealed off
to prevent leakage of coke oven emis-
sions;
(iv) If four hoppers are used, the third
hopper discharged and relidded or other-
wise scaled off to prevent leakage of coke
oven emissions;
, (v) The final hopper discharged until
the gas'channel at the top of the oven
is blocked and then the chuck door
opened and the coal leveled;
(tn) When the coal from the final hop-
per is discharged and the leveling oper-
ation complete, the charging hole re-
lidded or otherwise sealed oiT to prevent
leakage of coke oven emissions; and
(tri:') The aspiration system turned off
only after the charging holes have been
closed.
(c) Establishment and implementa-
tion of a detailed written charging pro-
cedure, designed and operated to elimi-
nate emissions during charging of each
pipeline or enclosed charged battery.
(ii> Coking. The employer shall oper-
ate existing coke oven batteries pursuant
to a detailed written procedure estab-
lished and implemented for the control
of coke oven emissions during coking,
consisting of at least the following
elements:
(a) Checking oven back pressure con-
trols to maintain uniform pressure con-
ditions in the collecting main;
(b) Repair, replacement and adjust-
'ment of oven doors and chuck doors and
replacement of door jambs so as to pro-
vide a continuous rr.etal-tc-nietai fit:
(c) Cleaning of oven doors, chuck
doors and door jambs each coking cycle
so as to provide an effective seal:
Regular inspection of the damper
system, aspiration system and collector
main for cracks or leakage, and prompt
implementation of the necessary repairs;
id) Regular inspection of the heating
system and prompt implementation of
the necessary repairs;
(e) Prevention of miscellaneous fugi-
tive topside emissions;
C/.i Regular inspection and patching of
oven brickwork;
Prevention of miscellaneous fugi-
tive topside emissions; and
_<2) Chuck-door gaskets, which shall
be installed prior to the start of the next
coking cycle.
(4) Filtered air. (i) The employer
shall provide positive-pressure, tempera-
ture controlled filtered air for larry car.
pusher machine, door machine, and
quench car cabs.
(ii) The employer shall provide stand-
by pulpits on the battery topside, at the
wharf, and at the screening station,
equipped with positive-pressure, tem-
perature controlled filtered air.
(5) Emergencies. Whenever an emer-
gency occurs, the next coking cycle may
not begin until the cause of the emer-
gency is determined and corrected, un-
less the employer can establish that it
is necessary to initiate the next coking
cycle in order to determine the cause
of the emergency.
' <6) Coj;ipii«Kce program, (i) Each
employer shall establish and implement
a written program to reduce exposures
solely by means of the engineering and
work practice controls specified in para-
graphs if) (2) through if) (4! of this sec-
tion.
(ii) The written program shall in-
clude at least the following:
(a) A description of each coke oven
operation by battery, including work
force and operating crew, coking time.
operating procedures and maintenance
practices;
(b) Engineering plans and other
studies used to determine the controls
for the coke battery;
(c) A report of the technology con-
sidered in meeting the permissible expo-
sure limit;
FEDERAL REGISTER, VOL. 41, NO. 206—FRIDAY, OCTOBER 11, 1976
71
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RULES AND REGULATIONS
46787
( In emergencies.
(ii) Notwithstanding any other re-
quirement of this section, until January
20, 1978. the wearing of respirators shall
be at the discretion of each employee
where the employee is not in the vicinity
of visible emissions.
'2) Selection, d) Where respirators
are required under this section, the em-
ployer shall select, provide and assure the
use of the appropriate respirator or com-
bination of respirators from Table I
below.
P.ESP::.'r-.r.Y r?.tTicrrios FOR COKE
OVEN r.'.::=.sioN'S
Airborne '.'.-:ccn- <•
traiion '*! cote Required respirator
oven crr.:::ions
(c) Any cor.isstra- tl) A Type C supplied
tion. air respirator
operated in pres-
sure demand or
other positive
pressure or con-
. tinuous flow
mode; or
(2) A powered air-
purLfying partic-
xilate filter res-
pirator for dust,
rr.ist, and fume;
or
(j) A pov/c-red air-
purifylng partic-
ular filter res-
pirator or com-
bination chemi-
cal cartridge and
paniculate filter
respirator 'or
coke oven emis-
sions.
(b) Concentrations (J) Any particulate
not greater filter respirator
"than 1500 for dust, mist
A'g/m1. and fume, except
single-use res-
pirator; or
(2) Any particulate
filter respirator
or combination
chemical car-
tridge and par-
ticulate filter
respirator for
coke oven. emis-
sions; or
(') Any respirator
listed in para-
graph (g)(2)(l)
(a) of this sec-
tion.
(ii) Not later than January 20.- 1978,
whenever respirators are required by this
section for concentrations not greater
than 1500 /jg/m', the employer shall pro-
vide, at the option of each affected em-
ployee, either a particulate filter respira-
tor as provided in paragraph (g)t2)(i)
(b) of this section, or a powered air
purifying respirator as provided in para-
graph (g'.x2Hi) of this section.
(iii) The emplo.- --r shall select respira-
tors from among thc.se approved for pro-
tection agaist dun. fume, and mist by
the National Institute for Occupational
Safety and Health •.\IOSH) under the
provisions of 30 CFH Part 11. except that
not later than January 20. 1979, the em-
ployer shall select respirators from
among those apprcved by NIOSH for
protection against coke oven emissions.
(3) Respirator p-og-am. The employer
shall institute a respiratory prelection
program in accordir.ce with S 1910.134 of
this part.
(4'i Respirator Lj^pe. (i) The employer
shall assure that the respirator issued to
the employee exhibits minimum face-
piece leakage and that the respirator is
fitted prcpsrly. The employer shall per-
form o;uftnt:t:-.tive fit tests annually for
each employee who uses a non-powered,
particulate filter respirator.
(ii) The employer shall allow each em-
ployee who uses a filter respirator to
change the filter elements whenever an
Increase in breathing resistance is de-
tected and shall maintain an adequate
supply of filter elements for this purpose.
'iii) The employer shall allow em-
ployees who wear respirators to wash
their face and respirator facepiece to pre-
vent skin irritation associated with res-
pirator use.
(h) Protective clothing and equip-
ment—(1) Provision and use. The em-
ployer shall provide ar.d assure the use
of appropriate protective clothing and
equipment, such as but not limited to:
(i) name resistant jacket and pants;
'ii) Flame resistant gloves;
(iii) Face shields or vented goggles
which comply with § 1910.133(a) (2) of
this part;
(iv) Footwear providing insulation from
hot surfaces;
(v) Safety shoes which comply with
§ 1910.136 of this part; and
(vi) Protective helmets' which comply
with ! 1910.135 of this part.
(2) Cleaning and replacement.
-------
467S8
RULES A'\'D REGULATIONS
(ii) The employer shall provide shower
facilities in accordance with § 1910.141
(d) (3) of this Part.
(3) Lunchrooms. The employer shall
provide lunchroom facilities which have
a temperature controlled, positive pres-
sure, filtered air supply, and which are
readily accessible to employees working
in the regulated area.
(4) Lavatories, (i) The employer shall
assure that employees working in the
regulated area wash their hands and
face prior to eating.
(ii) The employer shall provide lava-
tory facilities in accordance with § 1910.-
141 (d) (1) and (2) of this Part.
(5) Prohibition of activities in the reg-
ulated area, (i) The employer shall as-
sure that in the regulated area, food or
beverages are not present or consumed,
smoking products are not present or
used, and cosmetics are not applied, ex-
cept that these activities may be con-
ducted in the lunchrooms, change rooms
and showers required under paragraphs
(i) (1)-U) (3) of this section.
(ii) Drinking water may be consumed
in the regulated area.
(j) Medical surveillance. (1) General
requirements, (i) Each employer shall
institute a medical surveillance program
for all employees who are employed in
the regulated areas at least 30 days per
year.
(ii) This program shall provide each
employee covered under paragraph (j)
il) A 14"xl7" posterior-anterior chest.
x-ray and International Labour Office
UlCC/Cincinnati (ILO U/C) rating;
(iii) Pulmonary function tests includ-
ing forced vital capacity (FVC) and
forced expiratory volume at one second
(FEV 1.0) with recording of type of
equipment used;
(iv) Weight;
(v) A skin examination;
(vi) Urinalysis for sugar, albumin,
and hematuria;
(vii) A sputum cytology examination;
and
(viii) A urinary cytology examination.
(3 Periodic examinations, d) The em-
ployer shall provide the examinations
specified in paragraphs (j) '2) (i)-('vi) of
this sectian at least annually for em-
ployees covered under paragraph (j) (1)
(i) of this section.
(ii) The employer shall provide the
examinations specified in paragraphs
(j) (2) (i)-(viii) of this section at least
semi-annually for employees 45 years of
age or older or with five i5) or more years
employment in the regulated area.
(iii) Whenever an employee who is 45
years of age or older or with five (5) or
more years employment in the regulated
area transfers or is transferred from em-
ployment in a regulated area, the em-
ployer shall continue to provide the ex-
aminations specified in paragraphs (j)
(2) (i)-(viii) of this section semi-an-
nually, as long as that employee is em-
ployed by the same employer or a suc-
cessor employer.
(iv) Whenever an employee has not
taken the examinations specified in par-
agraphs (j) (3) (i)-'iii) of this section
within the six 16) months preceding the
termination of employment, the employ-
er shall provide such examinations to the
employee upon termination of employ-
ment.
(4) Information provided to the physi-
cian. The employer shall provide the fol-
lowing information to the examining
physician:
(i) A copy of this regulation and its
Appendixes;
(ii) A description of the affected em-
ployee's duties as they relate to the em-
ployee's exposure;
(iii) The employee's exposure level or
anticipated exposure level;
(iv) A description of any personal pro-
tective equipment used or to be used; and
(v) Information from previous medi-
cal examinations of the affected employee
which is not readily available to the ex-
amining physician.
(5) Physician's written opinion, (i) The
employer shall obtain a written opinion
from the examining physician which
shall include:
'a) The results of the medical exami-
nations:
The physician's opinion as to
whether the employee has any detected
medical conditions which would place
the employee at increased risk of mate-
rial impairment of the employee's health
from exposure to coke oven emissions:
(c) Any recommended limitations upon
the employee's exposure to coke oven
emissions or upon the use of protective
clothing or equipment such as respira-
tors; and
(d) A statement that the employee has
been informed by the physician of the
results of the medical examination and
any medical conditions which require
further explanation or treatment.
(ii) The employer shall instruct the
physician not to reveal in the written
opinion specific findings or ciagr.os.es un-
related to occupational exposure.
(iii) The employer shall provide a copy
of the written opinion to the affected em-
ployee.
(k) r??;p/o:/ce information cr.rf '--.
ing—d) Training program. ''-'v^
area at that time or at the time* of" :'"1
itial assignment to a regulated area'
(iii) The training program shs'- •-..-.
provided at least annually for all'V--"^
ployees who are employed in the ref-
lated area, except that training rerk-i"
ing the occupational safety and he:.Y~
hazards associated with exposure to coke
even emissions and the purpose, prop*-
use, and limitations of respiratory pro-
tective devices shall be provided at ".erj;-
quarterly until January 20, 1978.
(iv) The training program shall in-
clude informing each employee of:
(a) The information contained in the
substance information sheet for coke-
oven emissions (Appendix A) ;
(&> The purpose, proper use, and !i~-
itations of respiratory protective devit-c-s
required in accordance with paragraph
(g) of this section;
(c) The purpose for and a description
of the medical surveillance program re-
quired by paragraph (j) of this section
including information on the occupation-
al safety and health hazards c.s.socia-.ec
with exposure to coke oven emissions:
( A review of all written procedures
and schedules required under paragraph
(f) of this section; and
(e'> A review of this standard.
<2) -4ccess to training materials.
The employer shall make a copy of this
standard and its appendixes readily
available to all employees who are em-
ployed in the regulated area.
(ii) The employer shall provide all
materials relating to the employee in-
formation and training program to the
Secretary and the Director.
(1) Precautionary signs and labels—
(1) General, (i) The employer may use
labels or signs required by other statutes
regulations or ordinances in addition to
or in combination with, signs and label:
required by this paragraph.
'ii) The employer shall assure that nc
statement appears on or near any SILT
required by this paragraph which con-
tradicts or detracts from the eifects o!
the required sign.
(iii) The employer shall assure thai
signs required by this paragraph are il-
luminated and cleaned as necessary sc
that the legend is readily visible.
(2) Signs, (i) The employer shall ;.'0s:
signs in the regulated area bearing the
legends:
DANGER
CANCER HAZARD
AUTHORIZED PERSONNEL ONLY
NO SMOKING OR EATING
(ii) In addition, not later than Janu-
ary 20, 1978, the employer shall posi
signs in the areas where the permissible
exposure limit is exceeded bearing the
legend:
FEDEf.At REGISTER, VOL.
-------
RULES AND REGULATION'S
4 6 759
P.BSPIR.A POR REQUIRED
,3) L-r.bcls. The employer shall apply
-.-ecau! ionary labels to all containers of
--.-•.active clothing contaminated with
^~.ve oven emissions. The label shall bear
:'ne following legend:
CAUTION
r-OTKTXG CONTAMINATED WITH COKE
EMISSIONS
no NOT REMOVE DUST BY BLOWING OR
SHAKING.
(m) Kecordkeepir.g.—(1) Exposure
measurements. The employer shall estab-
lish and maintain an accurate record
of all measurements taken to monitor
employee exposure to coke oven emis-
;:;.ns required in paragraph ^e) of this
;.;-:'.:on.
ii) This record shall include:
Any employee medical complaints
related to exposure to coke oven emis-
sions.
'ii) The employer shall keep, or assure
that the examining physician keeps, the
following medical records:
fa) A copy of the medical examina-
tion results including medical and work
history required under paragraph (j) (2)
of this section;
(b) A description of the laboratory
procedures used and a copy of any stand-
ards or guidelines used to interpret the
test results;
(c) The initial x-ray;
!e Exposure Limit: 150 micro-
grams per cubic meter of air determined as
an average over an 8-hour period.
D. j\cgu'sie.e.-.r:r.g of respirators is voluntary. Until
that date, if you choose not to wear a respira-
tor you do not have to do so. You must still
have your respirator with you and you must
still wear it if you are near visible emissions.
Since how well your respirator fits your face
is very important, your employer is required
to conduct fit tests to make sure the respira-
tor seals properly when you wear it. These
tests are simple and rapid and will be ex-
plained to you during your training sessions.
B. Protective clothing: Your employer is
required to provide, and you must wear.
appropriate, clean, protective clothing and
equipment to protect your body from re-
peated skin contact with coke over emissions
and from the heat generated during the
coking process. This clothing should include
such items as jacket and pants and flame
resistant gloves. Protective ea.ulpnient should
include face shield or vented goggles, protec-
tive helmets and .safety shoes, insulated from '
hot surfaces where appropriate.
IV. HYGIENE FACI-LJTIES AND PRACTICES
You must not eat. drink, smoke, chew gum
or-tobacco, or apply cosmetics in the regu-
lated area, except that drinking water is
permitted. Your employer is required to
provide lunchrooms and other areas for these
purposes.
Your employer is required to provide show-
ers, washing facilities, and change rooms.
If you work in a regulated area, you must
FECERAI REGISTER, VOL. 41, NO. 2C6— FRIDAY, OCTOBER 22, 1976
74
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wp.sh your Trice, and hands before
You :r,ust ?':>ov.'er at the end of the work
shift. Do no', take used protective clothing
out of the ch:,nge rooms without your em-
ployer's permission. Your employer Is re-
quired to provide for laundering or cleaning
of your protective clothing.
V. SIGN'S AND LABELS
Your employer is required to post warning
signs and labels for your protection. Signs
must be posted In regulated areas. The signs
must warn that a cancer hazard is present,
that only authorised employees may enter
the area, and that no smoking or eating is
allowed. In regulated areas where coke oven
emissions are above the permissible exposure
limit, the signs should also warn that res-
. pirators must be worn.
VI. MEDICAL EXAMINATIONS
If you work in a regulated area at least
30 days per year, your employer is required
to provide you with a medical examination
every year. The medical examination must
Include a medical history, a chest x-ray;
pulmonary function test;, weight compari-
son; skin examination; a urinalysis and a
urine and sputum cytology exam for the early
detection of urinary or lung cancer. The
cytology exams are only included in the
initial exam until you are either 45 years or
older or have 5 or more years employment
in the regulated areas when the medical
exams including these tests are to be given
every 6 months. The examining physician
will provide a written opinion to your em-
ployer containing the results of the medical
exams. You should also receive a copy of this
opinion.
•
VII. orSEF.VATION OF MONITORING
Your employer is required to monitor your
exposure to coke oven emissions and you are
entitled to observe the monitoring procedure.
You are entitled to receive an explanation of
the measurement procedure, observe the
steps taken in the measurement procedure,
and to record the results obtained. When the
monitoring procedure is taking place in an
area where respirators or personal protective
clothing and equipment are required to be
worn, you must also be provided with and
must wear the protective clothing and
equipment.
Vin. ACCESS TO RECORDS
You or your representative are entitled to
records of your exposure to coke oven emis-
sions upon request to your employer. Your
medical examination records can be fur-
nished to your physician upon request to
your employer.
IX. TRAINING AND EDUCATION
Additional information on all of these
items plus training as to hazards of coke
oven en-.issions and the engineering and work
practice controls associated with your job
will also be provided by your employer.
APPENDIX B INDUSTRIAL HYGIENE AND MEDICAL
SURVEILLANCE GUIDELINES
I. INDUSTRIAL HTGIENE GUIDELINES
A. Sampling (Benzene-Soluble Fraction
Total Paniculate Matter) .
RIJLSS AND RsGULATIONS
Sri-iplcs coKc-cttd :-h.-.'.::d be full shift (8-
hour) samples. £:i::ip!in:.' .-houid be done us-
ing a ptrso::a! ;:::nphr>g f.nr.p with pulsation
damper at. a flow rate of 2 liters per minute.
Samples Should'be colic-ted on C 8 microme-
ter pore size silver membrane filters (37 mm
diameter) preceded by Gc-lman glass fiber
type A filters encased in three-piece phistic
(polystyrene) field monitor cassettes. The
cassette face cap shouid be on and the plug
removed. The rotarr.eter should be checked
every hour to ensure that proper flow rales
are maintained.
A minimum of three full-shift sarr.plss
shouid be collected for each job classification
on each battery, at least one during and the
night. If disparate results are obtained for
particular job classification, sampling should
be repeated. It is advisable to sample each
shift on more than one day to account for
environmental variables (wind, precipita-
tion, etc.) which may affect sampling. Differ-
ences in exposures among diiTerent work
shifts may indicate a need to improve work
practices on a particular shift. Sampling re-
sults from different shifts for each job classi-
fication should not be averaged. Multiple
samples from same shift may be used to cal-
culate an average exposure for a particular
job classification.
B. Analysis.
1. All extraction glassware is cleaned with
dichromic acid cleaning solution, rinsed with
tap water, then dionized water, acetone, and
allowed to dry completely. The glassware is
rinsed with nanograde benzene before use.
The Teflon cups are cleaned with benzene
then with acetone.
2. Pre-weigh the 2 ml Perkin-Elmer Teflon
cups to one hundredth of a milligram (0.01
mg) on a Perkin-Elmer autobalance AD 2
Tare weight of the cups is about 50 mg.
3. Place the silver membrane filter and
glass fiber filter into a 15 ml te_t tube.
4. Extract with 5 ml of ber.rene for five
minutes in an ultrasonic cleaner.
5. Filter the extract in 15 mi medium glass
fritted funnels.
6. Rinse test tube and filters with two 1.5
ml aliquots of benzene and filter through the
fritted glass funnel.
7. Collect the extract and two rinses in a
10 ml Kontes graduated evaporative concen-
trator.
8. Evaporate down to 1 ml while rinsing the
sides with benzene.
9. Pipet 0.5 ml into the Teflon cup and
evaporate to dryness in a vacuum oven at
40 • C for 3 hours.
10. Weigh the Teflon cup and the weight
gain is due to the benzene soluble residue in
half the Sample. —.
II. MEZTICAL SURVEILLANCE GUIDELINES
A. General.
The minimum requirements for the medi-
cal examination for coke oven workers are
given in paragraph (J) of the standard.
The Initial examination is. to be provided to
all coke oven workers at the time of initial
assignment to ,a job in the regulated area.
The examination includes at 14" X 17"
posterior-anterior chest x-ray and a ILO.'UC
rating to assure some stf.naardir.ation of
x-ray reading, pulmonary function tests
(FVC and FEV 1.0), weight, urinalysis, skin
examination' and a sputum r.nd urir-_
cytologic examination. These tt:-ts are"".''
serve as the baseline for comparing the r...
ployee's future test results. Periodic ev"'.V
include all the elements of the initial ty"^'
except that the cytologic tests are to""."
performed only on those employees who • •
45 years of age or older or who have v.-cr'.'J
for 5 or more years in the regulated a.-t'.'
periodic exams are to be performed jer-"
annually for this group instead of annttj''..'
The examination contents are niinlrr/jrr. -V
quirei.-jents, additional tests such as !a:&"--
and oblique x-rays or additional pulrr.or"-"".
function tests may be performed if d5t-:.-Vi
necessary.
B. P;;/;;iO7icry function tests.
Pulmonary function tests should be p...
formed in a manner which minimizes sub-
ject and operator bias. There has been shov-
to be learning effects with regard to the rt"
suits obtained from certain tests, such as F-r,
1.0. Best results can be obtained by multip;t
trials for each subject. The best of tr.'r£<
trials or the average of the last three of ;vi
trials may be used in obtaining reliable re
suits. The type of equipment used (ma:-;U
facturer. model, etc.) should be recorded «•;•.:•
the results as reliability and accuracy varis;
and such information may be Important !:
the evaluation of test results. Care should bi
exercised to obtain the best possible test'
ing equipment.
C. Sputum cytology.
Sputum can be collected by aerosol inhaia.
tion during the medical exam or by spon.
tar.eo\:s early morning cough at home. Spu.
turn Is induced by transoral inhalation of as
aerosolized solution of eight per cent (8-~;
Eodrum chloride in water. After inhaling a:
few as three to five breaths the subject uso
ally yields an adequate sputum 'specimen. A
minimum of three samples should be co!'
lected by the subject at home. All sputr.r:
should be collected directly into sixty perceni
(60To) alcohol.
Scientific evidence suggests that chest x-
rays and sputum cytology should be used
together as screening tests for lung cancer in
high risk populations, such as coke over
workers. The tests are to be performed ever;
six months on workers who are 45 years o!
age or older or have worked in the rc-gu':a;ed
area for 5 or more years. Since the tests seem
to be complementary, it may be advantageous
to alternate the test procedures. For instance
chest x-rays could be obtained In June and
December and sputum cytolcgys could be
obtained in March and September. Facilities
for providing necessary diagnostic investiga-
tion should be readily available as well a;
chest physicians, surgeons, radiologists
pathologists and immunotherapists to pro-
vide any necessary treatment services.
(Sees. 6. 8. 84 Stat. 1593. 1599 (29 TJ.S.C. 555
657); Secretary of Labor's Order 8-76 (41 FH
25059): 29 CFR Part 1911.)
[FR Doc.76-31037 Filed 10-20-76:11:30 am)
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