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Occupational Exposure to Hydrogen Sulfide Gas During Micro-Level Petroleum Refining Research Prepared for: The Insignia™ Health, Environment, and Safety Center of Excellence On: December 3, 2013 Prepared by: Zachary S. Anderson, MSPH, CIH, CSP Chief Corporate Industrial Hygienist, Insignia Technical Services (ITS)

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Page 1: Occupational Exposure to Hydrogen Sulfide Gas During Micro ...zandersonportfolio.weebly.com/.../2/6/...anderson.pdf · Figure 1: Bench Scale Unit used in micro-level crude oil refinement

Occupational Exposure to Hydrogen Sulfide

Gas During Micro-Level Petroleum Refining Research

                     

Prepared for: The Insignia™ Health, Environment, and Safety Center of Excellence

On:

December 3, 2013

Prepared by: Zachary S. Anderson, MSPH, CIH, CSP

Chief Corporate Industrial Hygienist, Insignia Technical Services (ITS)  

       

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Table of Contents Executive Summary 3 I. Introduction 4 II. Incident’s Background Description 4 III. Hazard Evaluation and Assessment 6 IV. Adverse Outcomes 8 V. Liabilities to the Company 10 VI. Hazard Control and Liability Mitigation 13 VII. Project Benefits 15 VIII. Conclusion 15 Works Cited 17 Appendix 20

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Executive Summary The enclosed reporte, prepared for the Health, Environment, and Safety (HES) Center of Excellence of the Insignia Energy Corporation (the ‘company’), is the final product of an HES incident’s investigation and analysis and will petition the approval and funding of a hazard control measure from the Center of Excellence. Two months ago, a laboratory technician of the Insignia Energy Technology Division (ETD) was diagnosed with hydrogen sulfide (H2S) poisoning after having fallen unconscious at work. ETD is presently researching the refining process of ‘sour’ – sulfur containing – crude oil. Because of the circumstances, the H2S source was determined occupational and a full-scale industrial hygiene hazard evaluation was conducted to assess the severity of the situation. Using direct-reading, data-logging instruments, H2S-containing crude oil samples were sent through the micro-level research units and corresponding H2S exposure levels were documented. The average exposure level was determined to be 4.15 ppm as a Time Weighted Average (TWA) and was compared against the American Conference of Governmental Industrial Hygienist’s (ACGIH) Threshold Limit Value (TLV) of 1 ppm. Thus, it was determined that, on average, all 75 employees across the 30 ETD laboratories are being exposed to concentrations above the TLV and are at risk of adverse health effects. H2S can displace oxygen in the bloodstream causing nausea, dizziness, and eventual syncope (fainting). Its poisoning must be treated with direct administration of 100% oxygen by trained physicians (the administration of which becomes the fiscal liability of the company). While the actual effect of H2S poisoning varies greatly from person to person, this report assumes the aggressive scenario that every worker overexposed will require daily oxygen treatment and estimates a total 7-year expense to the company of $80.5 million. The liability of occupational death was not considered because the present exposure levels are too low to cause it. Liabilities associated with long-term health effects were not considered either as the data linking prolonged H2S exposure to permanent health effects such as asthma or cardiovascular disease is inconclusive (Bates M. et al., 2012, 81). A verified local exhaust ventilation control method is proposed within. The control project would entail the installation of the Plymovement™ Extraction Arm into previously existing ducts within every laboratory. While the purchase, installation, and upkeep of the project runs a 7-year expected cost of $32.7 million, the company stands in a position to save $47.8 million in the long run and maintain its reputation as a world-class HES performer. The author strongly recommends that the Center of Excellence approve and fund this hazard control project. Our personnel will experience greater security at work, the company’s name will avoid certain public scrutiny, and economic benefits will be procured.

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I. Introduction Insignia Energy Corporation (Insignia; the ‘company’), the world leader in hydrocarbon and petrochemical production and distribution, prides itself on responsible operations in respect to its workforce and workplace. The Health, Environment, and Safety (HES) division is dedicated to ensuring that our people and our environment remain protected and healthful. It is our duty to mitigate safety and health risks and ensure environmental protection and remediation. This report, prepared for Insignia’s HES Center of Excellence, presents a facility improvement that will improve the health and safety of our workplace. As the fiscal and legislative governing body of HES, the Center of Excellence can approve expenditures for such improvements inasmuch as sufficient justification exists. For outside readers, the HES Center of Excellence is comprised of highly educated and experienced HES professionals including toxicologists, industrial and environmental hygienists, and safety engineers. The HES Center of Excellence is allotted two billion dollars of capital revenue a year for HES improvements. Insignia is also dedicated to the discovery and research of new energy technologies. Energy Technology Division (ETD), Insignia’s premier research and development group, performs their studies in 30 laboratories throughout three separate facilities. Currently, ETD focuses their research on a crude oil refinement pilot project. The pilot project hopes to improve the efficiency and safety of the macro-level petroleum refining occurring in our downstream enterprise. Recently, a serious health and safety concern within these laboratories was brought to our attention. Two months ago, a laboratory technician unexpectedly passed out and admitted to the hospital. The technician was diagnosed with hydrogen sulfide (H2S) poisoning and it was determined that the H2S source was occupational. This document is the final product of the incident’s investigation, analysis, and findings. In addition to the investigation, the author proposes a hazard mitigation option. In order for the hazard control to be implemented, the HES Center of Excellence must approve and fund the project. II. Incident’s Background Description Hydrogen Sulfide is an odorous and highly toxic gas found throughout various industries including sewage treatment, paper mills, and most pertinent to our situation, the oil and gas industry. In nature, it is a product of the decomposition of animals and other organic waste and is characterized by a ‘rotten egg’ smell. H2S is thought to be a respiratory hazard in that it can displace the diffusion of oxygen into the bloodstream (more detail to be covered in the Adverse Outcomes section of this report). Recently, the odor threshold

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was found to vary but have a range of 0.5 to 30 parts per billion (ppb) for most people (Schiffman and Williams, 2005, 121). Specific to the petroleum industry, hydrogen sulfide can be found within ‘sour’ crude oil. Petroleum, the result of the thermal conversion of decayed organic matter buried deep within the earth, often contains sulfur, an element that is sour to the taste (Skrtic, 2006, 5). This sulfur can be released as H2S either naturally while the crude sits in underground shale (prior to drilling) or during the refining process. ETD’s current research project focuses on the refining of the highly sour crude from Insignia’s San Joaquin Valley Business Operation (SJVBO) in California. Inside the ETD laboratories, pre-determined amounts of crude are sent through a Bench Scale Unit (BSU), the experimental apparatus used in refinery process research. The BSUs collect data on crude oil flow rates and viscosity, reactor and catalyst efficiency, and quality of end product. Figure 1 briefly describes the BSU process. Figure 1: Bench Scale Unit used in micro-level crude oil refinement (C. Nerín et al., 1999, 173) The crude oil is passed over a catalyst at 600°C inside of the reactor shown above (C. Nerín et al., 1999, 173). Upon passage, long-chained carbon polymers within the crude are broken down, or ‘cracked’, into useful chains. It is during the cracking process within the reactor that H2S gas embedded within the crude can be released.

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The BSU process requires constant supervision in order to ensure quality research. Laboratory technicians and research chemists (who spend the duration of their workday inside the laboratories) perform the BSU maintenance. Two to three laboratory technicians are assigned to each laboratory with a grand total of 75 employees across all 30 ETD laboratories. To ensure accuracy in BSU data, the process is only run while an employee is present, that is, the BSU is only in operation during normal work hours. The generation of H2S gas is entirely dependent on the BSU process itself, not an employee operating procedure or laboratory protocol. As long as crude oil is being run through the BSU process, H2S is generated in the reactor and released to the laboratory environment. Given the laboratory’s small size and limited ventilation, even small releases of H2S gas can accumulate quickly, becoming an HES concern. III. Hazard Evaluation and Assessment In 2009, the American Conference of Governmental Industrial Hygienists (ACGIH) released a Noticed of Intended Change (NIC) for hydrogen sulfide. Upon approval, the exposure limit, or Threshold Limit Value (TLV) for H2S was lowered. Previous values of 10 parts per million (ppm) as an 8-hour Time-Weighted Average (TWA) and 15 ppm Short Term Exposure Limit (STEL) were lowered to 1 ppm TWA and 5 ppm STEL (Hemingway et al., 2012, 319). These exposure limits are verified within the ACGIH Documentations of TLVs and BEIs. This exposure limit reduction created a unique challenge for our accurate evaluation of the risk of H2S poisoning. Most manufacturing companies have not yet released new equipment that is specifically designed to read low-level concentrations (less than 1 ppm), rather, most instrument’s accuracy ratings apply to concentrations of 5 ppm and above. Fortunately, researchers from the Health and Safety Laboratory in Buxton, United Kingdom had evaluated a method for accurate H2S sampling (their research was later published in the Journal of Occupational and Environmental Hygiene). The experiment was designed to test the accuracy of older model gas detection instruments at the new TLV concentration levels (M.A. Hemingway et al., 2012, 322). Their findings pertinent to this situation are summarized in Table I below.

Table 1: Accuracy Ranges of Gas and Vapor Concentration Instrumentation

Instrument Gas/Vapor Name Range Accuracy H2S Ecotech™ EC9852 Sulfur

Compounds Analyzer 0-2 ppm ± 5%

H2S, 5 ppm tests

PpbRae™ 0-150 ppm ± 10%

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Inasmuch as the Ecotech EC9852 Sulfur Compounds Analyzer has a 5% accuracy rating for the TWA concentration of 1 ppm, and the PpbRae has a 10% accuracy rating for the STEL concentration of 5 ppm, it was decided that these instruments would be appropriate for the environmental evaluation in the ETD labs. The decision to use the above instruments in our analysis was approved by ETD’s HES General Manager. Both the Ecotech EC9852 and PpbRae are real-time, data logging instruments. That is, they give instantaneous concentration readings on the display screen and log those readings for the duration of the sampling period. Sampling was conducted while using both instruments simultaneously given their accuracy ratings at different concentrations. Prior to sampling, both instruments were ‘bump calibrated’ within controlled environment as per the manufacturer’s directions. Note: it is company policy that all instrument-specific calibration methods are kept with the instrument at all times and that they be accessible on the corporate intranet (see Policy 224). Because the situation’s H2S exposure levels were uncertain and there is a current lack of exposure control, the hazard evaluation was also conducted in a controlled environment. In this instance, ‘controlled’ refers to an artificial environment where employees were not present and conducting normal work. Rather, only HES professionals were present to assess the hazard. If the sampling were conducted in ‘normal’ conditions, there would be risk of employee overexposure, adverse health effects, and company liabilities. With the permission of the lead chemist, crude oils of ascending H2S concentrations were fed through the BSU for 8-hour periods (over 9 business days) and exposure levels were documented. Those conducting the sampling wore appropriate Personal Protective Equipment (PPE) and an occupational physician was present in the event of H2S poisoning. Table 2 summarizes the results of this sampling. Note: the statistical ‘goodness of fit’ test was calculated using the crude oil H2S concentration (pre-treatment) versus the 8-hour TWA concentration; the r-squared (R2) value proved a linear correlation. The line’s equation and R2 values are found below and a pictorial graph is given in Appendix: I:

𝑦 = 6.7667𝑥 + 7500 𝑅! = 0.995

Table 2: 8-hour TWA and Peak Concentrations of H2S from Experimental Crude

[H2S] ppm in Crude (pre-treatment*)

[H2S] ppm Crude (post-treatment)

[H2S] ppm 8-hour TWA [H2S] ppm Peak

14,000 15 0.973 1.2 21,000 20 1.39 1.56 28,000 30 1.89 2.02 35,000 35 2.09 2.23 42,000 40 2.78 3.17 49,000 50 3.55 3.99 52,000 55 4.02 4.55

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61,000 60 4.51 5.12 70,000 70 4.82 5.68 130,000 120 ~8.95** N/A *-SJVBO provided all crude oil for this sampling. Immediately following drilling, sour crude is sent through an upstream treatment process to extract most H2S. **-Extrapolated value: 130,000 ppm H2S is the highest documented concentration to be drilled from SJVBO, but was not sampled during this period.

It is important to note that the use of the above H2S-containing sour crude is not uniformly distributed. That is, ETD researchers do not experiment with 30,000 ppm H2S sour crude as often as they do with 50,000 ppm H2S crude. 48% of all pilot refining experimentation is conducted with crude of 61,000 ppm H2S. The remaining percentage of experimental data comes from 14,000 ppm H2S crude (8%), 70,000 ppm H2S (42%), and experiments of corrupt data (2%). The above weighted distribution plays a critical role in the evaluation of the employee exposure. As 48% of ETD experimentation is conducted with crude of 61,000 ppm H2S, 48% of our entire employee population (36 of the 75 employees) are exposed to corresponding value of 4.51 ppm H2S gas per Table 2. Furthermore, as 8% of experiments involve 14,000 ppm crude and 42% involve 70,000 ppm H2S crude, 8% of the employee population is exposed to 0.973 ppm H2S gas and 42% of the employee population is exposed to 4.82 ppm H2S gas. ETD HES financed this exposure assessment in full. Costs included industrial hygiene labor in technical preparation, instrument calibration and sampling, the purchase (or rental) of the gas and vapor monitors cited above, and the lost research and development time of the laboratory where sampling was conducted. The PpbRae cost the company $6,515.00 for purchase and the EC9852 was rented for $782.00 (with shipping charges). Including instrumentation expenditures along with labor (about $100.00/hour per employee) and lost-productivity costs, the sampling project cost a total of $28,900.00. IV. Adverse Outcomes Industrial health professionals have long recognized the threat of hydrogen sulfide in the oil and gas industry. Great lengths were taken to protect contractors during the Deepwater Horizons oil spill remediation, for example (Howard, 2012, 1). Extensive toxicological research has been conducted on many of the known symptoms of H2S poisoning, publications of which are available through the Journal of Occupational Medicine. This report will focus on symptoms most relevant to the given laboratory situation. Dr. Robert Rogers of the Alberta Energy Resources Conservation Board presented a dose response curve (unpublished) for H2S concentrations versus observed symptoms in rats, goats, canaries, dogs and humans (T. L. Guidotti, 1996, 368). T. L. Guidotti of the University of Alberta Occupational Health Program created a table based on Dr. Rogers’ research. The most applicable parts of Guidotti’s chart are recapitulated in Table 3.

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Table 3: Health Effects of H2S at Various Exposure Levels (T. L. Guidotti, 1996, 368)

Of the compounding safety and health issues given by the data above, three will be expounded. First, the adverse effects of hydrogen sulfide are not dependent on length of exposure, rather the concentration of exposure only. Thus, the duration of exposure necessary to achieve the above affect is unpredictable; it does not follow Haber’s law. Haber’s Law is the mathematical correlation between the concentration of hazardous gas and how long the gas must be breathed in order to cause the adverse effect (G. Hoyle et al., 2010, 699). Some researchers have attempted epidemiological research in order to determine exposure durations necessary to cause symptoms (most importantly, long-term symptoms), but data has proved inconclusive. The University of California at Berkeley School of Public Health published an article earlier this year, which investigated the correlation between ambient H2S exposure from a volcano in New Zealand and subsequent public health impacts in a nearby city. The resulting data showed no evidence of correlation between symptom expression (particularly asthma) and exposure duration (M. Bates et al., 2012, 81). Note: considering the lack of correlation between long-term exposure and late-onset health effects, long-term liabilities were not calculated in the Liabilities to the Company section of this report. Secondly, when H2S reaches 100 ppm, a medical phenomenon known as olfactory paralysis occurs. Toxic gases and vapors including H2S can cause olfactory paralysis, the loss of the sense of smell due to the numbing of the olfactory nerve (T.L. Guidotti, 1999, 368). Were this to occur to an exposed technician, he or she would not have the perception necessary to evacuate the unsafe laboratory. Note: the risk of olfactory paralysis was a primary reason for the reduction of the ACGIH TLV from 10 ppm TWA to 1 ppm TWA (ACGIH Documentation of TLVS and BEIs, 2011).

[H2S] ppm Adverse Effect 1-5 Moderate offensive odor (rotten eggs), may be associated with

nausea, tearing of eyes, headaches or loss of sleep. Oxygen displacement in the bloodstream with prolonged exposure.

20-50 Keratoconjunctivitis (eye irritation) and lung irritation. Possible eye damage upon prolonged exposure and digestive upset.

100 Eye and lung irritation; olfactory paralysis (odor disappears)

500 Serious lung and eye irritation, amnesia and 'knockdown'

1,000 Cessation of breathing and immediate loss of consciousness, death.

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Lastly, an H2S-caused syncope, also known as ‘knockdown’, can occur at 100 ppm. Along with knockdown risk, H2S exposure in general can cause dizziness and nausea, reducing the chance for successful flight from the dangerous environment. It is essential to understand that all adverse health effects (excluding eye and lung irritation) are caused by the displacement of oxygen by H2S in the bloodstream. Because of this displacing behavior, proper medical treatment requires the administration of pure oxygen in order to counteract the H2S poisoning. An understanding of this physiology applies to the Medical Treatment costs in the Liabilities section to follow. The most important issue at hand is the fact that most exposures are above the TLV. While concentrations do not exceed the legally mandatory Permissible Exposure Limit (PEL) of 10 ppm TWA as established by the Occupational Safety and Health Administration (OSHA Table Z-2, 2013), Insignia’s HES policies have always demanded TLV compliance. For purposes of the liability cost exercise to follow, we assume that all exposures over the 1 ppm TLV become the fiscal and moral responsibility of Insignia. Table 4 summarizes potential exposure rates per the sampling conducted and summarized in Table 2 (assuming that all exposures exceeding the TLV are company liability). For a full explanation of the statistics used and a summary of their calculations, please consult Appendix: II of this report. Table 4: Exposure Levels, Their Probabilities, and Means. Probability (pi) Concentration (xi) Sample Mean Population Mean Aspect 48% 4.51 ppm 4.51 ppm 0.48(4.51) = 2.16 ppm 8% 0.973 ppm 0.973 ppm 0.08(0.973) = 0.078 ppm 42% 4.82 ppm 4.82 ppm 0.42(4.82) = 2.02 ppm

Population Mean*:

(2.05+0.078+2.02) = 4.26 ppm TWA

*-The population mean refers to the average exposure to all 75 employees across all 30 ETD laboratories. As the sampled peak value levels will not cause short-term overexposures, statistical analysis of STEL violation risk was not conducted. Given that the population mean implies all exposures are over the ACGIH TLV on a macro-level, exposure controls must be implemented. The need for exposure control is based on the adverse health effects that occur at 1-5 ppm H2S gas. Before proposing a control, the author will discuss fiscal liability in more detail. V. Liabilities to the Company While a perfectly accurate financial cost summary is impossible until actual payouts are made, an estimated liability cost analysis is included. Both direct and indirect costs will be factored into the economical evaluation.

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Any overexposure to H2S requires the administration of 100% oxygen gas in order to compensate for decrease in blood-oxygen saturation (T. L. Guidotti, 1996, 369). As stated in the Adverse Outcomes section, almost all health symptoms associated with H2S poisoning are caused by H2S blood-saturation and subsequent displacement of oxygen. If the H2S that has ‘invaded’ the bloodstream post-exposure can be eliminated by the administration of pure oxygen, then adverse health symptoms will be eliminated. Oxygen administration costs on average $179.00/session at private clinics and should be dispensed daily for at least one week (five days) or as necessitated by the attending physician (K. K. Jain, 1999). For this exercise, an aggressive scenario has been assumed. That is, the estimated liability supposes that every exposed employee need oxygen administration for every day they are exposed at work. The treatment cost estimation for all 75 employees across the 30 ETD laboratories yields

𝑐𝑜𝑠𝑡  𝑜𝑓  𝑚𝑒𝑑𝑖𝑐𝑎𝑙  𝑡𝑟𝑒𝑎𝑡𝑚𝑒𝑛𝑡 ∗ 𝑛𝑢𝑚𝑏𝑒𝑟  𝑎𝑡  𝑟𝑖𝑠𝑘 ≈ 𝑀𝑒𝑑𝑖𝑐𝑎𝑙  𝐿𝑖𝑎𝑏𝑖𝑙𝑖𝑡𝑦

$179.00𝑑𝑎𝑦 ∗

5  𝑑𝑎𝑦𝑠𝑤𝑒𝑒𝑘 ∗ 75  𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 ≈ $𝟔𝟖,𝟎𝟎𝟎/𝒘𝒆𝒆𝒌  

The actual need for pure oxygen administration will depend on the individual response of the overexposed employee. An employee’s response to H2S is highly unpredictable and unique. In a petroleum refinery in Sri Lanka, seven workers were exposed to high levels of H2S gas for about 10 minutes before being removed from the situation and sent to the hospital. It was assumed that exposure levels were equal to all seven employees, and yet each presented varied symptoms. One employee suffered from bronchospasms and cyanosis (blue-blood) while two other employees had no health effects whatsoever (Shivanthan et. al., 2013, 1-3). In addition to the Sri Lanka study, occupational medicine professionals have retrospectively studied deaths caused by H2S poisoning (D.C. Fuller et al., 2000 and R.G. Hendrickson et al., 2004). These studies had hope of establishing a correlation between exposure duration and the incidence of adverse health effects and death, but data proved inconclusive. Based on those findings and its inherent variability, the establishment of a definite incidence rate was not attempted. Because of the lack of an accurate incidence rate, the author chose a H2S treatment method that averages both ends of the symptoms spectrum. While treatment for cyanosis would cost thousands of dollars as in the first employee from the Sri Lanka refinery, the treatment of the two unaffected employees would cost a doctor’s visit co-pay at most. Since the cost to administer pure oxygen is around median of medical treatment spectrum, it was determined reasonable as a cost estimator. It was applied to all 75 employees assuming that some overexposed employees would require much more expensive treatment that oxygen administration, and some would not require any treatment after being exposed.

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For simplicity’s sake, all indirect costs will also be based on weekly estimates. Indirect costs will include lost productivity, salaries expressed as an hourly wage, and health insurance premium increases. Median wage for laboratory technicians is $35.00/hour with an additional $65.00/hour in benefits and perks. Should a person spend two hours per day during work hours to receive treatment, the weekly cost in ‘empty’ salary equates to:

                                        𝑤𝑎𝑔𝑒 ∗ 𝑡𝑖𝑚𝑒  𝑎𝑤𝑎𝑦 ∗ 𝑛𝑢𝑚𝑏𝑒𝑟  𝑎𝑡  𝑟𝑖𝑠𝑘 ≈

                                                                        ′𝐸𝑚𝑝𝑡𝑦  𝑆𝑎𝑙𝑎𝑟𝑦!𝑐𝑜𝑠𝑡 ∗ 2 ≈ ′𝐿𝑜𝑠𝑡  𝑆𝑎𝑙𝑎𝑟𝑦!𝑐𝑜𝑠𝑡

$100.00ℎ𝑜𝑢𝑟 ∗ 2ℎ𝑜𝑢𝑟𝑠/𝑑𝑎𝑦 ∗

5𝑑𝑎𝑦𝑠𝑤𝑒𝑒𝑘 ∗ 75  𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 ∗ 2 ≈ $𝟏𝟓𝟎,𝟎𝟎𝟎/𝒘𝒆𝒆𝒌

Not only would salaried employees be ‘paid’ to visit the doctor for oxygen treatment, but laboratory productivity would also decrease proportional to their time spent with a physician. To account for this, the ‘empty salary’ cost was doubled and estimated to total $150,000/week in ‘lost salary’. Health insurance premiums are guaranteed to increase proportional to the amount of employees that are overexposed and admitted for medical treatment. Insignia’s financial analysts project a $300.00 initial increase per person per year followed by a linear four-year doubling. Table 5 comprises Insignia’s entire financial liability. Table 5: Direct and Indirect Costs Associated with H2S Poisoning

Direct Costs Medical Expenses

Cost/Week Cost/Year 7-year Projected Payout* $68,000.00 $3.5 million $24.8 million

Unforeseen Medical Expenses** Cost/Week Cost/Year 7-year Projected Payout $2,000.00 $102,000.00 $714,000.00

Indirect Costs Lost Work

Cost/Week Cost/Year 7-year Projected Payout $150,000.00 $7.8 million $54.6 million

Health Insurance Premiums Increase*** Cost/Week Cost/Year 7-year Projected Payout $1020.00 $53,000.00 $370,000.00

 7-year Grand Total $80.5 million

*-Assumes a 10% treatment price reduction per year from the hospital. **-­‐Cost includes 'knockdown' treatment, for example - emergency medical transportation and nitrite administration (T. L. Guidotti, 1996, 368).  ***-Assumes a four-year linear increase in premiums, that is, Year 4 premiums are

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double those of Year 1. A full calculation can be found in Appendix: III. VI. Hazard Control and Liability Mitigation In order to mitigate the pending HES liability, Insignia must take action to control the industrial and environmental hygiene hazard inside ETD’s laboratories. Per industrial hygiene trial and error, PPE-level control (mandating the use of respirators) is the least cost effective and most cumbersome method of control. The next preferred method lies in the administrative infrastructure of the labs. An administrative control may involve training two teams of laboratory technicians and shifting teams in and out on a quarter or half-day basis. Administrative controls tend to be logistically difficult and present little savings for the company in the long run. The most preferred method of control is to design out the hazard via the engineering and installation of ventilation. In our case, the implementation of a local exhaust ventilation (LEV) system would significantly reduce exposure levels and liability costs and increase employee safety moral. ACGIH has published ‘VS’ diagrams, which describe ventilation apparatuses commonly used throughout industry. ACGIH VS-90-20 describes the ‘robotic manipulator arm’ – an elephant trunk type air receiver attached to an exhaust vent as shown in Figure 2 below (Popendorf, 2006, 333). Figure 2: The ‘Robotic Manipulator Arm’ as Described by ACGIH VS-90-20

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The installation of the robotic manipulator arm local exhaust ventilation system presents multiple health and safety benefits. Inasmuch as an appropriate control velocity is maintained and the LEV receiver face is positioned near the source, the airflow will nearly eliminate all H2S exposure concerns. Additionally, the arm’s unique design allows for its static placement in space. That is, employees will not have to hold the receiver face in one hand and perform their work with the other, rather, employees can move the receiver as needed and it will remain stationary until repositioning. The Brookhaven National Lab’s Industrial Hygiene Group has developed a method to test the efficiency of ventilation models such as this. Most verification methods are qualitative – smoke tube testing or rough duct velocity readings – but insofar as the LEV captures 97% of the contaminant at the recommended control velocity, it is assumed to be working properly (Brookhaven National Laboratory Industrial Hygiene Group, 2013, 24). Note: should this project be approved by the HES Center of Excellence, additional exposure sampling will be conducted following the LEV’s installation to ensure the 97% capture efficiency. ACGIH also provides guidelines for ventilation control velocities (the speed of the air to be exhausted at the source). Table 13.1 of the ACGIH ventilation manual suggests that for a toxic gas situation such as ours, the control velocity be 100 feet per minute (fpm) (Popendorf, 2006, 313). Given these parameters, research into various manipulator arm manufactures was conducted. After verifying the design and feasibility of the Plymovement™ Extraction Arm, model number MM-100 was chosen for purchase and installation. This decision was based on the following assumption:

𝑐𝑢𝑟𝑟𝑒𝑛𝑡  𝑐𝑜𝑛𝑐𝑒𝑛𝑡𝑟𝑎𝑡𝑖𝑜𝑛   𝑚𝑒𝑎𝑛 ∗ 𝑐𝑎𝑝𝑡𝑢𝑟𝑒  𝑒𝑓𝑓𝑖𝑐𝑖𝑒𝑛𝑐𝑦 = [𝑛𝑒𝑤  𝑐𝑜𝑛𝑐𝑒𝑛𝑡𝑟𝑎𝑡𝑖𝑜𝑛]

4.26  𝑝𝑝𝑚 ∗ 3%  𝑐𝑜𝑛𝑡𝑎𝑚𝑖𝑛𝑎𝑛𝑡  𝑟𝑒𝑚𝑎𝑖𝑛𝑖𝑛𝑔 = 0.1278  𝑝𝑝𝑚

A project cost analysis was done using the estimated design and operation parameters for the exhaust system. Plymovement quoted Insignia at $36,000 per Extraction Arm with an additional $14,000 for installation per unit. The installation charge includes the extraction arm’s integration into the existing environmental exhaust system (for which ETD has the appropriate permits) and the addition of one fan per laboratory to achieve the needed control velocity. ETD HES’s lead safety engineer previously determined that four receivers would be needed for each lab for a total cost of: 𝑝𝑟𝑖𝑐𝑒 + 𝑖𝑛𝑠𝑡𝑎𝑙𝑙𝑎𝑡𝑖𝑜𝑛  𝑝𝑒𝑟  𝑢𝑛𝑖𝑡 ∗ 𝑢𝑛𝑖𝑡𝑠  𝑝𝑒𝑟  𝑙𝑎𝑏𝑜𝑟𝑎𝑡𝑜𝑟𝑦 ∗ 𝑡𝑜𝑡𝑎𝑙  𝑙𝑎𝑏𝑜𝑟𝑎𝑡𝑜𝑟𝑖𝑒𝑠

= 𝑅𝑒𝑐𝑒𝑖𝑣𝑒𝑟  𝐶𝑜𝑠𝑡

$50,000.00𝑢𝑛𝑖𝑡 ∗ 4  𝑢𝑛𝑖𝑡𝑠/𝑙𝑎𝑏𝑜𝑟𝑎𝑡𝑜𝑟𝑦 ∗ 30  𝑙𝑎𝑏𝑜𝑟𝑎𝑡𝑜𝑟𝑖𝑒𝑠 = $6  𝑚𝑖𝑙𝑙𝑖𝑜𝑛

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Additional costs include system maintenance, make-up air conditioning, continued assurance sampling, and personnel training on proper receiver arm use (1 hour per year). These costs, including the purchase and installation charge, are summarized in Table 6 below. Table 6: Purchase, Installation, and Maintenance Costs for Proposed LEV

VII. Project Benefits While the purchase and installation of the proposed local exhaust ventilation system will be expensive up front, Insignia is in a position to save millions of future dollars. The above Grand Totals are discretionary as health insurance premiums are variable no matter what the circumstances. Even with these reductions, some personnel may still react to the lower H2S concentrations. However, the following savings estimate is very reasonable:

𝑐𝑜𝑠𝑡  𝑜𝑓  ℎ𝑎𝑧𝑎𝑟𝑑  𝑑𝑖𝑟𝑒𝑔𝑎𝑟𝑑   − 𝑐𝑜𝑠𝑡  𝑜𝑓  𝑐𝑜𝑛𝑡𝑟𝑜𝑙  𝑖𝑚𝑝𝑙𝑒𝑚𝑒𝑛𝑡𝑎𝑡𝑖𝑜𝑛  = 𝑇𝑜𝑡𝑎𝑙  7  𝑌𝑒𝑎𝑟  𝑆𝑎𝑣𝑖𝑛𝑔𝑠  

$80.5  𝑚𝑖𝑙𝑙𝑖𝑜𝑛 − $32.7  𝑚𝑖𝑙𝑙𝑖𝑜𝑛 = $𝟒𝟕.𝟖  𝒎𝒊𝒍𝒍𝒊𝒐𝒏  

The economic benefits aside, laboratory employees will also enjoy a more healthful workplace and Insignia’s reputation as a world-class HES performer will remain intact. VIII. Conclusion This project’s investigation, analysis and findings were conducted with the upmost standard of scientific accuracy and moral responsibility. The data presented strongly

Direct Costs Purchase and Installation

Present Cost/Year Future Cost/Year* 7-Year Projected Cost $6 million $200,000.00 $7.4 million

Maintenance and Air-Conditioning** Present Cost/Year Future Cost/Year 7-Year Projected Cost $3.6 million $3.6 million $25.2 million

Indirect Costs LEV Training (including HES preparation) and ‘Lost Time’

Present Cost/Year Future Cost/Year 7-Year Projected Cost $15,100 $15,100 $105,700 million

7-year Grand Total $32.7 million

*-Assumes four arms defect and must be replaced each year. **-See Appendix: IV for the corresponding calculation

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suggests that hydrogen sulfide exposures are occurring at levels that endanger our technicians. According to our industrial hygiene sampling data, the laboratory technicians are being exposed to over four times the ACGIH TLV for H2S gas. Toxicological data for H2S at these concentration levels suggest many adverse health effects including lung and eye irritation, olfactory paralysis, and the displacement of oxygen in the bloodstream. The medical cost of these adverse effects is a liability of the company given that the exposure source is occupational. The company stands to spend over $80 million in medical treatment costs, insurance premium increase, and lawsuit settlements. To avoid this, the installation of a local exhaustion ventilation system upgrade has been presented. In order for this project to be implemented, the HES Center of Excellence must approve and fund it. Certain measures have been made preemptively to ensure the smooth execution of this project should it be approved. The author, along with his cost analysis, identified a preliminary team of industrial hygienists, safety engineers, and lead ETD research scientists capable of completing the proposed project in the most timely and economical manner. The author strongly recommends that the HES Center of Excellence approve and fund the exposure intervention included above.

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Works Cited

References for this document were primarily extracted from scientific journals such as the Journal of Occupational and Environmental Health and the Journal of Occupational Medicine. Initially, relevant articles were found via search engines specific to scientific journals such as Scopus.com (a service provided by the Utah State University) and public access databases such as PubMed. Search engine keywords and phrases such as ‘hydrogen sulfide + petroleum industry’ and ‘H2S poisoning’ were used while exploring journals. The author then followed useful excerpts from the works cited in his original reference pool. Other common sources, such as textbooks and web pages were used to reinforce the reputable journal information. American Conference of Governmental Industrial Hygienists (2011). TLV for Hydrogen

Sulfide. TLVs and BEIs Guide to Occupational Exposure Limits. American Conference of Governmental Industrial Hygienists (2011). TLV

Documentation for Hydrogen Sulfide. Documentations of TLVs and BEIs. Bates, M. N., Garrett, N., Crane, J., & Balmes, J. R. (2012). Associations of ambient

hydrogen sulfide exposure with self-reported asthma and asthma symptoms. Journal of environmental research, (122), 81-87. doi: 0013-9351

Brookhaven National Laboratory Industrial Hygiene Group. (2013, October 14). Local

Exhaust System Measurements. Retrieved from http://www.bnl.gov/esh/shsd/sop/pdf/IH_SOPS/IH62400.pdf

Ecotech EC9852 product description and suggested use brochure (last updated

2/17/2013). http://www.ecotech.com/ecotech.com/index.php?option=com_docman&task=doc_details&gid=33&Itemid=150

Fuller, D. C., & Suruda, A. J. (2000). Occupationally related hydrogen sulfide deaths in

the United States from 1984 to 1994. Journal of occupational and environmental medicine, (42), 939-942.

Guidotti, T. L. (1996). Hydrogen sulphide. Journal of occupational medicine, Vol.

46(No. 5), 367-371. doi: 0962-7480/96 Hayter, A. (2012). Probability and statistics for engineers and scientists. (4th ed.).

Boston, MA: Brook/Cole, Cengage Learning. Hemingway, M. A., Walsh, P. T., Hardwick, K. R., & Wilcox, G. (2012). Evaluation of

portable single-gas monitors for the detection of low levels of hydrogen sulfide and sulfur dioxide in petroleum industry environments. Journal of occupational and environmental hygiene, 9(5), 319-328. doi: 10.1080/15459624.2012.670794

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Hendrickson, R. G., Chang, A., & Hamilton, R. J. (2004). Co-worker fatalities from hydrogen sulfide. American journal of industrial medicine, (45), 346-350.

Howard, J. U.S. Department of Health and Human Services, (2012). Worker health and

safety from the oil rig to the shoreline. Retrieved from Center for Disease Control and Prevention website: www.hhs.gov/asl/testify/2010/06/t20100623c.html

Hoyle, G., Chang, W., Chen, J., Schlueter, C., & Rando, R. (2010). Deviations from

haber's law for multiple measures of acute lung injury in chlorine-induced mice. Journal of toxicological sciences, 118(2), 696-703. doi: 10.1093/toxsci/kfq264

Jain, K. K. (1999). Textbook of hyperbaric medicine. (3rd Revised Edition ed.).

Gottingen, Germany: Hogrefe and Huber. Nerín, C., Domeño, C., Moliner, R., Lázaro, M. J., Suelves, I., & Valderrama, J. (1999).

Behavior of different industrial waste oils in a pyrolysis process: metals distribution and valuable products. Journal of analytical and applied pyrolysis, 55(2000), 171-183. doi: S0165-2370(99)00097-2

OSHA  Table  Z-­‐2:  Permissible  Exposure  Limits,  29  CFR  1910.1000  Table  Z-­‐2  

https://www.osha.gov/dts/chemicalsampling/data/CH_246800.html PpbRae product description and suggested use webpage

https://www.totalsafety.com/totalsafety/product.php?id=357 Popendorf, W. (2006). Industrial Hygiene Control of Airborne Chemical Hazards. Boca

Raton, FL: Taylor and Francis Group. Schiffman, S. S., & Williams, C. M. (2005). Science of odor as a potential health

issue. Journal of environmental quality, (34), 129-138. Shivanthan, M. C., Perera, H., Jayasinghe, S., Karunanayake, P., Chang, T.,

Ruwanpathirana, S., Jayasinghe, N., & De Silva, Y. (2013). Hydrogen sulphide inhalational toxicity at a petroleum refinery in Sri Lanka: a case series of seven survivors following an industrial accident and a brief review of medical literature. Journal of occupational medicine and toxicology, 8(9), 1-5. doi: 10.1186/1745-6673-8-9

Skrtic, L. (2006). Hydrogen sulfide, oil and gas, and people's health. (Master's thesis,

University of California at Berkeley School of Public Health) http://erg.berkeley.edu/people/Lana%20Skrtic%20-

%20Masters%20Paper%20H2S%20and%20Health.pdf

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Appendix

I. Pictorial Graph of the Exposure Data in Table 2

II. In-depth Explanation of the Table 4 Statistical Analysis The hazard evaluation of Table 4 employs a number of statistical principles and equations:

• Discrete random variables: A discrete random variable is the predictable value given to the outcome of a particular experiment (A. Hayter, 2012, 74). Although this experiment employed the use of discrete data, industrial hygiene data is almost always considered continuous, that is, data can have values across a continuum. Two reasons account for the use of discrete analysis for this report. First, because of the linear correlation between exposure levels and the H2S concentration of the crude, values are predictable. Second, in order for continuous random variable to have any statistical confidence, a very large sample size is required. Our sampling data is limited, and it was economically infeasible to conduct enough sampling to make the data continuous.

• The probability mass function: The probability mass function (p.m.f.) of the

random variable in question is a set of probability values assigned to each of the values xi taken by the discrete random variable (A. Hayter, 2012, 75). In Table 4, columns one through three represent the probability mass function for the sampling data. For example, the probability that the random variable (in our case, the exposure level of the employee to H2S gas) is on average 4.82 ppm is 42%.

Once the probability mass function has been determined, the sample means and, eventually, the entire population’s mean can be calculated. A sample refers to a smaller

y = 6766.7x + 7500 R² = 0.99539

0  

10,000  

20,000  

30,000  

40,000  

50,000  

60,000  

70,000  

80,000  

0.973   1.39   1.89   2.09   2.78   3.55   4.02   4.51   4.82  

[H2S]  ppm

 in  Crude  (pre-­‐treatment*)      

[H2S]  ppm  8-­‐hour  TWA  

Series1  

Linear  (Series1)  

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group of the entire population. For example, a sample might refer to the 6 of 72 employees working in the laboratory that experiments with 14,000 ppm H2S crude oil. The population would refer to all 75 employees at risk of overexposure.

• Expected Values of Discrete Random Variables: The expected value (E(X) or mean) of a discrete random variable with a probability mass function is (A. Hayter, 2012, 93):

𝐸 𝑋 = 𝑝!𝑥!

!

!

                                       

This equation, expanded:

𝐸 𝑋 = 𝑝!𝑥! + 𝑝!𝑥! + (𝑝!𝑥!)

Where x represents the exposure level of a certain sample group and p represents the probability of that exposure value to occur. Using this equation, the population mean was calculated:

𝐸 𝑋 = 48% ∗  4.51  𝑝𝑝𝑚 + 8% ∗  0.973  𝑝𝑝𝑚 + (42% ∗ 4.82  𝑝𝑝𝑚)

𝐸 𝑋 = 2.16  𝑝𝑝𝑚 + 0.078  𝑝𝑝𝑚 + (2.02  𝑝𝑝𝑚)

𝐸 𝑋 =  4.26  𝑝𝑝𝑚  

 III. Calculation for Health Insurance Premiums Increase

Insignia financial analysts estimate that if the current environment conditions of our laboratories persist, the company’s health insurance premiums will double every 4 years. Assuming this is true, a financial extrapolation was conducted using the initial premiums increase and its doubling rate.

𝐶𝑜𝑠𝑡!"#$  ! = 𝑖𝑛𝑐𝑟𝑒𝑎𝑠𝑒  𝑝𝑒𝑟  𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒 ∗ (𝑛𝑢𝑚𝑏𝑒𝑟  𝑜𝑓  𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠)

𝐶𝑜𝑠𝑡!"#$  ! =$300.00𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒 ∗ 75  𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 = $22,500

2 ∗ 𝐶𝑜𝑠𝑡!"#$  ! =  𝐶𝑜𝑠𝑡!"#$  !

2 ∗ $22,500 = $45,000

$45,0004𝑦𝑒𝑎𝑟𝑠 = $5,625  𝑖𝑛𝑐𝑟𝑒𝑎𝑠𝑒  𝑝𝑒𝑟  𝑦𝑒𝑎𝑟  𝑓𝑜𝑟  4  𝑦𝑒𝑎𝑟𝑠

In a similar fashion, the differential between the fourth and eighth year was determined to be $45,000, or an $11,250 increase per year between years four and eight:

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(𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒  𝑃𝑟𝑒𝑚𝑖𝑢𝑚  𝐼𝑛𝑐𝑟𝑒𝑎𝑠𝑒) = ($22,500  𝑌𝑒𝑎𝑟  1)+ ($28,125  𝑌𝑒𝑎𝑟  2)+($33,750  𝑌𝑒𝑎𝑟  3)+ ($39,375  𝑌𝑒𝑎𝑟  3)+ ($45,000  𝑌𝑒𝑎𝑟  4)+ ($56,250  𝑌𝑒𝑎𝑟  5)+($67,500  𝑌𝑒𝑎𝑟  6)+ ($78,750  𝑌𝑒𝑎𝑟  7) = $371,000 IV. Calculation for Local Exhaust Ventilation Maintenance and Air Conditioning

Cost The ETD laboratories are spread across the United States. Along with the geographic diversity comes climate variability. Some labs are located in hot, dry climates and some in humid, temperate weather conditions. Climate plays an important role in LEV maintenance and cost, as some air needs more cooling or heating in certain regions, and because humid air is typically harder to move through a ventilation duct. These considerations were taken into account when estimating this particular cost. Using an average value of $30,000/year per extraction arm, the overall maintenance and air conditioning cost was determined:

𝑚𝑎𝑖𝑛𝑡𝑒𝑛𝑎𝑛𝑐𝑒  𝑎𝑛𝑑  𝑎𝑖𝑟  𝑐𝑜𝑛𝑑𝑖𝑡𝑖𝑜𝑛𝑔

=𝑓𝑎𝑛  𝑜𝑝𝑒𝑟𝑎𝑡𝑖𝑜𝑛 + 𝑎𝑖𝑟  𝑐𝑜𝑛𝑑𝑖𝑡𝑖𝑜𝑛𝑖𝑛𝑔

𝑦𝑒𝑎𝑟 ∗ 𝑛𝑢𝑚𝑏𝑒𝑟  𝑜𝑓  𝑒𝑥𝑡𝑟𝑎𝑐𝑡𝑖𝑜𝑛  𝑎𝑟𝑚𝑠

=$20,000𝑦𝑒𝑎𝑟 +

$10,000𝑦𝑒𝑎𝑟 ∗ (120  𝑒𝑥𝑡𝑟𝑎𝑐𝑡𝑖𝑜𝑛  𝑎𝑟𝑚𝑠)

= $  3.6  𝑚𝑖𝑙𝑙𝑖𝑜𝑛/𝑦𝑒𝑎𝑟