1. Manager, Safety, Environment/Special Projects - appointed to present position in January 1985. No prior safety experience. No asbestos training.

2. Manager, Safety and Health - appointed to present position 6/85; formerly assigned as Plant Manager, MARF. No asbestos training. 3. Lead Industrial Hygienist - MS Biology - assigned as Site IH 9/84. Attended NIOSH Asbestos Counting Course - Temple University 12/85. No other outside training in asbestos controls. Not certified as an Industrial Hygienist.

The Kesselring Site Lead Industrial Hygienist is assigned "the principal representative for asbestos-related work activities at the Kesselring Site". He was appointed as Site Industrial Hygienist about two years ago and had been responsible for oversight of asbestos activities most of that time. However, the Lead Industrial Hygienist had no experience and has not received training which would qualify him to train workers in asbestos removal techniques.

4. Industrial Hygienist - former Medical Technologist, US Army; worked for General Electric since about 1971 primarily in chemical hazards. At Kesselring Site since 11/85. Primary duties related to HazCom. No asbestos training

5. Incident Prevention Captains - are required to maintain proficiency as asbestos monitors. They issue asbestos samplers and complete the Respiratory Permit associated with the Asbestos Work Permit. They also maintain the log of all permits issued.

The Incident Prevention Supervisor stated that Incident Prevention Captains were not receiving the semiannual asbestos control training required for an asbestos monitor by the Kesselring Site asbestos control requirements. The IP Supervisor stated that he realized his personnel were not knowledgeable enough to complete asbestos work permits. Therefore, the IP Supervisor had required that the Industrial Hygienist complete Section II Controls Section of the asbestos permits prior to his personnel issuing them.

6. S3G Plant Management and Supervision - None received asbestos training. None were qualified asbestos workers. None were authorized to enter asbestos work areas to observe and supervise operations.

H. Personnel Exposure

KAPL review of asbestos monitoring data and working conditions to establish actual personnel exposure has been underway since 1 October 1986. As of 12 November this review has not been concluded.

The lack of KAPL management overview and Site Safety Office inexperience led to failure to recognize the inexperience and lack of asbestos training of crew members and the need for KAPL to tailor their training program to meet crew needs. KAPL failed to recognize that the complexity and scope of individual asbestos jobs in S3G needed knowledgeable engineering to specify containment, work practices and monitoring techniques. Management attention to asbestos work requirements simply did not exist.

The lack of KAPL capability to manage and control asbestos work by S3G Plant Management did not go unnoticed. The fact that KAPL-SRA management considered it necessary to hire a lagging expert from Puget Sound Naval Shipyard (PSNS) indicates that SRA management was concerned about Site capability to control S3G asbestos work. This SRA action should have triggered higher KAPL management to the problem potential that was present and the need for corrective action to upgrade the Site's asbestos control capabilities. Prior asbestos experience with other on-site work and the hiring of the outside expert for S3G work were clear signals that the Kesselring Site Asbestos Control Program demanded management attention.