Document 10B90X03OmDkrRX1EEJNdz43m

OJij- ot^i/ & 3? t)<ef yd/ UNION CARB1DC ** INTERNAL SPECIALTY CHEHICALS DIVISION TO: Attached Distribution List DATE: CORRE SR o / QvJW '* Capy J ______ Sc>d copies K lf1 j/ Bldg. 82-902 South Charleston. WV S R.u// fc/.'il.-l-i/ 25303 , Kfat'irU Purl* Co'l March 3, 1987 /utfc FROM: C. R. Rotthoff ORIG. DEPT: HS&EA Personnel Safety & Occupational Health CC: Attached Dlstrlbuton List SUBJECT: Asbestos Management HS&EA's guidance on Asbestos Management for the Specialty Chemicals Olvlslon Is: >/ 1) J 2) V 3) Complete encapsulation of servlcable asbestos Insulation Is a / long term, viable and legitimate option ^See Attachment A). Damaged asbestos Insulatlofr-should be replaced with non-asbestos containing materials. Should complete removal of asbestos materials prove to be a viable economic approach. It should be undertaken In a planned program In strict accordance with existing regulations which have recently been revised and which. In-part, Include these significant requirements. o Use of negative pressure enclosures during asbestos removal (See Attachment B). o Disposal of asbestos containing materials In a suitable waste landfill. o Labeling of asbestos waste containers (boxes, drums, bags, etc.) o Proper personnel protective equipment and the asbestos removal notification requirements must be fulfilled as before. This correspondence provides the direction on two key asbestos Issues - encapsulation and negative pressure enclosures. Attachments A, B L are Included with this ~~ Information which ITlmportant to the nnripr^tandina of the guidance provided for Asbestos-Managements YolTFTuTi understanding and lirrpptAiire ot_jfrp~~ guidance is necessary. Please contact me as needed (304) 747-2397 or 8* 721-2397:--------------- ------ -------------------------------- --------------------------------- -------- CRR/rhw 2968K (3/04/87) At tachments Sincerely, ' KW* C. R. Rotthofl UCC 020029 UNION CARBIDE CORPORATION CHEMICALS & PLASTICS GROUP HEALTH, SAFETY & ENVIRONMENTAL AFFAIRS P-2 a/ ATTACHMENT "A 39 OLD RIDGEBURY ROAD 0AN8URY, CT 06817-0001 TO: D. Llebesklnd DATE: March 3, 1987 COPY: R. E. Bollinger D. R. Crowell C. R. Rotthoff*^ B. L. White SUBJECT: Encapsulation of Asbestos Oave, This Is In response to your request for guidance on the likelihood that an Agency would sometime In the future mandate the removal of asbestos or asbestos-containing products from the workplace. You noted the Importance of this Issue In view of the resources that you plan to expend to encapsulate asbestos Insulation In your facility. The response below reflects C&P HS&EA's view, with the concurrence of Don Crowell and Betty Lynn White. Recently I had the opportunity to meet Mr. Charles Adkins, Director of Health Standards Programs for OSHA, and was able to discuss this Issue with him WfrttF Mr flfinns gaYP~ttrr nwpnctnd caveat nf "not being able to give Eal assurances as to what the Agency-wll.1-or-won-4: do years froitmow^ he firmly stated that he could not contemplate" OSHA*1 ever requiring removal of In-place asbestos Insulation. He noted that that activity would in fact create a greater hazard than merely leaving the Insulation In-place. He further stated that OSHA's role In asbestos removal would be limited to setting standards when asbestos was to be removed based on other considerations. You are, of course, aware that EPA also gets Into the "asbestos business". The Asbestos Hazard Emergency Response Act of 1986 gives EPA authority to regulate containment and removal of asbestos In school buildings, and some Interests are pushing for expansion to commercial buildings. EPA Is also considering banning the use of asbestos In certain commercial products. While these possible actions do not apply to the (chemical) workplace, these are some circumstances In which EPA could. In the absence of an OSHA response to a hazardous situation In the workplace, take action. This, however, would appear to be highly unlikely here. Accordingly, there would appear to be no reason not to proceed with your encapsulation program. Sincerely, REP/pjm 0576Y 2957K, Wang received 3/3/87 R. E. Plevan UCC 020030