Document 2qmVXNBrYdOOea3zndB4EKNmb

R ECEIVgD =,, '<- C ,, -+; , -s_h ^ 00003 m B8? J k'M R. a QNDpesm UNION CARBIDE CORPORATION1300 Hercules Avenue - Suite 202 Engineering, Manufacturing 4 Technology Services Houston, Texas 77058 Cx< -v Tt }UV Vw Date: April 28, 1987 To: See Attached Distribution List Copy to: See Attached Distribution List Subject: Asbestos Gasketing and Packing Rapid changes in the asbestos area are taking place and the rate of change will probably stay high until the majority of asbestos is replaced. This communication is an overview of current activities to help you meet regulatory requirements. A task group (C. Neely, et al) dealing with the phase-out of asbestos containing materials in the work place for C&P, made their recommendation to the Manufacturing Council via B. G. Perry, and it was approved in March, 1967. (Recommendation attached) A key recommendation was termination of purchase of asbestos containing materials, after January 1, During the development of the original recommendation, the supply world has changed. UCC's three major suppliers are no longer manufacturing asbestos containing materials. No supplier is willing to make a firm commitment to supply asbestos containing materials after the end of 1987, because of the inability to get liability insurance. In addition, the cost of asbestos has gone up 25% in the last twelve months. Therefore, the recommended deadline for purchase cessation may be met by lack of supply. - continued - AU497 i ` UCC 006177 - 2- In order to help prepare for this change-over, the following actions are In progress: 1. The task force has initiated and expedited actions to do the engineering specification work for asbestos replacements for gasketing and packing. These C4P Engineering Standards will be available for each location by September, 1987. Specific questions before then should be discussed with Rex Engle at the South Charleston Tech Center. 2. Manufacturing Services - Maintenance working with UCC Carbon Products and Texas City Plant Maintenance is developing a video tape of "How-To's" for Grafoil installation in gasketing and packing applications. This videotape will be available thru Manufacturing Services - Maintenance in June, 1967 and you will be notified later how to obtain it. The videotape is designed to simplify the work of training your people. In addition to the use of the videotape, it would be wise to contact Jim Polomsky of Carbon Products to provide further follow-up, Hands-On Training. (715+852-9468 - Home - Houston, Texas or 1-800-822-4322 - Office - Cleveland, Ohio). See attached seminar content detail. 3. Exposure level data for situations of removing, cutting, and handling gasketing and packing is now being collected from several locations by Industrial Hygiene. With these data, the appropriate removal methods can be specified. Industrial Hygiene coordination of this data collection program should . eliminate the need for each location collecting data. 4. We are representing maintenance for all C4P locations in the on-going review of the- OSHA field compliance Instructions Draft. As conclusions are drawn we will let you know. We are coordinating these efforts in order to speed communications and minimize the efforts for each location. For further assistance, please call Ashton Barefoot at UNICOM 529-6437 or 713+4B6-6437. LEC/6262L/CC UCC 006178 A04974 t* UNION CARBIDE *** *+ * * it INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 16, 1986 TO: Mr. L. E. Calvert Mr. S. W. Clark Mr. G. B. Elder Hr. R. W. Engle COPY TO: Hr. C. C. Neely SUBJECT: Recommended C&P Program - Phase-Out Use of Asbestos-Containing Materials In Workplace Gentlemen: Attached Is a copy of your recommendation covering asbestos usage which I transmitted to Bob Perry. . Thanks for your Insights and efforts In pulling this together. I'll keep your team posted as the recommendation proceeds through the system. Very truly yours. JES'.he Attachment 47D4Y J. /E.. Sanders L/ # UCC 006179 A0497h OCT 1 b 13H& ,r. k* ** UNION CARBIDE CORPORATIONP. O. Box 6361 Engineering, Manufacturing, and Technology Services So. Chas., WV 25303 Central Engineering , BUSINESS CONFIDENTIAL September 30, 198b TO: Mr. J. E. Sanders COPY TO: Hr. L. C. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle FROM: C. C. Neely SUBJECT: Final Draft of Recommended CSP Program Phase-Out Use of Asbestos-Containing Materials in Work Place Chemicals and Plastic Group Attached herewith on behalf of the Special Working Group is a copy of the subject document dated 9/29/86. It Is a slightly fine-tuned version of the 8/28/B6 version which was transmitted to you under my transmittal also dated 8/28/B6. The changes that have been made are of a clarifying rather than substantive nature. At this point, we have not made an effort to obtain broad, formal review of the subject program. However, Larry Calvert has discussed It briefly with the Maintenance APM's and Maintenance Managers. In addition, Stan Clark arranged for Its review by the Safety, Health Advisory Committee (SHAC), and your staff has reviewed It. Feedback Indicates these groups to be supportive of the concept, but some have expressed concern regarding the January 1, 1989 date specified for the discontinuance of the purchase of asbestos-containing materials, believing It to be optimistic. Some of the concern relates to the following: 1. CED's ability to revise and reissue the VGP Specifications and the Valve Manual In time to support the deadline. The responsible CED specialists have carefully reviewed this matter and believe that reissuance of these Manuals by July 1, 1988 Is realistic. This date has not been published, however. UCC 006180 ^ 0 4 9 7 f.j Hr. J. E. Sanders -2- September 30, 1986 2. Belief that field testing of new gasket and packing materials will be required. Such testing will not be necessary since the plan at this time Is to accommodate most of the substitutions by broadening the use of materials already In use, materials such as reinforced Teflon and GRAFOIL*". This plan has not been broadly disseminated, and we can fully appreciate the reluctance to agree to a purchasing cut-off date for asbestos-containing products without knowing what the substitutes are. We also appreciate that, once this material substitute plan Is known, there will be a natural resistance due to the higher first cost of these substitute materials. 3. Some belief that Installers will need special training to handle the new gasket and packing materials. For reasons cited In (2), we do not believe this requirement will be significant. A. Perhaps lack of understanding that the January 1, 1989 date Is the cut-off date for the purchase of asbestos-containing materials except as approved bv a variance. 5. "Is this really necessary* attitude. The Special Working Group ! believes that OSHA's recently revised exposure limit of 0.2 fibers per cubic centimeter of air (was previously 2.0 fibers per cubic centimeter) add significant Impetus to Implement the proposed Recommended Program. According to Terry Hanning's September 5, 1986 memorandum (copy attached), labor union representatives do not believe that controlling the exposure limit to this lower level provides adequate protection. The above concerns notwithstanding, the Special Working Group decided to submit the subject Recommended Program to you with the January 1, 19B9 date Included since we believe that, with proper communication with the key plant personnel responsible for Its Implementation, along with management support, this date Is realistic and achievable. We are submitting under separate cover a proposed CED Technology Program which Includes request for funds to cover the Important communications aspect of the understanding, acceptance and Implementation process. Please let me know how we can be of further assistance regarding this matter. CCN:rar 43191 Attachment UCC 006181 tx 0 4 9 7 7 8/28/86 DRAFT RECOMMENDED POLICY CHEMICAL AND PLASTICS BUSINESS GROUP (C&P1 SUBJECT: USE OF ASBESTOS-CONTAINING MATER]ALSO>IN THE WORK PLACF PURPOSE/BACKGROUND The Corporate Charter (1.1) contains the following commitment to employees: "To provide working conditions, programs of training and education, and persistent review and appropriate modifi cation of facilities and practices to protect the health and safety of employees." It also contains a social commitment to conduct business "In accordance with all the applicable national and local laws and regulations." As a result of available evidence that airborne asbestos In the occupa tional environment had proven to be carcinogenic In man, all C&P Insulation Standards were revised In 1976 to specify only asbestos-free Insulating materials; and new or replacement Installations of these materials have sub sequently been selected accordingly. Additionally, a Safety/Health Standard designated SH-256 was prepared covering the safe removal and handling (In cludes disposal) of asbestos-containing Insulating material during renova tion and demolition. The requirements of this Standard equal or exceed those of current applicable government standards. DSHA's rule-making efforts relative to asbestos usage In the work place are mired In controversy. Hearings on the latest EPA proposal which In cludes the phaseout of all asbestos over a ten-year period are now In prog ress. The proposal states: "EPA Is considering banning the manufacture. Importation, and processing of asbestos construction products and asbestos clothing soon after the rule's promulgation with the category of asbestos friction products banned about five years later, and other asbestos products banned at a later time." Gaskets and packing that contain asbestos are In the category of "other asbestos products" that would apparently be banned after ten years. No peer company that we are aware of has a target date for removal of existing asbestos-containing Insulation, gaskets, or packing; however, one ma^or chemical company has recently discontinued the purchase of asbestos-containing gaskets and packing. A cost analysis of pipe-size gaskets shows that GRAEOIL*, probably the most expensive of the acceptable gasket substitute materials. Is, In fact, cost effective when only the cost of mandatory work practices associ ated with the use of asbestos (e.g. wetting for removal or airborne fiber U)"Asbestos-containing materials" Include but are not limited to Insulation, gaskets, packing, welding blankets, and building materials. UCC 006182 A0497a DRAFT -2- 8/28/86 exposure monitoring during removal, placing In labeled plastic bags after removal, landfill disposal, and record keeping) Is considered. The same conclusion Is drawn relative to valve packing when the additional considerations of Improved service life and sealablllty are Included. Consistent with the aforementioned commitments and the economic use of materials, CM* has concluded that positive actions relative to asbestos-con taining materials*1> should be taken. POLICY Cxcept as otherwise provided by applicable law. Chemicals and Plastics Business Group will: Continue to phase out the use of asbestos-containing materials: Asbestos-containing Insulation shall be replaced with asbestos-free materials as required to maintain structural and functional Integ rity. No asbestos-containing materials shall be purchased after January 1, 19B9. C&P approved practices shall be ..employed for the Identification, removal, modification, and/or disposal of asbestos-containing mate rials. Evaluation of asbestos substitute materials shall Include considera tion of health effects as well as suitability for Intended service and cost. A variance approval procedure shall be employed to cover considera tion of uncommon circumstances. Approval must always Include en dorsement of CGP HSScEA management. ' SCOPE ' This recommended policy applies to all CGP operated/hosted facilities. Other components of the Corporation will be apprised of Its content. DELEGATION The assignment of duties and authority to carry out the policy defined herein Is delegated as follows: To Central Engineering Department Develop and maintain engineering standards covering: _ - Identification of asbestos-containing materials; UCC 006183 DRAFT 6/28/86 -3 - Removal, modification and/or disposal of asbestos-containing mate rials; and - Use of asbestos-substitute materials. To Site Management Implement policies and practices for the Identification, removal, modification, and disposal of asbestos-containing materials. Use of CED Standards covering asbestos substitute materials and the communication of service experience with these materials. To Manufacturing Services Monitor use of asbestos-substitute materials and the communication of service experience with these materials. To C&P HS&EA Audit compliance with governmental regulations and CED-developed standards relating to asbestos-containing materials and, where applicable, their substitutes. ' UCC 006184 C. C. Neely 2D73W A04980 UNION CARBIDE CORPORATION SPECIALTY PRODUCTS GROUP * c* * > ^ 4.^ p wU bfr w % t James J. Polomsky ' District Sales Mgrl,, P, 0. Box 94637 Cleveland,] OH 44101 Ph 1-800-822-4322(0) (713)+852-9468 (K) P.D. BDX SJB37. CLEVELAND, CMO A41DI PHONE |21S]529-3900 ' |BOO]BS^a322 GRAK)HP> Flexible Graphite A Union Carbide Corporation Trademark Product GRAFOH SEMINAR OUTUNE 1. Solving your packing and gasketing problems. 2. Understanding Asbestos packings or gaskets. 3. The search for an asbestos replacement. A. Current non-asbestos offerings. 5. Characteristics of Graphite. 6. How GRAFDH is processed from chrystalline graphite. 7. Characteristics of GRAPOn# vs."Graphite 8. Chemical resistance of GRAFDHJ5). 9. Fire testing and fire safety -with GRAPOIL. 10. Corrosion protection with GRAFDH. 11. Oxidation of GRAFUHJ -- Misconceptions???? 12. Valves -- Packing Installation procedures and features. 13. Flanges -- Gasketing Installation procedures and features. 14. Gaskets -- GRAFUID laminate offering and S* filler. 15. Product Offerings: Packings, gaskets, ribbons, and tapes. The seminar includes demonstrations vhich assist the participant : ; ~ in his/her understanding of the product and lasts about 90 minutes. i NDOE*** .'A ._.i_h_L_i-' j.7m"~.r...-.. . _ ' -5S-S,4-2&, "1 Since several of the demonstrations require the use of ap open your management is requested to provide a conference room in /waicnthese demonstrations may be conducted without violating the safety regulations of your company. . . . A; -- .. -r - . & 0 L\ b O l UCC 006185 Newsletter Number Your Seat of Assurance PG 008 178 SUBJECT: Special Gasketing Techniques With GRAF01L Flexible Graphite INTRODUCTION GRAFOIL flexible graphite is a resilient form of graphite which has excellent properties as a gasketing material. By itself, GRAFOIl flexible graphite seals about as readily as rubber. It is also fabricated into metal core laminates or into spiral wound gaskets, and significantly improves their characteristics. In general, GRAFOIL gaskets will seal the maximum pressure Specified on properly designed, correctly manufactured and suitable maintained equipment. While being flexible and resilient, GRAFOIL flexible graphite is still all graphite. It has no resins, binders or filler materials or other additives that might detract from the chemical inertness and temperature resistance of pure graphite. GRAFOIL gaskets will not cold flow, become brittle, or vulcanize to gasketing surfaces in service. The unique chemical and physical properties of GRAFOIL flexible graphite combine to make it a nearly universal gasketing material especially suitable to high temperature and cryogenic service andjor corrosive environments. GENERAL POINTS TO REMEMBER WHEN GASKETING WITH GRAFOIL FLEXIBLE GRAPHITE 1. J The flange surfaces must be c 1 ean,'free of"nicksT"scratches, burrs, metal fillings, scale or other foreign matter. 2. ) Use a proper bolt tightening sequence to ensure a uniform load is applied to the joint (see Figure VI). The use of a torque wrench is advantageous to ensure that a uniform tensile stress is applied to each bolt. 3. ) GRAFOIL Grade GHE 316 Stainless Steel Tang Metal Inserted gaskets (Catalog Section G-8817 and G-8819) should not be used between any metal surfaces that are softer than the stainless steel (i.e. aluminum, brass, bronze), or between glass or ceramic surfaces. When GRAFOIL Grade GHE gaskets are used, the metal tangs must be compressed such that the GRAFOIL begins to seal. Due to the minimum seating stress recommended for these gaskets (i.e. 2500 psi), the metal tangs can-make small indentations in the softer metal of the flange face. The tangs can also create stress concentration points on glass or ceramic surfaces. 4. ) GRAFOIL flexible graphite gaskets must be loaded with a net compressive unit load as shown in the Unit Load vs. Leak Pressure Curve, Figure I, and in GRAFOIL Catalog Sections 6*8816 and G-8817. 5. ) The initial thickness of the GRAFOIL gasket must be such that when it is compressed between two mating surfaces, the GRAFOIL is strained sufficiently at all points in the joint to seal the maximum service .. pressure. If the flange surfaces are scratched, serrated, or warped, the initial gasket thickness must be large enough to completely fill and compensate for their effects when - the joint is made and the gasket is compressed. . UNION CARBIDE CORPORATION PO.Bo*w637 Ovelane CXw>10i Weononp [BKE22-4322 In One. (?161539 3900 TELEX: BKW?vOM7 UCC 006186 a SQPlO4M 9 8 ^ DISTRIBUTION LIST To: Eric Baumann Jim Dement J. M. McBride Robert Gauvin Roger Hampson Doug Pridgen Tony Amatangelo R. T. Jackson R. R. Rankin C. Smith J. B. Evans J. Sidlovsky T. L. Rogstad Victor Vega Burl Mallory Zulma Boroughs Broward Gable George Wulfert Duke Gossage George LeBlanche' John Turner H. Torrellas R. E. Bollinger D. C. McCauley R. E. Graebert W. P. Gorham J. P. Gracie T. L. Collins Stan Illikainen Copy to: Andy Allen Ashton Barefoot George Elder Bart Gliatta Tom Liles Cary Neal, Jr. E. G, Perry Alec Robertson R. W. 5couler Bill Summers R. T. Worrell/W. F. Merritt Frank Bobbie S. W. Clark R. W. Engle John Wittliff S. S. Murphree C. C. Neely Jim Polomsky Ben Robinson R. D. Spencer Syl Turicchi nvrFlV ED WAY 1 1987 & W. CLARK LC/6262L/cc UCC 006187 A04983