Document 3m3bX21MXEqM5J84qnwD2DGJ

San Francisco, California May 1, 1573 PLAINTIFFS_ EXHIBIT . ^ CHV-13 3 ASBESTOS REGULATIONS EPA: NATIONAL HUSSION STANDARD CALIFORNIA; OCCUPATIONAL STANDARD File: 110.1 SAFETY ENGINEERS employee relations managers (selected) EPA In addition to the limits imposed under the 08HA, asbestos^ has been classified as a hazardous air pollutant within the meaning of Section 112 of the Clean Air Act by the EPA. In brief, the Administrator has determined that asbestos is a causal factor in the development of mesotheliomas (cancers of the membranes lining the chest and abdomen). Mesothelioma has also been reported to be associated with non-occupational expo sures in areas with asbestos sources. The EPA further states that although available evidence suggests there are asbestos expo sure levels that will not be associated with any detectable risk, these levels ere not known. Available evidence does not show that asbestos levels in most community air cause asbestotic* disease. Therefore, in erder te protect the public health with consideration for an ample margin of safety, it is not necessary to ban ail emissions. Therefore, controls prohibit visible emissions in the five categories names as major sources of asbestos emissions: (l) Mining and Milling, (2) Manufacturing, (3) Fabrication, (4) Demolition and (5) Spraying. A brief summary of the regulation, which became effective April 6, 1973 is attached together with a copy of the Regulation and Report form. This summary includes those items on which immediate action may be required. The Manufacturing limits apply to stationary sources, primarily to formulation of Chevron Asphalt products containing asbestos. They prohibit visible emis sions containing asbestos but provide the option of using specified air-cleaning methods. The rules on demolition apply Company-vide. Even when the demolition is con tracted out it may be preferable, for the Company to file in order to ensure that the notice required in 61.22(d)(1) is given in a timely manner. With regard to demolition of certain buildings or structures, the actual standard specifies work practices to be followed, and requires notification to the Administrator at least 20 days prior to commencement of demolition. ~ The rules on spraying limit asbestos content to r.o more than 1$ in spray-on ePA materials used for insulation and fireproofing of buildings, structures, piperh*j and conduits. GJtMAicf -i- Safety Engineers Employee Relations Managers (Selected) -2- Spraying vith asbestos products should be avoided. If spraying appears essential we recommend that you consult with the Safety Division before pro ceeding. CALIFORNIA The California regulation for occupational asbestos exposure (GISO Section 5208) has been adopted and becomes effective as of March 30, 1973* It is essentially the same as the Federal regulation, vith clarifications. Two significant changes are: 1. While the Federal standard is vague as to what constitutes "exposure" to airborne asbestos, Section 5208 specifies a definite level, 1 fiber/cc, above which air sampling and medical monitoring must be done. This is consistent with USDL's interpretation of the Federal regulation. 2 The medical recordkeeping requirement is increased from 20 to 30 years. SHJ :mc Attachments: 1. Summary: National Emission Standards For Asbestos 2. EPA National Emission Standards for Hazardous Air Pollutants 3. California GISO Section 5203 (California only) rational emission standards TOR asbestos r Title 4o, Chapter 1, Part bl *" Section 61.22(c) - Manufacturing (Nine Categories of Stationary Sources) "There shall be no visible emissions to the outside air...from any building or structure in which the following operations are conducted or directly from any of the following operations if they are conducted outside of buildings or structures." Company Operations are limited to Category (7) Paints, coatings, caulks, adhesives and seal ants. Construction or Modification of Stationary Sources: Nrittem approval of the EPA ari.qi7iTsi-.yflt.n-r in required. However, "modification'1 as defined in 6l.02(,i) does not include routine maintenance, repair and replacement nor does it include in creases in production rates or hours. Operation: .All new sources must operate within the standard per 61.05(b).__ Existing sources must operate within the standard within 90 days of April 6, 1973 or a waiver must be obtained from the Administrator per 61.10(b) using the form in Appendix A. Waivers may be granted for up to tiro years provided corrective action is being talien. Immediate action may be inquired! Reporting: The owner or operator of any new or existing source must provide the information required in 6l.X0 and 6l.2h to the Administrator, using the form in Appendix A within 90 days of April 6, 1973. Immediate action requiredl Notification of Startup: "Any owner or operator of a source which has an initial, startup after the effective date..." shall notify the Administrator in writing per 61.09 "....of the anticipated date of initial startup not more than 60 days nor less than 30 days prior", and "...of the actual date...within 15 days after..." Section 61.22(d) - Perdition Procedures: The procedures such as vetting and careful handling given in 61.22(d)(2) 11 ...shall be used to prevent emissions of particulate asbesfcos material to outs5.de air:..." Demolition is not defined but appears to be oriented to structures rather than equipment. Reporting: "Any owner or operator or a demol5.tion operation who intends to demolish any...structure, facility, installation or portion thereof which contains any boiler, (pipe or load supporting structural members that is insulated with friable asbestos material shall..." provide at least 20 days advance notice to the Administrator as l provided in 61.22(d)(1). Modification per 6l.02(j) indieates that routine main-- * tenance, repair and replacement ere excluded. Section 61.22(e) - Spraying "There shall be no visible emissions to the outside air from the spray-on application of materials containing more than asbestos on a dry weight basis..." "Any owner or operator who intends to spray...shell report...to the Administrator at least 20 days prior to the commencement of the spraying operation." as provided in 6l .22(e)(2). Section 61.22(f) "Rather than meet the no-visible-emission requirements of...(c) and (e) of this section, an owner or operator may elect-to use the methods specified in Section 6l.23 to clean emissions containing particulate asbestos material, before such emissions escape to, ox* are vented to the outside air." Detailed requix-eroents for air cleaning equipment ore specified in 6l.23 and for reporting to the Administrator in 6l.24.