Document 4J65Kx0Mb8BrrbXoEjbn39981

t ^ ' INTER-COMPANY MEMO' Mkoch INDUSTRIES INC DATE TO March 3, 1986 Distribution List Below J Hfi I PLAINTIFF'S | EXHIBIT j KRC-66 FROM SUBJECT D. F. Janes ASBESTOS INSULATION DEMOLITION AND REMOVAL The two attached pieces of correspondence are selfexplanatory. Briefly stated, OSHA is requesting that we notify their local office when we conduct asbestos demolition or removal. This request pertains to work performed by Koch or a contractor. Your cooperation in providing me with an "early warning" of such work will be appreciated. I will then notify OSHA of our planned work. S. 4 0-^^; D. F. Janes Distribution: JHA, JJB, J'TC, RMC, EBD, JME, REF, MJH, ERH, HFH, RDH, JPH, SAH, JDJ, JRK, DLL, EAP, KLS, CJW, RDW, All Process and Refinery Engineers DFJ/vpc Attachments (3) O' KOI8250 PS-46 '' ! U. S. Department of Labor Corpus Christi Area Office Government Plaza 400 Mann Street, Room 300 Corpus Christi, TX 78401 ' 512-888-3257 Occupational Safety and Health Administration Reply to the Attention of: RLMH: keg February 12, 1986 Koch Refining Co. P.0. Box 2608 Corpus Christi, TX 78403 Attn: Mr. Dale James, Safety Manager Dear Mr. James: The Occupational Safety and Health Administration is currently conducting a National Emphasis Program for programmed health inspections of estab lishments where asbestos is used, stored or processed. Also included in this National Emphasis Program are any sites involving asbestos demolition and removal activities. (OSHA Instruction CPL 2.60B) Currently OSHA receives notices regarding the asbestos demolition/removal activities from the Environmental Protection Agency and the Texas Air Control Board, but in an effort to improve its response time OSHA re spectfully requests that your company notify us of any asbestos demo lition or removal activities on your site. OSHA would like for you to also inform your asbestos demolition/removal contractors of the assistance available from our local office. The local OSHA Office functioning as a full service office resource center will gladly meet with any asbestos demolition/removal contractors prior to their scheduled work. The 29 CFR 1910.1001 Asbestos Standard will be fully discussed including viewing of a video tape and/or slides. Also in this session will be a discussion of respiratory protection, other PPE and specific monitoring requirements. For notification purposes the address of our office is as follows: U.S. Department of Labor, OSHA Government Plaza 400 Mann Street, Room 300 Corpus Christi, TX 78401 (512) 888-3257 Together we can make the workplace safer and more healthful. Sincerely, //O' L. MIKE HUNTE Area Director KOI 8251 January 29, 1986 AP-86-08 Mr. Tom Palmer, P.E. Regional Director Texas Air Control Board 5602 Old Brownsville Road Corpus Christi, Texas 78415 Dear Mr. Palmer: RE: Asbestos Removal Notification Please accept this letter and attachment as notification of intent to remove friable asbestos as mandated by 40 CFR 61.146. We have based this notice of asbestos removal on planned turnarounds and pro cess revamps for the year 1986. The estimated quantities have been determined using plans for piping and equipment modifications. If you have any questions regarding this notification, please call. Yours truly JRK:1 jl Attachment cc: DFJ J. R. KAMPFHENKEL Chief Environmental Engineer /' Offices: Corpus Christi, Texas 78403 P.O.Box 2608 Telephone 512-241-4811 KOI8252 mwaL JOB DESCRIPTION OWNER OPERATOR MAILING ADDRESS PHYSICAL LOCATION JOB DESCRIPTION Koch Refining Company - Corpus 'Christi Refinery P. 0. Box 2608, Corpus Christi, Texas 78403 Off Interstate 37 at Suntide Road, 7 miles Northwest of Corpus Christi Demolition, removal-, and salvage of asbestos insulation in the following refinery units during 1986 Process Unit Removal Date Estimated Qjantity . (PjRJftg.) ,, Linear Ft. Square Ft Ultraformer February . 200 East Crude March, April 200 Fluid Cat Cracker Feb., Mar., Apr. 600 2,100 Cumene March, April 800 Alkylation March, April 300 Alkar March, April 400 Uni finer March, April 200 LERU March, April 300 Platformer March, April 300 Hydea1 March-, April 100 3,400 2,100 REMOVAL METHOD Every effort will be made to restrict the amount of asbestos emissions. The majority of the removal will be carried out in a remote area of the refinery. A small amount of asbestos may be removed in operating units which will be shut down for turnaround or revamp work. The asbestos will be wet down with water and bagged wet. DISPOSAL SITE Arrangements have been made with Texas Ecologists, Inc. of Robstown, Texas to handle disposal of the properly identified sacks of asbestos contaminated material. REPLACEMENT MATERIAL All material used to replace removed insulation will be new and asbestos-free. KOI8253