Document 4qpovkMEBVJmDVKKnM1bpk1x

FROM: KEVIN ROLAN ROCKDALE CONSTRUCTION TO: GARY GRIESBACH 1994 JANUARY 19 REF: SPRAY-ON FIREPROOF COATINGS GART , BACK IN THE MID TO LATE 1980'S, WHEN WE WERE JUST GETTING INTO ASBESTOS "MANAGEMENT", I WAS ASKED TO COMPLETE A SURVEY OF THE SMELTER FOR THE PURPOSE OF LOCATING ASBESTOS CONTAINING MATERIALS. I STARTED THE TASK BY MYSELF, BUT DUE TO TIME CONSTRAINTS, I WAS GIVEN THE ASSISTANCE OF A CONTRACT DRAFTSMAN TO HELP WITH FIELD WORK AND DOCUMENTATION OF THESE LOCATIONS ON A PLANT MAP. THE END RESULT WAS A MARKED UP PLANT MAP WITH LOCATIONS OF ASSUMED ASBESTOS MATERIALS (MOSTLY PIPE INSULATION) WHICH WERE GENERALLY VERIFIED FOR ACM PRIOR TO ABATEMENT. AT THIS TIME, BULK SAMPLES WERE SENT TO AN ACCREDITED LAB OFF SITE, BECAUSE WE DID NOT HAVE ANYONE CERTIFIED TO READ ASBESTOS SAMPLES AT ROCKDALE. SAMPLES WERE NOT DONE ON ALL MATERIALS, OR IN ALL AREAS BECAUSE OF COST AND TIME FACTORS INVOLVED. AGAIN, TESTING WAS MOST OFTEN DONE PRIOR TO ABATEMENT FOR CONFIRMATION OF ACM MATERIALS. IN ADDITION TO LOCATING AND DOCUMENTING PIPE INSULATION MATERIALS, I TRIED TO LOCATE OTHER FORMS OF ASBESTOS CONTAINING MATERIALS. ONE OF THESE MATERIALS WAS THE SPRAYON FIREPROOF COATING (COMMONLY REFERRED TO AS "FLAMASTIC" TYPE FIREPROOFING) USED IN ELECTRICAL CONTROL ROOMS. I DID NOT HAVE SAMPLE TESTING DONE ON ALL OF THE BUILDINGS CONTAINING SPRAY-ON FIREPROOFING, BUT FOR THE SAKE OF SAFETY AND EMPLOYEE PROTECTION, I MADE THE ASSUMPTION THAT THESE WERE ACM MATERIALS. TESTING MAY HAVE BEEN DONE, BUT I DON'T HAVE PROOF. MY REASONING WAS BASED ON INFORMATION OBTAINED FROM INDIVIDUAL ENGINEERS AND DOCUMENTATION LATER RECEIVED ON THE SUBJECT. (SEE ATTACHED LETTER DATED 1990 FEB. 05) HOWEVER, DUE TO CONSTRUCTION WORK SCHEDULED IN BUILDING 93X, (BUILT AROUND 1980) RECENT TESTING WAS DONE ON THE SPRAY-ON COATING IN THIS BUILDING. THE RESULTS CONFIRM A NON-ASBESTOS MATERIAL. ATTACHED IS A COPY OF THE LAB REPORT DONE BY JIM RICHTER. THIS REPORT CASTS DOUBTS ON THE ASBESTOS CONTENT OF SPRAY-ON COATINGS FOR SOME OF THE OTHER BUILDINGS I HAVE LISTED BELOW. THESE BUILDINGS WERE PREVIOUSLY SUBMITTED TO YOU (AND OTHERS) AS CONTAINING ASBESTOS CONTAINING MATERIALS. I WOULD STRONGLY SUGGEST THAT WE HAVE TESTING DONE IN THESE BUILDINGS TO CLEAR UP ANY UNCERTAINTY, AND THEN IF NEEDED, HAVE THE PROPER LABELING OF THESE AREAS DONE AS REQUIRED. ARD 003019 THESE BUILDINGS ARE AS FOLLOWS: BUILDING 19X BUILDING 23F BUILDING 32X BUILDING 52X BUILDING 58X BUILDING 59X BUILDING 66X -BUILDING 93X- BUILDING 160X BUILDING 161A BUILDING 161B BUILDING 162X BUILDING 163A BUILDING 163B (SEE ATTACHED REPORT) PLEASE CALL ME IF YOU HAVE ANY QUESTIONS. THANK YOU, KEVIN ROLAN CC: T.J. HORMUTH R.N. NARVAEZ T.E. HODGES J. RICHTER / R. LINNSTAEDTER ARD 003020 FROM T. E. HODGES CHIEF ELECTRICAL ENGINEER ROCKDALE WORKS TO SEE DISTRIBUTION 1990 February 05 RE: FIAMftSTTC - ELECTRICAL CABLE COATING - 15% ASBESTOS It has been known since 1988 that all Flamastic cable tray fire retardant coating used at Rockdale Works contains 15 percent asbestos. At that time a policy was adopted for dealing with these installations. This policy is: A) Maintenance, Construction and Engineering should be cautious about arbitrarily working in, on or about these cable trays since asbestos fibers could be generated. B) Cables should not be removed from these cable trays unless they are not coated and their removal does not disturb other coated cable or they are removed by an asbestos removal con tractor using proper procedures. C) If flamastic coated cables are being replaced or abandoned they should be cut off at both ends of the cable tray, taped, and marked. D) In the past eight years, it has been and continues to be the policy of Rockdale Works not to apply flamastic to new installations. T. E. HODGES distribution: All Electrical Engineers/Designers All Mechanical Engineers R. E. Clark S. J. Khight J. D. Leggett G. H. Lantz R. E. Green J. M. Mitchell A. L. Glaser C. P. Kouba J. C. Saxton G. C. Kraft 0 ALCOA i/.c. C.A/' a jzz. XA o /* - jAf /t^A.r a*/y V ARD 003021 ( ASBESTOS--BULK SAMPLES FOR TESTING IN ALCOA LAB (ROCKDALE) A) Type of material such as pipe Insulation, rope, wall insulation, floor tile, etc. \ t vtOL ^ ________ B) Source of Sample: Bldg. No. ISarfCLocation Within Bldg D) Results To: fl LUfUTlJ 0 E) Date/Tioe SampleduOt________ SAMPLE MUST BE TAKEN BY QUALIFIED. TRAINED PERSONNEL THE PEOPLE QUALIFIED TO DO THE SAMPLING ARE: PLEASE CHECK AREA SAMPLE IS FROM AND THE SAMPLER. Ufv\ SMELTER MINES J. RICHTER, R. LINNSTAEDTER J. LOVE, F. GERTHE, F. BURFORD T. BERRINGER, D. ORSAG POWER D. PIERCE, J. MELLOTT, D. STANLEY D. BURNS, T. BROWN, R. COKER SAMPLES MUST BB PLACED IN A SEALED, AIR-TIGHT CONTAINER AND DELIVERED TO JIM RICHTER fig RONNIE LINNSTAEDTER. LABORATORY (Bldg 80) (OR DON THOMPSON IN THEIR ABSENCE) LAB NO. Qiq QU~1^___________ STEREO MICROSCOPE(10X-4OX) GENERAL APPEARANCE fefK, ^ POLARIZED LIGHT MICROSCOPY: DISPERSION STAINING 1.550 CHRYSOTILE LIZARDITE' ANTIGORITE' OTHER' PERCENT ASBESTOS: 1.605 ANTHOPYLLITE_____ TREMOLITE_____ ACTINOLITE_____ OTHER % 1.680 AMOSITE_____ CROCIDOLITE OTHEI^C" CO I * COMMENTS ANALYST: _ DATE: 10 I ARD 003022  What may be Alcoa's third-party issues and how do we limit liability? Contractors are our major issue. We should insure proper communication ofthe hazards involved in asbestos related work; select good/qualified contractors; use Alcoa terms and conditions in contracts; use adequate insurance provisions andperform oversight role with respect to contractor work. General Industry requirements. What is definition of "area" under General Industry as this would relate to housekeeping? Unclear, there is a definition of "regulated area". What are requirements under General Industry for HEPA sweeping and recordkeeping? Dusting and dry sweeping must be performed using HEPA vacuums no less than one time per shift Recordkeeping requirementsfor General Industry are in I910.1001(m). What are training requirements (such as length, initial and refresher training)? There are two types oftraining (employees working in areas over the PEL and awareness trainingfor employees performing housekeeping duties). All employees must have some initial training and then be trained annually (refresher). However, there is no guidance on the length ofthis training, but it is probably analogous to training for Class III and IV work. Also what are requirements for employee information? Unclear, there is a provision in HAZCOMpart ofthe standard (1910.1001(m)(5)) which gives the employeefand employee reps) rights to certain information. -6ABD 003023