Document 5DkdbQnrxm5MJMdON1egRaKkV

FROM: S. M. ANDERSON TO: J. DAMIANO PITTSBURGH - 6 1988 September 02 RE: FLAMMASTIC I recently received the attached information on Flamroastic which I thought you may find interesting. Anderson /sma Attachment xc: J. M. Shaw - 60 D. E. Huddleston, Tennessee* ARD 003946 FLAMEMASTB August 26, 1988 Mr. Scott Anderson ALCOA P.0. Box 150 Massena, NY 13662 Dear Mr. Anderson: Pursuant to our telephone conversation of this morning, I am enclosing herewith a Material Safety Data Sheet for Flamemastic 71-A along with a copy of a Test Report of a study made of the quantity of asbestos'fibers Introduced into the atmosphere when cables are removed from a bundle which had been coated with Flamemastic 71-A. As you will note, the MSDS for Flamemastic 71-A is quite old. We have not updated It because manufacture of the product was terminated over fifteen years ago. I trust you will find this information helpful in your negotiations with the environmental protection people of New York state. If we can be of further assistance, please do not hesitate to contact us. SJiiniicwecriveiljyr jyrovuirsd ) Samuel L. Engel, Sr., Vice President, Research and Development Flamemaster Corporation 11120 Sherman Way, PO. Box 145a Sun Valley CA 91353-1458 Telephone: (818) 982-1650 or Telex: 19-4865 ARD 003947 j, w ANALYTICAL RESEARCH LABORATORIES, INC. "FlViC- ISO TAYLOR STREET. P.O. BOX 369. MONROVIA. CALIFORNIA 91016 (213) 337-1747 1 March 1976 LL 26019 The following test was performed to deEermine wheEher a significcnE amounE of asbestos fibers is released Eo Ehe aEmosphere when individual cables are removed from a group of cables EhcE have been sprayed w?Eh Flamemastic 71A. Eleven one inch cobles end one cable bundle comprised of 3, one-half inch inEertwined cables, were placed in a twelve inch P-W Western cable Eray. The ccbles end Eray were twelve feet long and the cables were individually attached to the Eray. FlamemasEer Corporation personnel sprayed the filled tray tep and bottom with a 1/8" thick coating of Flamemastic 71A. The coating wes allowed to dry for six days and the dried materia! had an average thickness of about 1/16". The cocted Eray and ocbles were brought Eo Analytical Research Laborctcries for testing. Asbestos fibers were monitored by three devices during the removal of the cables: 1. Analytical Research Lab., Inc. sampler (ARU - Stationary) - filter was mounted approximately three feet above the Eray and equidistant from the ends of the tray. 2. Analytical Research Lab., Inc. sampler (ARU - Opercrcr) - filter sves cttached to the person removing the cables, in his breathing zone. 3. Fiomemaster Corp. - MSA portable sampler (FMEN - 1) - filrer was held by a second operator at the point where the cable was being removed from the tray. This filter was from six to twelve inches from the Flcmemcstic 71A coating, cs it was breaking loose from the tray and ccbles. This filter followed the removal of all twelve cables in the manner described above. The operator removed the cables from the tray individually. Total time to remove the twelve cables was 15.5 minutes. ARD 003948 Poge 2< oF 2 l March 1976 LL 26019 The filters were examined by the method described In the NIOSH Bulletin HSM 72-10267 (1972) by Mr. K. Inouye of ARLI. The results are as follows: SAMPLE ARLI - Stationary ARLI - Operator FMEN-1 SAMPLING RATE 3 l./min. for 15.5 mins. 3 1/min. for 15.5 mins. 2 1/min. for 15.5 mins. ASBESTOS PARTICLE COUNT 0.07/cc. 0.07/cc. 0.15/cc. CONCLUSION: The level of airborn asbestos fibers produced during removal of the cables from the Flamemasfic 71A coated bundles is significantly less than the existing (5 fiber/cc.) or proposed ( .5 fiber/cc.) OSHA limits. ARD 003949 w. J. o. t l 'h Occupations'. S=*ety and Keauh Administration 0^4 H. Required under USDL Safety and Health Regulations for Ship Repairing, Shipbuilding, and Shipbreaking (29 CFR 1915, 1916, 1017)_______ SECTION 1 AMW<ACTUM*'S NiMJ THE FLAMEMASTER CORPORATION (M(G(ACV T(UxCR| tio. /213) 982-1650 Tit2o Mcaftrwvretta VALLEY, CALIFORNIA 91352 NAME ANO StNONTMS . ` 1 TAAO( NAM* ANO SYNONYMS' . N/A FLAMEMASTIC 71A SPRAYABLE IOUAIIA N/A T SECTION J1 HstAF-DCJS 1KCF.EDS5NT3 r j paints. preservatives, a solvents Q PiCMSNTS ! Antimony Oxide _ | TLV * 1 (U.itt) Ll.3!0.5mfJ I3 ALLOTS AMD METALLIC CO ATMOS Q Catalyst j ALLOTS II vs**cu Yv` IP 1 METALLIC COATINGS } FILLER VITAL LUS COATING OX CO** FLU* ' V' ADDITIVES 5;________ * Be to chloroethyl pho5phote!2.6; UnknowI nO-MEXS OTHERS Asbestos |9.6|(See oitoched test report) l&---- HAZARDOUS MIXTURES O* OTHER LISUIDS. SOLIDS, OR CASES '{ The osbestos ond antimony oxide contained in .ttiis material ore wetted ond 1 coated with the vehicle and do not offer the hazard associated with the dry 1 material. (See enclosed test reports)_______________ 11 .________________________ __ y* * . -I fF . * ; ; w SSCTiCT! ;:s PHYSICAL DATA>_ . OILING POINT <*F.) VAPOR PRESSURE I*""* Hj.| VAPOR OENSITr |AI=1J 212 H?0 of RT H2O Vopor SPECIFIC GRAVITY IHjO=11 PifSPvCoCuN?TvVOLnA.Ti ILE tVA^T^XATE "' : " SOLUBILITY IN WATfa Misc. - APPEARANCE ANO ODOR White, heavy-bodied paint - slight odor. *_ 1 TLV (Unlit) i i i I II i % | Q7JL.lVt.) : t : 1.37 ' 32.7 Approx. 1 ! SECTION IV FIRE ANDES?!CSiCN HAZAnD DATA Flash point *.al UTINCUISHINC M.OIA kl_____ (None N/A KAMiALBLC LIMITS - : *- ________________________ __________ Sf*iC>AL MAC HCMl.NG AAOCIOU^CS N/A UAl UNUSUAL MAC and CXALOSION M A2ANOS i N/A PAGE(l) (Continued on (' . {d.) 1 1 '> K*L;l T '**V*A`y^1 ''* w-;< .1 I 1 ,r.c;S,i: .. , Fom OSH A-20 *iv. April 72 ARD 003950  * *'.! * t.l # . *- ^ 'n..** * -*"; '.V'' ' --1 ^ ^ / *n** ii, .11 ni l A7 iV. ii I ( iHSi1* ( ;*stiC.D i*mit value Vi tMccr>c* ovhi^o$uri ><*--------------------------------- N/A None observed. u VilI iwiRui-'iCT AN3 HAST AIO PAQCCOUftES n /> V.*\ ` * ,, ' '*'' ' ? ' ---iV 'O'- :'!.V , .iV ' '"i* Eyes; Wosh with water for opprox. 15 min, ond get immediate medical 1'< . cid. Skin; Wosh with plenty of wnt*r and soao immedioteiy- 1, | STARilirV UNSTAtwC 1 i STASlg k IXCOMPATASltiTT (Hcfcrsali i* wifi SECTION VI FACTIVITY DATA CONDITIONS TO AVOID X . m ^ M-O-IJCO.-S DECOMPOSITION PRODUCTS ii >t V.f HAZARDOUS V*; E! | MAT OCCUR | mu. not occur X . \ CONOiTiONS TO AVOID 1, *' -- t ** L9\ n U .< aI H4. * . . SZCTiC'J VII SPILL C2 LEAa FGGCIDL'I^S pi ST IPS TO ii TAKEN IN CASE MATERIAL IS RELEASES OR SPIL.LEO * . 'b 1'i Scrape op spill end place in plastic container. Wipe floor with v/ater-soaked rogs. * <------------------------------------------'-t----------------------:-- ------------------------------------------------------:-----------------:--~ f* YtxST* OiSPOSAl AIETmOS l Dispose as asbestos-containing v/aste. Land burial where statutes permit. Ti ' t:{ *;* s *c7:on vi:i spzcialf?.ctCT:c;: :x7c:_':at:c:j f | siSp;*ATOAr protection fSr*->h tin) Usual protection used when spraying water-based coatings. i. VENTILATION LOCAL ERHAUST ?! AIECNANICAl (Ctnt-ilJ WOTiCTlVi C.OVES I SPE*CriIaA.*L ITf protection OTHER - - it .* i OTHER PROTECTIVE EQwIPMtNT SECTION 12 S?iC>AL PRECAUTIONS PRICauTiC'.S TO fee !iM l-N HANDLING ANO STORING lS J, OTP>*s PRECAUTIONS >* i'i ARD 003951 ^ rr _____l] ----...~ . -......... ......... __-- __ .__ a "The information contained herein is derived trom the best available sources PACE (2) anj js believed to be accurote. However, no guarantee is expressed or implied regarding the accuracy of these dota or the use of this product.!^ FROM: S. M. ANDERSON J. M. SHAW TO: MEMORANDUM 1988 August 12 RE: FLAMMASTIC COVERED CABLE Recently we surveyed some of the electrical substations for asbestos in the flammastic which covers the cable and cable trays. Our survey revealed that the flammastic contains 5 to 15% chrysotile asbestos. This material is gray in color and was sprayed on the cables when the substations were built. The asbestos is in a non-friable form and it will not easily generate fibers. However, the presence of asbestos presents a significant problem for us in light of New York's asbestos regulations. The State regulations treats the removal or disturbance of ANY asbestos containing material as an asbestos abatement job. This requires us to construct a plastic enclosure, place the enclosure under negative pressure, use water to reduce asbestos dust, de-energize all electrical equipment and to only allow state certified asbestos removers to perform the work. Many of these requirements cannot be safety carried out in our substations. Effective immediately the following procedures will be carried out when working in cable trays that have flammastic covered cable: 1. Flammastic covered cables that are no longer useful are not to be removed, rather they are to be cut where they enter and leave the flammastic covered area. The flammastic covered portion will be left in place and the cable ends clearly identified and labeled. The non-flammastic covered cable will be removed. 2. The re-routing of flammastic covered cables is no longer permitted. New cable must either be installed or other solutions sought. We have discussed leaving de-energized cables in cable trays with Mr. William Burke of the Syracuse OSHA office and he said, "that it is acceptable to do this provided we label and do not violate the requirements of the National Electrical Code". To help us out of this regulatory catch 22, we are applying for a variance from some of the requirements of New York's asbestos regulations. When or if we receive a variance, the decision to remove the cable or to leave it in place will be left to the Chief Electrical Engineer. ARD 003938 By copy of this letter to the Electrical Maintenance Supervisors, we are asking that they inform the electricians of this condition and policy. SCOTT M. ANDERSON JAMES M. SHAW SMA:JMS:af1 Copies to: Electrical Engineers Electrical Maintenance Supervisors R. M. Overbey - 8 C. E. Johnson, Pittsburgh - 21 R. R. Taylor, Pittsburgh - 23 L. L. Rippey, Pittsburgh - 6 C. F. DiMascio, Pittsburgh - 6 J. P. Carroll - 316 B. L. Konkoski - 204 D. A. O'Connell - 50 S. C. Smith ARD 003939 ALUMINUM COMPANY OF AMERICA MASScNA OPERATIONS P.0 BOX 150 MASSENA. NEW YORK 1366:' 1988 August 11 ALCOA Mr. Daniel Sullivan State of New York Department of Labor Engineering Services Unit The Gov. Averell Harriman State Office Buidllng Campus Albany, New York 12240 Dear Mr. Sullivan: Enclosed are three (3) copies of our request for variance from Part 56 of the New York Industrial Code. If you have any questions, please call me at (315) 764-4186. Very truly yours. ANDERSON, CIH Sr. Industrial Hygienist SMA:af1 Enc. Cc: J. M. Shaw S. C. Smith ARD 003940 ENGINEERING SERVICES UNIT Th Gov. W. Averell Harriman Stata Office Building Campus Albany, N.Y. 12240 SUBMIT IN TRIPLICATE complete front ani PETITION FOR A VARIANCE OR OTHER RELIEF 1 NAME AND ADDRESS OF PETITIONER (PERSON OR CORPORATION AFFECTED BV THE LAW OR CODE GIVEN BELOW) Aluminum Company of America, P. 0. Box 150, Massena, New York 13662 2. NAME AND ADDRESS OF PETITIONER'S AGENT. IF ANY I TELEPHONE NO 1 (315) 764-418 (TELEPHONE NO N/A 3. NAME ANO ADORESS OF OWNER OF PREMISES .4 NAME OF OCCUPANT OF PREMISES Same Same THE PETITIONER HEREBY. PETITIONS THE COMMISSIONER OF LA80R FOR A VARIANCE (OR OTHER RELIEF) FR( REQUIREMENTS OF THE LABOR LAW, ORDERS OF THE COMMISSIONER OF LABOR REQUIRING COMPLIANCE WITH THI BUILDING CONSTRUCTION CODE, THE NEW YORK STATE UNIFORM FIRE PREVENTION AND BUILDING CODE. AND/ RULES OF THE COMMISSIONER OF LABOR AS STATED BELOW. FOR ITEMS 5 -8, IF APPLICABLE, GIVE THE SECTION AND PARAGRAPH OF THE RELEVANT LAW. CODE. OR REGULAT S. LABOR LAW S. STATE BUILDING CONSTRUCTION COOE 7. UNIFORM FIRE PREVENTION COOE a. industrial cooe rule nui 9. DATE OROERS ISSUED. IF ANY Part 56 of Title 10. ORDERS ISSUEO BY: 11. ISSUED TO: [_J OWNER Labor Law Sect. S Li agent l_| lessee STATE INSPECTOR LOCAL BUILDING INSPECTOR GIVE NAME APPEARING ON VOTICE OF VIOLATION 12. AFFECTING PREMISES KNOWN AS Alcoa, Massena Operations 13. STREET ADORESS OF SUCH PREMISES Park Avenue East, Massena, New York 14. These premises are situated on North NORTH-CAST-SOUTH-WEST side of Park Avenue ST REET-AVENUE-ROAO (Check one) m the Dcity GiffowN Dvillageof 15. QUOTE HERE THE OROERS, IF ANY, MENTIONED ABOVE Massena! " , County of St. Lawrenct -------- It. If variance hat b--n granted previously covering the ami vection end paragraph ol ttie libor law at lined ebove in item 6.. the nw action aodew d itste Building connruction code, m listed ebove in item 6, the aim section and paragraph of the uniform fire prevention code, ee listed above in h the aama code rule number as listed above in item 8, give case number and date of such variance. DOSH-7S1 (4-33) ARD 003941 24. Periodic maintenance and emergency repairs conducted in various electrical substations may require the removal or re-routing of electrical cable which is covered with a sprayed-on non-friable flammastic fire-proofing material. This material was sprayed on to our cables to prevent catastrophic damage in the event of a cable fire. However, this material may contain up to 15% chrysotile asbestos bound in a mastic substrate. These electrical substations distribute power to the environmental control systems for our aluminum reduction cells, cooling system of our rectifier station, carbon handling equipment, and many other systems essential to the safe, efficient, and the environ mentally sound production of aluminum. These substations cannot be deenergized without halting all aluminum production or creating severe environmental emissions and occupational exposures to dust, hydrogen fluoride and coal, tar, pitch. In addition, water cannot be used in an energized substation because of electrocution hazards. 25. The substations are located within our plant site and access is limited to only Alcoa maintenance personnel. The work practicies employed will be used to minimize any fiber generation during the re-routing or removal of cable sprayed with asbestos containing flammastic. The results of air monitoring conducted during the removal of cable trays sprayed with flammastic at other Alcoa locations outside New York found fiber counts to be<0.02 f/cc. The following are our proposed work practices: General Scope of Work 1.01 (a) The work covered by their request includes the re-routing and removal of cable covered with asbestos containing flammastic. Qualifications 1.02 (a) All employees involved with the removal of flammastic covered cable will have received three (3) days of training in a course approved by the New York Commissioner of Health on the hazards of asbestos exposure, on the use of and fitting of respiratory protection, on protective clothing, on the use of showers, on entry and exit from the work area, and all other aspects of work procedures.and protective measures. (b) All employees removing flammastic covered cable will have received medical examination as required by 29 CFR 1026.58. (c) Project Supervisor will have successfully completed an EPA/NYS approved training course in asbestos abatement. ARD 003942 2 Work Site Preparation 1.03 (a) All non-essential movable items shall be removed prior to any work. (b) Two layers of 6 mil. poly, shall be spread beneath the cable trays. Walls and control panels will not be covered because of the combustible nature of poly, and the presence of high voltage. (c) All entrances to the sub-stations shall be posted with signs which comply with 29 CFR 1916.58. (d) All ventilation systems, where possible, shall be shut down and covered with two layers of 6 mil. poly.. Some ventilation systems may need to be maintained to prevent the overheating of energized electrical equipment. Personal Protective Equipment 1.04 (a) All workers shall be provided with, as a minimum, 1/2 facepiece respirators with HEPA filters. The respirators shall be worn at all times in the asbestos work area. Sufficient filters shall be provided for replacement as required. (b) All workers shall be provided with sufficient sets of disposable full-body clothing to be worn in the designated work area and/or whenever potential exposure to asbestos exists. Full-body clothing shall consist of full-body disposable coveralls with attached hood made of tyvek or equivalent material, gloves, eye protection, hard hats, and footwear. (c) Non-skid footwear shall be provided to all workers. Disposable clothing shall be adequately sealed to the footwear to prevent body contamination. (d) Protective clothing shall not be worn in lieu of street clothing outside the work area. (e) Visitor clothing: Alcoa shall provide authorized visitors with suitable respirators, protective clothing, gloves, head protection, eye protection, and footwear. EXECUTION: Cable Tray Preparation 2.01 (a) Flammastic covered cable tray and cable shall be pre-cleaned using a HEPA vacuum. ARD 003943 3 Cable Re-Routing 2.02 (a) Cables being re-routed shall be done with as little unnecessary bending and pulling as possible. (b) Cables shall be continuously vacuumed whenever they are pulled or otherwise rubbed against them selves or the cable tray. (c) Re-routed cables shall be vacuumed with a HEPA vacuum after all re-routing has been completed. (d) Air sampling will be conducted during the project. Cable Removal 2.03 (a) Whenever possible, disconnected cables shall be cut and left in place. At times, electrical safety considerations may require the removal of the flammastic covered cable. The sawing of the cable or cable trays shall not be permitted. (b) Whenever a cable must be removed, it will be carefully separated from the other cables. (c) The cable will be cut using a cable cutter in lengths that will minimize the amount of pulling and possible abrasion that the cables would be subjected to. (d) The cable shall be HEPA vacuumed at each cut during shearing. (e) The cut lengths of flammastic covered cable shall be carefully lowered into a sealable fiber or metal drum which has been appropriately labeled. (f) The seal on the waste drum and HEPA vacuum must be on the outside. (g) Air sampling will be conducted during the project. CLEAN-UP/DECONTAMINATION 3.01 (a) The cable tray and cable shall be HEPA vacuumed. (b) All ladders and other equipment shall be HEPA. vacuumed. (c) The first layer of plastic shall be HEPA vacuumed and then picked up and disposed of in an approved asbestos waste bag. (d) The second layer of plastic shall be HEPA vacuumed and then picked up and disposed of in an approved asbestos waste bag. ARD 003944 (e) Coveralls, boots, and respirators shall be HEPA vacuumed prior to removal. () Coveralls shall be removed and disposed of as asbestos waste. (g) A clean set of coveralls shall be donned and the workers shall remove the waste drums from the substation and then immediately proceed to a shower facility. ARD 003945