Document 5LNzDV1y5qLe28renN3m25bqz
I
UNION CARBIDE CORPORATION
P. O. BOX 0004, SOUTH CHARLESTON. W. VA. 25303
Silicones and Urethane Intermediates South Charleston Plant
To: Mr. T. G. Swanson
Copy to:
Mr. W. E. Ballard Mr. J. R. Dean Mr. C. E. Fry Mr. D. G. Moshier Mr. R. A. Ream ES Routing'List 2
From:
J. G. Roy
Date:
December 27, 1984
Subject: No. 2 Steam Plant Asbestos Insulation Replacement
One of my MOP' s for the 4th Quarter is the development of a program to phase out asbestos from the steam plant. I understood from Bob Ream at the time I was given the assigment that special budget provisions were being made to kick this off in 1985. This apparently came about during budget presentations to SUI division management.
Attached is my proposal to accomplish the overall objectives. I've not attempted to quantify the project into monetary blocks (Bob indicated that guideline established was $250,000 expenditure per year) but have presented it in pieces as a control measure. I believe the approach outlined will provide the greatest return both from a health and economic standpoint.
By copy to the department staff I would appreciate their re view of both the approach and the individual work list. The most successful projects are those with the most thorough and up front work.
JGR;kab Attachments
J. G. koy UCC 011550
ASBESTOS ELIMINATION PROGRAM
Building 151
General: As an energy conversion facility constructed in large part
during its first twenty years (1933-1953), the No. 2 Steam Plant insulation was originally all asbestos. While rebuilds of pre cipitators and 25 Boiler together with SCESUP additions incorporated non-asbestos materials the majority of the insulation is still asbestos. In reviewing the health related issues involved in steam plant operation asbestos exposure has to be viewed as one of the critical few.
There are several approaches which can be taken to the resolu tion of this problem. One is to continue the phasing out of asbes tos by attrition i.e. repairs with non-asbestos material. Asbestos can also be rendered harmless by sealing the surface to prevent fiber migration into the atmosphere. The ultimate solution is a total replacement of all asbestos material.
The program outlined in this proposal is aimed at elimination rather than control. Realizing that the project cannot be accomplished overnight so to speak, a phased approach incorporating discrete pieces of work (shown on attached listing) is recommended to proceed in the following manner. Schedule/Funding
The precautions and health monitoring required for asbestos re lated work is very intensive in comparison to other types of work. For this reason it's important that specific task be started and completed in a timely fashion. Full replacement of all asbestos
UCC 011551
2- -
has been roughly estimated to be in excess of one million dollars.
The magnitude of the project almost dictates a phased approach not
only from the monetary standpoint but to avoid chaos in the normal
operation and maintenance activities. For this reason the attached
list of work has been arranged in a quasi prioritized order. You
will note that the first part deals with the removal only require
ments. This of course offers the greatest return on expenditure.
The remaining individual items are arranged to make significant
;
contributions with emphasis on places where exposure is most likely.
For instance the last item is the 25 Boiler feed water lines. These
were fairly well sealed during SCESUP. Also work around the turbine
generators should coincide with the scheduled overhaul of these
machines.
Funding is visualized at a rate of 150-250M$ pwer year and be
comes a budgeted item until the project is completed. I believe
that the distribution of work outlined below will produce a high
level of efficiency to keep the overall cost well below the original
estimate.
Work Assignments
There's plenty of work for everyone! However keeping in mind
the need for timely execution coupled with costs, the project seg
ments can be best accomplished by various groups. I visualize the
use of demolition contractors, insulation contractors, and UCC
Construction as well as Plant Maintenance. Each of these work
groups offers unique skills that can expedite as well as minimize
the costs for various pieces of the project.
Demolition Contractors; These people are geared to removal work
UCC 011552
-3-
and can strip idle facilities very quickly at reasonable costs. Insulation Contractors: Traditionally, UCC insulation projects have been overdone in the sense that we do a better job than is needed. Of course our costs are higher as a result. We almost universally use the block and wire approach with fabric coatings on large flat surfaces when other systems such as mineral wool on impaling wires and metal lagging are much more prevelent in the industry. Con tractors having to meet stiff competition have developed systems ; that are sufficiently sturdy but minimize both material cost and
\
labor. A case in point is the system we bought from Riley Stoker for the No. 25 Boiler rebuild. This project scoffed at by a number of construction people at the time, appeared to be flimsy. The entire insulation and lagging is supported on the impaling wires with no use of stand-offs and angle iron frames to mount the metal lagging. The bottom line is that it works and the cost is lower. For this reason I recommend that major equipment such as boiler ducts and breechings be insulated by contractors. UCC Construction: For the most part it will be virtually impossible to isolate steam and hot boiler feed water headers for stripping and reinsulation. From a health, safety and economic standpoint, it is important that long segments of header be stripped with re-, insulation following closely. Construction's manpower availability is suited to this kind of activity. Maintenance: There is a definite need to address miscellaneous lines and equipment that while limited in scope are more time con suming. The nature of work it lends itself to an intermittent pro gression of this type of work and should aid in the overall plant
UCC 011553
-4-
scheduling of this manpower short craft.
The following is a suggested assignment of the attached items
to the various resources described above.
Demolition Contractors - 1 through 10
Insulation Contractors - 11 through 18
UCC Construction
- 19 through 37
51A Maintenance
- 38 through 49
Project Control
'
Unless tight control is exercised for a project of this type
monies have a way of being spent without a whole lot to show for it.
It is important that all changes accrue to a single account and be
reviewed on a monthly basis. Additionally a file must be maintained
to measure progress of the overall effort.
Some time ago a program was undertaken to identify all asbestos
with stickers. I understand that stickers were placed on just about
every insulated surface and I've heard insulators say that many non
asbestos surfaces were eroneously labeled. Also due to dirt con
ditions many stickers failed to stay in place.
Perhaps a more effective way to start the project would be to
identify all of the insulation that is non-asbestos. There has
been a lot of insulating done since 1972 and with our knowledge of
project timing etc. it should not be difficult to pin down the
majority of non-asbestos material. Identification with a stencil
and spray paint would be a good first step leading into the overall
project.
UCC 011554
ASBESTOS ELIMINATION PROGRAM
Building 151
Removal From Idle Factilities 1. No. 14 I.D. fan and breeching to the south stack 2. Nos. 12 and 13 precipitator hoppers 3. No. 12 I.D. fan 4. No. 14 Boiler air ducts, drum heads, feed water lines, and
steam header to the main header isolation valve 5. No. 12 precipitator* inlet breeching and duct 6. No. 12 Boiler air'heater, ducts, feed water lines, drum heads,
and steam header to the isolation valve at the main header 7. No. 12 bubar ash collector 8. No. 12 pulverizer coal ducts from feeders 9. No. 13 pulverizer coal ducts from feeders 10. No. 13 hot air ducts to the coal feeders Remove and Replace With Non-Asbestos 11. South stack breeching serving Boilers 15 and 16 12. No. 15 I.D. fan and precipitator hoppers 13. No. 16 I.D. fan and precipitator hoppers 14. No. 16 precipitator inlet breeching 15. No. 16 Boiler air heater, ducts, drum heads, feed water piping
boiler headers and steam header to isolation valve at the main header 16. No. 15 Boiler, air heater, air ducts, drum heads, feed water piping, boiler headers and steam header to isolation valve at main header 17. No. 15 precipitator inlet breeching 18. No. 13 Boiler air heater, air ducts, feed water piping, drum heads, and steam header to the isolation valve at the main header
UCC 011555
2- -
Remove and Replace With Non-Asbestos (Continued)
19. No. 25 atmosphericflash tank 20. No. 25 deaerator 21. No. 25 high pressureheater
22. South end 10 psi flash tank and associated headers
23. No. 3 deaerator
24. 200 psi flash tank and headers
25. 10 psi steam header from north end to No. 3 deaerator, south end feed water pumps and on to the 200-10 psi reducer; section behind 14 Boiler is OK
26. No. 2 deaerator and headers on that level 27. North 600-200 psi (Hagen) reducing station and all steam
headers in that area
28. All deaerated boiler water lines below No. 2 deaerator on operating level
29. North end 200-10 psi reducing station and associated headers
30. South end blowdown recovery heat exchanger and associated piping
31. South end high pressure feed water heater and associated piping
32. All steam and feed water piping associated with Nos. 4 and 5 boiler feed water pumps
33. Ducts between the coal feeders and pulverizers serving Boilers 15 and 16.
34. Boiler feedwater headers serving all boilers
35. Main 200 and 600 psig headers through basement
36. West process steam header
37. North end boiler feedwater pump steam and water lines
38. Atmospheric flash tank and associated piping at No. 8 turbine generator
39. No. 8 turbine generator inlet and exhaust steam headers 40. All remaining miscellaneous lines and equipment at the basement
level
UCC 011556
-3Remove and Replace With Non-Asbestos (Continued) 41. All remaining miscellaneous lines and equipment on the operat
ing level 42. All remaining miscellaneous lines and equipment at the 3rd
level 43. All remaining miscellaneous lines and equipment at the 4th
level 44. All remaining miscellaneous lines and equipment in the bunker
and east roof level 45. All remaining miscellaneous lines and equipment on the main
precipitator platform 46. All remaining miscellaneous lines and equipment on the 25
precipitator platform and I.D. fan area 47. Steam header serving 25 high pressure heater and all water
piping associated with both the high pressure heater and the deaerator 48. All remaining miscellaneous lines and equipment in the struc ture located on the north side of 25 Boiler 49. All water lines and miscellaneous steam tracer supply headers in the north yard area and around the north residue manifold
JGRoy:kab 12/28/84
UCC 011557
FROM THE DESK OF J. G. ROY
Bldg. 151
7^7-2588
South Charleston Plant
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UNION CARBIDE CORPORATION
P. O. BOX 8004, SOUTH CHARLESTON. W VA. 25303
Silicones and Urethane Intermediates South Charleston Plant
To: Mr. D. L. Burger ES Supervisors
Copy to: Mr. J. E. Barron Mr. L. D. Diggs Mr. E. 0. Lewis Mr. G. F. Painter Mr. T. G. Swanson Mr. A. E. Thompson Mr. C. L. Thompson
>5 ' Mr. W. C. Young ES Routing Lists 2
&5
From:
J. G. Roy
Date:
April 4, 1985
Subject: Entry Into No. 1Steam Plant During Asbestos Removal Project
A locker stocked with paper coveralls, disposable 3M resiprators and cotton gloves has been placed in Building 40. There are two keys to this locker, one with D. L. Burger and the other with the E.S. Shift Supervisor.
The above mentioned equipment is minimum approved protection gear for entry into asbestos work areas and must be worn any time the work zone is penetrated whether or not the work is in progress. The harmful asbestos fibers remain in the air long after ttje activities cease!
A trash can has been provided along side of the locker to dispose of used masks, coveralls, and gloves. Please make sure the lid stays on.
JGR:kb
UCC 011559
AFFILIATED ENVIRONMENTAL SERVICES, INC..
219 Fremont Avenue Sandusky, Ohio 44870 (419) 627-1976
r
TO UNION CARBIDE PERSONNEL:
J. C. Cogar L. T. Brannon B. P. Johnson
T. G. Swanson
J. G. Roy
J. D. Myres
H. L. Wise G. M. Robertson W. C. Young C. E. Fry C. R. Gillespie
FROM:
Jack Dauch - AFFILIATED ENVIRONMENTAL SERVICES, INC.
Gentlemen,
The removal of the asbestos containing insulation will be performed in full compliance with OSHA and EPA regulations. The following is an outline of items to be included to ensure the removal personnel and Union Carbide personnel are provided a safe working environment.
I. The building shall be posted off limits to all personnel not assigned to work in it. This shall be done by Union Carbide placement of "safety ribbon" with written tags plus the contractor shall post warning signs at all entrances.
a. The pump room shall be kept out of the asbestos removal area until the inside of the building from the top level to the basement has been cleared of asbestos. The pump room area will be completed in a single 8-hour shift after discussing the actual date with Union Carbide.
b. The steam reducing area and possible electrical work will require access by Union Carbide personnel. When Union Carbide personnel must enter these areas, the removal contractor shall minimize actual removal operations in the vicinity.
UCC 011560
2
I. (continued)
c. The use of air cleaning systems (HEPA filtration) will be used during the removal. Note: when work in the pump room is performed, one (1) unit (120,000 cfh) shall be set up on this area to reduce the air levels as rapidly as possible.
d. The contractor has set up two (2) 2-room change areas. Entrance shall be into the clean change area. Street clothing is removed at this point and disposable coveralls, gloves and boots are put on as well as a respirator. The contractor checks his respirator (both positive and negative pressure checks). Upon entry into the dirty side change room, the zone side shoes and boots are put on. When leaving the work area, the contractor removes all clothing in the dirty change area. Then, still wearing the respirator, proceeds to the shower. After showering, the employee re-dresses in street clothing or if on break into new disposable clothing.
e. Air monitoring shall be performed in/on the following
1. Workers - at least 2 persons daily for first five (5) days. Then at least 1 person/day.
2. Clean room - daily.
3. HEPA exhaust units shall be monitored the first two days then weekly.
4. Pump room - daily first week then once/week.
5. Steam reduction area - daily first week then
once/week.
'
Note: #4 & 5 will be terminated when removal in the building is complete.
f. To minimize asbestos contaminated air from the removal operation becoming a hazard, the following is required.
1. Minimize dust by wetting material and by removal technique.
2. Reduce levels of asbestos in air by use of HEPA units.
UCC 011561
3
I f. (continued)
3. Drape plastic curtain over openings in building (broken) windows.
4. Work on top of building requires construction of enclosure (will require combination of frame, plywood and plastic).
5. Protective clothing and respirators in the zone,
g. Action limits for asbestos concentrations in air.
1. The current OSHA 8-hour time weighted average permissible exposure limit is 2-fibers/cc. The type of respirator required is dependent on the air concentration. The use of a 1/2 face respirator is required if levels exceed 2-fibers/cc (if over 20-fibers/cc, the use of full face powered air or air line is required).
2. The action level in the various cages shall be:
a. workers
2.0 fibers/cc
b. clean room
0.1
c. pump room
0.1
d. outside of bldg 0.04
Note: Respirators will be required in the work area no matter how low the level was on previous measurements.
3. Analysis of air samples taken by the contractor during the week of April 1, 1985 shall be analyzed prior to the next day's work.
h. Asbestos waste shall be placed in bags provided by Union Carbide, loaded into containers provided by Union Carbide and disposed of by Union Carbide.
i. Water (including showers) shall be filtered prior to exit from building.
j. Emergency
a. Contractor shall immediately shut down work and come to clean change area if area 1 alarm. In an emergency, personnel will not shower and change clothing, but if time permits, removal of boots and gloves shall be performed.
UCC 011562
UNION CARBIDE
UNION CARBIDE CORPORATION SILICONE AND URETHANE INTERMEDIATES
P.O. BOX 8004 SOUTH CHARLESTON, W. VA. 26303
MATERIALS MANAGEMENT DEPARTMENT
APRIL 3, 1985
TO: PLANT PERSONNEL
FROM:
J. G, COGAR
SUBJECT: INSULATION REMOVAL AT MAINLAND POWERHOUSE
AS OF WEDNESDAY, APRIL 10, IRELAND BROWN WILL BE REPLACING JOE MYRES AS DEMOLITION SAFETY WATCH FOR THE REMOVAL OF INSULATION AT THE MAINLAND POWERHOUSE FACILITIES BUILDINGS 47, 56 & 78.
MAILING LISTS: A-l, A-2, A-3, M-l, M-2 UCC 011563
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