Document 5Lj5k2zGd34w4mQ84YY8ga5e0

SC-100^ if?ev. WO) SHELL CHEMICAL COMPANY to DEER PARK MANUFACTURING COMPLEX SUPERINTENDENT-CHEMICAL DEER PARK MANUFACTURING COMPLEX ENGINEERING - SUPERINTENDENT DEER PARK MANUFACTURING COMPLEX PURCHASING - MANAGER date FEBRUARY /5, 1975' from STAFF ENGINEER - ENVIRON MENTAL CONSERVATION-REGULATIONS DEER PARK MANUFACTURING COMPLEX subject HANDLING OF ASBESTOS-COVERED PIPE AND STRUCTURAL STEEL DURING DEMOLITION RELATIVE TO EPA AND OSHA REGULATIONS Asbestos is classified as a hazardous material and is subject to both OSHA and EPA regulations. Removal, handling, and disposal of asbestoscovered pipe and structural steel during demolition is of specific concern in the field work for BA expansion scheduled to begin mid-February. The applica ble regulations are OSHA - "CFR 29 Part 1910.93a, Asbestos subparagraph (h)(2) Waste disposal" and EPA - "CFR 40 Part 61.22 Emission standard, subparagraph (d) Demolition". The EPA regulation requires notice to the EPA ten days before starting of demolition of the procedures to be employed; wetting of asbestos material opened to the environment and careful handling are generally specified. "Fria ble asbestos debris shall be wetted adequately to insure that such debris remain wet during all stages of demolition and related handling operations." The OSHA regulation calls for "asbestos debris which may produce in any reasonable foreseeable use, handling, or transportation airborne concentra tions of asbestos fibers in excess of the standard shall be collected and dis posed of in sealed impermeable bags or other impermeable containers". At issue is the establishment of a precedent of (1) removing all asbestos wet in the field and bagging for disposal in an approved landfill or (2) wetting the asbestos as necessary to safely remove the pipe sections and handle the asbestos with weather cover in our scrap yard with the scrap dealer picking up such covered pipe and assuming liability for further proper handling. The first choice was followed in some work at Marietta. We are cur rently following the second choice in our present maintenance/construction. If we elect to continue the present practice, some additional steps need be taken to prevent friable asbestos from emitting fibers. Further, we must assure ourselves that the scrap dealer will assume proper asbestos control of material picked up. I recommend we follow the present practice, Choice 2, with the following additional safeguards provided by Purchasing: 1. All exposed asbestos covering to be spray coated with some sort of sticky mastic. 2. A letter be obtained from our scrap dealer indicating his knowledge of the appropriate rules and intent to follow same. DPMC-02674 LAM 005058 Deer Park Manufacturing Complex Superintendent-Chemical DPMC-02675 LAM 005059 0 /*X /V * nC LAM 005057 DPMC 02673.1