Document 5kzMZJVZ5gj9vXGpQp57jody5

- 72-0 She!! Ci! Company Shell Chemical Company Interoffice Memorandum APRIL 14, 1980 s FROM: R. P. FRUTIGER TO: G. C. ANDERSON SUBJECT: REPAIR OF ASBESTOS INSULATION We have reviewed the subject DPMC-North project with Head Office Operations Safety & Health to determine what criteria should be used in identifying asbestos insulation that needs maintaining from a health standpoint, and whether those areas identified as needing repair as part of our project were consistent with this criteria. The OSHA Standard 1910.1001 (h)(i) requires "All external surfaces in any place of employment shall be maintained free of accumulations of loose asbestos fibers if, with their dispersion, there would be an excessive concentration." In addition, because of the low level (0.1 fibers/ml. of air) at which osna requires medical exams, particular care must be taken in controlling work areas where there is a high level of foot traffic. In reviewing our project, I believe the criteria we used was consistent with the above CSHA requirements. Although the three(3) years projected for completion of the job could be construed by regulatory officials as too long, I believe it's reasonable and something that we could defend. Anacortes initiated a similar project about a year ago following Head Office approval. They have completed about 60% of the work to-date. They are using a contract maintenance crew of about ten(10) with a Shell foreman providing the supervision. Please let me know if you need additional information. cc: North Management Team LAM 014192 i j DPMC-15452 Color Code- For ~TVpe "Reipavr A. VJHITE __Install aluminum oover omsr. asphaltic felt VEV.LOW ^.'KePAIE. WASHED-OUT area in INSULATION COVERED Y^iTH (AS-PWALTIC felt DSIMS C EPA I2.LAN tCEr/nUD -IN FOLLOWED WITH COMPLETE ALUMINUM WRAP. c. Red ______Repair or pepuacs aluminum cover D. Op.aN<se__Replace weatherproof in & valves - on tees ; ells and p. ~RemcvF |u5U LAT1 OfN AND K-EINSOLATe/COVER. Attachment I LAM 014193 DPMC-15453