Document 6B0k03mDN34Z9d2RKLynwjQo6

, i^-. in. /^wiTe 7 - r/-L t- E P..L. -d&4e^ P584 359 608 CERTIFIED MAIL RETURN RECEIPT REQUESTED UNION CARBIDE CORPORATION isapo. BOX sistersvicle. west Virginia bqi7o SUJconaa and Urethane Intermediatea SHJCONES PLANT March 15, 1985 Mr. 5. R. Vaaaersug, Director (3ENOO) Enforcement Division U.S. EPA, Region III Sixth and Walnut Streets Philadelphia, PA 19106 RE: Notification of Unscheduled Renovations at Uhlon Carbide's Slstersville, W.V. Facility This la to notify you, as required by the prov:_________ ___ _____ that (Jhlon Carbide Corporation, Old Rldgebury Road, Danbury, Connecticut 06817, ' as owner, expects to engage In unscheduled renovation activities during the remainder of calendar year 1985 which, In the aggregate, are estimated to involve removing 80 linear meters (260 linear feet) or more of friable asbestos on pipes or 15 square meters (160 square feet) or more of friable asbestos used to cover other facility components. Q Because the renovation operations are only predicted to occur at Union Carbide's Slstersville facility during the remainder of 1985, we cannot at this time advise you when each renovation will begin and be completed and exactly how much asbestos will be removed during each renovation. We estimate the total aggregate quantity of asbestos-containing Insulation to be removed during unscheduled renovation activities will be approximately 2000 linear feet from piping and 1200 square feet from other equipment. Removed Insulation will be ,replaced with non-asbestos Insulation. All asbestos containing material will be handled In a wetted state In accordance with Section 61.147. The wetted asbestos material will be placed In impermeable sealed plastic bags, delivered to the disposal area (located at the Slstersville Plant), and buried within 24 hours of delivery In accordance with Sections 61.152 and 61.156. In our opinion, this blanket notification meets the requirements of 40 CFR 61.146 for unscheduled renovation operations. Additional notification will be provided for any single project whlah, by Itself, will involve removing 80 linear meters or more of friable asbestos from pipes or 15 square meters or more of friable asbestos from other facility components. If you have any questions concerning this notification, please call me at (304) 652-3211, Extension 286. ELDzslc V.02B.20 UCC 019837 PAH 13 014 `(jliJ'D -v Adequate Planning Prevents Heat Stress at Asbestos Abatement Site Workers may have to compromise the integrity of the sealed area when fire creates an immediate hazard Editor's note: This is the third in a se ries of articles deeding with basic and often overlooked safety problems faced during asbestos abatement projects. So far, the series has examined hazards as sociated with electricity ladders, scaf folding, and slips and falls. Due to the nature of restrictions and extraordinary measures involved with asbestos re moval, these safety problems become more acute. This article focuses on spe cific problems of fire safety emergency action planning and first-aid problems unique to the asbestos abatement pro ject emoving asbestos, a hazard in it Rself, becomes more dangerous be cause of the way removal must be performed. Areas must be sealed with plastic. Emergency lighting and lighted exit signs are often removed or covered in preparing the work area. In some companies, a crew seals the work area and a separate group removes as bestos. Entrances and exits are re stricted often to one way in and one way out. All of these can lead to prob lems if a fire or other emergency occurs in asbestos projects or at any job site. Sealing off areas and blocking en trances and exits conflict with the Oc cupational Safety and Health Adminis tration, National Fire Prevention Association and local fire code require ments. The contract specifications may state "one means of egress through a properly designed air lock and decontamination system;" how ever, emergency plans should be devel oped to include alternative exits in emergency situations. And, they must be familiar to all employees. CHECK POTENTIAL HAZARDS. Perform a pre-work survey to deter mine potential fire hazards, sources of ignition, hot spots and the location of exits. Coordinate this with the number of workers to be in the area, the square footage and the types and amount of combustible or flammable materials that will remain on site. Removing all contents from a work area prior to removing asbestos mate rial is a good idea regardless of whether it is flammable or not. This re duces the chance of contamination. Some protective clothing used in as bestos removal will burn and melt quickly. It can shrink, adhere to skin and drip while it burns. Heavy black By Michael Lowish, ASP, Safely and smoke is a combustion byproduct. Health Specialist. Environmental, Health, and Safety Division, Georgia Tech Research Institute, Atlanta, Ga. Polyethylene, which is combustible, will start to bum slowly and pick up speed as more heat is generated. It MARCH 1986 gives off heavy smoke as the fire pro gresses, and flames spread slowly and steadily. Sheeting should be kept away from heat sources such as transform ers, steam pipes or boilers that will be heated during removal. (Polyethylene should not be allowed to contact sur faces above 150 F.) In addition, if boil ers are operating in isolated asbestos removal areas, there is a danger of heat 31 UCC 019838 ASSEXTOS stress among workers. lb avoid problems in asbestos con trol areas: Make sure sources of ignition are removed. Be sure that gas and other fuel sources are cut off and that pilot lights in boilers, heaters, hot water tanks and compressors are extin guished. In addition to creating a fire hazard, gas leaks create a positive air pressure with respect to areas outside the sealed enclosure. Locate hot spots. Often equip ment will have to be draped instead of sealed off to prevent overheating (computers, terminal boards, switch panels and transformers are exam ples). Usually, however, this equip ment is turned off during the removal project since personnel required to op erate it do not have access to the area. Allowing such equipment to operate during removal would require special consideration. Cut off supply to steam lines, electric and steam heaters, and radia tors. Do not permit polyethylene to lie against hot surfaces. * Do not allow lighters, matches and cigarettes in the work area. ASBESTOS CONTROL TECHNOLOGY, INC P.O. Boa 183. Maple Shade. NJ 080S2 (In NJ) 609-235-1190 For All Levels of Exposure Asbestos Control Technology. Inc., is North America's leading distributor of respirator systems for asbestos work. We carry half-face negative-pressure respirators and HEPA cartridges by 3M, North. Willson and AO. We also carry the full line of Racal Airstream powered, air-purifying respirators, including the revolutionary new "Powerftow" unit pictured here. The battery-powered, positive-pressure Fowerflow is the first PAPR with a motor so small it is mounted on the face piece for the ultimate in comfort and versatility. ACTI also offers the "ACTI-Air" purifying system for the rented compressor of your low-pressure Type C respirator system. Or, we can provide you with a complete, high-pressure Type C system capable of supporting up to 16 men. This includes a compressor, filter systems, monitors and alarms, air bank, pressuredemand face masks, and all hoses, lines and fittings required for a fully operational system. Call now for further information. Ask about our 18-minute PAPR demonstration video or our 90-minute training video on Type C systems. CALL TODAY! 1-800-221-1911 32 Circle 27 on card. Strictly enforce no smoking, eating and drinking rules inside the work area. When using an oxygen/acetylene torch to cut pipe, post a fire watch with an appropriate fire extinguisher such as pressurized water. Do not use carbon dioxide extinguishers in con fined or enclosed spaces. Dry chemical extinguishers are effective, but the powder is a respiratory irritant. When using a cutting torch, know what is on the other side of the wall and below the floor. Use sheet metal or a treated tarp to catch sparks. Reduce the amount of flammable and combustible materials to a mini mum before hanging plastic inside a space. This includes removing chemi cals, flammable liquids and heat sensi tive materials. Mark exits from the work area and post directional arrows when ex its are not visible from remote work areas. This can be done using tape on the polyethylene walls and barriers. Keep trash and debris--tape, poly bags and lumber--to a minimum. If the work area is large and many workers are present, several Asbestos CORRECTION SPECIALISTS We are experienced asbestoscorrec tion contractors who can success fully survey, label, test and remove contaminated areas professionally and safely according to EPA and OSHA regulations. Competitive pricing anywhere in the country. Compare our "Occurence Insurance and Umbrella" with our competitors. No job too big. too small or too far. Members of National Association of Asbestos Abatement Contractors. Air monitoring, bulk testing and consulting. Let us bid on your next project SuperiorSystems, Inc. St. Louis, MO Lexington, KY LaCrosse. Wl 1-800-942-0066 In 8L Louie cN 9t4>4-002? Circle 2B on card. OCCUPATIONAL HEALTH & SAFETY UCC 019839 . 3\ emergency exits may be needed. Choose exits that are locked from outside but can be opened from the inside. A daily inspection should be conducted to en sure secondary exits are not blocked. Because secondary exits will probably be sealed with tape or plastic, workers should each carry a blade or knife to quickly cut or tear the material in an emergency. Lighting exits and exit routes should be provided. In case of fire, the fire hazard be comes more immediate than the asbes tos hazard, and workers may need to violate the plastic barriers. Workers should be trained in the emergency action plan for the job site. If workers carry blades or knives, they can cut their own exits through the plastic bar riers in a fire emergency. Be alert for flammable vapors-- from solvents like naphtha, toluene or xylol--in industrial areas. This is espe cially critical in industrial vacuuming operations where vacuum motors are not explosion-proof. Compressed air vacuums may be required. A telephone should be available at all times for notifying authorities in an emergency. Post local fire department Mark exits from work areas with duct tape arrows. and rescue squad phone numbers. Ad vise them of the operations in progress. A monitor should be outside at all times who is trained in emergency pro cedures, first aid and treatment of heat stress. EMERGENCY ACTION PLAN. Effec tive Dec. 11, 1980, OSHA revised its fire safety standards. The agency now requires a written emergency action plan and fire prevention plan. The re quirements are detailed in 29 CFR 1910.38. Briefly, the plans should in clude: The manner in which emergencies are announced Emergency escape procedures and routes Procedures for employees who must remain to operate critical plant operations which may take time to shut down Procedures to account for all em ployees after evacuation Rescue and medical duties Names or job titles of people to be contacted for additional information A list of the major workplace fire hazards continued on page 37 MARCH 1986 ..Emergency Procedures:., MedlcaltSelvices^aiidFIrst^Ald TheOccupaLoi^Safetyand Health'Administrationre^uires that all, employees exposed to asbestos be offered a physical exam within 30.days of J . employment and within'30 days before or after termination- The examinlng ^;' ' physician or dime should be aware that employees:will be expbsed,toasbestos.^ and will be required to.wear respirators and work Under hot and advea^ 'r-' t ' cc^tiqi^^f " y.The physicitmls.reamed by.OSHA theWorifittcan waring ; andieatstrokeareseridu3;hazaids.fa^ __ fitterevsteinSfocsped ' tils designed for a specific tgtfcf ^.TM...isbesfo --ittpn dust and mercury; to noclealsjl^ unit is engineered toprcp^eV "`'`^performance onttiejob.Simptf"1311 `grid modular comjxinentry.fwlj Saintehanceand downtirrietC __ 'filter system provides added profeSspffp-?^ for critical components and primary fi>:' , ters. And the disposable bag reducesfiiaz^g ard to the operator during emptying;i%|||!i$5 while making clean up faster, easieL^^?^^ Buy any other critical filter vac and you. ' -may be spending twice as much for; ` second best. Talk to us aboutacom^ plete system tailored to your special t application. For more information, write: .Ifc^Hako Minuteman, 111S. Route 53, ^ySddison, IL 60101. Or call 312/627-6900. Halm Minuteman - J Sianc Lift iwcfws waiat) | AsftonlCFM) Wei Capacity (gaaons) 0>y Capacity (cu ft I Static L>h (tncnes *>ate>t Ar> Flow (C F M l Wei Capacity (gallons) Ory Capacity feu It 1 Hoeprtaf Aabastoa AfbHtM Aabaatoe X-100 Vac. 15 JO ss 15 88 08 88 88 88 95 95 95 95 !?B - to 25 50 12 82t ? 3 7 15 t 87 x-tooo -4 I-IOOO e x-tooo -ts x-tooo x-tooo 30 55 88 88 88 86 88 95 96 t?8 28 128 - - - 2S 50 21 62 1 87 4 36 7 IS X-100 X-1T00 -30 -4 88 128 25 436 218 166 _ 21 MX-1000 MI-1000 Wet/Dry Ory 88 88 t?8 28 10 - 2 07 2 07 X-1700 -8 218 166 _ t 56 MAS. -1 110 115 - 62 1-703 IS 218 166 to 82 MAS. 2 110 115 - 2 07 X-703 -30 218 166 25 436 MAS. 3 no 115 - 62 X-703 -55 218 166 50 7 15 MAS. -4 no ns 10 2 07 Circle 29 on card. UCC 019840 <oKe< Ar&naMkME/l Jj'VSpray Polypi | Based spray-on"<'" I tplaccs hanging- ruie'cleanest; sa tjob.possible fa With ..........-`^During abatement, Spray fClPoly stays securely in place,; igproviding its contamination s .protection without a break:.. ^ tl^oughout the job, through you . 100% humidity and extreme Less worry, less waste. You'd expect a system this SUDerior to *, ------------------Adheresuuu&spw la. ' mSSA^u, . . it 100%humidity. ,__ qugtlOuttne. iMere's 'always0i! I quesuonpfreal? comparable lobs.'SPmmKffi' covers 25,000;sjft.'pef l-structures as thfc^beatulgioJg^ia^Vna that^Whei if'only 2,500 sq. ft. per mapnay.vj %4f^Ther6's no need to t .......... aitedlyvfaUsfSpra^P^^^^^^^^inpsturraoK2(i ^^pv^Om^hgfidiher^beSinae'^k ily totaUy contains any rooin^^Hiuinaiey were before ifwasTW fpnc^^^^Pofyis:upy {CsupfojrJ si I stays up throughout the job`-{fapplied because it traps the : nd provides better protection, dirt and loose contaminants;; . ;v; easier cleanup,^and fasta- : ;;i^during application. It's pujled ir.arpuna.^;^^ & an elastic sheet that .. . envelops and "packages" the' " fes^26''^i*^arour^'; J&wmdcfn^and doors in f&Lone'eoritistubw coating. .- f debris. Because,Spray Poly ad heres to itself without trapping air, the contaminants are wellcontained and won't disperse < And clbm;Up is quideer'. because.tfie fwasleis: compact and easyTp nuths ^ Poly produceS%1 laminated wasteaboutjS third the size ofthe cum]? some bundle created byi and poly. Isotek, with ten years of on' the next wind that blows. Cleaner safer is letter serience in providing supe- Ipipfldecontamination methods, Built-in protection. Spray Poly creates a 'toS^ tally improved preppingywfli^s. 7^^&rwrted Spray Poly to ; ^achieve the most important 'SThe^smne. resistance to cell that is cleaner, safer, ahd.^f | water undercreep also protects much easier to manage: Whictrj r. goals of every abatement . Workers from slips and falls. means less down time, and leSs3 | ; And its resilient surface-' : worry. That's better for your *^j provides safe, secure footing..- - business. And better for you' v i Toii^bness'at work: on the job reliability vrr. spray Poly uses1 water as a ^solvent, so there's no flash point. No fire hazard from vapors. Spray Poly conforms pre ' And it's flame retardant. cisely to the surfaces it pro tects, and sticks like flypaper. ; Contaminants can't get under it. I Neither can water, so there's 'f.less worry aih-nnt?w>/ ater nqrW- Tests have shown that hanging poly can ignite in as little as 7 Seconds when exposed to flame. In the same conditions Spray To get the full story, call or write today: 13152 Chef Menteur Highway Post Oftice Box 29799 UCC 019841 march 1986 Don't risk Disaster! When you have gasses, fumes, vapors, solvents. . . clean those hazardous locations with HILD explosion-proof and dust ignition proof vacuum cleaners for use in Class I, Group D and Class II, Group G hazardous loca tions. The most complete line of explosion-proof cleaning equipment. . five vacuum cleaner models from 10 to 55 gallon tank sizes, plus hoses and attachments for almost every wet and dry clean ing need. Model CX UL Listed Explosion-Proof Floor Macnine scrubs, polishes and buffs all types of floors. Write for a free brochure. Hild Floor Machine Co.. Inc. 5339 W. Lake St. Chicago. III. 60644 Circle 30 on card. UCC 019842 continued on page 36 Mechoncol Asbestos Remooi, Inc THE ASBESTOS SOLUTION IF YOU THINK... being within the law will eliminate your liability, or 2 FIBERS/CC IS A SAFE PEL, or MOST CONTRACTORS ARE KNOWLEDGEABLE OF PROPER ABATEMENT PROCEDURES, OR IT IS ACCEPTABLE TO HAVE A CONTRACTOR PERFORM HIS/HER OWN AIR MONITORING, THEN YOU NEED TO TALK TO US Asbestos contractors ore like other business people, some do good work, others don't. Unfortunately, bod work con contaminate o building with cancer-promoting dust. Don't risk it. Use a firm with a proven track record. MARCOR is committed to providing the expertise, professional staff and equipment to handle any asbestos problem. (800) 547-0128 BALTIMORE (301)628-0942 LOS ANGELES (818)401-0722 SAN FRANCISCO (415)895-5252 WASHINGTON, D.C. (301)937-4858 36 Circle 32 on card. occupational health & safety UCC 019843 ASBESTOS continued from page 33 * Names and job titles of people responsible for mainte nance of fire prevention equipment Names and job titles of people responsible for the con trol of fuel source hazard Establish a system for alerting workers of a fire or an other problem that may require evacuating the work area. A compressed air boat horn provides an effective alarm that can be heard and does not rely on a power source. All persons entering the work area should be familiar Workers should drink plenty of water and take adequate breaks. with the evacuation alarm signal and primary and second ary exits. A simple floor plan drawing of the work area should be posted to familiarize persons entering the work area with the location of exits. Written emergency plans should cover procedures to be used in case of: fire with heavy smoke conditions, power failure, compressor failure with the use of air-supplied respi rators, accidents or employee injuries. Editor's Note: Next month, the final article in this series will discuss miscellaneous hazards encountered during asbestos abatement projects. pthCt* Patented auto matic bag loading washable/reus able filter system Powerful vacuum pump Total portability hepa filtering protection I standard models: 5HP, 7Vi HP, 10 HP The facts add up. From pick-up to pack-up of your wet or dry, hazardous or non-toxics, bulk or powdered materials, the VACULOADER"1 does It better. The affordable vaculoaderm teams supersuction with automatic bag loading, to provide ease of use and safe efficient disposal to make quick work of It all. Call or write for details on the extra productivity/ profitability edge only VACULOADERm provides. it pays to have more pull. M VACTAGONPNEUMATIC SYSTEMS, INC. 16 Hotn.tt.ad Ptac* Bmv*nfl*ld, N.J. 07621 1 -201-364-2893 MARCH 1986 Circle 35 on card. Asbestos Abatement Services, Inc. Your Answer to the Asbestos Problem A Professional Consulting Firm Providing: Inspections Testing Evaluation Alternative Solutions Specifications Project Management Certification The simple solution to a difficult problem 4801 Massachusetts Ave., N.W. Washington, D.C. 20016 (202) 362-2525 Circle 34 on card. 37 UCC 019844