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INTERNAL CORRESPONDENCE
UNION CARBIDE CORPORATION o box e/c BOUND BHOOK. NEW JERSEY OBB05
SPECIALTY CHEMICALS OVISlON
T0|Name|
D-Vison
loco^oo
Area
Mr. W. Bosserman
--1 --
Sistersville
Mr. W. H. Barton* *Letter only
Origriatinp Dept.
March 30. 19^3 SHARE
Asbestos Procedure
Per your recent request, I am enclosing the Bound Brook Procedure for Asbestos with background information giving salient points of our program in response to the OSHA citation of May 6, 1982.
Also included are personal monitoring data on typical asbestos removal jobs with references to figures in the addendum of the procedure. With this background data, we prescribe disposable dust respirators (3M No. 8710 or Norton No. R1070) as sufficient protection for up to five times the TLV.
/rk att.
P. A. Schultz
UCC 016214
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UCC 016215
REPORT DKC1
KCNITG RING ORTA - BOLKD BROOK P LA N T, 198C TH R l 1582
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UCC 016218
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REPORT ONC1
-FCNITCRING DATA /BOUND EROOK PLANT 1 9 8C THRL 1982
FACE
MAINTENANCE
PROCEDURE
By:
J. Nadbielny w. D. Neal
PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT
No:
MP- 366.1
Page: i
of 5
Effective: 1-26-79
Revised:
5/25 /82
Approved:
1.0 PURPOSE
ASBESTOS REMOVAL PROCEDURE
To protect workers and others from Inhalation of asbestos fibers, to safely remove and dispose of insulation materials which contain friable (easily crumbled or crushed into powder) asbestos and also to specify appropriate notification to regulatory agencies.
2.0 RESPONSIBILITY
It is the responsibility of the appropriate First Line Supervisors and Craftperson to control the safe removal, disposal and notification activities.
2.1 It is the responsibility of Environmental Protection/Occupational Health (EP/OH) to notify EPA of yearly amount of asbestos activity
r in the plant, per R. Burstein's letter (attached).
2.2 Where unanticipated asbestos removal work is to be conducted (i.e. notification was not given at beginning of calendar year or end of previous calendar year), the responsible person must notify the EP Department (R. Burstein) 45 days prior to demolition. (Notification requirement is for demolition work-not required
\H for repair work.)
2.3
The responsible Supervisor shall provide the following information regarding the proposed work to the Environmental Engineer and/or the Industrial Hygienist:
1. Specific location of the job site.
2. Date and time interval-of the work.
3. Initiate a Hazardous Work Permit
2.4 The responsible supervisor shall ensure that employees assigned to the work have medical clearance and respirator training.
3.0 PROCEDURES
3.1
Overlap of EPA and OSHA regulations - the regulations do overlap some, as the OSHA objective is protection of workers and others directly involved. The EPA objective is protection of people everywhere. These procedures consider all regulations for each
agency; EPA and OSHA. L
UCC 016220
-
MAINTENANCE . PROCEDURE
By: S. J. Nadbielny
W. D. Neal
WM
PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT
No:
MP- 366.1
Page: 2 of 5
Effective:
Revised r
Approved:
1-26-79 5-25-82
ASBESTOS REMOVAL PROCEDURE
3.2 Personnel engaged In asbestos work.
Personnel engaged in asbestos work shall wear respirators and protective clothing according to the hazard rating of the job as follows:
Hazard Rating
Fibers ^ Protective
Per cc
Clothing
Respirator
1
< 10
Coveralls
Optional
Air Purifying (3M Disposable)
2 > 10
Air Purifying (3M Disposable)
3
>20
Whole Body
Powered Air Purifying
Coverings: .
or
1 f. Coveralls Head Covering
Type C Supplied Air, Continuous Flow or
Foot Covering Pressure-Demand
Gloves
4 or Unknown Rating
>200
Type C Supplied Air Continuous' Flow or Pressure-Demand
To determine the hazard rating, compare the proposed job with typical jobs already monitored (See Addendum I). If the job is not similar to one listed, it must be treated as rated 4 requiring air-supplied respiratory protection.
If the proposed job cannot be identified with a correspond ing job with a hazard rating, it shall be considered to have a rating of 4 until properly monitored for an initial de termination of fiber level. While this determination is being made, it is mandatory that whole.body covering in cluding coveralls, head, foot, and hand covering and supplied breathing air be used.
3.2.3 The SHARE representative shall enter the hazard rating on the Hazardous Work Permit to release the job if the work does not have an established hazard rating. Successive Hazardous Work Permits shall be submitted to the SHARE representative or Emergency Coordinator for entry of hazard ratings in the event that the continuation of the job may
result in a change of hazard ratings.
UCC 016221
MAINTENANCE PROCEDURE
By: S. J. Nadbielny H. D. Neal
PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT
ASBESTOS REMOVAL PROCEDURE
No:
MP- 366.1
Page: 3
Of S
Effective:
Revised:
Approved:
1/26/79 5/25/82
3.2.4- No outerwear shall be worn over disposable protective
clothing.
'-
3.2.5 Personsshall desuit for breaks and lunch within the protectee work area except for jobs with Hazard Rating of 1.
3.2.6 Dispose of contaminated protective clothing in sealed, mark ed plastic bags, at the end of the workday.
3.2.7 Personnel engaged in asbestos work shall make every effort to minimize air borne particles.
3.3 Work Area Identification
3.3.1 Perimeter of hazardous area shall be identified with yellow barricade tape.
3.3.2 Warning signs (3.7.1) shall be posted at 50 feet intervals along barricade- tape.
3.4 Removal of Insulation
3.4.1 Removal prior to demolition is required if excessive dusting is expected.
3.4.2
Insulation shall be wet down with "amended water" (1 oz. Tergitol Min-foam 2-X) per 5 gal. water,' prior to removal and kept wet during removal, including that on equipment to be dismantled in sections exposing the broken edges of insulation.
3.4.3 Loose insulation stripped from equipment, pipe, etc. shall not be dropped or thrown to the ground.
3.4.4 Drop cloths are required on grating to catch falling debris.
3.4.5
Loose insulation shall be placed in plastic bags, sealed, tagged and placed in sealed fiber drums (so they won't break in loading) (3.7.2) prior to disposal.
3.4.6
Area cleanup shall be by wet or vacuum method -- never use air, brooms or brushes. Waste shall be put in plastic bags, sealed and warning tags (or printing on bag) (3-7.2) applied.
UCC 016222
MAINTENANCE PROCEDURE
By: s. J. Nadbielny
W. D. Neal
PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT
No:
MP- 366.1
Page: 4
of 5
Effective:
Revised:
Approved:
1-26-79 5-23-82
ASBESTOS REMOVAL PROCEDURE
3.5 Disposal
. 3.5.1 Disposal is by U.C.C. EP Department.-
3.5.2 Small amounts of insulation removed from repair work should
be put in plastic bags and deposited in fiber drums.
3.5.3 The responsible person will notify EP Department (R. Burstein) of the number of drums (after completion of work).
3.6 Notify EP Department of annual amounts of insulation to be removed (by UCC EP Department).
3.7 Warning Communications - sign, tags and bags.
3.7.1
Signs for posting work areas and'disposal sites are
available from stores. They comply with OSHA copy,
letter size, sign color, size, etc.
Code if 69 -- 251--005.
a.
TV Asbestos Dust Hazard
Avoid Breathing Dust
Wear Assigned Protective Equipment
Do Not Remain In Area Unless Your Work Requires It Breathing Asbestos Dust Maybe Hazardous To Your Health
3.7.2
Tags and Bags and Drums for insulation waste and contamination clothing are available in stores. They also.comply with OSHA regulations regarding copy, letter size, size of tag, color, etc. Tags are available in stores.
CAUTION Contains Asbestos Fibers
Avoid Creating Dust Breathing Asbestos Dust May
Cause Serious Bodily Harm
3.8 The asbestos containing materials on this site are at the following locations.
3.8.1 Older elbows and fittings applied before 1973 very likely were coated with asbestos cement mixtures.
UCC 016223
MAINTENANCE PROCEDURE
By ; S. J. Nadbielny
W. D. Neal
PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT
No:
MP-' 366.1
Page: 5 Of 5
Effective: 1-26-79
Revised:
5-25-82
Approved:
ASBESTOS-REMOVAL PROCEDURE
3.8.2
"Pipelines containing hot liquids and vapors such as steam, hot water, Dowtherm, heating oil, etc. installed prior to 1973."
3.8.3 "When in doubt, treat insulation of unknown composition as asbestos until proved otherwise."
3.8.4 If identification of insulation is required contact EP/OH Department (D. Neal).
UCC 016224
ADDENDUM I
TYPICAL INSULATION REMOVAL JOBS WITH HAZARD RATING OF 1
30 9SI ST*TA
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UCC 016225
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3 JF7: ll" INJULAT1S6/
HIGHLIGHTS OF ASBESTOS PROGRAM
- . OSHA 1910.1001 CANNOT BE PRACTICALLY ADMINISTERED DUE TO FULL SUIT UP AND SELF-CONTAINED BREATHING REQUIREMENT ON ALL JOBS.
ESTABLISHED COMPROMISE PROGRAM BASED UPON DEPARTMENT OF LABOR COMPLIANCE SECTION INTERPRETATIONS OF REGULATION 1910.1001 ALLOWING THAT EXACT COMPLIANCE TO 1910.1001 WOULD RESULT IN A
DE MINIMUS TECHNICAL VIOLATION PROVIDED THAT ELEMENTS OF THE "INTERPRETATION" ARE FOLLOWED.
DEVELOPED TYPICAL JOB CATEGORIES AND GENERATED DATA SHOWING
FIBER COUNT FOR EACH CATEGORY--ALL OF WHICH ARE AT LEAST 15%
LESS THAN TWA STANDARD.
ESTABLISHED ONGOING PROGRAM TO EXPAND DATA BASE FOR EACH CATEGORY.
REVISED ASBESTOS REMOVAL PROCEDURE TO COMPLY WITH OSHA STANDARDS BY MEANS OF JOB CATEGORY CONCEPT.
STRENGTHENED COMPLIANCE TO PLANT'S RESPIRATOR PROGRAMS IN LINE ORGANIATION/ I.E., MEDICAL QUALIFICATIONS/ FIT TESTING/ FACIAL HAIR POLICY.
KEYS TO COMPLIANCE ARE: . USE OF "AMENDED WATER". . PROPER HANDLING TECHNIQUES BY PERSONNEL. . THROUGH TRAINING OF INVOLVED PERSONNEL.
pas/rk 6/3/82
UCC 016226
POINTS TO RFMFMRFR
1. OPERATING DEPARTMENT IS RESPONSIBLE TO IDENTIFY ALL JOBS THAT COULD INVOLVE ASBESTOS REMOVAL.
2. ALL JOBS THAT COULD INVOLVE ASBESTOS REMOVAL REQUIRE A HAZARDOUS WORK PERMIT. ON SHIFTS, ASBESTOS REMOVAL WILL BE CONSIDERED "CLASS B" WORK.
3. WETTING OF INSULATION, PRIOR TO REMOVAL, WITH "AMENDED WATER" IS REQUIRED.. 1 OZ. TERGITOL PER 5-GAL. WATER
4. ASBESTOS REMOVAL SIGNS ARE TO BE POSTED AT THE JOB PERIMETER AND ARE AVAILABLE IN STORES. CODE 69-251-005.
5. ALL RESPIRATOR USERS MUST BE MEDICALLY QUALIFIED.
6. ALL EMPLOYEES TRAINED IN THE ASBESTOS REMOVAL PROCEDURE SHALL BE RECORDED ON STAIRS.
ejb/rk 5/25/82
UCC 016227
IAIUS_QF.-ASBESTQS MONITORING PROGRAM OSHA 1910,1001 TLV'S 8 TWA = 2 FIBERS/CC
15 MIN, CEILING = 10 FIBERS/CC
5 INSULATION REMOVAL JOBS MONITORED MAY 11-19. 4 HAD LEVELS UNDER 0.5 F/CC 1 EXCEEDED TLV WITH 5 F/CC DUE TO INADEQUATE WETTING.
WET DOWN IS THE KEY WITH NEED FOR IMPROVED TECHNIQUES.
TEST PROGRAM CONTINUING BUT END IS IN SIGHT
ASBESTOS REMOVAL PROCEDURE RE-REVISED FOR CRITIQUE.
DRUM OF TERGITAL MIN-FOAM 2x IS ON TAP IN BUILDING 21 SHOP.
HANDY-DANDY TEST KITS RECEIVED.
WORKING UP REFERENCE MANUAL FOR ASSIGNMENT OF HAZARD RATING.
wdn/rk
5/20/82
UCC 016228
ADDENDUM I TO HP-366.1: ASBESTOS REMOVAL PROCEDURE
REFERRING TO MAINTENANCE PROCEDURE 366.1 "ASBESTOS REMOVAL PROCEDURE", SECTION 3.2 REQUIRES THE SPECIFYING OF PROTECTIVE CLOTHING AND RESPIRATORS ACCORDING TO "HAZARD RATING" BEFORE STARTING THE JOB.
COMPARE THE PROPOSED JOB WITH TYPICAL JOBS ALREADY MONITORED (SEE ATTACHED SHEET) AND FOUND TO HAVE A HAZARD RATING OF 1, THEREBY PERMITTING AIR-PURIFYING-TYPE RESPIRATORS RATHER THAN FORCED AIR. IF A SIMILAR JOB CAN BE FOUND, ASSIGN THE HAZARDOUS RATING GIVEN THE TESTED JOB, IF THE JOB IS NOT SIMILAR TO ONE LISTED, IT MUST BE TREATED AS RATED 4 REQUIRING AIR-SUPPLIED RESPIRATORY PROTECTION.
wdn/rk 5/20/82
ATT.
UCC 016229
PROPOSED ASBFSTOS PROGRAM
- u/a modified asbestos removal procedure which meets osha regulation
. medtcal requirements
. protective clothing outside
. change room issue for contingency - FORM UNION/MANAGEMENT COMMITTEE TO IMPROVE PROCEDURE
0
, CONSIDER RECOMMENDATIONS FROM COMMITTEE FOR INCORPORATION
INTO LONG TERM PROGRAM.
- FORM SHARE/MAINTENANCE COMMITTEE TO EXECUTE PRACTICAL LONG TERM PROGRAM. pas/ejb/wdn/lem/rw/? . IDENTIFY TYPICAL ASBESTOS REMOVAL JOB CATEGORIES FOR PLANT. . DEVELOP BASELINE/ BACKGROUND DATA FOR EACH OF THE ABOVE CATEGORIES. . CATEGORIES FALLING BELOW 20 FIBERS PER CM^ - WILL REQUIRE
3M-8710 DISPOSABLE FACE MASKS.
. CATEGORIES FALLING BETWEEN 20-200 CM^ WILL REQUIRE
POWERED AIR PURIFIER. . CATEGORIES FALLING ABOVE 200 CM^ WILL REQUIRE SCBA DURING
DURATION OF JOB. . ALL OF THE ABOVE FALL INTO MEDICAL SURVEILLANCE PROGRAM.
- ABOVE LONG TERM PROGRAM CARRIES A "de'MIN INI s" RISK PENALTY BUT IS SUPPORTED BY P.O.D. SHARE. . GULF COAST PLANTS PRACTICE ESSENTIALLY THE SAME PROCEDURE. . DU PONT PRACTICES THE SAME APPROACH.
PAS/RK 5/10/82
UCC 016230