Document 7MD5nNZDn8V0DNYww20bM1pmo

UNION CARBIDE CORPORATION INDUSTRIAL HYGIENE PLAINTIFF'S EXHIBIT UC-1067 = 3SCX 47' TJXiS:;'' T:Xi37755C January 18, 1985 Dr. E. R. Ibert, Ph. D. Director, Environmental Galveston County Health P. 0. Box 939 La Marque, TX 77568 Control Dept. Subject: Response to Notices of Violation Dated January 9, 1985, Demolition of #2 Powerhouse and Butadiene Unit by Kimmins Corp. Contractors Dear Dr. Ibert: This letter is in response to the two separate Notices of Violation dated January 9, 1985. We have taken the following steps to assure that the NESHAP asbestos work practice requirements are complied with. 1. The contractor has been reinstructed to clean the area of asbestos insulation as soon as possible, and to continue to keep exposed asbestos wet at all times. Periodic inspections have been and will continue to be conducted by a UCC team in the demolition areas to assure that the contractor complies with NEPHAP asbestos work practice requirements. 2. The insulation observed to be in the scrap iron container has been removed and bagged for proper disposal. It is believed that the insulation was in the container when it arrived on site from the subcontractor. The contractor has been advised that such containers should not be used on site unless they are free of asbestos-containing material. 3. The insulation observed at the base of a removed column has been properly bagged for disposal. 4. Mr. Mark DeWitt of Kimmins Corp. has advised us that the scheduled date of completion for the demolition has been changed, and that he has communicated the change to your office. We note that 40 CFR 61.146 does not require that changes to scheduled completion date of demolition or renovation be submitted to the agency. UCTC10719 Dr. E. R. Ibert January 18, 1985 Page 2 We appreciate the opportunity to discuss asbestos related compliance matters with you last week. Please let me know if you have any questions or require further clarification. Yours very truly, APY:IR:NOV10985 A. Perihan Yalcciinnkkaya Industrial Hygiene Director UCTC10720 Bcc: Mark DeWitt - Kimmins c. L. Dudnick s. J. Footer w. P. Haskins J. B. Leverton F. S. Provenzano J. F. Erdmann J. L. Glass Corp. UCTC10121