Document 7O7ZZLGarx982L1bzg6RwLMZe

DOW CHEMICAL U.S.A. November 19, 1984 TEXAS DIVISION FREEPORT, TEXAS 77S41 A. P. Beutel Bldg. Jim Demland J. T. Hill Ernie Mueller Darrell Worman Gordon Miller Bill Doumas xc: Carl Burleson ASBESTOS Juan Longoria George Kidwell Archie Stice Larry Parrett John Jack NOV 2 i IS84 SLEOD Engineering Group SLEu. Engineering u. _ The requirements for handling asbestos has been discussed at our last two staff meetings. In spite of this, I think there may be some confu sion as to what the requirements are. Please read the following which is from our departmental description of the Clean Air Act. Be sure that your people who may handle asbestos are informed of these requirements and understand them: I. Asbestos In 1984, the EPA published a final rule amending the National Emission Standard for Asbestos. This rule revised the require ments for notification to the Texas Air Control Board prior to demolition or renovation involving asbestos. The revised noti fication requirements are as follows: Demolition: Written notification to the TACB must be post marked 20 days prior to starting any demolition project involving the stripping or removal of friable asbestos. All demolition pro jects must be reported. Planned Renovation: To determine whether notification for planned renovations is required, one must predict the amount of friable asbestos, either as separate projects or coupled with other asso ciated facility renovations, to be removed from a facility during a calendar year. Asbestos removal resulting from small jobs such as repair of leaking valves, leaking pipelines, or other equipment maintenance should be included in the estimate. If the additive amount exceeds 260 linear feet or 160 square feet, the TACB must be notified in writing as early as possible before the start of a project. The TACB has informally requested a minimum of 10 days prior notification. PLAINTIFF'S EXlimn DOW-2490 f=rm4nR5i7 o T o to te n A Jim Demland, et al Page 2 November 19, 1984 Environmental Services will continue to make the required noti fications. It is the responsibility of the block superintendent or his representative to contact Environmental Services so the proper notification can be made. Insulators are not responsible for the notification. Refer to Safety Standard No. 45 for asbestos handling requirements. When we do projects involving asbestos, we should expect an on-site inspection by the Texas Air Control Board, either during or after comple tion of the job. They will be checking to see if we are following all the proper asbestos handling procedures as described in Safety Standard 45 and in the booklet "Handbook for Handling Asbestos Material". attachment - definitions STndnp^i7A 91580*101.8 DEFINITIONS Friable Asbestos - Any material containing more than one precent asbestos by weight that hand pressure can crumble, pulverize, or reduce to powder when dry. Demolition - The wrecking or taking out of any load-supporting struc tural member of a facility. Renovation - Altering in any way one or more facility components. Planned Renovation - Renovation operation in which the amount of friable asbestos material that will be removed or stripped within a given period of time can be predicted. Individual nonscheduled operations are included if a number of such operations can be predicted (i.e. leaking valves). Facility - Any institutional, commercial, or industrial structure, installation, or building. An individual process or production block can be considered a facility. RES/jlw 8-24-84 ST0408518 H S 80101* TEXAS OPERATIONS ASBLSTOS HANDBOOK, REVISED, APRIL 1985 (Page 11) SECTION IV SAFE WORK PROCEDURE SUBOECT: REMOVAL OF NON-FRIABLE ASBESTOS MATERIALS (TRANSITE, HAVEC PIPING, ETC.) Minimum 5afety Equipment requirements: 1. Hard has must be worn. 2. Sideshield glasses must be worn. 3. Approved dust respirator must be worn during materials removal and also during cleanup. 4. If sawing or drilling Is required as part of the Job then an Asbestos Safety Checklist (page 13) must be filled out prior to the Job. The safe work procedure for sawing and drilling of materials containing asbestos must be followed. 5. All other safety equipment which Is required by Job location must be used. (Read Area Safe Work Permit.) Special Precautions: 1. In some Instances, the use of water to wet the material to prevent airborn emissions may be required. 2. Materials should not be handled In a manner that will create dust. 3. Upon removal, provisions must be made with Environmental Operations for disposal. 4. After remove, a thorough Inspection and cleanup must be made to remove all asbestos material. Examples of areas to be cleaned are pipe/vessels, scaffold boards, piperacks, surrounding area at grade, etc. LRB/drr ASBESTOS HANDBOOK Page 1 of 1 ST0408519