Document 7Rkdd9XDXRQm6mOgVwN2XdvB

From Ljj..Ljj.. RRIPirPrEtYi PITTSBURGH OFFICE LQCAT10N MANAGER ROCKDALE WORKS 047 1991 April 30 RE: ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY - FINAL The attached Alcoa Asbestos Management Policy has been developed as a subset of Alcoa's Environmental Policy. This policy was jointly written by representatives of Environmental, Industrial Hygiene and Safety, Procurement, Real Estate and Legal. Drafts were twice reviewed by operating locations from some of the U.S. and non-U.S. plants. Input from these sources has been incorporated into the attached policy. All of the locations polled agreed that the attached policy should represent a minimum operating standard for the protection of Alcoa employees and the management of risk. Any location could write their own internal management program to exceed the standard set in this policy. The basic philosophy expressed in this policy is that when Alcoa controls a facility, asbestos can be managed via remediation and monitoring, but if a facility is sold, friable asbestos must be removed to minimize Alcoa's long term liability. The policy itself doesn't contain an implementation schedule for the development of the written Asbestos Management Program described in item 3. Each Alcoa location's implementation plan and schedule should be negotiated within their business unit and approved by the appropriate Management Committee Member. This concept is modeled after the written plans for corrective action described in the Environmental Policy. P.R. C.F. J.L. R.E. R.M. W.L. Atkins, Pgh. 19 DiMascio, Pgh 6 Fungaroli, Pgh 13 Yester, Pgh 20 James, Pgh 6 Wells, Pgh. 26 ALCOA ARD 004723 ASBESTOS POLICY MEMO 1991 April 30 Page 2 L\ASBESTl.LLR DISTRIBUTION: Plant Managers - Worldwide IH and Safety contacts - Worldwide Environmental Contacts - Worldwide Procurement Managers - Worldwide P.H. O'Neill, Pgh. 30 G. E. Bergeron, Tennessee D.w. Ray, Pgh. 28 R.C. Rawe, Tennessee C.P. Fletcher, Pgh. 29 R.F. Slagle, Pgh. 29 M. J. Schreier, Arkansas N. F. Stephen, Australia Executive Safety Committee C.F. DiMascio, Pgh. 6 v.R. Scorsone, Pgh. 29 J.L. Diederich, Pgh. 29 R.R. Hoffman, Pgh. 29 A. Belda, Brazil C. F. Fetterolf, Pgh. 30 T.L. Carter, Pgh. 29 H. M. Goern, Pgh. 29 D. R. Whitlow, Pgh. 29 1991 April 30 ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY SCOPE: Proposed-policy will apply to all Alcoa owned or controlled facilities including industrial as well as office buildings. Relevant aspects of the policy also extend to properties leased by Alcoa where Asbestos Management Programs should be required of building owners. Some variations may occur where local regulations or special circumstances dictate. POLICY OBJECTIVES: 1. Uniform and consistent practices are hereby established for the purchase of facilities, equipment and new products and for the divestiture of equipment and facilities including real estate. A. Sponsoring managers shall require that environmental surveys conducted prior to purchase of new facilities involve asbestos surveys and risk assessments. Full compliance with all Alcoa asbestos management policies will apply if properties with asbestos are purchased. B. Procurement agents shall insure that only non-asbestos products are purchased. Every effort will be made to find non-asbestos substitutes for the remaining asbestos containing products used in Alcoa facilities. Deviations from this policy will require written approval of the Location Manager. The Procurement Manager must maintain written records of asbestos products purchased in exception to this policy. C. Procurement agents shall insure that equipment sold by Alcoa must be free of friable asbestos prior to sale unless an exception is made by Pittsburgh Environmental Control. Where an exception is granted, written disclosure of the presence of asbestos must be provided to the purchaser and this record shall be maintained for a period of 30 years. D. Sponsoring managers shall insure that before any sale of real property, an asbestos survey will be conducted. All friable asbestos materials must be removed and disposed of properly. In some cases, non-friable asbestos materials should also be removed if it is suspected that the future use of the property will subject them to damage, thereby releasing asbestos fibers. Exceptions to the removal policy can only be made by Pittsburgh Environmental Control. Buyers must be informed in writing of the presence of any asbestos in buildings which are sold. This record shall be maintained for a period of 30 years. ARD 004725 4 asbestos policy 1991 April 30 Page 2 2. Operations Managers shall require surveys for all Alcoa facilities to determine the presence of Asbestos Containing Materials, "ACM" (greater than 0.1 % of any fibrous asbestos /gjf mineral forms). Surveys must follow the general format recommended in the Alcoa Engineering Standard on Asbestos Surveys and must include the condition of ACM in addition to the location accessibility and an estimate of ACM quantity. 3. Plant managers operating facilities having any ACM shall develop written Asbestos Management Programs which must be approved by a member of Alcoa's management committee or by the Managing Director Alcoa of Australia as is appropriate. The Location Asbestos Management Program is to include: A. Identification of ACM via direct labels or any alternatives to direct labeling which would clearly communicate the presence of ACM to affected employees. Such alternatives could include placards, inventories, diagrams, or marked blueprints. To effectively communicate the presence and location of ACM, some of the alternatives should be associated with training and be made accessible to employees. B. Communication of the presence of asbestos to facility employees and contractors who work in areas where asbestos is present C. A plan for reinspection of ACM on a periodic basis (minimally, every 3 years) with written inspection reports D. Remediation, through removal, repair, enclosure or encapsulation of ACM in a deteriorated condition (Attachment 1) E. Assurance that all asbestos work including removal and disposal is carried out in compliance with all relevant Federal, State and local regulations (ref. Alcoa Engineering Standard 18.18 "Asbestos Removal Standard") F. Directions to ensure that Operation and Maintenance procedures will be defined to prevent employee exposure to asbestos during normal day- to-day operation of facilities where ACM is present. G. Acknowledgement that all U.S. asbestos contracts will be written in Pittsburgh in close cooperation with the various field Procurement Departments and will be retained for a minimum of 30 years accordance with the 1989 Pittsburgh Procurement policy. Sample contracts can be provided to international Alcoa locations for informational purposes. ARD 004726 ASBESTOS POLICY 1991 April 30 Page 3 H. A plan to address any potential emergencies where asbestos may be released in the facility. The SPCC (Spill Prevention Control and Countermeasures Plans) could be revised to include this contingency where appropriate. I. A long range strategic plan that recognizes that at the end of a facilities life, prior to its sale or demolition, all friable asbestos must be removed 4. Alcoa locations will comply with all applicable asbestos laws and regulations and will employ more restrictive internal standards where necessary to conform with the above policy. ARD 004727 Attachment 1 MANAGEMENT OF ASBESTOS CONTAINING MATERIALS IN ALCOA FACILITIES ACM - Asbestos Containing Materials both friable and non-friable materials containing > 0.1% fibrous asbestos mineral forms. Friable - EPA definition - asbestos containing materials which can be crushed with hand pressure. Examples of friable asbestos include sprayed on fireproofing, most asbestos insulation and any other ACM which is deteriorated to the point that it can be crushed with hand pressure. Non-friable - Examples asbestos include transite (asbestos cement products) and vinyl asbestos tile. ARD 004728 PROCUREMENT CONTACTS T. W. Dodson, Arkansas R. Hartmayer, San Diego (Alcoa Electronic Packaging) J. Feder, TRE-Aztech T. C. Spurlock, Vernon R. A. Topp, Fort Meade L. Lauderdale, Tifton - GA W. R. Pottgen, HC Products J. R. Mitchell, Lafayette G. C. Bailey, Richmond A. Atkins, Richmond E. T. Klenske, Jr., Warrick V. Poleshaj, Davenport H. R. Sands, New Orleans (Alcoa Export Supply Division) A. R. Hering, Vidalia F. E. Lux, Massena D. W. Pettit, Badin J. R. Rettinger, Cleveland G. Branco, Stolle T. G. Snyder, ATC D. L. Utley, Lebanon G. E. Babinsack, Halco Mining T. Agostine-Allen, Warrendale L. Blackwell, AFL - Spartanburg W. S. Zuber, Tennessee B. McDevitt, El Paso T. A. Innes, Point Comfort J. R. Fry, Rockdale C. H. Barker, Jr., Paradise Point M. Brooks, Northwest Alloys (Addy) R. Surbeck, Vanexco R. D. Huber, Wenatchee V. L. Hammersmith, Permatech KEY\Procure.key ARD 004729 PLANT ENVIRONMENTAL CONTACTS (Domestic) KEY\Environkey j. A. Shockey, ATC j. Harper, Arkansas C. A. Carter, Badin R. C. King, Cleveland G. O. Pratt, Davenport A. Ness, Ft. Meade D. E. Huddleston, Lafayette K. L. Adams, Lebanon j. A. Lease, Massena D. G. Applegate, Mobile O. E. Wilkinson, Northwest Alloys C. H. Barker, Paradise Point J. C. Mayfield, Point Comfort j. L. Eicher, Richmond j. C. Saxton/C. L. Green, Rockdale H. G. Sakoian, Tennessee W. Housworth, Tifton-GA T. Schmidt, Tifton-Delhi M. B. Dalrymple, Washington Office J. P. Hupy, Knoxville T. L. Fearington, ACI - Santa Ana, CA G. Emanuelson, ACI - Monrovia, CA R. B. Shick, ACI - Springville, UT S. H. Myers, Vancouver J. S. Stratton, Vanexco A. B. Piecka, Vernon B. R. Hopper, Vidalia J. K. Mackay, Warrick J. A. Thompson, Wenatchee J. Jackson, AFL/Nashville D. Heather1, AFL/Spartanburg K. D. Meholic, Alcoa Electronic Pkg. - San Diego, CA R. S. Hospodar, Alcoa Steamship - Pgh. 24 S. L. Anderson, Alcotec Wire Co. - Traverse City, MI C. E. Coker, Dalton Alumina & Chemicals - Rocky Face, GA J. K. Clark, HC Industries - Crawfordsville, IN G. Calvery, HC Industries of MS - Olive Branch, MS G. R. Hartnett, HC Products - Princeville, IL F. Kile, Illinois Water Treatment - Rockford, IL J. K. Steelman, Permatech - Graham, NC D. A. Krich, Pimalco - Chandler, AZ J. E. Francis, Alcoa Separations - Warrendale, PA J. H. Gemmill, Southco Metals Services - Atlanta, GA J. McCarty, TEPCO - El Paso, TX F. F. Viguerie, Alcoa Coastal - Houston R. K. Shuler, Alcoa Coastal - Nashville C. Webster, Ragsdale Machinery - Englewood, CO A. Titscomb, Randolph Machinery - Randolph, NY M. Decker, Randolph Machinery - Randolph, NY P. DeSocio, Autoprod - Clearwater, FL R. H. Gatewood/J. M. Brown, Stolle Corp. - Sidney, OH ARD 004730 PLANT ENVIRONMENTAL CONTACTS (Worldwide) M. B. Vianna, Sao Paulo J. Mauricio de Macedo Santos, Sao Luiz G. A. Morgan, Clarendon - Jamaica W. Luders, Pocos de Caldas J. Kerkhof, Drunen G. Thomas, Swansea G. Slessar, Booragoon J. Lippelgoes, Portland J. Eyles, Pt. Henry R. H. Ramden, Suriname J. R. Archibald, Mexico City J. M. Leach, Barcelona Y. Shibazaki, Tokyo R. Armbruester, Worms H. J. Preub, Worms H. H. Pohland, Ludwigshfen KEY\Environ.key ARD 004731 FROM: KEVIN ROLAN CONSTRICT I ON DIVISION ROCKDALE CONSTRICTION TQo G. C . GRIESBACH --------------- --- 91/05/1G RF: ASBESTOS ABATEMENT PRACTICES MR. GRIESBACH AS PER OUR CONVERSATION ON 13 MAY 1991, THIS LETTER CONFIRMS MY STATEMENT TO YOU ON ABATEMENT CONTRACTOR COMPLIANCE WITH ALL OSHA REGULATIONS AND EPA GUIDELINES PERTAINING TO THE ABATEMENT AND DISPOSAL OF ASBESTOS MATERIAL IN THE SMELTER. I HAVE REVIEWED ALL PROJECT DOCUMENTATION IN MY POSSESION CONCERNING ASBESTOS ABATEMENT PROJECTS DATING BACK TO 1989, AND HAVE FOUND NO INSTANCES OF EXPOSURES WHICH EXCEED THE LIMITATIONS OF THE AGENCIES LISTED ABOVE. THIS INCLUDES CONTRACTOR PERSONNEL EXPOSURES BEYOND THE PROTECTIONLEVEL RATING OF THEIR PERSONAL PROTECTION EQUIPMENT, OR ANY EXPOSURES CONTAINING ASBESTOS MATERIALS TO AREA PERSONNEL AS / ARD 004732