Document 91mDrLZa57z4oqVj9VK9z42qV

t1 I' UNION CARBIDE CORPORATION Chemicals and Plastics To: Mr. S. E. Nicolson cc: Mr. V. F. Ark Dr. E. F. Cox Mr. R. A. DeCoudres Mr. P. W. Duces Mr. J. L. Goodson Mr. A. R. Grover Mr. E. W. Rrurrmel - NY Mr. L. Madestau Mr. C. F. Martino Dr. 1. Kolked Mr. A. J. Pin Mr. P. B. Potter - NY Mr. R. A. Ream Mr. F. A. Schlllinger Mr. J. M. Swe Lm Mr. J. P. Zuccarelli Date: Bound Brook, New Jersey November 22, 1972 Subject: Asbestos Filler Used In Phenolic Molding Compounds Mas:srs,. A'Ibright, Made: to develop strategies and programs for the future regarding the use of asbestos in phenolic molding compounds. F.c-cent activities by General Electric in the marketplace have directly and indirectly affected our ability to proceed In o timely manner with our hulk handling project. Their activities in the field might alto influence our posture as to whether or not we vent to continue using asbestos, depending on the success of their nex-J (as yet unavailable) replacement compounds. General problems were identified at this meeting with an understanding of the affect they might have on our short term and long term asbestos position. It appears that by the end of January of 1973 certain critical information will be developed which will allow us to formulate recommendations for strategy and pro grams to the Operations Team shortly thereafter. Esck-rrcuad Until recently our ''plan" for asbestos has consisted of the following elements: 1. Implement In 1973 a system to bulk handle Carey asbestos in specially codified trailer trucks to compounding unit B. 2. Only use asbestos in heat resistant products 2035, 5303 and 5418 and their crossover numbers. a. Remove asbestos from all low concentration formulas. b. Discontinue the concept of a commodity heat resistant compound (6935). 3. Possibly install a closed extruder for fluxing of powders on Unit B before July 1, 1976 (date of lowered OSEA limits). The above plan implied continued use of Carey asbestos in heat resistant products. aJ53SC S }}r. R. E. Nlcolson 2 - November 22, 1972 Asbestos Filler Used In Phenolic Molding Compounds Recently, also. General Electric has announced that they are discontinuing the manufacture of, and the molding of, all asbestos containing products at the end of 1972. Substitute products are to be made available. This causes two general problems for OCC: Firstly, if GE is ''successful'1 in the marketplace, this action could force us to also develop replacement products. Secondly, this action has rosdblocked our ability to move quickly on our bulk handling project. Verbal understandings with Carey company were based on their assumption th3t they would also cooticue to supply General Electric with large quantities of asbestos which would give them an acceptable return on their total new investments. T*e were previously not aware of this. Carey will not ceroit to their participation in our planned bull; handling project. neace, we have an immediate need to redefine our posture, programs end timing relative to the use of asbestos. The following problems and alternatives have bean recognized. Tntsvn.nl Problems 1. A plant cost reduction of $54M per year we3 planned starting 1974 based on Che bull; handling project. Timing cay have to be changed or substitute cost reduction projects may have to be developed. 2. Current CSHA regulations are being met but our third floor handling system is not foolproof. Operator/asbestos interaction allows for the possibility of exceeding limits. Continuing operating costs and small investments are in curred in meeting all of the various parts of the OSKA regulation. Froduct 5413 which is planned for transfer from S-l to Unit B cay cause us to exceed limits. D'.is product might have to be eliminated. 3. 0RA regulations become more stringent on July 1, 1976. At that time we will definitely exceed limits on the third floor handling area and nay exceed limits oq the charge roll. Seme think the 1976 limits could be advanced to an earlier V- <3 te. 4. Asbestos is harmful and the public is aware of it. Even meeting the letter of the law can result in residual emotional problems on the pert of the wage people. These problems can become real problems, e.g. our agreement to supply disposable coveralls (at a co3t to us) even though by law we don't have to do it. External Problems 1. Do our customers come under the OSHA regulations? Do compounds contain free fibres of asbestos greater than 5 microns in length? Must we apply warning labels to containers of finished product? If so, the nature of our customers is such that they cay not want to both with the compliance program. This could force us to find substitutes. 1r- ^ " Mr. R. E. Nioolson - 3- Koveaber 22, 1972 Asbestos Filler Used la Pheaollc Molding Compounds 2. The approval procedure for substitute products is a lengthy one for many applications. 3. Will competitive pressure, i.e. General Electric, create a thrust auay from asbestos even if molders comply to the letter of the law? 4. We have made partial short term committments to some customers to con** tinue supplying asbestos filled products. Soma Alternatives 1. Find a substitute for asbestos. 2. Discontinue manufacture of all products containing asbestos (602 of current product mix). 3. Manufacture products which contain asbestos but which do not generate free fibres at our customer's shops. 4. Confine asbestos compounds to selected mar'u.et3 and customers. 5. Develop a wet handling process to solve Our internal prebl^s. 6. Develop a closed fluxing and compounding system. 7. Implement a bulk handling project with Carey at a substantially higher cost to us. 8. Develop more economical transportation technology relative to Carey asbestos. 9. Convert formulas and implement a bulk handling system to use UCC pelleted asbestos. In order to continue to make progress, the following actions are planned to be completed by January 31. 1. C. F. Martino will define the iupact of 0S3A regulations on our customers. 2. P.3.Potter will define the significance of any other external activities that will relate to our position. 3. C. F. Martino will define magnitude and timing of a formulation progrem to convert to UCC asbestos. 4. D. R. Albright and I. Moked will review the development of asbestos trans portation technology and define any new alternatives. 5. D. R. Albright will define economics and timing of a project relative to bulk handling of UCC asbestos. D. R. Albright -V