Document 9337g0ergevMK9RyN9z80KQ3e

$/ *,l ?/-? ?, / Shell Oil Company Shell Chemical Company A Division ol Shed 0*J Company July 5, 1983 Deer Park Manufacturing Complex P.O. Box 100 Deer Park, Texas 77536 PLAINTIFF'S EXHIBIT CERTIFIED MAIL - RETURN RECEIPT REQUESTED SH-1721 Texas Air Control Board ATTN Mr. Cecil Bradford 6330 Highway 290 East Austin, Texas 78723 Gentlemen: ASBESTOS INSULATION REMOVAL This letter is to give notice of our intent to remove asbestos materials over the next one-year period as required by 40 CFR Part 61.22(d)(3)(i)(A). This estimate covers small jobs as well as planned maintenance projects and unit demolition projects that may involve asbestos materials. If any other major job of demolition or renovation arises that is covered by Part 61.22(d), we will notify you in a letter specifically describing that job. The following information is for your consideration: (1) Name of Owner or Operator Shell Oil Company, Deer Park Manufacturing Complex (2) Address of Owner or Operator One Shell Plaza, Houston, Texas 77002 LAM 017865 (3) Description of Facility Involving Asbestos Shell Refinery and Chemical Plant will remove about 460,000 square feet of asbestos insulation and transite siding associated with maintenance shutdowns of certain production units. These units include the Aromatics Concentration Unit, Platformer No. 2, the Alkylation Unit, the Orthoxylene Unit, the Cat Feed Hydrotreater, the Catalytic Reforming Unit, and the Saturates Gas Plant. Several units will be dismantled entirely or in part during the next one-year period. These units include: the Ethyl Alcohol Plant, Platformer No. 1, the Paraxylene Unit, and Power Plant No. 1. Additional small quantities of asbestos insulation will be removed from the Resins Plant, the Olefins Plant, and the Light Oil Fractionation Unit. DPMC-11558 Texas Air Control Board 2 (5) Scheduled Starting and Completion Dates July 10, 1983, through July 9, 1984. (6) Procedures to Be Followed (a) Shell personnel (or contractors under Shell super vision) will remove insulated piping as units or in sections in accordance' with paragraph (d) (4) (iii) of the regulations. Asbestos materials exposed during cutting or disjointing or exposed to permit lowering of equipment to grade shall be wetted. Units, sections, or other parts will be lowered carefully to ground level to avoid air dispersion of asbestos fibers. (b) Shell will strip the asbestos insulation materials from removed piping by removing the weatherproof cover, immediately wetting the exposed asbestos material, and promptly removing the wetted asbestos material into heavy-weight plastic bags. Filled bags shall be tied tightly at the top, proper "Asbestos" warning labels affixed in accordance with regula tions, and transported to an approved disposal site in a covered roll-off bin. (c) When sufficient asbestos-filled bags are accumulated, they will be transported by truck to Chemical Waste Management, Inc. at Port Arthur, Texas, for final disposal. (d) Shell will wet down transite sheets and cover with heavy-duty plastic for transport to disposal. If you have any questions, please contact M. S. Waugh at (713) 476-7515. Very truly yours, Orig. Signed by W. H. Thompson W. H. Thompson, Manager be: Mr. T. R. Williams, Manager Environmental ConservationOperations - Head Office LAM 017866 DPMC-11559 Texas Air Control Board bbc: R. R. Erickson J. G. Massey P. J. Snyder R. H. Slaughter J. T. Woods ECB Satellite (2) Env. Con. Chron (2) MSW:oc 3 LfcNlO''7867 DPMC-11560