Document 99ONmoZ0BYqxr4dk77VEkM286

October 1997 ALCOA ASBESTOS MANAGEMENT REQUIREMENTS Halethorpe Extrusions, Inc. (HEI) will follow the Alcoa Asbestos Management Procedure and Alcoa Engineering Standard 18.18 (Asbestos Removal Standard). IDENTIFICATION OF ASBESTOS Asbestos containing materials have been used throughout the plant, mainly for insulation of pipes/ductwork and fumaces/ovens, floor tiles, and mastic associated with floor tiles and baseboards. The EHS Manager maintains an inventory of locations that are known to contain asbestos containing materials (ACM). Copies are the current asbestos survey conducted by Dames & Moore are included in the HEI Environmental Manual. Copies of this manual have been distributed to the Location Manager, EHS Manager, Process Manager, Product Manager,^Maintenance Manager, Manager of Business Analysis, and the environmental consultant: i: Galbestos is suspected to be in present in some roofing and siding materials. A survey of possible galbestos materials will be developed by the end of 1997. COMMUNICATION OF THE PRESENCE OF ASBESTOS All employees receive hazard communication training in each department on an annual basis. This program identifies how an individual can obtain information of any chemical at HEI and who to contact for concerns. Asbestos will discussed in these meetings and may be a topic for individual plant safety meetings. INSPECTION PROGRAM Quarterly inspections of ACM at HEI will be conducted to evaluate the condition of areas of the plant with ACM. These inspections will be conducted by the EHS Manager, the Process Manager, and/or the environmental consultant. These inspection findings will initiate actions for remediating damaged or friable ACM. Every 3 years an asbestos survey will be developed with cooperation from the landlord. The next survey is due to be conducted by year-end 1999. Revised: October 1997 by J.K. Mackay HQ 000066 HALETHORPE EXTRUSIONS, INC. ASBESTOS MANAGEMENT PROGRAM October 1997 page 3 PROCUREMENT REQUIREMENTS No asbestos containing materials are to be purchased for HEI. All records must be maintained for a minimum of 30 years. EMERGENCY PLANS In the event of a spill or release of ACM into the environment, HEI emergency notification procedures in the RPCC Plan and the HEI Environmental Manual will be followed. Revised: October 1997 by J.K. Mackay HQ 000068