Document 9JRoqDOOxpXNk28Qr7owXMKqq

UC 149-2: .UNION CARBIDE INTERNAL CORRESPONDENCE OLEFINS DIVISION lOV-Oi^ ?Hdu f^bt 8899 P. 0. BOX 8004, SOUTH CHARLESTON, WEST VIRGINIA 25303 To (Natna) Company Location Copy to Mr. C. J. Swan March 30, 1967 PLANT 514 Originating O.pt. PLANT ENGINEERING Answering /offer dale Mr. M. J. Hughes Sub/ect Mr. R. P. Little - Mr. W. J. Erdman Mr. L. S. VanDeUnder - -4-***=^ Mr. J. C. Canterbury JLB - File - SCUW-113 - Subject Revisions to No. 2 Double Effect Evaporator --- Chlorhydrin Unit -- Building 6 -- Plant 514 -- Job No. 20995 -- Engineering No. 4316 -- Installation of New Bottom Outlet Connection Bolted In Place Utilising Epoxy Adhesion Sealant Dear Mr. Swan: As noted in my letter of March 7, 1967, the fallowing is a supplementary instructions for the appUcation of the epoxy joint sealer. Mr. J. C. Canterbury has just advised me as to the proper addition of the asbestos filler required for the mixing of the joint sealer. In ray letter of March 7, I noted that the amount of asbestos fiUer to be added would have to be determined experimentally. This information follows in complete de tail. Note, the following mixing instructions are by weight and not by volume. The epoxy joint sealer mixing instructions when utilizing asbestos fiUer 1. BakeUte ERL-2774 (Resin Base) -- 100 pprts 2. Sonite No. 41 Hardener -- 19. 5 parts 3. UCC Resin Grade Asbestos No. 144 -- 20 parts Sf M-;- j Note: Mr. Canterbury advises that the addition of the asbestos fiUer should be fairly closely controlled. No less than 20 parts and no more than 25 parts should be added. The steps for mixing should bs as follows: 1. Measure out proper amount of ERL-2774 Resin Base. 2. Add the proper amount of Sonite No. 41 Hardener mixing well the two components. \ \3. Add asbestos filler as'noted above. 3 13%//^ / /; j w UCC 015689 M Mr. C. J. Swan March 30. 1967 ***___________ This mixture will provide a good, well bodied mix and should serve to provide the joint sealer that we wish to utilise. The estimated work* ing time -- pot life -- for this mixture is approximately one to two hours. y jt The other additional application instructions are as outlined ^ in my* letter of March 7. should you wish any further information, please i feel free to call on me or Mr. Canterbury. Very truly yours, > J.C L. Barker Plant Engineering Department i'V': JL*B:gd \ \ UCC 015690 "4 * UC 1492 UNION INTERNAL CORRESPONDENCE CARBIDE UNION CARBIDE CARIBE INC. materials Ei\GlVERiNQ AL FILE U)V- 00* ^fIAS -q { "* .! PONCE, PUERTO RICO June 17, 1977 TO: CC: Mr. E. Baez Mr. L. N. Garcia Mr. 0. Guntz Mr. C. R. Kline Mr. R. A. Mendez Mr. J. R. Mora Mr. R. Ocej o ' . Mr. H. Shing Mr. J. Velazquez MOC SUBJECT: Phe nol--Acetone Un Gaske t Materials - Oxidizers Relief Manhead Construction Recommendations Teflon envelope Neoprene or teflon envelope Buna N are recommended as the materials of construction for the PhenolAcetone Unit oxidizers manhead gaskets. In view of a future ban of asbestos products by OSHA, the Phenol-Acetone Unit staff requested an alternative to substitute the current oxidizers relief manhead gaskets. _ Currently, the Ponce Plant Phenol-Acetone Unit uses Garlock 7021,. a white asbestos gasket, with excellent results. The Bound Brook Unit is using, to my understanding, Garlock 8554, felted blue'asbestos gaskets for a similar service. f > 'These gasket^ are exposed to cumene hidroperoxide ranging from 5% to 24% in concentration at temperatures between 85C and. 93C. . . ...................... ........... . - ' In view that Bound Brook had Viton A gasket s in cumene hidroper oxide with satisfacto ry s ervice life whi ch cont ras t s Dupont ! s Chemical resistance data for per.oxides , a lab o ratory test was done to check on the pos sibility of Vit on A as gaske material for the oxidizers. Vit on A stri ps were inme rsed in 6% CHP and 24% CHP at a temperat ure r ange of 85 0 C to 93 C for 415 hours UCC 015691 Mr. E. Baez June 17, 1977 Page 2 Results are as follows: 1.0 Samples softened 2.0 Samples showed large volume and weight increase. Adsorption of the CHP by the elastomer noted. 3.0 Bubbles and cracks formed at samples surfaces. 4.0 The higher the peroxide content in the test solution, the more marked the consequences were. Based on these results, Viton A elastomer is not recommended as a gasketing material in the CHP service. Eventhough teflon has the proper chemical resistance to cumene hidroperoxide, it was discharged because its "Cold Flow'1 property and the unit had requested a gasket with good resiliency. Considering that Neoprene and Buna H have good compression set, tear resistance and heat resistance properties and are elastic to provide good sealing, my feeling is that with a teflon coating a proper gasket would result. _ Based on these observations, teflon envelope Neoprene or teflon envelope Buna N are recommended as gasket materials for the PhenolAcetone oxidizers relief manheads. If any doubt or additional information concerning this letter is needed, feel free to contact me. 9 ggr Very truly yours. Ricardo J. Prieto Materials Engineering"Group Index: 22A, 22D, 28, 50, 112,> 119, 126, 137, 184B-, 1-90, 197, 317, 347 UCC 015692 UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS ENGINEERING V^ INSTITUTE, WEST VIRGINIA MEMORANDUM October-3, 1979 MATERIALS ENGINEERING CENTRAL FILE TO: Mr. E. E. Baez Ms. J. E. Ballard Mr. S. J. Kubisen Ms. D. A. Monti video Mr. R. Ocejo Mr. L. L. Madestau CC: Mr. G\ B. Elder Mr. ,L! N. Garcia Mr. G. E. Rutzen FROM: A. J. Montero SUBJECT: Recommendations for the Use of Haveg and/or Chemtite in the Cumene Unit at the Ponce Plant - Cumene Corrosion Team The Cumene Unit personnel asked if Haveg and/or Chemtite piping could be used in the reaction area in place of the Teflon lined steel piping to control external corrosion. The chemicals which are present in the reaction system are propylene, benzene, DIP, aluminum chloride catalyst, hydrogen chloride, and cumene. The operating temperature in the reaction system is about 50C. The question whether Haveg and/or Chemtite can be used in the reaction area was prompted by the use of a furan resin which was used to patch the glass-lined steel catalyst mix tank and degasser. Haveg piping is produced by loading a mixture of asbestos and resin (phenolic or furan) into molds and then applying heat and pressure. Haveg piping can be supplied with or without an external reinforcing which consists of filament wound fiberglass impregnated with an epoxy resin. The purpose of the external reinforcement is to give the Haveg material the mechanical strength and impact resistance of the armoring or external reinforcement. The unrein forced Haveg material does not possess high mechancial strength nor high impact resistance. The Chemtite piping, which is also manufactured by Haveg, is also a material produced by pressure molding asbestos fibers with a resin (epoxy or phenolic resin). The Chemtite piping and fittings are not supplied with an external reinforcement such as in the Haveg. The mechanical and impact properties of the Chemtite are similar to that of the unreinforced Haveg material. UCC 015693 Mr. E. E. Baez, et a! -2- October 3, 1979 A review of the chemical resistance of the Haveg 41 (phenolic resin), Haveg 61 (furane resin) and of the Chemtite phenolic and epoxy shows the following: 1) the Haveg 41, the Haveg 61, and the Chemtite phenolic are resistant to all of the chemicals present in the reaction system, 2) the Haveg 41 and the Chemtite phenolic have better chemical resistance to aqueous hydrochloric acid streams, and 3) the Chemtite epoxy is not resistant to all the chemicals present in the reaction system. A review of Haveg equipment and piping and of Chemtite piping at the Institute Plant was made to establish what the field experience has been with these materials. The Institute Plant was chosen because Haveg is used and has been used for many items of equipment in the SEVIN Complex and Chemtite piping has been used at the Plant. The experience at the Institute Plant has shown that Haveg equipment can be used successfully provided that the equipment is designed properly, installed properly, and not physically abused. The review also reveals that: 1) Some of the Haveg equipment has experienced breakage of nozzles and section flanges caused by improper handling of the Haveg columns and by piping stresses on the nozzles, 2) Haveg equipment has also experienced weeping caused by permeation of hydrochloric acid through the Haveg, and 3) there have been several instances where either Chemtite pipe or Haveg pipe due to their low mechanical strength have broken due to someone stepping on the line in the case of the Chemtite pipe and pressure surges in the case of the Haveg pipe. (The Haveg equipment used at Institute is all externally reinforced.) The use of Haveg and Chemtite pipe in the reaction system at the Cumene Unit is not recommended because Haveg and Chemtite are subject to mechanical damage due to their low mechanical strength and brittle nature. Leaks caused by breakage of Haveg or Chemtite piping cannot be tolerated because there are chemicals in the reaction system which are toxic and flammable. Another reason for not recommending these materials of construction for the reaction system is that there are other materials of construction which can be used successfully in the reaction system. For other areas in the Cumene Unit where Haveg equipment or piping or Chemtite piping may be used, it is recommended that these materials be evaluated for the specific application. These materials can be used successfully in the Cumene Unit in corrosive areas provided that the equipment and piping is designed properly, installed properly, and not mechanically abused. If you have any questions or comments concerning the above recom mendations, please feel free to call. INDEX: 22A.31, 32, 43, 112, 116,121,131,132,133,155,176B,182,184,184B,336 ABSTRACT: These MOC not recommended for reaction system. In other areas, it was proposed that they be evaluated for each application. UCC 015694 BUSINESS CONFIDENTIAL MATERIALS ENGINEERING CENTRAL FILE UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM ApriT 7, 1987 uy-pi3lo fm 18583 TO: CC: FROM: SUBJECT: J. R. Allen, 3001 R. G. Eager, Jr., 312 E. A. Knockaert, Weston Canal J. B. Rader, 514 G. B. Elder, 511 M0C H. T. Pritt ASBESTOS-CONTAINING GASKETS Attached is the final draft of the Recommended C&P Program to Phase out Use of Asbestos-Containing Materials In The Work Place. Since this program makes the statement "no asbestos-containing materials will be purchased after January 1, 1989", I felt you would want to be aware of the possible implica tions affecting your use of asbestos sealing materials. Although the program does not forbid the use of asbestos sealing materials, EPA rules for handling asbestos are such that the usage of asbestos will rapidly decline which will help them (EPA) implement their purposed ban of asbestos in ten years. Effective July 1, 1986, EPA lowered the acceptable exposure to asbestos from 2.0 to 0.20 fibers per cubic centimeter on an 8 hour time-weighted average. The 0.2 fibers/CC has been exceeded in some air samples when handling asbestos gaskets. The present recommendation for replacement of asbestos compressed gasketing is Grafoil and spiral wound gaskets with Teflon or,Grafoil filler. Reinforced Teflon may also be used. The organic fiber (ARAMID) compressed gaskets are not recommended for use in the plants because they do not pass the API 607 fire test. Preliminary data from a current test program being conducted by the Materials Technology Institute show that after 24 hours at 750F the organic fiber gasket is disintegrated and at 550F retains zero breaking load strength compared to 50 PSI breaking load for compressed asbestos. The chemical resistance of Teflon is outstanding, as is well known. Grafoil also had excellent chemical resistance, particularly in organic chemicals. We will be doing some specific chemical compatibility testing with Grafoil. 0101J UCC 015695 2- - Grafoil is a relatively expensive material and I have attached a cost study comparing Grafoil and asbestos gasketing with the additional cost of handling asbestos according to EPA requirements being considered. The technical service people at the Carbon Products Division are available to discuss Grafoil for specific application needs. There is also enclosed the UCC Specification SH-256 from the Health, Safety and Environmental Technology Group that details the handling of asbestos-containing insulation material. While the specification addresses insulation the handling requirements apply to asbestos in general. If there j(re further questions, please contact me. HTP:es ATTACHMENT 18583 INDEX: B, 23, 42, 50, 112 113, 180, 343 H. T. Pritt 0101J UCC 015696 DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS(1>IN THE WORK PLACE PURPOSE/BACKGROUND . The Corporate Charter (1.1) contains the following commitment to em ployees: "To provide working conditions, programs of training and . education, and persistent review and appropriate modifi cation of facilities and practices to protect the health and safety of employees." It also contains a social commitment to conduct business "In accordance with all the applicable national and local laws and regulations." As a result of available evidence that airborne asbestos In the occupa tional environment had proven to be carcinogenic In man, all C&P Insulation Standards were revised In 1976 to specify only asbestos-free Insulating materials; and new or replacement Installations of these materials have sub sequently been selected accordingly. Additionally, a Safety/Health Standard designated SH-256 was prepared covering the safe removal and handling (In cludes disposal) of asbestos-containing Insulating material during renova tion and demolition. The requirements of this Standard equal or exceed those of current applicable government standards. OSHA's rule-making efforts relative to asbestos usage In the work place are mired in controversy. Hearings on the latest EPA proposal which In cludes the phaseout of all asbestos over a ten-year period are now In prog ress. The proposal states: "EPA Is considering banning the manufacture. Importation, and processing of asbestos construction products and asbestos clothing soon after the rule's promulgation with the category of asbestos friction products banned about five years later, and other asbestos products banned at a later time." Gaskets and packing that contain asbestos are In the category of "other asbestos products" that would apparently be banned after ten years. No peer company that we are aware of has a target date for removal of existing asbestos-containing Insulation, gaskets, or packing; however, one major chemical company has recently discontinued the purchase of asbestos-containing gaskets and packing. A cost analysis of pipe-size gaskets shows that GRAFOIL*. probably the most expensive of the acceptable gasket substitute materials. Is, In fact, cost effective when the cost of mandatory work practices associated with the use of asbestos (e.g., wetting for removal or airborne fiber ^^"Asbestos-containing materials" Include but are not limited to Insulation, gaskets, packing, welding blankets, and construction products. UCC 015697  DRAFT 2- - 9/29/86 exposure monitoring during removal, placing In labeled plastic bags after removal, landfill disposal, and record keeping) Is considered. The same conclusion Is drawn relative to valve packing when the additional considera tions of Improved service life and sealab111ty are Included. Consistent with the aforementioned commitments and the economic use of materials, C&P has concluded that positive actions relative to asbestos-con taining materials*^ should be taken. RECOMMENDED C&P PROGRAM Except as otherwise provided by applicable law, Chemicals and Plastics Business Group will: Continue to phase out the use of asbestos-containing materials: Asbestos-containing Insulation shall be replaced with asbestos-free materials as required to maintain structural and functional Integ rity. No asbestos-containing materials shall be purchased after January 1, 1989. C&P Standard Practices shall be employed for the Identification, removal, modification, and/or disposal of asbestos-containing mate rials; and for use of asbestos-substitute materials. Evaluation of asbestos-substitute materials shall Include considera tion of health effects as well as suitability for Intended service and cost. A variance approval procedure shall be employed to cover considera tion of uncommon circumstances. Approval must always Include en- . dorsement of C&P HS&EA management. SCOPE This Recommended Program applies to all C&P operated/hosted facili ties. Other components of the Corporation will be apprised of Its content. DELEGATION The assignment of duties and authority to carry out the Recommended C&P Program defined herein Is delegated as follows: To Central Engineering Department Develop and maintain C&P Standard Practices covering: - Identification of asbestos-containing materials; UCC .015698 DRAFT 9/29/86 -3 - Removal, modification and/or disposal of asbestos-containing mate rials; and - Use of asbestos-substitute materials. To Line Operations Management Implement C&P Standard Practices for the Identification, removal, modification, and disposal of asbestos-containing materials. Implement C&P Standard Practices covering asbestos substitute mate rial applications, and communicate the service experience with these materials. To Manufacturing Services Monitor use of asbestos-substitute materials and communicate the service experience with these materials. To C&P HS&EA Audit compliance with governmental regulations and C&P Standard Practices relating to asbestos-containing materials and, where applicable, their substitutes. UCC . 015699 C. C. Neely 47071 received A\jGiy ^986 18 August 1986 TO: C. C. Neely 511/2000 RECEIVED 1:1986 CCN SUBJECT: ASBESTOS VS NON-ASBESTOS Issue: The higher cost of non-asbestos gasketing Is less than the extra handling cost of asbestos. To properly dispose of asbestos gasketing It should be wetted for removal, bagged after removal, and taken to a disposal site for landfill. The following calculations show how much time at a base labor rate of $15/hour could be spent on these extra steps to reach breakeven on a cost only basis. Also a calculation Is made on a $35/hour sold service rate basis. Gasketing: ' 2* - 150# Gasket Asbestos Non-asbestos Grafoil 10* 16< $1.00 Non-asbestos ri6C - 10<1 f60 Minutes! [$15/Hour ] [ Hour ] - 0.24 minutes 0$35 0.10 minutes Grafoil: m.OO- 10C1 rso Minutes! [ $15/Hour ] [ Hour ] - 3.6 minutes 0$35 1.5 minutes In other words. In the worst case If more than 3.6 minutes were required to wet, bag, and dispose of an asbestos gasket It would be more expensive. UCC 015700 Praaucukinnug;; S/Lb. Chanaes/Year S/Yr.1 Asbestos 10 5 50 Grafoil 200 1-2 300 (1) Assume 1 lb. of packing Is used per change. Consider a very conservative case. Assume the total time to change packing Is 1 hour and each change requires 1 lb. of packing. Asbestos: [($10/Lb.)(l Lb./Change) ($15/Hr.)(l Hr./Change)] x 5 Changes/Year - $125/Yr. . 0 $35/Hr. - $350/Yr. Grafoil: [($200/Lb.)(l Lb./Change) + ($15/Hr.)(l Hr./Change)] x 1.5 Changes/Year - $320/Yr. Breakeven; 0 $35/Hr. - $225/Yr. 0 515/Hr. $320 - ($10 $15 X ) 5 X - 2.56 Hours 0 $35/Hr. $350 - ($10 $35 X ) 5 X - 1.56 Hours Breakeven does not occur until 2.56 hours per packing change at the $15/Hr. rate, or 1.56 hours at the $35/hour rate. Either Is easy to Imagine when all factors are Included. Some are the following: % o Receive the Job assignment o Inspect the Job for condition and correct packing o Get the necessary packing (may require ordering material) o Get the tools for the Job o Repack the valve (frequently leaking must be stopped before work can begin) o Clean up the Job o Put away materials and tools o Seek the next Job ' LEC:ka 6267K Larry E. Calvert . UCC 015701 RECOMMENDED PRACTICE CENTRAL ENGINEERING SH-2b PAGE 1 OF SEPTEMBER 198 REMOVAL AMD HANDLING ASBESTOS-CONTAINING INSULATION MATERIAL 1 GENERAL 1.1 Tnls Practice provides a procedure for the sate removal and handling of asbestos-containing insulation material and compliance with OSHA regulation 2b CFR lblU.lOul'and EPA regulation 40 CFR bl Subpart M. The purpose of the Practice is to ensure the safety and health of employees directly Involved with performing the work and of others, either in the innediate area or downwind, who may be exposed to residual dust/fibers. Insulation material containing asbestos is no longer Installed by UCC; therefore, the concern of this Practice is to control renovation ana demolition operations Involving the removal of old, asbestos-containing insulation. ' All insulation materials approved through the use of UCC Insulation Standards have been specified asbestos-free since 197b. 2 STANUARDS 2.1 Permissible Exposure Limits . 2.1.1 Employee S-nour time-weighted average exposure to airborne concentrations of asbestos fibers shall not exceed 0.2 fibers, longer than b micrometers, per cubic centimeter of air. 2.1.2 An action level of 0.1 fibers, longer than b micrometers, per cubic centimeter of air has been set which triggers the monitoring, medical, ana employee Information and training requirements. 2.2 Work Practices 2.2.1 Insofar as practicable, demolition, removal or handling of asbestos-containing insulation shall be performed while the material is In a sufficiently wet state to prevent emission of airborne fibers exceeding exposure limits prescribed in 2.1.1 ana 2.1.2. bee Section 2.0.3 for the specific EPA regulations that control work practices. 2.2.2 Caution signs shall be posted at all approaches to areas which may contain excessive concentrations of airborne asbestos fibers so that an employee may read the signs and take necessary protective steps before entering the area. The signs shall state: DANGER-ASBESTOS; CANCER AND LUNG DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS AND PROTECTIVE CLUlhING ARE REQUIRED IN THIS AREA In addition to these signs, legible signs warning of the health hazards of asbestos shall be provided and displayed at each location where airborne concentrations of asbestos fibers may exceea the exposure limits listed In Section 2.1.1. See Section 2.6.4.4 for additional requirements for posting signs. 2.2.2.1 An appropriate barricade, using caution or barrier tape for example, shall be erected around the perimeter of outdoor areas as a supplementary, protective measure to discourage unauthorized entry. 2.2.3 Insofar as practicable, removed insulation shall be wetted and placed directly into labeled plastic bags (or other suitable containers) for disposal at an approved landfill. Otherwise, place plastic sheeting beneath the job site, mist spray the removed insulation with water, and then place in plastic bags. When wet methods of removal/cleanup are impractical, e.g., when temperatures are below freezing, vacuuming or sweeping may serve as an effective alternate cleanup method. Sweeping compound shall be applied to the work area to prevent dust generation when sweeping. See Sections 2.6.3.7 ana 2.6.4 for ' specific work practice requirements. . UCC 015702 RECOMMENDED PRACTICE SH-2bb PAGE 2 OF 6 SEPTEMBER IWt CENTRAL ENQINEERINQ 2.2.4 Label Specifications - Container caution labels shall be printed In letters of sufficient site ana contrast as to be readily visible ana legible. The label shall state: DANGER - CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST; CANCER AND LUNG DISEASE HAZARD 2.2.5 Regulated Areas - Employers must Identify as regulated areas ai\y locations In their workplaces where there may be occupational exposures to airborne concentrations of asbestos above the PEL. Only authorized persons may enter regulated areas which must be clearly posted. Eating, drinking, and sinking are prohibited In regulated areas. 2.2.6 Housekeeplng - All external surfaces In any place of employment shall be maintained free of accumulation of asbestos fibers. Special attention should be given to cleaning scaffolds used In demolition work. Clean-up of asbestos oust Is prohibited with compressed air, dry-sweeping or any dry clean-up process. 2.2.7 Waste Disposal - Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos-contaminated disposable clothing, that Is consigned for disposal and which may produce airborne concentrations of asbestos fibers In excess of permissible exposure limits, shall be collected and disposed of In sealed leak-tight containers to an approved landfill. See Section 2.6.4 for specific disposal requirements. 2.3 Personal Protective Equipment 2.3.1 Respiratory Protection - Employees engaged In the spraying [wetting-downj of asbestos, the removal; In the demolition of pipes, structures, or equipment covered or Insulated with asbestos; and In the removal or demolition of asbestos Insulation or coverings shall be provided wltn respiratory equipment having high efficiency filters selected from among those approved by the Nine Safety and Health Adninlstratlon, Department of the Interior, or the National Institute of Occupational Safety and Health, Department of Health and Human Services described In 30 CFR Part II. Compliance with exposure limits prescribed In 2.1, Permissible Exposure Limits, shall not be achieved by the use of respirators, except: 1. During the Interval necessary to Install or Implement feasible engineering and work practice controls, 2. In work operations such as maintenance and repair activities or other activities which the employer establishes that engineering and work practice control procedures are not feasible, 3. In work situations where feasible engineering and work practice controls are not yet sufficient to reduce exposure to or below the PEL, - 4. In emergencies. Where respirators are permittee the employer shall provide a powered, air purifying respirator In lieu of any negative pressure respirator specified In Table 1 whenever: . a. An employee chooses to use this type of respirator; and b. This respirator will provide adequate protection to the employee. 22.5.1.2 mb.t : UCC 015703 RECOMMENCED PRACTICE CENTRAL ENGINEERING TABLE 1 RESPIRATORY PROTECTION FOR ASBESTOS, TREMOLITE, ANTHOPHYLLITE, AND ACTINOLITE FIBERS Airborne Concentration of Subject Materials or Combination of These Materials Requlreo Respirator SH-296 PAGE 3 OF 6 SEPTEMBER 1986 1. Not In excess of 2 f/cc (10 x PEL) 2. Hot In excess of 10 f/cc (90 x PEL) 1. Half-mask air-purifying respirator equipped with high-efficiency filters. 1. Full facepiece air purifying respirator hlgh-etflclency filters. 3. Not In excess of 20 f/cc (100 x PEL) 1. Any powered air-purifying respirator equipped with high efficiency filters. 2. Any supplled-alr respirator operated In continuous flow mode. 4. Not In excess of 200 f/cc (1000 x PEL) 5. Greater than 200 f/cc (greater than 1,000 x PEL) or unknown concentration) 1. Full facepiece supplied air respirator operated In pressure demand mode. 1. Full facepiece supplied air respirator operated In pressure demand mode equipped with an auxiliary positive pressure self-contained breathing apparatus. 2.3.2 Special Clothing - The employer shall provide and require use of special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed. Contaminated clothing must be stored In closed containers such as sealed lockers. It should be changed dally. 2.3.3 Hygiene Facilities and Practices - At any fixed place of employment exposed to concentrations of asbestos fibers In excess of permissible exposure limits, the employer shall provide change rooms for employees working regularly at the place. Two separate lockers or containers shall be provided each employee, so separated or Isolated as to prevent contamination of the employee's street clothes from his work clothes. Employees exposed to asbestos during their work shift must shower before leaving the plant and must not leave wearing contaminated work clothing. Employees working In asbestos areas mist have ready access to filtered air lunchrooms and must wash their face and hands prior to eating or smoking. Protective clothing must not be worn in the lunchroom unless cleaned before hand. 2.3.4 Laundering - Laundering of asbestos-contaminated clothing shall be done so as to prevent the release of airborne asbestos fibers In excess of prescribed exposure limits. Those performing laundering of asbestos-contaminated clothing must be Informed of all requirements listed in Section 2.3, Personal Protective Equipment. Contaminated clothing shall be transported In sealed Impermeable containers and labeled In accordance with Section 2.2.9, Label Specifications. If disposable coveralls are used, they should be placed Into containers with asbestos for dlsf sal. 2.4 Industrial Hygiene Responsibility 2.4.1 Monitoring - Employee exposure monitoring shall be conducted to determine compliance status with regard to permissible exposure limits and respiratory protection requirements. Environmental/Area monitoring shall be conducted along tlx periphery of the restricted area to assure that fugitive emissions exceeding permissible exposure limits do not extend past the . . ucc 015704 RECOMMENDED PRACTICE SH-256 PAGE 4 OF 6 SEPTEMBER 1986 CENTRAL ENGINEERING demarcated area. Samples shall be collected using 25 mm diameter mixed cellulose filters and a 50 mm extension cowl. Samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. Monitoring Is required at least every b months for employees whose exposures to asbestos Is at or above the action level. Samples must be analyzed using a phase contrast microscope calibrated using a phase shift test sl'fde and equipped with a Halton-Beckett graticule. The filter samples must be prepared using acetone-trlacetln cleaning solution and be counted In accordance with the "A* rules contained in the NIOSH 7400 method. * . 2.5 Training 2.5.1 All employees who are exposed to airborne asbestos concentrations in excess of the exposure limit listed In Section 2.1.1 with or without the use of respirators shall participate In a training program at the time of or prior to Initial assignment and at least annually afterwards that Includes these Information topics: 1. Health affects associated with asbestos exposure. 2. Relationship between exposure to asbestos and smoking In producing lung cancer. 3. Nature of operations which could result In exposure to asbestos and necessary protective steps to minimize exposure including, as applicable, engineering controls, work practices, respirators, housekeeping and protective clothing. .4 Purpose, proper use, fitting Instructions, and limitations of the respirators used to protect against asbestos fibers. 5. Review of all provisions contained In 29 CFR 1910.1001, Asbestos. 6. Purpose for and description of the asbestos medical surveillance program. 7. Instructions for handling spills as well as emergency and clean-up procedures. .,2.5.2 Training records shall be maintained by the location and shall be readily available to all affected employees and to OSHA personnel upon their request. 2.6 Federal EPA Regulation, 40 CFR 61, Hazardous Air Pollutants; Subpart H - National Emission Standard for Asbestos 2.6.1 Applicability - These requirements apply to the demolition of structures or renovation of equipment and piping that involves removal of Insulation that contains friable asbestos materials. Friable asbestos material means any material containing more than 1 percent asbestos by weight that hand pressure can crunble, pulverize, or reduce to powder when dry. Demolition means the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations; on the other hand, renovation means to alter one or more facility components In any way without taking out load-supporting structural members. Planned renovation operations Include scheduled and unscheduled operations In which the amount of friable asbestos material that will be removed or stripped within a given time period can be estimated or predicted based on operating experience. Adequately wetted means sufficiently mixed or coated with water or an aqueous solution to prevent dust emissions. 2.6.2 Key Notification Requirements 1. Timing - The EPA must be notified with a written notice of intention to demolish or renovate according to these timing requirements: - a. As early as possible before renovation begins If planned, but not necessarily scheduled, renovation operations are predicted to Involve the stripping or removing of at least 260 linear feet on piping or 16u square feet on other facility components of friable asbestos materials within a year. 22.5.1.2 UCC . 015705 4 si RECOMMENDED PRACTICE CENTRAL ENGINEERING SH-256 PAGE 5 OF 6 SEPTEMBER 1966 b. At least 10 days before a demolition operation that involves at least 260 linear feet on piping or 160 square feet on other facility components of triable asbestos Materials. c. At least 20 days before a demolition operation that involves less than 260 linear feet on piping or 160 square feet on other facility components of friable asbestos materials (EPA requires further advance notice for these demolitions that are shorter in duration). d. As early as possible before a structurally unsound facility in danger of inmlnent collapse is demolished under an order of a state or local government agency. 2. Text of notification Letter - A suggested notification letter for the demolition and/or renovation of facilities containing friable asbestos material per requirements of 40 CFR 61, Subpart M, Section 146 (c). Is: Form of Notification NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES. EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION 1. Name of Owner 2. Address of Owner 3. Description of Facility Union Carbide Corporation (Location Street Address of facility being demolished or renovated). Various buildings, equipment and piping used in manufacture and distribution of chemicals and plastics and also age, size and prior use of these facilities. 4. Estimate of Quality of Asbestos Approximate amount of friable asbestos material present in the facility and explanation of techniques of estimation if estimate for demolition operation is less than 160 square feet or 260 linear feet. 5. Scheduled Start and Completion Oates 6. Method(s) of Demolltlon/Renovation 7. Compliance Procedures How EPA regulations will be followed_________________________________ B. Disposal Site Name and location of site where asbestos waste material wfll be deposited________________________________________________________________ Only parts 1 through 4 are necessary for demolition operations Involving less than 260 linear feet or 160 square feet of friable asbestos material. The name, title, and authority of the State or local government representative who orders the demolition should be added to the notification for demolition of structurally unsound facilities. Some states. Including Georgia, New York, North Carolina, and California, also require notification of demolition and/or renovation operations involving friable asbestos materials. 2.6.3 Key Removal Requirements - For a planned demolition operation or for the total of scheduled renovation operations in which at least 260 linear feet or 160 square feet of asbestos material is removed: 1. Friable asbestos materials shall be removed before a demolition or renovation operation if the operation would likely break up or preclude access to the asbestos materials for subsequent removal unless the asbestos materials are on a facility component encased in a material such as concrete or are adequately wetted whenever exposed. 2. If a facility component is covered or coated with asbestos materials and is removed In sections or units, it shall be carefully lowered, not dropped or thrown, to the ground level and shall have any exposed asbestos materials adequately wetted while cutting or disconnecting. 3. Wetting is not required during renovations If the EPA is requested to confirm that wetting would unavoidably damage equipment. If the EPA confirms this, then a local exhaust ventilation and collection system must be used to collect asbestos particulates. The exhaust system must exhibit no visible emissions to the outside air or be designed and operated according to 40 CFR 61.154. UCC . 015706 22.5.1.2 RECOMMENDED PRACTICE SH-256 PAGE 6 OF 6 SEPTEMBER 19bo CENTRAL ENQINEERINQ 4. After sections or units of piping or equipment with asbestos materials have been taken out of the facility, the asbestos materials during stripping shall be adequately wetted or shall be collected by a ventilation and collection system as specified In 2.6.3.3. - b. Dust-tight chutes or containers shall be used to lower asbestos material removed or stripped more than 50 feet above ground level and not removed In units or sections. 6. All friable asbestos materials that have been removed or stripped shall remain adequately wet until collected for disposal. 7. If the ambient temperature Is below 0*C, then the only wetting requirements are those specified In 2.6.3.4 and 2.6.3.6. Equipment or piping coated or covered with asbestos materials shall be removed to the maximum extent possible. 8. For demolition of a structurally unsound facility under the order of a State or local government agency, the portion of the facility that contains friable asbestos materials shall be adequately wetted during the wrecking operation. The wetting requirements specified In 2.6.3.4, 2.6.3.5, 2.6.3.6, and 2.6.3.7 shall also apply to any emergency demolitions. 2.6.4 Key Disposal Requirements 1. Visible emissions shall not occur during the collecting, transporting, or disposal of any asbestos-containing waste material unless the air-cleaning methods specified In 40 CFR Part 61.154 are used to collect asbestos fibers before they escape to the outside air. 2. The disposal method for collecting and transporting asbestos-containing waste materials shall be approved prior to use by the EPA, unless either of these two EPA-approved methods are used: a. Form all asbestos-containing waste material Into nonfriable pellets or other shapes, or b. Adequately wet and seal while wet In leak-tight containers all asbestos-containing waste material. The waste containers shall be labeled according to Section 2.2.4. ' 3. The disposal site for asbestos-containing waste material shall have no visible emissions, or the disposed material shall be covered within 24 hours with at least six Inches of nonasbestos-containing material or with an effective resinous or petroleun-based dust suppression agent (waste crankcase oil Is not acceptable.) Alternative methods for controlling asbestos emissions must have EPA approval before being Implemented. .4 Either a natural barrier or a fence shall adequately deter (as determined by the EPA upon request and supply of appropriate Information) public access to the waste disposal site. If fenced, then warning signs (20* x 14*) Shall be posted at all entrances and at Intervals no greater than 330 feet along the perimeter of the sections of the site where asbestos-containing material Is deposited. The signs shall state: - ASBESTOS WASTE DISPOSAL SITE DO NOT CREATE OUST BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH 2.7 AUDITS 2.7.1 Each location shall periodically audit this procedure to ensure understanding and compliance. 22.5.1.2 . . .-y Vy UCC 015707 U)i/ -D/310 4r ME 17394 UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM MATERIALS engineering CENTRAL KLB July 18, 1984 TO: CC: FROM: SUBJECT: J. A. Fey, 514 A. E. Wood, 514 P. D. Black, 511 D. J. Hart, 514 R. H. Johnson, 511 J. E. Kidd, 514 J. E. Kidd, Jr., 514 D. T. Nguyen, 514 J. 0. Silvey, 514 J. N. Wickert, 514 MOC H. G. Clem INSPECTION OF TRANSITE PIPING SECTION OF WASTEWATER COLLECTION SYSTEM, SOUTH CHARLESTON PLANT At your request, a further investigation into concerns with the subject piping system was conducted with particular emphasis on apparent deflection of joints due to improper support, repair pro cedures, and general integrity of the system. The major problems, as noted in your recent report0) are a series of failures or leaks in the area of transition between polyethylene piping and the transite which are due mainly to thermal expansion and improper support of the piping system. The transite was reportedly not found to be severely deteriorated or embrittled. Our findings are outlined be low. Reference material was obtained from obsolete UCC Piping Speci fications and the "Transite Ring-Tite Pressure Pipe Installation Guide" which is available from the J-M A/C Pipe Corporation: (D Jr., Kidd, J. E., Silvey, J. 0., Wickert, J. N., Wood, A. E., Inspection of the Wastewater Collection System, South Charleston Plant, November 16, 1983, File No.: 17149. UCC 015708 2 Deflection of Transite Pipe Joints: The piping system is designed to operate under pressure with 3 to 5 degrees deflection per coupling depending upon pipe diameter. Jn our recent field inspection, none of the transite pipe joints appeared to be deflected more than 3 degrees. This condition could change if ground movement or land slides in the area cause a further deterioration of support for the piping, but the degree of deflection, in itself, is not a major concern at this time. Details on this topic from Pages 14-15 of the installation guide are attached for reference. Repair of Transite Piping: The existing repairs on the transition section of the transite piping are in accordance with J-M A/C Pipe Corp. recommendations as shown in the attached excerpts. Pages 98-101, from the installation guide. Repair clamps are normally used for this work. Joint repairs while the system is in operation are best handled with mechanical couplings. If the leak is relatively minor, the joint may be repaired with epoxy grout reinforced with a fiberglass over wrap. These repair procedures will restrict the flexibility of the original joint but should be satisfactory for emergency situations. General Integrity of the Transite Piping System: Although our existing transite piping is apparently in good condition aside from mechanical damage from thermal expansion in the transition area near the polyethylene piping, transite is losing popularity due to poor structural strength and environmental concerns related to asbestos (see attached UGP-5 newsletter). Mr. Tom Mullen, area representative of J-m A/C Pipe Corporation, stated that their tran site piping product line may be phased out within the year because of declining markets. If this is the case, we should consider stocking additional transite fittings, adaptors, and piping in the appropriate diameters and lengths to replace any sections of existing installed pipe that may be damaged beyond repair in the future. As men tioned in your report, the transite piping system should be monitored for failure areas, dates and costs. UCC 015709 -3- Since the service life of the system is unknown, a re placement plan should also be developed using an alternative piping system like fiberglass reinforced resin pipe. In conclusion, current repair procedures and the degree of deflection of existing pipe joints are satisfactory. Since there are concerns about the service life of the system and future avail ability of the piping, a contingency plan for eventual replacement should be considered. If there are additional comments or questions on this subject, pi ease call. HGC:es Attachments 17394 INDEX: R, 6, 7, 17, 23, 32, 112, 114, 141, 154, 180, 294, 301, 318, 351 UCC 015710 Table B Minimum Radius of Curvature for Pipe on Curves Minimum Radius of Curve (feet) Deflection Length of Pipe per (Feet) Coupling 3'3" 6V2' 13' (Degrees) Offset per 13' Length (Inches) 186.8 92.8 62.0 Pipeline to Curve 46.6 From Point A to B 37.2 373.5 185.5 124.0 93.1 74.3 747 1 371 2 249 3 186 4 149 5 2.7 5.4 8.1 10.9 13.6 Pipe in sizes 4"-12" may be deflected up to 5; pipes 14" and 16" up to 4; 18" thru 24" up to 3V2, and 30"-36" up to 3. These deflections apply to couplings belled on the job site. For factory-belled couplings,use one-half of the above deflections or offsets. How to Use 1. Find the radius of the proposed curve by actual measurement or by making a sketch to scale. (See diagram above.) 2. Check the table to make sure the radius is not too small. For example: Assume the radius will be 188 ft. and that 8" pipe in 13 ft. lengths will be used. Under the 13 ft. column the figure nearest 188 ft. is 186 ft. -- checking to the right we find this is equal to 4 degrees of deflection at each coupling. (Referring to Table B shows that 4 degrees is satisfactory for 8" pipe.) 3. Then, by checking the offset column above, we find that the required curve can be made by offsetting each 13 ft. length 10.9". Note: If the radius had been shorter, say 125 ft., the deflection at couplings would be too great and the curve should be eased up or short lengths used if they were available. The table (see second column) shows that 6V2' lengths on a curve of 125 ft. radius would give 3 degrees deflection per coupling. 14 f e +" * e^ % % '"O to to fc % fc fe fe * * * e tr * If the offset exceeds the maximum recommended deflectior the curve is too sharp to allow the use of full lengths. When short lengths are used, the maximum deflection at each coupling cannot be any greater than for the full length -- but, since there will be more couplings in the same length < line, a sharper curve can be made. (See Fig. 12.) Width of trench Sometimes a wide trench will be necessary. In other cases the soil will be such that a narrow cut could be made. Whatever width may be used at the top of the trench, be sure that, for pipe sizes above 16", at the pipe-level, it is kef between the maximum and minimum widths given in th< Transmission Pipe Handbook TR639. There are two reaso for this: 1. Loads on pipe. The wider the trench at the top level of t pipe, the greater the earth load on the pipe will be up to I transition width. To determine the exact loads on pipe, consult the engineer. It is desirable to keep earth loads < pipe lines at a minimum. As Figure 13 shows, no additio earth load will result from wide, sloping trenches so lon< as the extra width is kept above the pipe. It's the width 1 the top level of the pipe that determines the extra earth load. UCC 015711 Repairs to Damaged Pipe When pipe has been damaged and repair is required, all damaged material may be replaced in kind or the pipe may be repaired using a repair clamp or other methods authorized by the engineer 1. Bruises are caused by heavy impact against such things as timber and iron edges, rocks, other pipes and fittings. This can result in a breakdown by crushing of the pipe-wall under the bruise. The weakened spot may blow out under high pressure or may cause seepage through the pipe and a blow-out at some future time. This condition is usually indicated by bulging and broken structure on the inside surface of the pipe or by cracks. 2. Whether the blow results in a bruise or in a hole through the pipe-wall, some or all of the pipe will still be useable. As shown in Fig. 67, bruises and punctures can be repaired with repair clamps. Bruised or punctured -4* * t -4r ff the rubber lining smoothly during final adjustments). The clamp is then put around the pipe with the nut position on top for easy access. After the nuts have been tightened lightly the clamp should be rotated slightly in the same direction as the overlap of the rubber lining to assure its smoothness. The nuts are then tightened so as to distribute the pull evenly on all the bolts and the repair is completed. Either clamp shown in Fig. 67 or 68 is suitable for either repair. 3 If the pipe has been broken cleanly into two pieces the ends can be joined together with a repair clamp. Broken Barrel Repair with clamp Repair with clamp If a repair clamp is to be used the full circle type with opposed bolt-line flanges is recommended and should be installed in accordance with the manufacturer's instructions. When using a repair clamp the area on the pipe barrel around which clamp will be placed should first be cleaned with a wire brush. Apply Ring-Tite lubricant to the cleaned area -- (to help seat Fig. 68 4. Chips that extend more than Vi" in as shown in Fig. 69 should be trimmed off and the end re-machined with a field machining tool as described on page 42. Test with a knife point to make certain that pipe is sound beyond the chip--or wet the area with water and, as the pipe dries, a crack will become visible because it remains wet longer. It is advisable, before field-machining, to trim an extra inch off to be certain of reaching undamaged material. UCC 015712 Chipped End Ring Area "nnr > JXJL FIG. 69 Trim off to sound pipe and re-machine. Trim back beyond any crack that may exist. (See page 99.) 5. Cutting, or abrading the pipe is another type of abuse that may require repair. This takes the form of gouging, scratching, chipping and scraping actions which cut or wear away some part of the pipe surface. Such damage is caused by carelessly dragging pipe across sharp objects; by dragging heavy, rough objects across the pipe; or by constant friction against protruding bolt-heads, rubbing action of wires, etc. 6. On the machined end of the pipe (where water-tightness is attained by sealing with rubber rings) grooves and scratches that run lengthwise, and would be in the rubber ring area, will have to be repaired or trimmed off and re-machined. Refer to Fig. 70. Slight scratches (not over 1/16" deep and no wider than W') can be repaired by sanding the sharp edges so that the rubber rings will seat properly on the pipe. Wider or deeper scratches will prevent the ring from sealing properly and should be trimmed off. 7. Scratches that run around the pipe will not cause trouble if the rubber ring will fully cover the scratch (see Fig. 70) --but, if the ring will cross it at an angle, it would cause leakage and should be repaired or trimmed off as described above. -Js * * * * 0 r 8. At other points along the barrel of the pipe (where the Ring-Tite Coupling and rubber rings are not used) a cut or abrasion that is larger than V deep, W wide and 2" long should be repaired with a clamp. Gouges Lengthwise or at an angle Ring For gouges outside of Area rubber ring area -- * ii ^ Gouges Around pipe Ring Area r H Ring will straddle and cause leak. See page 100. Fig. 70 1 Sand edges if gouge is light. 2 Trim off if gouge too deep. Ring will seal minor gouges and run squarely around pipe. UCC 015713 UGP-5 UNDERGROUND PIPING NEWSLETTER PVC A UCC Chemicals/Plastics Standard Underground Valve and Piping Specification for Polyvinyl Chloride (PVC) or Chlorinated Polyvinyl Chloride (CPVC) piping does not exist. Three explosions of PVC pipe used for potable water supply have been reported in the State of Washington. One of these explosions destroyed about 600 feet of pipe. Apparently, the hypochlorite used for disinfecting potable water piping systems reacts with the pipe bonding solvents used by some manufacturers creating an inadvertent pipe bomb. Potable water passing through PVC piping does pick up unpoly merized residuals of the material. Concentrations, however, are below the level now considered to have adverse effects on experimental animals. Recent studies verify the VC concentration by gas chromato graphy examination. The newest installations tested show a higher VC concentration than the older systems. The temperature limitation for PVC piping is I20F and for CPVC, l80F. The temperature-pressure curve decreases rapidly as the temperature exceeds 73-4F (20C), e.g., the design pressure of PVC must be derated by 50% if the anticipated temperature is !I0F. (R) Bell and spigot plastic piping joined with rubber 0-rings must be restrained at intersections, changes of direction, and reductions in pipe size. Concrete thrust blocks are the only known method of restraint for plastic piping. Thrust blocks use valuable real estate, are usually oversized since accurate soil-bearing data is rarely avail able, and create local subsidence that could damage the pipe. The concrete block adds to material and labor costs and precludes extension of trunk headers and branches. Some manufacturers are now promoting large thread joints to over come restraint and solvent problems and are over wrapping the PVC with Reinforced Thermosetting Resin (FRP) to increase the structural strength of the piping and fittings. AC Asbestos cement (transite) piping systems are losing popularity due to poor structural strength, manufacturing problems with asbestos Fibers, external erosion in low pH soils, and internal bacteriological attack. Studies are currently in progress to determine the concentr ation of asbestos fibers in potable water supply systems using AC piping Thrust blocks are also required for this piping system. A Standard Underground Valve and Piping Specification for AC piping does not exist. L. A. Peggs February 1978 Revised: November 1978 UCC 015714 /f'- ',*< - J /1 / 7 U)Vv0l3(cr^ UNION CARBIDE CORPORATION SILICONES & URETHANE INTERMEDIATES ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM May 22, 1985 MATERIALS ENGINEERING CENTRAL FILE 58 % TO: All Department Heads COPY TO: W. E. Ballard D. H. Harrah F. M. Holmes D. J. McNeil D. J. Moody B. G. Stump W. S. Walker P. G. West Wickert FROM: A. E. Wood SUBJECT Use of Non-Asbestos Gaskets To decrease exposure to asbestos materials, the GR shop has been using non-asbestos gasketing on pump heads since 1983. They originally used Garlock 3000 with nitrile binder. No gasketing failures were reported but severe gasket deterioration was noted. So they switched to the Garlock 3200 (with SBR binder) in early 1985. In May, they again switched to the Durabula and Garlock 3700 with EPR Binder. N Non-asbestos gaskets can not be a direct substitute for asbestos gasketing. Non-asbestos gaskets contain significant amounts of rubber binder and their proper selection has to consider the chemical resistan^-of the rubbers to the process chemical. Asbestos gaskets are 80% fiber, 10% rubber binder and 10% filler. If the rubber binder is attacked 90% of the gasket is left. The new non-asbestos gasketing materials on the market are 50% fiber, 30% rubber binder and 20% filler. An attack on the rubber binder can result in a catastrophic failure of the seal. Last week, I inspected four non-asbestos gaskets that were installed in pump services. Three of the gaskets were in pumps that were in the shop for routine repair and these gaskets were only 50-95% attacked. These pumps were: 1. Polyols No.2 Reactor Circulating Pump (Garlock 3200SBR binder, attacked by Ethylene Oxide). 2. Upper Island Residue Pumps (Garlock 3200-SBR binder attacked by kernes).ucc ^5 3. Silicones II Dowtherm Pump (Durabula-EPR binder, attacked by 700F temperatures (Mfg. said it was good to 900F') and attack of the EPR binder by Dowtherm). The fourth gasket was a Durabula gasket with an EPR binder that was used on a piston pump. The gasket "blewout" due to either an overpressure or as a result of loss of the EPR binder due to attack by oils. The above data, indicates that we have not yet had enough service life on the compressed non-asbestos gaskets, to have experienced the catastrophic failures that are possible once the binder has been attacked. But the probability of an occurrence is high if the situation is not addressed quickly. A review of our hazardous and toxic chemicals lists with respect to the resistance of the SBR binder in the Garlock 3200 has been conducted. This review indicates that this gasket is not resistant to 90* of the hazardous and toxic chemicals in our plant (see attached listing). The Durabula gasket with the EPR binder is a newer, superior gasket but a preliminary review shows that EPR is not resistant to 50* of our process chemicals. There are no records of where these gasketing materials have been installed. Please identify those pumps that are in services shown to attack these binders and work with the GR shop, Nelson Wickert and I to pull these pumps and verify that they have either Asbestos, Grafoil or Teflongaskets. Any other gasketing material should be replaced with one of these 3 materials. The action plan is to: 1. Identify pumps handling high impact potential chemicals that attack non-asbestos gasketing binders (will need the following information: Pump Location, Service, Property Number by 6-14-85). Send lists to E. 0. Harrah and A. E. Wood. 2. Determine gasket materials used in pump. 3. Re-gasket pumps that are gasketed with compressed non-asbestos gaskets. 4. Identify pumps handling medium impact potential chemicals and repeat above procedure by 6-21-85. 5. Identify pumps handling low impact potential chemicals and repeat procedure by 6-28-85. The potential for an emission due to gasket failure is high please work with us to correct this situation as soon as possible. Attached is D. J. McNeil's letter on use of Asbestos/Non-Asbestos Gasket Valve Packing Materials. Feel free to call me on extension 3424 if you have any additional questions. AEW/sml UCC 015716 A. E. Wood HAZARDOUS AND TOXIC MATERIAL QUESTIONNAIRE MEDIUM IMPACT POTENTIAL C.V\ <,**<. A Acetic Anhydride Butyl Acrylate Butyraldehyde Chlorine Diethylamine Ethane, Stabllzed (Institute) Ethyl Acrylate Isobutylene Isobutyraldehyde Natural Gas (Logan) Natural Gas (C-12 Gas) PropionFc Acid Vinyl Acetate Vlnylidene Chloride Pour UR K/ R. to R. FoxxT to R_ to R- - F<x*r to R. " KJ R O-ACg. Oura\)ii\i ~ZTTFFr e. WR R. aJR R R R R k)R --- January 30, 1985 0111S fJR., KJ0+ p _ ___ Jj --------- ,*s,, -V JoA-ot UCC 015717 HAZARDOUS AND TOXIC MATERIAL QUESTIONNAIRE C kt M LOW IMPACT POTENTIAL At< Acetone Acetylene Amyl Acetate Brucine Sulfate Butanol ...... -- -- Butyl Acetate CELLOSOLVE^Acetate------------- Cyclohexanone Di-t-BuTyT Peroxide Dloxane Dodecanoyl Peroxide Ethanol Ethyl Acetate Ethylenediamine 2-Ethylhexyl 'Acrylate Ethyl Silicate, Condensed Ethyl Silicate TO Gasoline, Drips Gasoline, Fuel Hydrogen Isobutanol Isobutyl Acetate Isopropanol Isopropyl Acetate Mesityl Oxide Methanol Methyl Acetate"" Methyl n-Aayl Ketone Methyl CELLOSOLVE Methyl Ethyl Ketone Methyl Isobutyl Ketone Nicotine Alkaloid____ Nicotine Solution 2,4 - Pentanedione 'Propane ~ n - Propanol n - Propyl Acetate " Pyridine Triethylamine ' Trimethylamine, 251 Toluene k~<^\r* S JkSL January 30, 1985 0111S UCC 015718 _UR MR JJR " -- to "a bt fL - too. ___ Fa.. r fj RtoR Fa \c pAr A/P Fait R. ue toe. uQ V*. 1 Kl R. __ R B _R -- R fc R R -- R R wt J fc K. R -- R -- R R R e. R R R .R ME. to R -- K/P fc R R -- R. i HAZARDOUS AND TOXIC MATERIAL QUESTIONNAIRE HIGH IM-PA, C-T POTENTIAL -W ^5^ T Acetaldehyde Acrylonitrile Allyl Alcohol Ammonia Carbon Monoxide, 512 to du Pont Dimethylamlne Dimethyldichlorosilane Ethane, Liquid (Hastings) Ethylene Oxide Hydrogen, 512 to du Pont Hydrogen Chloride Liquid Concentrates Methyl Chloride Methyldichlorosilane Methyltrichlorosilane Monomethylamine Propylene Oxide Silicon Tetrachloride Sulfur Trioxide Trichlorosilane Trimethylchlorosilane Vinyl Methyl Ether I1t1 <o*.rLtW3lfco S RK SK+U ON'^J kj R -- - Kie- uor F(>.i r KJ R KJ R KJ R K R R .-- -- NR KJ R. KJ R. -- PKJ R F~xr UR KJ R kjR . . Dor-A>A R uR -- -- R -- UR KJR MK R -- ---KJR KJR KJR -- & -- R -- -- January 30, 1985 0111S KJ R - "V ' ^ Ja^a. UCC 015719 UNION CARBIDE CORPORATION SILICONES & URETHANE INTERMEDIATES ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM May 15, 1985 TO: W. E. Ballard J. C. Cogar* J. R. Dean E. 0. Harrah* F. M. Holmes* D. W. Moody* W. C. Young Attended Meeting FROM: D. J. McNeil* SUBJECT: Use of Asbestos/Non-Asbestos Gasket/Valve Packing Materials On 5/10/85 the above group met to discuss the use of non-asbestos gasket and valve packing materials. When the asbestos health concern was first disclosed the South Charleston location made a concentrated effort to remove and discontinue the use of asbestos materials (gloves, insulation, etc.}. This policy was also applied to asbestos gasketing and valve packing materials. Therefore, the 514 location began to buy and use other gasketing materials, such as "Blue-Gard" and Garlock 3200. No records were kept on where these materials were used. It is the E&TS organization's position that there are significant risks involved in the use of these materials. Ncr.-asbestos compressed non-metallic gaskets have been shown to be inferior in chemical resistance and have a lower maximum temperature limit than teflon (Ashbaugh/Moody/Neeley letter of 6/22/82-attached). Asbestos gaskets are 80* fiber, 10* binder and 10* filler. If the binder is attacked 90* of the gasket is left. The new gasketing materials are 50* fiber, 30* binder and 20* filler. An attack on the binder can result in a catastrophic failure of the seal. It is also the E&TS and Safety Department's positicz that asbestos materials can be stored, cut and handled in a safe manner since the fibers are encapsulated in binder. UCC 015720 2 The action plan developed by the group was to: 1. Limit gasket and valve packing materials at 514 to BGS/WEB -Asbestos -Grafoil -Teflon (Gylon-Fawn) -Elastomers such as Viton. Neoprene, etc. in low temperature and special services only EPR, Any exception must be clearly identified and monitored with copies going to D. J. McNeil and A. E. Wood. Any exceptions need technically supportable reasons. WCY 2. Run tests on exposure during handling/cutting of asbestos materials in the 514 shops. BGS Review operating procedures JCC 3. Get rid of "other" unacceptable materials AEW 4. Try to determine where "other" gasketing materials were put in service and the risks involved in leaving them in that service. AEW/EOH Document service life of "other" materials when . equipment with this material is pulled to gather data base for when asbestos becomes unavailable. Replace "other" material with one of the acceptable materials when found. BGS/ WCY ,, 5. Review and train personnel on accepted "wet down" procedures for handling "failed" asbestos gaskets (failed means that the binder was lost) Run tests on exposure in handling old/failed asbestos materials. 6. Run organized/well documented tests on "other" materials by contacting the MOC group (AEW) for monitoring. A. E. Wood will monitor and document these activities. Any additional concerns or questions can be addressed to him. DJM/sml Thanks for your support, jQdr H ~ D. J. McNeil UCC 015721 BUSINESS CONFIDENTIAL MATERIALS ENGINEERING CENTRAL FILE UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM February 13, 1987 18495 TO: G. B. Elder, 511 CC: D. D. Barnette, 512 R. L. Boggess, 514 J. E. Boley, 380 D. L. Carrick, 519 A. W. Keene, 510 G. H. Reinhart, 312 L. E. Calvert, 511 S. W. Clark, 511 R. W. Engle, 511 T. E. Hanning, 511 D. J. Hymel, 515 R. W. Maddox, 511 D. D. Miller, 512 C. C. Neely, 511 M. Patel, 511 MOC FROM: H. G. Clem SUBJECT: IDENTIFICATION CODE FOR ASBESTOS-FREE INSULATION This report is in response to your letter on asbestos identifica tion concerns with insulation in our plants. Three primary issues, integral asbestos-free visual coding for insulation materials, weather barrier coding, and asbestos identification tests are discussed under separate headings: 1. Integral Non-Asbestos Identification of Calcium Silicate Pipe and Block Insulation " All of our approved vendors for calcium silicate pipe and block insulation have visual identification dispersed throughout the white product in the form of either gold colored mica flakes or black fibrous material to indicate that the insulation is asbestos-free as shown below: 0037J UCC 015722 0037J -2- Calcium Silicate Insulation Manufacturer Asbestos-Free Identification Kaylo 10-AF Owens-Corning Fiberglas Corp Mica Flakes Thermo-12 Manville Corp. Mica Flakes Super Cal temp NA PABCO Black Fibers Manufactuers of expanded perlite. Material Spec. 4, also have asbestos-free visual identification. The current approved material, Goodtemp 1500 from the Howred Corporation, has a uniform pink color throughout the material. Celotemp 1500, a formerly approved insulation that is no longer being manufactured, contained mica flakes like the current calcium silicates. Since apparently only solid white compositions like the early calcium silicates, 85% magnesia, and insulating cements for steam piping and boilers contained significant percentages of asbestos fibers, manufacturers of most other insulation materials have not adopted an asbestos-free coding system. Insulations with distinc tive characteristics or appearance like cellular glass (UCC Spec. 1), polyurethane foam (UCC Spec. 3 and 7), performed fiber glass (UCC Spec. 6), flexible plastic foam (UCC Spec. 12), and mineral wool (UCC Spec. 14 and 40) never contained asbestos. Of course, since the use of mica flakes and other visual coding was not widespread until the mid 1970's, most insulation in older units may require laboratory testing for possible asbestos content before replacement or modification. 2. Asbestos-Free Visual Indicator for Metallic and Mastic Weather Barriers You asked for a durable visual indicator for metallic and mastic weather barriers to indicate that the insulation underneath did not contain asbestos. I have found that several methods are being used in the petrochemical industry, but there is no universal standard on this important subject. A summary of asbestos-free identification methods related to weather barriers is listed below: Surface Texture Variations: Reportedly, Tennessee Eastman, Eastman Kodak, and Amoco have adopted the use of a "stucco embossed" texture finish in either flat or 3/16" corrugated configuration for aluminum or stain less steel weather barriers on all insulation replacement projects. This method provides a distinctive visual coding that contrasts with the older smooth finish metal weather barrier sheet material. UCC 015723 -3- 0037J Surface Texture Variations - Cont. Only minor changes are required in installation procedures with this approach, and planned or inadvertent painting of the weather barrier will not affect the visual identifica tion characteristics. The method is not applicable to mastics or plastic weather barriers, however. Color Coding: This procedure involves the use of factory finished weather barrier in a specific color to indicate that the insulation is asbestos-free. The colors most used for this purpose are white, green and blue. To be effective, this method would require coordination with existing UCC safety color coding in the plants. Identification Tapes: This method utilizes making tapes applied over standard weather barrier materials to indicate that the insula tion either contains asbestos or is asbestos-free. E.I. DuPont de Nemours & Co. (Inc.) uses this method. A copy of the DuPont specification entitled "Identifi cation for Installed Asbestos-Bearing Insulation" is attached for reference. This type of identification tape is available from several suppliers. The DuPont tape features fade proof ink lettering and background with a clear polypropylene coating for chemical resistance and durability. The asbestos code lettering is combined with arrows to show the direction in which the indi cated insulation runs. The primary advantage of identification tapes is that any type of weather barrier may be marked whether new or exist ing. Entire sections of plant units can be defined as asbestos-free with this technique. The main disadvantage of tapes is that they may be inadvertently painted over or removed during routine maintenance activities. Various versions of asbestos-free identification tapes are available from graphics label suppliers. In most cases, pressure sensitive vinyl is used for the tape material. Unlike the DuPont specification tape, the "ASBESTOS FREE INSULATION" labels and direction arrow tape are usually separate items, not combined. The blue background/white lettering is the same in most instances. UCC 015724 -4- 3. Asbestos Identification Methods The identification and monitoring of asbestos fibers from insulation or other sources is the responsibility of UCC Industrial Hygiene Groups at our various locations. According to Mr. Manhel Patel at the Tech Center, several test methods are available to identify asbestos including colorametric test kits, microscopic examination with polarized light, scanning electron microscopy and trans mission electron microscopy. However, the colorametric technique is not as reliable as the microscopic methods because it only detects iron and magnesium from bulk samples; interference from related compounds can affect test results. The microscopic methods are approved by OSHA, EPA and NIOSH and represent the best current procedures available. It is apparent that devising a better way to identify asbestos that meets government approval will be difficult. If quicker results are needed at our plants on insulation replacement jobs, consideration should be given to pre sampling the existing insulation well ahead of any planned work. Conclusions and Recommendations The visual asbestos-free coding methods of our calcium silicate and expanded perlite suppliers, ie mica flakes, black fibers, etc., will be included in our UCC Material Specifications 2 and 4 as suggested by Don Miller of the Institute Plant. This may provide some valuable assist ance in the field identification of insulation materials. Concerning the visual asbestos-free coding of weather barriers, it appears that no single identification procedure may be suitable for all conditions in our plants and other facilities such as laboratory buildings. One of the main problems is the diverse types of weather barriers encountered; aluminum, stainless steel, PVC, fiberglass laminate sheet, and mastics. Some differences are also evident in our options when we are replacing asbestos containing insulation versus simply labeling or marking a "good" existing asbestos-free system. Current asbestos and asbestos-free insulation coding procedures at UCC locations range from no identification marking to marking all asbestos containing insulation with labeling tape and entering a code for asbestos replacement jobs in the computerized work orders for storage and retrieval. Before we introduce a UCC recommended practice or standard on weather barrier 0037J UCC 015725 -5- identification coding, a poll or request for comments should be solicited from plant insulation representatives and other responsible parties. To assist in the proposed poll, actual samples of identification tapes and embossed metal weather barrier would also be sent to each respondent. If there are further questions or comments, please call me. HGCres ATTACHMENT 18495 INDEX: 6, 7, 10, 23, 28, 30, 32 42, 43, 44, 44A, 62, 71, 81 112, 120, 121, 122, 127, 138 142, 180, 307, 318, 351 0037J H. G. Clem UCC 015726 225 IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION THERMAL INSULATION STANDARD ENGINEERING SPECIFICATION ISSUED THIS PAGE REVISED STANDARD REAFFIRMED JULY 1975 APRIL 1964 APRIL 1984 Page 1 of 2 1. SCOPE 1.1 This specification provides information for a stan dardized method of placing identification on installed insulation which contains free asbestos fibers or insu lation ofunknown asbestos content. 1.2 This specification is applicable only for identi fying installed insulation which has a questionable free asbestos fiber content. Obviously, materials such as cel lular glass, glass fiber, mineral wool, polyurethane foam, and polystyrene foam do not contain asbestos fibers and, therefore, do not need to be marked for identification. 1.3 Follow this specification only at locations where such identification is required by the operating de partment and the plant does not have a conflicting estab lished identification procedure. 2. CONDITIONS installed, do not require identification. At turnover, the local construction organization is to notify the plant that the facility is free of materials containing free asbestos fibers. 4.2 Condition II. Individual insulated lines or equip ment pieces in clearly defined additions in which no insulation containing free asbestos fibers was installed, do not require identification. In lieu of marking individ ual lines or equipment pieces, place strips of tape strate gically along the plane that defines the building addition. Locate the tape on selected columns, beams, walls, or ceilings, to clearly identify the plane at which the asbestos-free insulation starts. Apply two parallel strips of tape. Position one piece of tape with the arrows orientated to indicate that, from that point on, all insu lation is nonasbestos. Position a second piece of tape with the arrows orientated to indicate that, front that point back, the insulation may contain free asbestos fibers. - 2.1 From an installed insulation viewpoint, specific areas on a site are classified as follows: 2.1.1 Condition I. New facilities on which no in sulation containing free asbestos fibers was installed. This could be an entire site or a segregated building on a site. 2.1.2 Condition II. New additions to existing buildings which can be clearly defined by designated column lines or a defined plane through the building. The addition does not contain any insulation containing free asbestos fibers. 2.1.3 Condition III. Existing areas which are modified by the addition of insulated lines or equipment. 4.3 Condition III. Individually mark all new insulated lines and equipment pieces installed as additions or modifications in existing areas to indicate insulation as bestos content. Where asbestos-free insulation is in stalled on a pipeline, place a strip of tape around the circumference of the finish at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a tie-in is made to a line insulated with a material of unknown asbestos content, identify the junction of the insulation by parallel pieces of tape around the circumference of the finish. Position one piece of tape to indicate that, from that point on, the insulation is asbestos-free. Place a second piece of tape with the arrows orientated to indicate that, from that point on, the insulation may contain free asbestos fibers. 2.1.4 Condition IV. Existing areas in which exist ing insulation is being replaced. 3. TYPE OF IDENTIFICATION For identification, place strategically located strips of appropriately marked tape around the circumference of the pipe finish or on the equipment finish. Position the tape so as to indicate the type of insulation used with the arrows pointing down the line in the direction in which the indicated insulation runs (see Figure 1). 4. PLACEMENT OF IDENTIFICATION WHEN REQUIRED 4.1 Condition I. Individual insulated lines or equip ment pieces in new facilities or segregated buildings in which no insulation containing free asbestos was 4.4 Condition IV. Where insulation is being replaced in an area of unknown asbestos content, by asbestos-free insulation, identify the replacement insulation by a strip of tape placed around the circumference of the pipe finish or at strategic locations on equipment pieces. Where a line running from wall-to-wall is reinsulated, place a piece of tape at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a portion of the insulation is replaced, identify the junction of the existing and replacement insulation by parallel pieces of tape around the circumference of the finish. Place one piece of tape to indicate that, front that point on, the insulation is asbestos-free. Place a second piece of tape with the arrows orientated to indi cate that, from that point on, the insulation may contain free asbestos fibers. SUBCOMMITTEE NO. 25 UCC 015727 SN 218 P Page 2 IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION This Page Rev April 1984 -- 5. HANDLING INSULATION When handling, fabricating, or removing insu lation in the absence of positive knowledge that it is asbestos-free, assume that it contains free asbestos fibers, and follow S4T. 6. TAPE 8.1 Specifications (see Figure 1) a. Supplied in rolls. b. Pressure-sensitive contact cement backing -- developed for aircraft use. C. N - 90 tape material - developed for aircraft use. d. Provide slit in release paper for easy removal. #. ASB letters and arrow red, repeated on 3-inch intervals, on white background. NA letters and arrow blue, repeated on 3-inch intervals, on white background. Letters are approximately 1-inch high. 7. TAPE SUPPUERS (PARTIAL LIST) Davis Printing Co P. O. Box 6% Camden, SC 29029 (803) 432-1901 Top Flight Corp 165 East 9th Avenue York, PA 17404 (717)843-9901 T & B Westline Division of Thomas & Betts Corp 220 South Rose Street Los Angeles, CA 90012 (800)421-8618 Sheriden Safety Supply 7029 Huntley Road Suite E Columbus, OH 43229 (614)888 - 8040 York Tape and Label Corp P. O. Box 6805 ' Columbia, SC 29260 (803) 788 - 2635 226 < ( NA s Nonosbsstos Bearing FIGURE 1 - TAPE FOR IDENTIFICATION UCC 015728 BUSINESS CONFIDENTIAL UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM April 8, 1987 ^-yy^ TO: Plant Insulation Representatives D. D. Barnette, 512 R. L. Boggess, 514 J. E. Boley, 380 D. L. Carrick, 519 A. W. Keene, 510 G. H. Reinhart, 312 R. E. Woodcock, 515 Maintenance Managers B. M. Gable, 581 Robert Gauvin, 503 P. D. Gossage, 511 R. J. Hampson, 312 George LeBlanche, Moses Lake B. A. Mallory, STAR Doug Priegen, Mobile Carol Prince, 513 John Turner, Prentiss CC: L. E. Calvert, 803 S. W. Clark, 511 G. B. Elder, 511 R. W. Engle, 511 T. E. Hanning, 511 0. J. Hymel, 515 R. W. Maddox, 511 D. D. Miller, 512 C. C. Neely, 511 , M. Patel, 511 MOC FROM: H. G. Clem SUBJECT: REQUEST FOR COMMENTS ON VISUAL IDENTIFICATION CODING OF WEATHER BARRIERS INSTALLED OVER ASBESTOS-FREE INSULATION You are invited to participate in our request for comments on asbestos-free visual identification coding options for metallic and mastic weather barriers for our chemical plants and related facilities. Background information on this subject was included in my recent report.H) 0074J Clem, H. G., Identification Code for Asbestos-Free Insulation, February"!3, 1987, file No.: T8495. UCC 015729 2- - We are responding to concerns at some of our petrochemical faci lities on methods of quickly identifying insulated piping and equipment that are known to be free of asbestos. Visual identification coding of weather barriers is not mandated by government regulations, but it would provide a positive means of defining areas of asbestos-free or non-hazardous insulation for personnel involved in plant operations and maintenance. Our intent is to write a new recommended or location practice for the Thermal Insulation Manual incorporating the preference for each major location on asbestos-free insulation identification coding. Your responses to the attached questionnaire will greatly assist in this effort. If all insulation at your facility is known to be free of asbestos, please note this in the "Remarks" section of the form. To avoid multiple responses from each plant, each designated plant insulation representative is requested to discuss this subject with department heads and plant management to obtain agreement for a given location on one or a combination of asbestos-free insulation visual coding methods. Actual samples of asbestos-free insulation and arrow directional identification tapes, and corrugated and flat "stucco" embossed aluminum weather barrier are enclosed for reference in your discussions with plant personnel. Our deadline for responses is May 15, 1987. If there are any questions, please call me at UNICOM 721-3689. HGC:es ATTACHMENT INDEX: Attach to File No.: 18495 0074J UCC 015730 REQUEST FOR COMMENTS ASBESTOS-FREE INSULATION VISUAL IDENTIFICATION CODING Check the asbestos-free insulation coding preference for your UCC location from the options listed below: 1. Identification Tapes: a. "NA with arrows" tape b. "ASBESTOS-FREE INSULATION" plus separate directional arrow tape 2. Color Coded Weather Barrier: a. Blue b. White c. Green 3. Embossed Metal Weather Barrier: a. Stucco Texture - Flat b. Stucco Texture - Corrugated 4. Alternative Coding Preference: (explain in remarks section) REMARKS: Please return this questionnaire to Harold Clem, Bldg. 740-3320, Location 511 by May 15, 1987. 0074J UCC 015731 NAME UCC LOCATION DATE INTERNAL CORRESPONDENCE UC 149 18585 P. O. BOX 471, TEXAS ClTY, TEXAS 77590 TO: W. W. Long, B1 CC: VI. VI. Henderson, B1 J. A. Roberts, B62 R. W. Engle, Tech J. F. Riffle, Tech G. L. Rivera, B1 MOC - No Attachments DATE: 4-2-87 SUBJECT: Asbestos Containing Gaskets & Packings/ Variance Procedures INDEX: 18,32,33,50,112,113,137 157,357 Dear Wally: Attached are documents fron G. B. Elder and C. C. Neely on the phase out of asbestos-containing materials within UCC. We are being asked to discourage the use of asbestos-containing gaskets and packing new, in order to minimize disposal problems in the future. Although asbestos materials can still be bought and used, they will soon become increasingly difficult to obtain (be cause of Suppliers insurance premiums), and the price is bound to soar. As we have stated previously, the only approved non-asbestos substitutes for gaskets and packing are Teflon and Grafoil. These can be used in almost all of the chemicals handled at Texas City. As with all materials though, they have their service limitations. Among these are teflon's upper temperature limit of about 450F and Grafoil's lew resistance to sulfuric acid. The Corrosion and Materials Group should be consulted when in doubt on specific cases." This change will undoubtedly highlight the concern more and more people are having. Specifically, hew to document substitutions or variances to the Valve and Piping Specifications. Many substitutions are upgrades in material (i.e. Grafoil for asbestos) or due to discrepancies in the specifications. I would venture to say there are numerous substitutions to Valve and Piping Specs, daily in maintenance work. In most cases, these are perfectly acceptable from a technical standpoint. However, there may be little or no documentation. The Variance procedure in the Plant Engineering Criteria Manual and the Plant Procedure l-G-13 Facilities/Operations Change Review are designed primarily for project work. Because of all the signatures and reviews required, there is a tendency not to follow these procedures for seemingly minor variations to a mandatory standard. UCC 015732 I reccnmend the Texas City Plant develop a sinplified procedure to document apprqved material substitutions or variances to mandatory standards. Other wise, there may continue to be a problem with proper documentation. I'll be glad to discuss these issues with you at any time. Sincerely, 7^. X T. F. Laundrie TFL/vb UCC 015733 UNION CARBIDE CORPORATION SPECIALTY PRODUCTS GROUP RO BOX 04637; CLEVELAND, OHIO 44101 PHONE: [216] 520-3000 [BOO] 622-4322 J.C. Arnold (CPD-Danbury) Dr. L.M. Baker (UCC-Danbury) R. M. Berzok (UCC-Danbury) S. Brier (UCC-Danbury) W.J. Burroughs Dr. P.D. Coulter T. D. Finigan (UCC-Washinaton) J.C. Howell (CPD-Danbury) C.F. O'Brien (UCC Law-Danbury) J.D. Griffith R.M. Ross C.H. Pelanne R. Wishart (UCC-Danbury) February 3, 1987 Alternate Materials Institute (AMI) Gentlemen: Minutes for the subject non-asbestos coalition's meetings of December 4, and 18, are enclosed. A historical background and executive summary of these two meetings follows: Historical Background: The Goal of the AMI is to accelerate changeover from asbestos to non-asbestos products. A final regulation on banning asbestos products is scheduled to be promulgated by the EPA the end of 1987. Organization of the AMI was driven by DuPont's KEVLAR Friction Products Group. They have provided seed funding and continue heavy resource support. Norm Griffiths, their legal counsel, has attended all meetings. UCC's involvement through the GRAFOIL Group was solicited by DuPont via our joint involvement in the Fluid Sealing Association (FSA), a trade group of suppliers of fluid sealing (packings, gaskets, etc.) products. We are charter members and sit on the board of directors. Current involvement consists of Tom Finigan and myself. Currently, the membership is small, five companies, and membership efforts have been encumbered by the need for immediate focus on EPA issues rather than by-laws and membership fees. The latter issues have been resolved and active recruitment is underway. The AMI is still in its formulative stages and ultimate viability still a major concern. Our involvement is consistent with EM & TS Division's Program, chaired by Clyde Neely, to stop purchase of asbestos packing and gasketing products for the C & P Business Groups Plants by end of 1988. The consequent replacement of asbestos-based materials with UCC 015734 GRAFOIL, recognized as a more effective fluid sealing product, also further demonstrates our commitment to the Air Toxic Control Policy. Executive Summary Under highly qualified guidance by E. Bruce Harrison, this is a very professional effort that justifies continued and expanded support, not only because of "what's in it" for the GRAFOIL Products Group, but other potential CPD and Corporate interests. Some selected product possibilities in this category include: CPD Boron Nitride - Friction Products Graphite Powders - Friction Products UCC Silane Coupling Agents? Urathanes? Polyolefins? Others? There are undoubtedly other primary chemicals whose expanded use is related to displacement of asbestos fibers. Appendix I shows information gaps in ICF's (EPA's Contractor charged with determination of the economic impact of the change over to non-asbestos) list of material substitutes "known to them". Whether a primary substitute such as GRAFOIL or a secondary material used as part of the substitution composition or technology full benefits to UCC need to be established to get maximum benefits from involvement and "bang for our buck". Direction and guidance relative to other UCC products that might benefit from involvement is requested from Dr. Baker. The sooner the ban on asbestos is implemented the greater the opportunity for existing viable substitutes, such as GRAFOIL, to capitalize on the market opportunity. New technology substitutes will diminish the opportunity with time. The December 4, Meeting with IFC|EPA and the December 18, meeting with ICF were timely and brought an immediate opportunity to correct|enlighten thisregulatory agency on packing and gasket products with focus on flexible graphite within the AMI (A direct Union Carbide response will focus on GRAFOIL Brand Flexible Graphite.) An example of misinformation obtained by ICF, which would have been submitted to EPA is "Garlock BlueGuard is the only effective non-asbestos gasket material for high temperature". This statement is false and this KELVAR based product has been a failure. Not only does this type of misinformation distort current UCC 015735 "state-of-the-art" knowledge but when reported in serves to erode EPA's credibility and further the case for the asbestos lobby via the Asbestos Information Association (AIA). Their current focus is challenging the cost of EPA's proposed ban on asbestos as well as potential health implications of the substitutes. The AIA, of course, is counter proposing close regulation and continued use of asbestos. UCC, a member of AIA before our*sale of the CALIDRIA Operation, is no longer on the membership list. The ICF computer model for establishing cost of replacement is grossly inadequate and will lead to erroneous conclusions relative to the "cost per life saved" EPA criterion (See Appendix V). EPA considers < $2.OMM|1ife as justified. Comments on these inadequacies will be part of our direct response to the EPA. The immediate and positive response by the EPA to formation of the AMI is displayed in their press release. Appendix VII. Outside legal counsel has now been appointed because of DuPont's concern about potential conflict of interest (and cost). Minutes of the January 13th meeting are forthcoming. PSP(kkf Enclosure UCC 015736 Meeting Summary December 18, 1986 Page 2 Battelle Memorial Institute has a subcontract to study the efficacy, etc., of substitute materials in automotive brakes. There is a first draft which is undergoing peer review by the American Society of Mechanical Engineers. A draft should be available in March 1987. Friction. Products Using a table of data gaps that was prepared by ICF, Mr. Bansal reviewed questions listed under the friction products category. In each of the areas discussed below, ICF needs more information on the aftermarket for brake components. How long will it actually take to accomplish a switch to non-asbestos products? Do they just have to pass the 105 standard and be dimensionally the same with the same coefficient of friction? Drum Brake Linings Mr. Bansal told AMI members that the consensus is that semi-metallies will take over the drum brake lining market. However, most AMI members present disagreed , stating that non-asbestos organics (NAOs) will probably take most of the market. Carbon fibers are also potential substitutes' for asbestos in drum brake linings, but were not listed as substitutes known by ICF. Ashland will provide supplementary sustantiation to ICF directly. Rich Gould (DuPont) asked if AMI can provide EPA with information that discusses the varying roles asbestos plays in brake components -- as a filler and insulator as well as a friction conponent. Asbestos and the substitutes are both used with different ingredients in a wide range of formulas. ICF welcomed any information that will improve their analyses. Brake Blocks, Clutch Facings and Friction Materials Several AMI members noted that ceramic fibers, carbon fibers and graphite (synthetic/particulate) should also be listed as ingredients in the NAOs for brake blocks, clutch facings and other friction materials. UCC 015737 Meeting Summary December 18, 1986 Page 3 Each said that exact make-up, that is, percentage of materials used, of these NAOs is not known, but clearly these substitutes are being used in these applications as NAO ingredients. Information on the substitute products used in NAOs will be supplied to ICF by the member companies directly. Disc Brake Pads Mr. Boyer noted that a carbon-c.arbon complex is being used in aircraft and some semi-metallic brakes are used for small aircraft. Mr. Boyer also said that the racing industry has developed some new carbon-carbon brakes but they must have a rotor of carbon to be technically feasible. Ashland will provide information to ICF on this application. . ' Gaskets and Packings Mr. Petrunich reviewed the conventional types of packing materials: braided fibers/yarns made of aramids, PTFE, carbon, and graphite; and expanded PTFE, ceramic fibers, glass, and PBI. Non-conventional substitutes for packing materials include PTFE and flexible graphite Some conventional substitutes known for gaskets are aramid fibers, micas, mica/graphite, glass, carbon fibers, and cellulose. Non-conventional substitutes include PTFE, (solid & filled glass and graphite), flexible graphite and expanded PTFE. Processes used to manufacture gaskets, both the "beater add" and compressed types, were discussed. With regard to ICF's table, Mr. Petrunich noted that ICF's information on high temperature gasketing material on the market is incomplete. He will attempt to provide supplementary data and information on the temperature ranges of gaskets. UCC 015738 Meeting Summary December 18, 1986 Page $ Other Miscellaneous Uses Mr. Gould will provide more information on use of Kevlar in missile liners. Mr. Boyer will provide information on carbon fibers used in flooring felt, missile liners, and textiles. Followup Submiselong AMI members agreed to try to provide the information ICF and EPA need in mid-January 1987. The information AMI members agreed to gather and submit will not be shared among the companies. It will be sent directly to ICF/EPA and AMI, which will protect the confidentiality of the detailed data and develop generic submissions for the Institute itself. Submissions to EPA containing confidential business information should be sent to the Document Control Officer, return receipt requested (e.g., registered mail or Federal Express). The materials themselves should be contained in an inner envelope addressed to Tony Bansal at ICF marked as follows: "CONTAINS CBI. TO BE OPENED ONLY BY ADDRESSEE." . AMI020LQP UCC 015739 ALTERNATIVE MATERIALS INSTITUTE MEETING WTH EPA AND ICF REs ASBESTOS SUBSTITUTES NAME December 18, 1986 ATTENDANCE LIST CflffAHY Wilfred Kenan D. Chris Boyer Richard Krock John Newman Glen Wrap Richard Gould Tony Bansal Pete Petrunich Tom Finnigan Cheryl Morton Ernie Rosenberg Christine Augustyniak Asbury Graphite Ashland Ashland Ashland Carborundum (Standard Oil) DuPont ICF, Inc. Union Carbide . Union Carbide AMI (E. Bruce Harrison Co.) AMI (E. Bruce Harrison Co.) USEPA OTS/ETD ARM027.LQP UCC 015740 `appendix II hVjll ALTERNATIVE MATERIALS INSTITUTE AMERICAN SUPPLIERS OP NON-ASBESTOS PRODUCTS GENERAL BUSINESS MEETING SUMMARY ATTENDANCE: List Attached DATE;TIME;PLACE: December 4, 1986; 10:00 AM; Standard Oil Company 1001 22nd Street NW Washington, DC 20037 Purpose of Meeting As agreed at the October 31 meeting, members of the Alternative Materials Institute met to discuss efforts of Phase I of the project and other business matters related to the establishment of the coalition. Name of Coalition After brief opening comments by Tom O'Brien (DuPont), Jeff Conley (E. Bruce Harrison Company) presented the name created for the coalition, the "Alternative Materials Institute" with the tag line: "American Suppliers of Asbestos-Free Products." Jeff explained the basis for the selection and then showed the art work done. It was decided by the members present that the term "asbestos-fVee" would be replaced with "non-asbestos" as the former may imply that not even trace amounts of asbestos would be present in products manufactured by member companies. It was also decided that the color of the letterhead would be changed to blue. Update on Activities Ernie Rosenberg (E. Bruce Harrison Company) gave an update on the rulemaking. EPA had expected AIA to petition for additional cross examination but instead EPA has received an AIA request to withdraw the entire rule and go back to start. (The AIA letter was distributed to those present). EPA is expected to deny the request. After that, EPA will either close the hearings phase of the rulemaking and ask for final written comments or it will allow AIA time for additional cross-examination of EPA's contractors. In any event, EPA will re-open the entire record for comment before ending the opportunities for formal comment. UCC 015741 605 Fourteenth Street, NW, Suite 900, Washington, DC 20005 . Telephone 202 737-1419 Meeting Summary December 4f 1986 Page 2 The final comment period Is expected to be open during the first quarter of 1987* During that period the coalition should plan to submit its initial, formal comments with data that affects how substitutes are characterized. EPA is engaged in several efforts to obtain additional information on asbestos substitutes before Issuing a final rule. Ernie reviewed several ongoing projects on non-asbestos materials, their scope of work and deadlines, (as presented in the summary table prepared by EBH Co). , ICF has an EPA contract to conduct a comprehensive review of asbestos substitutes. The American Society for Mechanical Engineers (ASME) has a subcontract reviewing feasibility of substitution in asbestos brake applications. Battelle Columbus-Laboratories is, in turn, ASME's subcontractor. It has done the basic research and drafting. ASME is providing peer review, already under way. (A list of peer review panel members was provided to AMI members.) With regard to the ASME/Battelle contract, it was agreed that certain members of AMI would contact peer review members that they know personally to get more information on the draft report's contents and to determine what the general consensus is among panel members. In connection with another effort to collect data on durable fibers, the EPA Health and Environmental Review Division (HERD) has prepared a document on the biological testing of durable fibers (of which some data on substitutes is going to be extracted). HERD is also drafting a hazard assessment for fibers. ICF also has a contract in connection with this proceeding to do an exposure assessment on all durable fibers. These ^ongoing projects will probably reveal new information that will affect how substitutes are characterized in the docket and present a new, separate area of effort for the coalition. We have established contacts with ICF and several EPA staffers and we expect information sharing forums to evolve. To prepare for these forums, Ernie briefly reviewed a guideline that he prepared on dealing with EPA contractors. , EPiLCgntrastsca Bob Dresser, Vice President, and Tony Bansal, Project Manager, from ICF, joined the group for lunch along with Bruce Sidwell from EPA's Chemical Evaluation Branch. Mr. Sidwell gave a brief overview of the rulemaking, in particular, the efforts to collect information on substitutes and the Agency's general interest in durable fibers. His discussion led into the ICF's contract work. UCC 015742 Meeting Summary December 4, 1986 Page 3 Mr. Dresser described the scope of work of the ICF contracts and explained how ICF's work fits Into the overall framework of the Regulatory Impact Analysis that his company will assist EPA in developing. Tony Bansal, who actually manages the project (on substitutes, their performance and availability), discussed specific data gaps that his group has encountered during the course of their work. Tony also described the methodology used for identifying and collecting data on asbestos substitutes. , The gaps in ICF's data were surprisingly large. For the most part, ICF has used questionaires directed to the fabricators of products using asbestos or substitutes and has not had prior contact with the materials producers. Generally speaking, ICF needs data on costs, useful life, and projections of the future market share that substitutes would take as ICF's goal is to project use of substitutes for each application. It was apparent after this discussion that AMI member companies have critical information, without which the final ICF report would be deficient in its findings on the availability of substitutes and the costs of asbestos replacement. The members agreed that the coalition and ICF would conduct several information sharing sessions (by application) possibly the week of December 15, providing that EPA approves of these meetings. Bvlaws Ernie and Jeff reviewed the bylaws that were developed for the coalition. It was agreed that although membership by. companies strongly tied to asbestos and AIA members might present tactical and public affairs problems, AMI will have to accept any company that meets its membership criteria. Norm Griffiths (DuPont) agreed to examine the question of whether active opponents of AMI's goals and purposes can be legally excluded. With regard to legal counsel for AMI, Ernie told the group that we had been informed by our current legal counsel that they can no longer represent AMI due to an apparent conflict of interest. Norm also agreed to work on obtaining legal counsel along with David Litvin (Standard Oil) and another person to be nominated by Chris Boyer (Ashland). UCC 015743 Meeting Summary December 4, 1986 Page 4 Membership and Dues Ernie discussed our membership development efforts to date. So for, five companies have either committed or given a strong indication that they will do so. In addition to Ashland, who confirmed its membership at the meeting, these companies include DuPont, Carborundum, Fhodes-American, and Onion Carbide. Engelhard and NYCO and a number of potential associate members are still prospects. A more intense effort may be required to get such companies to join -- possibly an AMI newsletter, minutes from this meeting or an invitation to the upcoming meetings with EPA contractors. With regard to new prospects, we still are recommending that initial contacts come from member companies, rather than coalition staff. Also discussed were some of the specific legal concerns of the companies like Owens-Corning Fiberglas, who are involved in asbestos ligitation and fear involvement with AMI. AMI's firm commitment not to attack asbestos or to address the risks presented by asbestos has not been enough to allay these companies' legal staffs. Ernie suggested that lawyers from AMI member companies contact those companies with legal concerns. Further, it was agreed that the appropriate marketing person may have to be contacted at Celanese, Bethlehem Steel, Monsanto, Amoco and PPG, as it appears that in these cases we may not yet have been in contact with the right people. Other companies that members agreed to make initial contacts with include Allied, Pyron Corporation, W.L. Gore, and W.R. Grace. Pete Petrunich (Onion Carbide) agreed to forward the Fluid Sealants Association's member list to be used for membership development. Technical Committee Persons nominated to serve on AMI's technical committee included Bill Breitsman (Carborundum), Ted Merr (DuPont), Pete Petrunich (Union Carbide) and on a tentative basis, Chris Boyer (Ashland). Technical committee members will be responsible for forwarding to AMI rebuttals to information in the docket by the week of December 15 as well as preparing for the upcoming meeting with ICF and EPA. Next Meeting It was agreed that the next general meeting of the Institute will be on January 6, 1987. If the agenda is full, members should plan to arrive in town the night before the meeting and start the meeting at 8:30 AM. (The meeting date was subsequently slipped to January 13.) ami013.1qp UCC 015744 NAME ALTERNATIVE MATERIALS INSTITUTE December 1986 ATTENDANCE LIST CflffABI D. Chris Boyer Bill Hettinger John Nevnnan Bill Breitsman Buzz Peters David Litvin Richard Gould Tom O'Brien John Roberts Norman Griffiths Norm Soep Pete Petrunich Tom Finnigan Jeff Conley Cheryl Morton F.rnie Rosenberg Ashland Ashland Ashland Carborundum Carborundum Carborundum (Standard Oil) DuPont DuPont DuPont DuPont Rhodes-American Union Carbide Union Carbide E. Bruce Harrison Co. E. Bruce Harrison Co. E. Bruce Harrison Co. ARM027.LQP UCC 015745 APPENDIX III r^n ALTERNATIVE MATERIALS INSTITUTE AMERICAN SUPPLIERS OF NON-ASBESTOS PRODUCTS ATTENDANCE: DATE;TIME;PLACE; MEETING SUMMARY U.S. Environmental Protection Agency, ICF and Alternative Materials Institute (List Attached) December 18, 1986; 10:00 AM; Standard Oil Company 1001 22nd Street NW Washington, DC 20037 Purpose of Meeting As agreed at the December 4 meeting, members of the Alternative Materials Institute (AMI) met with Christine Augustyniak (USEPA) and Tony Bansal (ICF, Inc.). ICF is an EPA contractor conducting a review of the cost, efficacy and availability of materials which could substitute for asbestos in the applications under review by EPA. The agenda for this meeting was to discuss Just two of those applications: friction products and gaskets and packings. (Note that after introductions, Ernie Rosenberg (AMI) read and provided each person attending with a statement cautioning against discussion of issues which might raise antitrust questions such as prices, projected market shares, and costs.) The PwlemaklnB-Cost. Model.Data Before addressing the product categories, a general discussion was held of the computer model that EPA and ICF are using to estimate the costs of replacing asbestos and the model's specific assumptions. In her summary of the rulemaking, Ms. Augustyniak stressed the fact that the cost model does not fully account for life-cycle costs and that it is conservative -- it will tend to overstate replacement cost. Mr. Bansal said that he could provide a list of data Inputs for the cost model, but cautioned AMI members that the basis of any data submitted to ICF and/or the Agency should be included. UCC 015746 605 Fourteenth Street, NW. Suite 900, Washington, DC 20005 Telephone 202 737-1419 APPENDIX IV SCIENCE Volume jh Number 4779 l.rfN-r- Table 7.2 Estimated individual lifetime rules from a continuous exposure to asbestos at 0.0004 fiber/ cm*1 2(a median dose) or 0.002 fiber/cm3 (a high dose). ftj*k from Expoaore to AeImmm In the light of the Environmental Protec tion Agency's proposed ban on the remain ing uses of asbestos, it should be of interest to Science readers that there is a significant error in certain risk estimates of low-level asbestos exposure. We report a mistake we discovered in the mesothelioma risk assessment portion of the National Research Council (NRC) report Asbestiform Fibers: Nonoccupational Health Risks (l). The report's authors proposed, on the basis of the analysis of Pcto, Scidman, and Selikoff (2), a cumulative incidence function,/(r,<f) * cd(t - to)*, for equation 7 (p. 209) of the report, where t is age; r - r0 is the time since first exposure at age r0; cd is b, a constant depending on the type of asbestos exposure for workers exposed at dose level d; and k is a constant. The values of the constants k and b (and hence c) were intended to be chosen from those calculated by Pcto et al. by using maximum likelihood fitting to several data sets, including SelikofPs 1979 data (3) on insulation workers. Unfortunately, the analysis of Pcto et al. seems to have been misread, and as a conse quence the lifetime risk ofmesothelioma has been consistently underestimated by a factor approaching 20. Pcto et al. fit observed death rates to the function b(t - r0)* and found, for example, that when k is 3.2 and b is 4.37 x 10'*, the Selikoff data are repre sented. The NRC chose these values of t and b for direct insertion in equation 7 to illustrate the cumulative incidence function, despite the fact that the Pcto et al. death rate is the time derivative of the function Iit.d). If the values of b and k are as determined by Pcto et al., then the resulting cumulative incidence function (cumulative death rate in the absence of competing causes) becomes l(t,d), which is equal to (r-fb)**1 ol! (k r 1) or (f - rb)**` * 1),-rather than equation 7. To grasp the magnitude of this correc tion, we observe that lifetime risk of meso thelioma, calculated (presumably incorrect ly) on page 221 of (1) for an admittedly hazardous exposure profile, is as follows: school risk, 21 x 10"*; background risk, 46 x 10'*; and total risk, 67 x 10'*. These become, after correction, school risk, 399 x 10"*; background risk, 800 x 10'*; and total risk, 1199 x 10"*. A major implication of this correction is that estimated lifetime mesothelioma risks arc nearly 20 times larger than those shown n the NRC report. Therefore, mcsothelio- Disease Exposure group Lung cancer Male smoker Lung cancer Female smoker Lung canter '' . . -Male nonsmoker Lung cancer Female nonsmoker Mesothelioma All groups ma risks would appear to dominate those of lung cancer for $hc exposure profiles illus trated in chapter 7. Jekay Aroesty Kathleen Wolf Engineering and Applied Sciences Department, Rand Corporation, Santa Monica, G4 90406-2138 REFERENCES 1. Board on Toxicology and Environmental Health Hazards. National Research Council. Asbemjbnm Fiben: SoruccnpantruU Htnlih Ruts (National Academy Press, Washington. DC. 1984). 2. V. Pcto. H. Scidman. 1. Selikoff, Br. /. Conor 45. 124(1982). 3. I. ). Selikoff. E. C. Hammond. H. Scidman. Ana. S.r.AaU. So. 330, 91 (1979). Response: Aroesty and Wolf arc correct in pointing out an error in the calculation of mesothelioma risk due to asbestos exposures in the National Research Council (NRC) report Asbestiform Fibers: Nonoccupational Health Risks (1). The error was in using the simple (annual) incidence function for risk rather than the cumulative incidence tunc- tion. As a result, equation 11 on page 216 of the NRG-report should base read: ... L = r(0.004) (73)**1 `(k - 11 rather than L = c(0.0004) (73)* Using the correct function increases the estimated lifetime risks for mesothelioma by a factor of 17.4. Aroesty and Wolf mention that the corrected mesothelioma risks would now dominate those of lung cancer in the environmental estimates made in the NRC report (table 7.2). This, however, is not the case because the published lung cancer risks were also understated. A multiplier of 4.56 was used to adjust risks for mesothelioma arising from occupational exposures of 1920 hours per year to risks from general environ mental exposures of 8760 hours per year. This was not done for lung cancer. Using this same multiplier to estimate lifetime risks for lung cancer resulting from asbestos ex posure increases the estimated projections bv a factor of 4.5. UCC 015747 Estimated individual lifetime risk (x 10*) Median exposure (0.0004 fibetfem3) 292 105 27 14 156 High exposure (0.002 fiber/ cm3) 1459 524 132 68 780 Incorporating these corrections increases the estimated risks of both lung cancer and mesothelioma (2). The table above is a correction for able 7.2 in the NRC report. It should also be pointed out that when values of k and c arc used which reflect the correlation between their measures, the range of risk estimates in able 7.2 of the NRC report is greatly reduced. The NRC regrets these errors and urges persons working with the risk estimates to note the new values in the able above. We thank Aroesty and Wolffor calling attention to this matter. Lester Breslow Steven Brown John Van Ryzin Committee on Nonoccupational Health Risks ofAsbestiform Fibers, Board on Environmental Studies and Toxicology, National Academy ofSciencesNational Research Council, Washington, DC 20418 REFERENCES 1. Board on Toxicology and Environmental Health Hazards. National Research Council. Ajbtmfimn -Ftiers Smacarpnnmnt Htnitb Rub i National Acadcm*' Press. Washington. DC. 19841. 2, Airborne Asians Htmlth Ancamtni Update tEPA/ 600/8-84.003F. Environmental Protection Agency, Washington. DC. June 1986). '^pPENDIX V DATA FEDUlF&tMTS TOR THE ASBESTOS FEGULXTOfV COST MODEL 1. Year of data 2. Price per ton of asbestos fiber For each asbestos product market: 3. Product Asbestos Coefficient, i.e., tons of asbestos used per unit of output. 4. Price of the asbestos product. (Total price including purchase and installation costs. If O & M costs are available, please note separately.) 5. Quantity of product produced domestically. 6. TAfe of the asbestos product. 7. (Xiasi-rents per unit of output. (Ibis is the difference in the selling price and the average variable cost.) 8. Life of the quasi-rents. 9. Consumption-Production Patio, i.e., the ratio of domestic consumption to domestic production of the asbestos product. Alternatively, quantity of product consumed domestically is sufficient. For each substitute product: 10. Price of the substitute product. (Total price including purchase and installation costs. If O & M costs are available, please note separately.) 11. Life of the asbestos product. 12. Market, share of each substitute product. This refers to the share of the existing market that will switch to the substitute, given the non-availability of the asbestos product. UCC 015748 APPENDIX VI ' December 12* 1986 TPITKTIVH LIST OP CAT8Q08IB8 OF ASBESTOS PRODUCTS X. Friction Products Disc Brakes (LH) Disc Brakes <H) . Drum Brakes Brake Blocks Automatic Transmission Component* Clutch Facings Friction Haterials 2. Gaskets and Packings Beater-add gaskets ' Sheet gaskets Packings 3. Coatings and compounds Roof Coatings and Cements Non-Roofing Adhesives* Sealants, and Coatings 4. Asbestos-Cement Products A/C Pipe A/C Sheet. Flat A/C Sheet, Corrugated* A/C Shingle 5. Paper and Felt Products Millboard Pipeline Wrap Roofing Felt Electrical Paper Flooring Felt* Specialty Paper* Coenerclal Paper* Rollboard* 6. Textile Products Cloth Thread, Yarn and Lap 7. Other Products Reinforced Plastics Missile Liner Sealant Tape Diaphragms Acetylene Cylinders Fuel Cells V/A Floor Tile* Repackaged Fiber* * No longer being produced or sold in the U.S. 3040D UCC 015749 APPENDIX VII An Inside Wnshinfton Publiconon An exclusive report on the U.S. Environmental Protection Agency Voi. No. 2 January 9. 19*7 INDUSTRIES PRODUCING ASBESTOS SUBSTITUTES HAVE BANDED TOGETHER TO PROMOTE their products tod to counter what they consider "erroneous" information about the safety and availability of asbestos alternatives. EPA last January proposed to ban five major asbestos consumer pro ducts and phase out remaininr uses over a 10-year period (Inside EPA, Jan. 31, plO). The agency is re quired to show when substitutes will become available in order to ban specific products, and the new Alternative Materials Institute seeks to provide EPA, as well as industry and consumers, with the most accurate and current information. A spokesman for AMI this week said the need for such a group became evident last fall when EPA records released for cross-examination hearings (Inside EPA, Oa. 10, pS) revealed "a lot of erroneous in formation" about the risks, costs and availability of asbestos substitutes! The source said that while AMI "is not in this to make the case against asbestos," the group does seek to promote its products during the transition period as public awareness increases about asbestos-linked health risfci." - Initial members of the group are Du Pont, Standard Oil, Rhodes-Ameri&rif, Akhland Oil and Union Carbide. They represent manufaaurers of asbestos substitutes that include aramid fibers, ceramic fibers, carbon fibers, flexible graphite and steel fibers used in automotive brakes and transmissions; gaskas and packings; and adhesives and sealants. * ' * \ t -L. . . 14 INSIDE EPA -- January 9. 19*7 UCC 015750 UNION CARBIDE UNION CARBIDE CORPORATION SPECIALTY PROOUCT5 GROUP pq box 34637. Cleveland, oho <nncn. us^v. TELEX 810-421*0047 ANSWER BACK -- UC ELECT UO PHONE: (2161529-3300 March 4, 1987 Document Control Officer ICF, Inc. 1850 K Street NW Washington, DC 20037 Attention: Tony Bansal Project Manager RE: Asbestos Substitute Packings and Gaskets Flexible Graphite Dear Tony: This letter's purpose is to address the subject issues, more specifically to provide information relevant to Union Carbide's GRAFOIL Brand Flexible Graphite, which is a functional substitute for asbestos based packing and gasketing materials. Packings are generally used to seal various fluids when some movement (dynamic) occurs between members of a fluid .containing device. Examples include valves and pumps employed in the electric power, petroleum refinery, petrochemical, chemical, pulp and paper industries. Gaskets are cut and fabricated from gasketing materials and are generally used to effect a static seal, for example between pipe flanges, vessels, or within a valve design (body to bonnet) used in these industries. Gaskets and other semi-static seals, such as those in an exhaust gas recirculating valve (EGR) and transverse engine flexible exhaust connection, also are employed ^extensively *to seal fluids in internai combustion engines. Example include head gaskets and exhaust manifold gaskets used in automobiles, trucks, auxiliary electrical power systems, lawn mowers, and other internal combustion engines. This memorandum will focus on gaskets. Gasketing Material The majority of gaskets are either non-metallic sealing material alone or a non-metallic reinforced with a metal component. Conventional non-metallic, asbestos based gasketing is elastomerically bonded and processed via two major methods; the "Compressed" and "Beater Add". The Fluid Sealing Association (FSA), a trade association which includes manufacturers of packing and gasketing materials defines "the two in their*Non-Metal lie Gasketing Handbook, currently being revised, as: UCC 015751 Beater Add: A manufacturing process for making non-metalllc sheet employing a paper making process, using fourdrlner or cylindrical paper machines. Compressed: . ....manufactured on a special calender, known as a "sheeter" In such a manner that the compound is "built up" under high load, on one roll of the "sheeter" to a specific thickness. With either process, asbestos fibers, the principal reinforcing fiber, are incorporated within various elastomeric binders and other fillers to form the material. Compressed products have been more extensively used in high performance (temperature and pressure) industrial (power, petroleum refining, etc.) service because they inherently contain more asbestos. "Beater Add" generally have been used more extensively for internal combustion applications such as head gaskets. This class of material also is used as the sealing component in spiral wound gaskets, which are employed extensively in high temperature|pressure industrial applications. Appendix I describes the basic design of a spiral wound gasket. Flexible graphite is a solid, non-fibrous material that can functionally replace the above elastomeric bonded asbestos products. Appendixes II and III overview process and property differences between flexible graphite and the conventional asbestos-based, elastomerically bonded gasketing. Flexible graphite generally has been accepted as the only proven functional replacement for asbestos based gasketing for essentially all applications and services. GRAFOIL Flexible Graphite also has been proven to provide value benefits to the user which represent advantages over the asbestos based products. These will be quantified later. The FSA service temperature limits for asbestos and non-asbestos gasketing are shown in Table I. Note the superiority of flexible graphite over the conventional asbestos and non-asbestos based elastomeric bonded products. The latter are processed with various fiber replacements for asbestos and fillers. Also, as noted in Appendix II and III fluid temperature limits for flexible graphite are independent of gasket compressive load, and thereby, fluid pressure, whereas all "Compressed" and "Beater Add" gaskets are temperature and pressure dependent. As temperature increases their pressure capability decreases. Principal fiber reinforcements for the compressed non-asbestos gasketing are aramids and glass. Compositional differences for these products are discussed in Appendix IV. Useful 1 temperature ~and pressure ranges for asbestos based and non-asbestos gasketing materials are shown in Table 2. Note that flexible graphite covers the entire range and is the only non-asbestos material that is suitable for the high temperature range. Note also that compressed asbestos is manufactured in several quality]price ranges. UCC 015752 -2- Economic Impact Current prices for flexible graphite gasketing material range from 2.0 - 3.0 times, on weight basis, that of premium compressed asbestos (CA) for the same gasket thickness. Typically a CA sheet contains 801 asbestos by weight. Density of the flexible graphite Is approximately 60* that of CA and in many applications a thinner (than CA) flexible graphite gasket can be used because of its superior sealability e.g. reduced leakage. Examples of this improvement in leak tightness are shown in Appendix II and V. On the same thickness basis typically 0.7 weight units of flexible graphite are needed to replace 1.0 weight units of CA. For the same thickness price difference on equivalent weight basis, would be 1.4 - 2.1 times that of CA. Flexible graphite gaskets generally are supplied with a metal insert to improve handleability. Since reduced thickness, e.g. one-half that of CA with a metal insert will produce equivalent performance in many cases, even '"first cost" can be comparable with that of CA. A major value benefit from use of flexible graphite is reduced emissions. Industries are moving to this product because of this and many other economic value benefits. These include inherent fire safety, greater than double life improvement over asbestos, reduced energy losses, greater tolerance to changes in flange load, and unlimited shelf life. Flexible graphite is, therefore, not just a replacement for asbestos-based gasketing but the only material proven via industry experience to have superior, long term sealing characteristics. An example of industry acceptance is the American Petroleum Institute, Refinery Division, Technical Subcommittee proposal to include flexible graphite as the only listed non-asbestos gasket material in their gate valve standards API-603 and API-604, which currently list only CA as gasket material. Based on the previously cited factors and in spite of the "first cost" difference between flexible graphite and CA, on the same thickness basis, a conservative value pay back of less than one year is estimated for the industrial market segment above 750F. In the case of internal combustion applications this pay back is immediate in some cases because flexible graphite is the only non-asbestos material that satisfies engine design requirements e.g. exhaust systems, manifold gaskets, EGR seals, head gaskets, etc. Value benefits are demonstrated through reduced machining of flanges, reduced engine wear, improved emission control, and greater reliability e.g. reduction in "recalls". Maximum penetration is expected for these applications with some into the 250-750F range. Recent examples of this latter case is use of GRAF0IL Head Gaskets by General Motors, Buick Division. Best estimates indicate that current penetration of flexible graphite into the total asbestos-based gasket market, excluding internal combustion applications e.g. automotive, truck, tractor, etc., is in the order of 1%. This is projected to grow to 20* within five years assuming a ban on asbestos. This penetration will be complemented by displacement of asbestos gasketing with other materials principally Polytetrafluroethylene (PTFE), "compressed" and "beater add" UCC 015753 -3- non-asbestos for temperatures under S00F. For Internal combustion applications estimated current penetration Is 15X. This Is projected to grow to 501 within five years. Other non-asbestos gasket material principally "beater-add" and PTFE, will displace asbestos based products at the lower pressure!temperature operating range. Incremental capacity for GRAFOIL Is being added by Union Carbide to accommodate this scenario. The same applies to the other products which are made by other AMI Members. Therefore, the replacement of asbestos gasketing by flexible graphite will not be capacity limited. This assessment addressed only the asbestos gasketing material Issue since packings represent a different technology. A more detailed assessment of the important roll GRAFOIL flexible graphite Is and will serve as a replacement for asbestos based packing products is forthcoming in a separate memorandum. PSP|kkf Enclosures P.S. Petrunich Customer Service Manager UCC 015754 -4- TABLE I GASKETING MATERIALS CHARACTERIZATION Material Maximum Temperature* Rank In Order of Torque Retention Flexible Graphite 5400F (3000C)** 1 Compressed Asbestos 650|1000F (340|550C) 1 Compressed Non-Asbestos 600|750F (320|400C) 3 Asbestos Beater Add 450|650F (230|340C) 4 Non-Asbestos Beater Add 350|750F (180|400C) 3-4 Expanded PTFE 500 F (260C) 3 Vegetable Fiber 250F (120C) 4 Rubber (Chloroprene|SBR) 212|250F (100|120C) 5 Cork-Rubber 250F (120C) 6 Cork Composition 250F (120C) 7 * NOTE: For specific service temperatures consult the manufacturer. ** Non-Oxidizing environment Numerically rated from 1 to 10 indicating comparative torque retention e.g. "1" is best, "10 is worst. From: FSA Non-Metal lie Gasketing Handbook - In Print UCC 015755 -5- PTFE USEFUL FLUID TEMPERATURE AND PRESSURE RANGES NON-METALLIC GASKETING MATERIAL k u E o 1 i 5 tO o 3E u 4-> <o < >V 41 4-> Q. k C3 U E f4) 3 S3 r* EX 0) 4) k a. U. to o. o o CSJ y i to .o 5E O < 0) 4-> T" JC CL <o k < (3 o 41 E r3 O r-- f-- EX 41 4) k Q- Li- o T9 T9 41 "O < 4-> T9 E k< J5 O. k 4-* k < a 4) k ai 4- c o T9 CD J <_> 41 4) 4* VI M CD 4> VI o U .3 *" 4) t * M TfB9 > X a. 4> E k 4) E .O 41 r-- o VI k </l Lu (_> < C VI </> <o f" (3 o T9 4) TJ < T9 4-> T9 T" E k < S3 <o 4) a. k 4-> k <o c <e 4) k 4) *-> < <3 T9 CO (O O 4) 41 '41 4) O S3 f-- f-- VI V) CD i/l o 4> *-> o k VI r* > X Q. 4) E k 4) 4) r-- E .a <o O VI k OO U. o < < w T3 U 0> 4- 0 c 0) CO u 01 o> 4^ to 40 o 0> CD 3 r_ u 01 o oo to to p4M0 C3 0) "O 4-> r* E x: 40 a. u 40 ct s- < <d u <y 0) CO > E !o V) 0) o *1" s. cX Q_ o 0) E o UJ ul o O PTFE PTFE (Reinforced) sO.) 3to taro-. to 0U) a. oo o--4 E3f- "O 1 oo 0) CO z: A T-- CO O. oo cr> 0) rH t- 3| tO iA a> T" to u o. CL o ojz CD o fH DC A +Or--->) O. 4i-0 o<c C9 <D E3 r* EX 0) 0^ U Cl u. 4Q->) o. 40 u Co o E 0) 3 JD r- EX 0) 0) S- r-- o. U- a> u 3 4-> U- 40 U o o. o0). oo E (U I-- 1 JC CD r" 2C rom**B A .40 CO r40 C3 T9 0) -- --- T9 <T9 T9 4- o. kEa k 44J1 <T9 k o 4S0o 0) I T9 41 V) (O C4Q1 in 44J1 <o C4D1 41 >k 41 X 0) VI 4k) +oJ VI Tr9- CL 41 E S3 o VI E(kO lO u. C_) < C VI V) <o f !' C3 0) T9 4-> r-- X Ou <kEo 40 C t os. T9 O 41 0) V) oai X r-- >k Xa; 4) f-- V) 4k1 Cl oE VO u. o CO CO 40 fm CD +0->) -o < <r J= o. 4u0 CD 4E0 c -o o >, 0) atCo>O EO Xr-- OuJ c X o. o u 0) oE UJ u. CJ tCoO 40 CD a; -o fj E X Q. 40 u 40 &. ct CD u "O a> 0)^ >% CO CO eo X r- EX O <u o r-- UJ U. O) u o. oE o k41 3 4-> ko 41 a. CL o EO 41 wr> H- E3 T9 i ior> Z41 CM A UCC 015756 01 u 3 4-> 40 u. u0 0) o a. s0-) to CM 1 o ro^i SYNTHESEAL - Armstrong (P ro p rie ta ry Beater Add) o 3~r-- NOBESTOS - Lydall (Aramld Beater Add) BLUEGUARD - Garlock (Compressed Aramld) - Dupont (PTFE) XJ 4<r---C> Q. E ou cn c E3 i0n> 5- Q- "0O) TEFLON <VoI X5 <ou m o i0n) X<ccnI ouin 3 V/>) a; 3 *--Oc m<U O) -0o) in i0Sn) i0i/-)i Q. oEo 403r$tJ>j Q. -<oo s- < 0) o -<t-U> o UCC 015757 I I UNION CARBIDE UNION CARBIDE CORPORATION SPECIALTY PROOUCTS GROUP RQ BOX 34637. CLEVELAND, OHO 44101 PHONE: [316] 523-3300 [BOO]822-4322 April 7, 1987 Document Control Officer ICF, Inc. 1850 K Street NW Washington, DC 20037 Attention: Tony Bansal Project Manager RE: Asbestos Substitute[Packings and Gaskets - Flexible Graphite Dear Tony: This letter's purpose is to address the subject issues, more specifically to provide information relevant to Union Carbide's GRAFOIL Brand Flexible Graphite, which is a functional substitute for asbestos based packing and gasketing materials. Packings are generally used to seal various fluids when some movement (dynamic) occurs between members of a fluid containing device. Examples include valves and pumps employed in the electric power, petroleum refinery, petrochemical, chemical, and pulp and paper industries. Gaskets are cut and fabricated from gasketing materials and are generally used to effect a static seal, for example between pipe flanges, vessels, or within a valve design (body to bonnet) used in these industries. Gaskets and other semi-static seals, such as those in an exhaust gas recirculating valve (EGR) and transverse engine flexible exhaust connection, also are employed extensively to seal fluids in internal combustion engines. Examples include head gaskets and exhaust manifold gaskets used in automobiles, trucks, auxiliary electrical power systems, lawn mowers, and other internal combustion engines. The present memorandum will focus on packings. UCC 015758 Tony Bansal Page Two April 7, 1987 Packing The non-metallie materials that comprise the bulk of past "high performance" packing technology have been based on various compositions and configurations of braided yarn. Historically* the dominate yarn fiber has been asbestos, but more recently other organic and inorganic yarns and combinations of yarns have been introduced, primarily for insurability, legal, regulatory, health, and environmental reasons. The high performance braided asbestos packings included an alloy wire reinforcement, various lubricants., a zinc powder corrosion inhibitor, and a graphite powder coating on the yarn itself. Asbestos yarn usually is braided around a core composed of the inhibitor, asbestos and binders with or without lubricants. Other compositions contain various binders, fillers, and dry lubricants such as metal sulfides. These braided packings generally have been applied where service pressures do not exceed 4000 psi (28 MPa) or temperatures 1200F (650C). Braided asbestos has been the performance standard for packings used in valves and pumps for a wide range of industrial applications. Except for the carbon and graphite yarns, the other braided "non-asbestos" replacements generally have not approached the breadth of performance of braided asbestos. GRAFOIt Flexible Graphite is a relatively new, non-fibrous packing material. It was introduced over 20 years ago by Union Carbide and has been applied extensively, worldwide, in the laminate and ribbon form, but primarily as a preformed ribbon packing ring,-with-and without a suitable carbon or graphite braided end-ring. Sweden has one of, if not the, most advanced National Policy on ban of asbestos products with total exclusion implemented on January 1, 1987. Based on extensive testing and experience, the Swedish Electrial Power Board has standardized on flexible graphite packings to replace the braided asbestos product. Proposed technical revisions to the API Refining Division valve standards will show flexible graphite with braided graphite yarn "end rings" as the listed non-asbestos packings in gate valve standards API-600 and API-603, where braided asbestos was listed. Appendix I provides a detailed overview comparing flexible graphite with braided asbestos packings. Many independent studies by research agencies, original equipment manufacturers, and ultimate users have verified the superiority of flexible graphite valve packing over conventional braided asbestos. As shown in Appendix II, the Fluid Sealing Association (FSA), a trade association which includes manufacturers of packing and gasketing materials, currently lists flexible graphite as the only valve packing material that equals and exceeds temperature and pressure ratings of braided asbestos packings (See Table V, page 8 of Appendix II.) The same applies for temperature, pressure, and velocity ratings for pump packing (see Table IV, Page 7 of Appendix II). UCC 015759 Tony Bansal Page Three April 7, 1987 Extensive studies of valve packings for steam service in Nuclear Power Plants have been on-going as the result of research studies funded by the Electric Power Research Institute (EPRI). Results of one of these earlier studies, Project 1623-1, is enclosed as Appendix III. This 1982 Final Report, EPRI NP-2560, clearly states the conclusion that flexible graphite packing is superior .to braided asbestos for .this service (see Page 5-1 Appendix III). More recent EPRI funded studies, e.g., "Valve Stem Packing Improvements EPRI NP-4255, Project 2233-3, Interim Report, February 1986, concentrates on only one packing material, flexible graphite, because of its proven superiority over braided asbestos. Appendix IV written by a major oil company, Exxon, basically draws the same conclusion relative to flexible graphite valve packings for refinery and petrochemical service. Appendix V reports results of an exhaustive study by a major valve manufacturer, Rockwell, to establish a viable non-asbestos packing. Agairv the conclusion is that flexible graphite is the only viable replacement for asbestos based packings. Economic Impact Currently there are two major domestic U.S. manufacturers of braided asbestos packings, Chesterton, and Inter Tech GroupjRM Industrial Products (formerly Raybestos Manhatten). The largest manufacturer, John-Crane Houdaille, discontinued sales of their Grade 1871 in August, 1985. This was the grade of braided asbestos used in largest volume in the U.S. Major moves to replace braided asbestos packings were underway since the discontinuance of John-Crane-1871Prices of remaining braided asbestos packings have been increasing during this period which makes economic comparisons difficult and the general issue of price comparisons a moot one. Current "first cost" prices of flexible graphite ring die formed from tape are 1.5-2 times.that of braided asbestos on a volume basis, when adjustments for small density differences are made. Typical densities for braided asbestos are 100 Tbs.jft'.3 while that for die 'formed flexible graphite rings are 90 lbs|ft.3. However, because of their superior sealing characteristics, only one-third to one-half as many GRAFOIL die formed rings are required to provide an effective seal. (Multiple ring sets are typically used to fill the stuffing box of a valve. Some are designed to accommodate as many as 10 - 15 individual rings.) The reduction in packing volume possible with die formed flexible graphite is discussed in Appendix V as well as other independent studies. Generally, for in-service valves, a metal spacer can be used to displace the vacant space in the stuffing box, while more cost effective new valve designs incorporate a smaller stuffing box for fewer and smaller cross section flexible graphite rings. Because of these improvements, even "first cost" prices for replacing braided asbestos packings with flexible graphite present essentially no penalty. As indicated in Appendix IV, valves are presently being sold with flexible graphite packings at the same price as with braided asbestos. The added durability of the flexible graphite provides packing life significantly greater (e.g. from 2 to over 10 times) than that of asbestos. Examples of life improvements can be found in Appendix VI. UCC 015760 Tony Bansal Page Four April 7, 1987 A major value benefit from use of flexible graphite is reduced emissions. Industries are moving to this product because of this and many other economic value benefits. These include inherent fire safety, greater than double life improvement over asbestos, reduced energy losses, greater tolerance to changes in fluid conditions, and unlimited shelf life. Flexible graphite is, therefore, not just a replacement for asbestos-based packings but the only material proven via industry experience to have superior, long term sealing characteristics. Best estimates indicate that current penetration of flexible graphite into the total asbestos-based packing market is in the order of 5%. This is projected to grow to 2Q% within five years assuming a ban on asbestos. This penetration will be complemented by displacement of asbestos packings with other materials, principally Polytetrafluroethylene (PTFE), and aramid for temperatures under 500F. Incremental capacity for 6RAF0IL is being added by Union Carbide to accommodate this scenario. The same applies to the other products which are made by other AMI Members. Therefore, the replacement of asbestos packing by flexible graphite will not be capacity limited. This assessment addressed only the asbestos packing material issue since gasketing represents a different technology. A more detailed assessment of the important roll GRAFOIL Flexible Graphite is and will serve as a replacement for asbestos based gasketing products was forwarded in my prior memorandum of March 4, 1987. | lw Attachments cc: T.D. Finnigan E. Rosenberg W.J. Burroughs C.H. Pelanne P.S. Petrunich Customer Service Manager UCC 015761 s`JZJSuppliers of asbestos substitutes form insdtut *4 ! Manufacturers of materials to re place asbestos fiber have formed the Alternative Materials Institute (AMI) to strengthen their case in the En vironmental Protection Agency's mandate to replace and phase out asbestos in cases where workable substitutes exist. In addition to Du Pont, manufac J turer of aramid fiber, initial membership in AMI includes the Carbo rundum division of Sohio, a ceram ic fiber manufacturer; carbon fibers division of Ashland Oil; Union Car bide, manufacturer of expanded graphite sheets; and Rhodes Ameri can, a metal fiber manufacturer. All of these companies supply substi tutes for asbestos for uses including friction materials, gaskets, adhesives, and cements. In recent years, asbestos has been labeled a carcinogen because the tiny asbestos fibrils have a tenden cy to attach themselves to lung tis sue. However, use of asbestos has persisted because the fiber is eco nomical, durable, and thermally stable. According to Richard Gould, a se nior Du Pont marketing specialist and chairman of the new group, "Our principal function is to pro vide EPA with information on al ternatives to asbestos. We are not trying to start another trade associ ation. Once EPA promulgates rules on asbestos replacements, we'll go out of business." It is not clear how long it will take EPA to formulate rules regard ing asbestos replacements. EPA started hearing testimony in July on a proposal made Jan. 29, 1986, to ban asbestos immediately in certain uses and phase out others over the next 10 years. Ernest Rosenburg, who acts as AMI's executive director in Wash ington, D.C., insists that "Our job is not to attack asbestos." Instead, says Rosenburg, AMI wants to be sure EPA has access to information on asbestos alternatives. Rosenburg is a lawyer who once worked for EPA and now works for public affairs concern E. Bruce Harrison Co. On the other side of the issue is Bob J. Pigg, president of the Asbes tos Information Association (AIA), an organization of asbestos mining and milling companies. Pigg says that AIA takes no position in oppo sition to alternate asbestos materi als, but it does "hope EPA will be evenhanded in its approach." He says that AIA has "demonstrated that asbestos does not pose an un usual health risk" where the fiber is encapsulated within another ma terial as it is in friction materials, roof coatings, gaskets, and cement. "We have called on EPA to with draw its proposal," Pigg says, be cause the documents EPA has drawn up are faulty with regard to both the health threats posed by asbestos in encapsulated materials and the cursory review EPA has made of potential health effects posed by as bestos substitutes. Union Carbide carbon products division manager of customer tech nical service Peter S. Petrunich be lieves AIA's argument over the health threats posed by asbestos sub stitutes is a red herring. For one. Carbide's Grafoil graphite sheet for gaskets and valve packings is a sol id, not a fibrous material, and so is not respirable. In addition, he says, a reason for AMI's formation is to ensure that safety studies of fibrous substitutes conducted both by mem bers and independent laboratories get to EPA. Marc Reisch, New York UCC 015762 March 16, 1987 C&EN 17 DJ: 200 2.*25, up 8.30 ;194,520^00sh. HQUQCi 25, up 1/4; on l,588,00q^^ WEATHER: Clouds cloudy, low to mi in afternoon, pos night. Tapering ^ * BUSINESS NEWS * \t ^ &^ ALTERNATIVE MATERIALS COALITION WANTS YOU . Union Carbide has joined with several companies making non-a\ Alternative Materials Institute (AMI). One of the purposes c the availability and practicality of substitute substances in _..vxronmental Protection Agency's plans to issue a final ruling on its propooaj. Banning asbestos, ucc is a member through the Grafoil business of Carbon Products. Any other Carbide components believing they may have an interest (either in proposing asbestos substitutes or in substituting materials for asbestos in their operations) can contact Carbide's Pete Petrunich in Cleveland (216-529-3909). An article on Grafoil as an asbestos substitute appears in the Union Carbide WORLD currently in the mail. DOW JONES BREAKS 2000 The stock market's New Year's rally carried the Dow Jones Industrial Average to its first close above 2000 yesterday. The final number was 2002.25. The industrial average has gained 106.3 points in 1987's first five sessions. The average has climbed 1100.94 points since August 1982. (WALL STREET JOURNAL, Jan. 9, p. 23) HOUSE RE-APPROVES WATER BILL REAGAN VETOED LAST YEAR The House gave overwhelming approval Thursday to a $20 billion water-quality plan vetoed by the President last year as too expensive. The legislation to reauthorize the Clean Water Act of 1972 was approved 406-8 and sent to the Senate. In the Senate, 75 senators are cosponsoring an identical bill slated for floor debate next week. (DOW JONES wire, Jan. 9) CARL ICAHN DROPS BID FOR USX Investor Carl Icahn dropped his $7.19 billion bid for USX Corp., saying the steel and oil giant had made it "all but impossible" for him to complete his $31-a-share proposal. Wall Street quickly labeled the failed bid as the latest and largest takeover casualty of the Ivan Boesky insider-trading scandal. (WALL STREET JOURNAL, Jan. 9, p. 3) HONDA PLANS BIG EXPANSION IN OHIO Honda Motors will boost engine production capacity at Anna, Ohio, by sixfold and start making transmissions, suspension assemblies, and brakes there. The $450 million expansion will make it the first Japanese car maker to build all major parts in the U.S. (All media, Jan. 9) * WORLD/NATIONAL NEWS * SENATE PANEL REPORT OFFERS EVIDENCE IRAN ARMS SALE WAS MEANT TO FREE HOSTAGES A Senate Intelligence Committee report, obtained by NBC News, offers new evidence the Administration sold arms to Iran more to win the release of American hostages in Lebanon than -- as President Reagan has insisted -- to cultivate moderates in Iran. (All media, Jan. 9) IT'S A FIRST! SOVIETS DISCLOSE TO HOME FOLKS THAT K.G.B. ABUSED ITS POWERS In a rare admission that the K.B.B. abused its extensive powers, the Communist party newspaper Pravda disclosed yesterday that disciplinary action was taken against several officials of the internal security agency. They'd arrested a Soviet reporter who exposed Government corruption in a coal mining region of the Ukraine. (NEW YORK TIMES, Jan. 9, p. 1) A DIGEST OF BUSINESS & POLITICAL NEWS ISSUED WEEKDAYS BY CORPORATE COMMUNICATIONS UCC 015763 Ext. 6988 WEATHER': Clouds and sun, 30's. Tonight, partly cloudy, low to mid 20's. Saturday, snow developing in afternoon, possibly mixing with rain Saturday night. Tapering off Sunday. Temps, both days 30's. * BUSINESS HEWS * ALTERNATIVE MATERIALS COALITION WANTS YOU Union Carbide has joined with several companies making non-asbestos substitutes to form the Alternative Materials Institute (AMI). One of the purposes of AMI is to advise the E.P.A. on the availability and practicality of substitute substances in light of the Environmental Protection Agency's plans to issue a final ruling on its proposal banning asbestos. UCC is a member through the Grafoil business of Carbon Products. Any other Carbide components believing they may have an interest (either in proposing asbestos substitutes or in substituting materials for asbestos in their operations) can contact Carbide's Pete Petrunich in Cleveland (216-529-3909). An article on Grafoil as an asbestos substitute appears in the Union Carbide WORLD currently in the mail. DOW JONES BREAKS 2000 The stock market's New Year's rally carried the Dow Jones Industrial Average to its first close above 2000 yesterday. The final number was 2002.25. The industrial average has gained 106.3 points in 1987's first five sessions. The average has climbed 1100.94 points since August 1982. (WALL STREET JOURNAL, Jan. 9, p. 23) HOUSE RE-APPROVES WATER BILL REAGAN VETOED LAST YEAR The House gave overwhelming approval Thursday to a $20 billion water-quality plan vetoed by the President last year as too expensive. The legislation to reauthorize the Clean Water Act of 1972 was approved 406-8 and sent to the Senate. In the Senate, 75 senators are cosponsoring an identical bill slated for floor debate next week. (DOW JONES wire, Jan. 9) CARL ICAHN DROPS BID FOR USX Investor Carl Icahn dropped his $7.19 billion bid for USX Corp., saying the steel and oil giant had made it "all but impossible" for him to complete his $31-a-share proposal. Wall Street quickly labeled the failed bid as the latest and largest takeover casualty of the Ivan Boesky insider-trading scandal. (WALL STREET JOURNAL, Jan. 9, p. 3) HONDA PLANS BIG EXPANSION IN OHIO Honda Motors will boost engine production capacity at Anna, Ohio, by sixfold and start making transmissions, suspension assemblies, and brakes there. The $450 million expansion will make it the first Japanese car maker to build all major parts in the U.S. (All media, Jan. 9) * WORLD/NATIONAL NEWS * SENATE PANEL REPORT OFFERS EVIDENCE IRAN ARMS SALE WAS MEANT TO FREE HOSTAGES A Senate Intelligence Committee report, obtained by NBC News, offers new evidence the Administration sold arms to Iran more to win the release of American hostages in Lebanon than -- as President Reagan has insisted -- to cultivate moderates in Iran. (All media, Jan. 9) IT'S A FIRST! SOVIETS DISCLOSE TO HOME FOLKS THAT K.G.B. ABUSED ITS POWERS In a rare admission that the K.B.B. abused its extensive powers, the Communist party newspaper Pravda disclosed yesterday that disciplinary action was taken against several officials of the internal security agency. They'd arrested a Soviet reporter who exposed Government corruption in a coal mining region of the Ukraine. (NEW YORK TIMES, Jan. 9, p. 1) A DIGEST OF BUSINESS & POLITICAL NEWS ISSUED WEEKDAYS BY CORPORATE COMMUNICATIONS UCC 015764