Document DD8492jpK5w0Mn2g5rej4KvRB

A UNION * * * CARBIDE ** * * * INTERNAL SPECIALTY CHEMICALS DIVISION CORRESPONDENCE Bldg. 3005-256 South Charleston, WV 25303 TO: FROM: CC: F. E. Dailey - 580 DATE: W. P. Fethke - 323 S. E. Galbreath - Amerchol J. P. Kennedy - 323 C. T. Lamberth - Katallstlks J. A. Nelson - Chickasaw, AL J. E. Pikula - 323 E. T. Voss - CPI D. A. Watson - Katallstlks J. L. Worstell - 514 R. L. Foster ORIG. DEPT: D. Liebesklnd E. D. Southard - 500/L - 312 SUBJECT: December 17, 1986 Environmental Affairs EPA Asbestos Notification The attached memorandum and correspondence was issued in December 1985 as a reminder to make appropriate EPA Asbestos Removal Notifications as required by regulations. I'm reissuing again in December 1986 as another reminder for 1987. RLF/rhw 1633K Attachment R. L. Foster UCC 008859 u 4 z 6A r \ / a r, 2 specify the exact start and completion dates of said renovation (considering your prediction may be up to 13 months in advance) , it would be advisable to say that, because of the nature of your operations, unplanned, but routine renovations make it difficult to predict such exact dates. In such individual cases (none of which by themselves exceeds the TL and therefore would require a notification) , the owner of the facility would not notify the EPA or State immediately prior to each specific event unless specifically requested to do so by the Agency. In your blanket notification, you may ask the Agency if it still would like to receive an additional prior notification for each single event. If so, the manner and the timing of such notification should be determined by discussions between the owner/operator of the facility and the Regulatory Agency (e.g., a satisfactory agreement might be the establishment of a telephone call to a 24 hour "hotline"). Individual Event Notification Rationale A large renovation project (which exceeds the TL by itself) would, by its nature, require substantial preparation (e.g., securing adequate amounts of insulating materials and maintenance personnel). Appropriate planning should allow ample time to make a notification in writing prior to the commencement of such renovation operations. Therefore, for any large single event which, by itself, exceeds the TL, the owner/operator must provide prior notification to the Agency regarding the specific event. The regulations require this notice "as early as possible" prior to commencement of renovation. I suggest a 10-20 day advance notification, similar to notices for demolitions. Asbestos: Pre-notification Guideline for Renovation Operations in order to be assured that you comply with a reasonable interpretation of the Asbestos NESHAP regulation, it is necessary to: 1. Provide to the Regulatory Agency before the start of a given calendar year (preferrably December) a notification that during the next calendar year the owner or operator of the facility expects to remove asbestos during various unscheduled operations which in aggregate will be in excess of the trigger level specified in the regulation. 2, Provide the Regulatory Agency with specific information on any large, single project which, by itself, will exceed the trigger limits so specified in the regulation. Since the prior notification requirement is confusing and at best vague in how to handle small quantity, unscheduled renovations, we believe that compliance with this guidance will provide you sufficient protection in following the intent of the prior notification requirement. As a reminder of earlier guidance on this issue, I have included a copy of C. L. Dudnick's 4/30/84 letter on the subject. She has also included a new form "C" which is a suggested format for the Blanket Notification letter. 592 8B UCC 008861 FORM C Re: Notification of Unscheduled Renovations at (name of plant: e.g., Texas City, Texas Facility) Dear Sir: This is to notify you, as required by the provisions of 40 CFR 61.146, that Union Carbide Corporation, Old Ridgebury Road, Danbury, Connecticut 06817, as owner, expects to engage in unscheduled renovation activities during the coming calendar year which, in the aggregate, are estimated to involve removing 80 linear meters (260 linear feet) or more of friable asbestos on pipes or 15 square meters (160 square feet) or more of friable asbestos used to cover other facility components. Because the renovation operations are only predicted to occur at Union Carbide's facility located at (address) during the next twelve months, we cannot at this time advise you when each renovation will begin and be completed and how much asbestos will be removed during each renovation. However, we can advise you of the procedures we intend to employ in handling and disposing of the asbestos materials. [Describe in general terms nature of anticipated renovations, methods and' procedures to be used as per 40 CFR 61.146 (c)(6) and (7), 61.147 and 61.152.] All asbestos material will be disposed of at (name and address of site, if known. If not, state you don't know but chosen site will have to meet NESHAPS regulations). In our opinion, this blanket notification meets the requirements of 40 CFR 61.146 for unscheduled renovation operations. If, however, you would like to receive an additional of each individual unscheduled renovation, please contact (name of employee at plant and position) at (address and phone #), so that mutually acceptable procedures can be arranged. Very truly yours 5928B UCC 008862 CARBIDE CO R FOR AT'0 - P' ^CAD 0A\-g,. - V- op- LAW DEPARTMENT April 30, 1984 TO: R. F. Kelley Environmental Coordinators J. E. Knap RE: Notification of Demolition or Renovation of Friable Asbestos Material U.S. Environmental Protection Agency (EPA) regulations, recently revised and repromulgated at 40 CFR 61.140 et seg.,* restrict and control activities involving the demolition and renovation of certain buildings and equipment which contain asbestos. One of the requirements of these regulations is that advance notice of the demolition or renovation of friable asbestos material be given to the Administrator of EPA. "Friable asbestos material" is defined as any material containing more than one percent asbestos by weight that hand pressure can crumble, pulverize or reduce to powder when dry. 40 CFR 61.141. "Demolition" is defined as the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations. 40 CFR 61.141. "Renovation" is defined as altering in any way one or more facility components, such as pipe, duct, boiler, tank, reactor, turbine, furnace, or non-load supporting structural member. 40 CFR 61.141. (Renovation does not include removal of load-supporting structural members, since such removal constitutes demolition.) - Renovations involving stripping and removing from any facility less than 80 linear meters (260 linear feet) of friable asbestos on pipes, or less than 15 square meters (160 square feet) of friable asbestos used to cover any other facility component are exempt from these regulations and no notification need be filed. For the purpose of determining whether a planned renovation operation or an emergency renovation operation falls within this exemption, the * See 49 Fed. Reg. 13657 (April 5, 1984) UCC 008863 A04203 3 2. Description of facility being demolished, including age, size, and prior use; 3. Estimate of approximate amount of friable asbestos material present; 4. Address of the facility being demolished or renovated; 5. Scheduled starting and completion dates; 6. Nature of planned demolition or renovation and method(s) to be employed; 7. Procedures to be employed to meet the substantive requirements of the regulations governing handling and disposal of the asbestos materials. See 40 CFR 61.147 and 61.152; and 8. Name and address of the waste disposal site where the friable asbestos material will be deposited. The written notice must be postmarked or delivered at least 10 days prior to commencement of demolition, and as "early as possible" prior, to commencement of renovation. 40 CFR 61.146(b)(1) and (b)(4). The exact content of each notice will differ significantly from case to case, and each notice will require some narrative description specific to the individual activity involved. Thus, it is not practical to develop a simple form notice that would be usable in all situations. However, for your convenience, two basic forms have been prepared which, if followed, will allow compliance with, the notification requirements with a minimum of effort. Form A is to be used for small demolition activities subject to 40 CFR 61.145(b). Form B should be used for all other demolition and non-exempt renovation activities. These notices to the Administrator of EPA are required by 40 CFR 61.04(a) to be submitted in duplicate and addressed to the appropriate EPA Regional Office. If the Administrator has delegated the authority to implement and enforce the national emission standard for asbestos to a state or local agency, then that agency must also receive these advance notifications of demolition or renovation. 40 CFR 61.04(b). Since specific delegations may provide that the U.S. EPA need not receive these notifications if the appropriate state or local agency receives them, the delegated agency or Regional U.S. EPA Office should be consulted to determine UCC 008865 4 04 4 whether both agencies must receive copies. send a copy to U.S. EPA. If in doubt, however, Should both the Investment Recovery Department and the specific division of Union Carbide responsible for the plant at which demolition or renovation activities will take place be<involved with those activities, it would be advisable to coordinate with the Environmental Coordinator for each division so that only one notice is filed for any given activity and each notice that is filed is accurate. Should you have any questions please contact me. Very truly yours. CLD/ Enclosures Carol L. Dudnick UCC 008866 FORM A Dear Sir: This is to notify you, as required by the provisions of 40 C.F.R. 61.146, that Union Carbide Corporation, Old Ridgebury Road, Danbury, Connecticut 06817, as owner, plans to demolish a (provide description of facility, structure, building or installation, etc., being demolished, including its size, age and prior use) which contains (amount) of friable asbestos material, as (measured)/ (estimated). (If estimated, add description of technique used in estimating). The (building, facility, etc.) is located at (address). Demolition is scheduled to begin on (date) and to be completed on (date). Very truly yours, . UCC 008867 A04207