Document DvQZ4QQVVQBDVJDxbEY83vK7a

PLAINTIFF'S EXHIBIT SHELL OIL COMPANY P. O. BOX 100 DEER PARK, TEXAS 77536 January 26, 1977 Regional Administrator, Region VI U. S'. Environmental Protection Agency 1600 Patterson Street, Suite 1100 Dallas, Texas 75201 Gentlemen: This letter is to give notice of the start of demolition of a facility containing equipment and piping insulated with friable asbestos material as required CFR 40, Part 61.22(d). The following information is submitted: (1) Name of owner or operator Shell Oil Company (2) Address of owner or operator One Shell Plaza, Houston, Texas 77002 (3) Description of facility to be demolished A water treating unit constructed in 1935. The facilities to be demolished have been idle for approximately five years, and con sist of the following: (a) One vessel. Shell item number V-800, 19'0" diameter by 22'6" high, insulated. (b) One vessel. Shell item number V-801, 15'0" diameter by 18'7" high, insulated. (c) Approximately twelve concrete vessel supports and three structural steel pipe supports, uninsulated. (d) Approximately 1200 lineal feet of piping, none exceeding 20 inches nominal diameter. The amount of friable asbestos material used for insulation is: (a) For vessels -- approximately 3000 square feet. (b) For piping -- approximately 200 lineal feet. DPMC-09067 LAM 002954 Regional Administrator, Region VI January 26, 1977 Page Two (4) Location of the facility to be demolished Deer Park Manufacturing Complex, Deer Park, Texas (5) Scheduled starting and completion dates Starting date -- February 7, 1977 Completion date -- March 15, 1977 (6) Procedures to be employed (a) Insulated piping shall be removed as units or in sections in accordance with paragraph (d)(4)(iii) of the regulations. Asbestos materials exposed during cutting or disjointing or exposed to permit lowering of equipment to grade, shall be wetted. Units, sections, or equipment shall be carefully lowered to ground level? (b) The friable asbestos insulation materials shall be stripped from removed piping by removing the weatherproof cover, immediately wetting the exposed asbestos material, and promptly removing the wetted asbestos material into fibreboard drums lined with heavy-weight plastic bags. Filled drums shall have plastic liner bags tied tightly at the top, lids installed, warning labels affixed in accordance with the regulations, and stored, adequately protected from weather, pending transporta tion to an approved disposal site or facility. (c) As sufficient asbestos wastes are accumulated, they will be transported by truck to Texas Ecologists, Inc. at Robstown, Texas, for final disposal. If you have any questions concerning this matter, please con tact C. H. Rivers, (713)-476-7667. CHR/HLL/rwh Very truly yours. Original Signed by R. LOPEZ R. Lopez Superintendent-Refinery Deer Park Manufacturing Complex be: Head Office -- Manufacturing -- Environmental Conservation UbCccv- GUt<eiluneUTv'cilvhdeK^" R F' Van Inaen W. V. Jacks H. L. Lee R. V. Mattern/C. H. Rivers J. D. Ransdell/ J. L. Rivard/ File Chron Env. Cons. Chron DPMC-09068 LAM 002955