Document Ex9d8Gm1O273pEoXxy3ZenYvR

ROUGH DRAFT INSULATION STAFFING STRATEGY SOUTH CHARLESTON PLANT Short Term (2/86 - 4/86) 1. Continue work on asbestos insulation identification, repair, and/or removal: . Allocate maintenance resources to complete the plant survey for work required - stripping, reinsulation, repair. Utilize pictures for documentation, a color code highlighting the type of work required, and a repair estimate. (Approx. 3 folks for weeks) . Make "critical" or "emergency" repairs as needed or identified (Approx. 10 folks ongoing) 2. Maintenance insulator resources not committed to the asbestos survey or "critical" repair activities will be available to service unit needs on a prioritized and scheduled basis. (Approx. 8 folks ongoing) . Legitimate winterization and/or large high priority insulation projects may require reallocation of resources and working approved overtime for timely completion. 3. Continue work on defined and approved asbestos insulation removal projects from idle equipment (two 838 type projects authorized for approximately $200M) using firm bid contracts where possible including completion time schedules. 4. Pursue use of firm bid projects for well defined, isolated jobs. All con tracted work will include a schedule for completion - Gant chart, etc. 5. Develop scope document based on survey results for remaining asbestos insula tion work to include a cost estimate and funding/staffing strategy, i.e. can the work be effectively bid on hard money basis? Make an 838 type project, etc. Long Term (4/86 - 12/86) \ 1. Decide on strategy for completing remaining asbestos insulation work, per item 5 above. 2. Begin work on this year's winterization lists in June/July to allow for maximum lead time and possible early completion. Observation/Comments 1. The volume of insulation work, including asbestos insulation work, is greater than the available resources. 2. The plan does allow for manpower reallocation to minimize overtime for critical non-asbestos jobs, which may appear to be a change in the strong message last year that asbestos insulation repairs were top priority. 3. The plan heads us in the direction of being "ready" for the next winter, piggy backing on the success achieved in 1985 with an early start. 2/11/86 UCC 006508 .APR 2 21986 * * maintenance dept. * UNION * * * ENVIRONMENTAL PROTECTION - SOUTH CHARLESTON PLANT * CARBIDE April 21, 1986 TO See List Attached CC R. L. Foster/E. D. Southard C. H. Hancock Shift Department Heads Shift Superintendents EPD Staff Circulate SUBJECT: Asbestos: EPA Regulations REFERENCE 1: J. R. Solce to W. S. Walker, January 9, 1985 2: F. A. Sanchez to R. E. Peele et al.. May 30, 1984 In view of the flurry of asbestos-related activity In the Plant, It seems like a good Idea to re-issue the two letters cited In reference, which outline some of the EPA regulations ("NESHAPs") on asbestos. Note that -- These regulations partially overlap OSHA regs--i.e., wet down before removal. -- But they also go beyond OSHA regs In some ways--e.g., notification. -- The lead time (at least thirty days) Is necessary for large jobs so that EPD can file a notification with EPA and WVAPCC. Also In addition to the NESHAP regulations, asbestos falls under CERCLA emlsslon/spl11 reporting--the 1 lb RQ issue. JLW:cp 0447W Attachments J. L. Worstell UCC 006509 t INTERNAL I COPRGSPONOENCe UNION CARBIDE CORPORATION P O BOX 0004. SOUTH CHARLESTQN.WV 95303 : i .11 tir jis Afs/r.i until MAfMi; irsj j(. nfvn'i >tA n s ! it )1 J I M t'.l <AMl>.:!.iTCKM * *LAfSlT '* W.In ffvi.ij < I S. Walker I h,,. i., Ok jii it. A. , i January 9, 1985 Environmental Regulations E. P. Contacts P. D. Gossage Sal Rossi - F. A. Sanchez J. L. Worstell W. R. Yerkey ...... EPA Asbestos Regulations Ref: Letter, F. A. Sanchez to R. E. Peele, et.al., "Asbestos Standards Applicable at 514 Plant", May 30, 1984. Bill On May 30, 1984, F. A. Sanchez sent you a letter summarizing the EPA standards for asbestos. The purpose of this letter is to highlight some of the more important aspects of those standards. All demolition and/or renovation activities which involve asbestos must be reported in advance to the EPA. Plant 514 will submit three types of notifications. (1) A letter will be sent to the EPA each year covering routine miscellaneous maintenance operations (renovations). A letter has already been sent for 1985. (2) Any large scale maintenance jobs (renovations) must be reported separately. For instance, the stripping of several hundred feet of line for repairs would fall under this classification. (3) Any demolition activities must be reported by a separate letter. In order for EPD to submit notification letters on time, we must be kept informed of any anticipated large scale renovations and any demolition work. To meet the EPA deadlines, EPD must be notified thirty days before any job is scheduled to begin. Removal of asbestos must follow EPA criteria which generally prohibit any emissions of asbestos during the removal operation. This will usually involve thorough wetting prior to removal and sealing asbestos in leak-tight, labelled containers. Removed asbestos is not to be dropped or thrown to the ground as this will cause the release of asbestos fibers into the air. UCC 006510 2- , Once the asbestos is bagged for disposal, it should be promptly transported to Goff Mountain for disposal. A properly prepared mainifest is required. One of the deficiencies noted during the Corporate Audit during August was our lack of prompt disposal of removed asbestos. Trucking must be kept aware of jobs involving asbestos removal so that prompt disposal can be made. No job should be considered complete until disposal has been accomplished. Departments which have ongoing maintenance jobs involving asbestos should monitor the worksite daily to assure the prompt disposal of removed asbestos. "Orphan" bags of asbestos must be called to the attention of Trucking promptly to avoid a repeat of the situation discovered in August. Each Department must be responsible for avoiding any accumulation of removed asbestos within its area. Very truly yours. JRS/lms 0103S UCC 006511 INTERNAL CORRESPONDENCE UNION CARBIDE CORPORATION south charleston plant (w'-ocmas and UreUkKw iniw-fniiiiiin-j, P.O. BOX 0004, SOUTH CHARLESTON. WV 25303 u.,v;v. U-n .run Ai"c,i R Peele w_ $ Walker May 30, 1984 .............. L..-C ENVIRONMENTAL PROTECTION G. W. Bott P. D. Gossage B. P. Johnson, Jr. J. R. Soice J. L. Worstell EPD Staff (Circulate) Asbestos Standards Applicable at 514 Plant The attached summarizes the NESHAP Standards for asbestos which apply to operations at Location 514. This summary is being sent to you as primary contacts in order that you might pass the information on to the specific individuals that will ensure compliance with these standards. Normally, only maintenance and construction activities will be involved in the handling of asbestos. I would like to request a copy of any written procedures or if you should know of someone who has written procedures for the handling of asbestos, please forward this information to me by June 30, 1984. If you have any further questions or comments, please feel free to call me at X-2799. Truly yours. FASs/rls 0033A Attachment UCC 006512 NESHAP STANDARDS FOR ASBESTOS APPLICABLE AT 514 Title 40 of the Code of Federal Regulations, Part 61, Subpart M specifies the standards for handling and disposing of asbestos. Asbestos is considered a hazardous air pollutant due to its adverse health effects. Exposure to asbestos can cause fibrosis in the lungs leading to more serious illness like lung cancer. I. DEFINITION: Asbestos means the asbestiform varieties of serpentinite, riebeckite, cummingtonite-grunerite, anthophyllite, and actinolite-tremolite. As used here, the word asbestos includes asbestos, asbestos containing material, asbestos containing waste, and friable asbestos (i.e. can be pulverized) II. STANDARDS APPLICABLE AT 514 A. Roadways: No owner or operator of a roadway may deposit asbestos on that roadway. B. Demolition and Renovation: 1. Notification: The following information must be reported to the EPA Administrator: a) Name and address of the owner or operator b) Description of facility being demolished or renovated including size, age, and prior use. c) Estimate of the amount of asbestos removed. d) Location of the facility e) Schedule of demolition activity f) Nature and methods to be used g) Procedures to be used to comply with these regulations h) Name and location of the waste disposal facility used for the asbestos. The report should be made in one of the following manners: a) At least 10. days before demolition when the amount of asbestos is at least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other equipment. b) At least 20 days before demolition when the amount of asbestos is less than 80 linear meter (260 linear feet) on pipes or at least 15 square meter (160 square feet) on other equipment. c) As early as possible before demolition when such demolition is ordered by a state or local agency due to ' danger of immediate collapse or unsoundness. At 514 Notifications will be made by EPD. UCC 006513 2. Emissions Control: a) Asbestos must be removed before demolition begins unless: i) It is encased in concrete or similar material ii) It is adequately wetted whenever exposed b) When a component with asbestos is taken out in sections: i) Adequately wet any asbestos exposed during disjoining operations ii) Carefully lower the sections to the ground, not dropping or throwing them. c) Adequately wet all asbestos before being stripped from the facility components unless: i) A request has been made to EPA not to wet the asbestos due to unavoidable equipment damage; and ii) EPA has approved the use of a ventilation and collection system that will prevent any emission. d) After a component with asbestos has been taken out: i) Adequately wet asbestos before stripping; or ii) Use a ventilation, collection system that will prevent any particulated asbestos emissions. e) For asbestos that has been removed or stripped: i) Adequately wet and keep wet until disposed. ii) Carefully lower to the ground not dropping or throwing it. iii) Transport via dust-tight chutes or containers when removed or stripped over 50 feet above ground. f) When the temperature is below 0 degrees C. (32 degrees F.): i) Remove components covered with asbestos as sections as much as possible. ' ii) Adequately wet asbestos before stripping and keep wet after removed until disposed. g) If the facility is being demolished because of an agency order: i) Wet the portions covered with asbestos during the demo!ition. UCC 006514 C. Insulating Materials: No owner or operator may install or reinstall any insulating materials that contain commerical asbestos if the materials are either molded or wet-applied. D. Disposal: 1. No visible emissions are allowed while collecting, packaging, transporting, and disposing asbestos: - a) Treat asbestos with water: i) Mix asbestos from emissions control devices with water to form a slurry and adequately wet all other asbestos wastes. ii) No emissions must be discharged from collection, mixing and wetting operations iii) After wetting, seal all asbestos in leak-tight containers while wet. iv) Label all containers as follows: "CAUTION CONTAINS ASBESTOS Avoid Opening or Breaking Container Breathing Asbestos Is Hazardous To Your Health", or use the warning signs specified by OSHA. b) Process all asbestos waste so it can't be pulverized. i) Form into pellets or other shapes ii) Discharge no emissions while doing so c) After all the asbestos waste has been packaged; i) Complete a waste manifest and get EPD approval ii) Dispose of the waste at Goff Mountain Landfill FAS/rl s 0033A F. A. Sanchez 5/22/84 UCC 006515 DISTRIBUTION R. P. Campbell J. R. Dean J. R. Dement P. R. Oesal J. W. Hansgate R. G. Hull S. J. Chanley D. H. Ott J. C. Ketcham L. C. Stewart D. R. Stokely T. G. Swanson K. A. Windhorst 300-2 309-2 309-2 50 156 309-2 152-2 261 50 133-2 323 151-2 106-4 UCC 006516