Document KRpdYV6ZNM9MGD2Gv1NoX4JbN

SHELL CHEMICAL COMPANY A DIVISION Of SHELL OIL COMPANY P. O. 80X 2633 DEER PARK, TEXAS 77536 June 14, 1978 MANUFACTURING Environmental Conservation Department rtECEIVED JUN 164978 Subject: Removal of Asbestos Insulation DFIULEE DATE CERTIFIED MAIL RETURN RECEIPT REQUESTED __ , / f/ PLAINTIFF'S EXHIBIT Regional Administrator, Region VI U. S. Environmental Protection Agency 1201 Elm Street, First International Building Dallas, Texas 75270 Gentlemen: This letter is to give notice of the start of demolition of a facility containing equipment and piping insulated with asbestos material as required by CFR 40, Part 61.22(d). The following information is for your consideration. (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 sulfur recovery unit was built in 1952. A second unit was constructed in 1966. These facilities, which have been idle for several years because of the construction of more modern recovery units, will be dismantled. Approximately 10,000 square feet of nominal two-inch thick pipe insulation will be removed by contract per sonnel under Shell supervision from lines ranging from 2 inches to 30 inches in diameter. Also, approximately 15,000 square feet of insulation will be removed from eleven pieces of process equipment such as columns, vessels, and furnaces. The smallest vessel is 3 feet in diameter and 15 feet high. The largest is 10 feet in diameter and 20 feet high. (4) Location of the Facility to be Demolished LAM 028894 Deer Park Manufacturing Complex, Deer Park, Texas ABS-017889 Regional Administrator, Region VI U. S. Environmental Protection Agency 2 (5) Scheduled Starting and Completion Dates Starting Date: July 5, 1978 Completion Date: October 1, 1978 (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 other parts will be lowered carefully to ground level to avoid air scattering of asbestos material. (b) The asbestos insulation materials shall be stripped from removed piping by removing the weatherproof cover, immediately wetting the exposed asbestos material, and promptly removing this wetted asbestos material into fibreboard drums lined with heavy weight plastic bags. Filled drums shall have the plastic liner bags tied tightly at the top, lids installed, warning labels affixed in accordance with regulations, and stored, adequately protected from the weather, pending transportation to an approved disposal site or facility. (c) When sufficient asbestos-filled drums are accumulated, they will be transported by truck to Rollins Disposal Service at Deer Park, Texas, for final disposal. If there are any questions concerning this operation, please contact W. W. Wright, (713) 476-7248. Very truly yours. H. J. Bettencourt Superintendent - Chemical Deer Park Manufacturing Complex be: Head Office Manufacturing Environmental Conservation Manager, Mr. A. G. Smith^-i-ms copy LAM 028895 ABS-017890