Document KejeyYKYDOv1Rbjjav1xXqYX

TPL& CMrwc O0UA. UNION CARBIDE CORPORATION 1300 Hercules Avenue - Suite 202 Engineering, Manufacturing & Technology Services Houston, Texas 77058 ! ZjW iWj'rtu/M *lwl*L VffimPndto' tU* Date: To: 1987 (RK h> H ^ ** lt,rA April 28, 1987 is> 04 /ymr* JX tcpft ft ^ See Attached Distribution List I% Copy to: See Attached Distribution List Subject: Asbestos Gasketing and Packing JviMAL %1 qu AxM} buJb wt*- /VMUv-- O.s/6 l^jW-- oJtlTHTb aJ- /vuiflce- 'tta / Rapid changes in the asbestos area are taking place and the r change will probably stay high until the majority of asbestos is replaced. This communication is an overview of current activities to help you meet regulatory requirements. A task group (C. Neely, et al) dealing with the phase-out of bestos containing materials in the work place for C&P, made their commendation to the Manufa^tmi^a-J^nnnril via ^ c Perry, and it was roved in March, 1987. pation of purchase ^naininfj after January 1, 4^1 V/ During the development of the original recommendation, the supply world has changed. UCC's three major suppliers are no longer manufacturing asbestos containing materials. No supplier is willing to make a firm commitment to supply asbestos containing materials after the end of 1987, because of the inability to get liability insurance. In addition, the cost of asbestos has gone up 25% in the last twelve months. Therefore, the recommended deadline for purchase cessation may be met by lack of supply. - continued UCC 015814 ' (t>* i 5 In order to help prepare fitfr this change-over, tne following actions are in progress: / 1. The task force has/initiated and expedited actions to do the engineering!specification work for asbestos replacements forglsketinaand packing. These C&P Engineering^^ppBWS^HiD^available for each location b^-S^ptember, 1987^^5pecific questions before theiSUQ^^j3g^i*if?usse^ with Rex Engle at the South Charleston Tech Center. 2. Manufacturing Services - Maintenance working with UCC Carbon Products and Texas City Plant Maintenance is developing a video tape of "How-To's" for Grafoil installation in gasketing and packing applications. This videotape will be available thru Manufacturing Services - Maintenance in June, 1987 and you will be notified later how to obtain it. The videotape is designed to simplify the work of training your people. In addition to the use of the videotape, it would be wise to contact Jim Polomsky of Carbon Products to provide further follow-up, Hands-On Training. (713+852-9468 - Home - Houston, Texas or 1-800-822-4322 - Office - Cleveland, Ohio). See attached seminar content detail. 3. Exposure level data for situations' of removing, cutting, and handling gasketing and packing is now being collected from several locations by Industrial Hygiene. With these data, the appropriate removal methods can be specified. Industrial Hygiene coordination of this data collection program should . eliminate the need for each location collecting data. 4. We are representing maintenance for all*C&P locations in the on-going review of the OSHA field compliance Instructions Draft. As conclusions are drawn we will let you know. We are coordinating these efforts in order to speed communications and minimize the efforts for each location. For further assistance, please call Ashton Barefoot at UNICOM 529-6437 or 713+486-6437. ' LC/6262L/cc L. E. Calvert UCC 015815 (C DRAFT RECOMMENDED C&P PROGRAM CHEMICAL ANO PLASTICS BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS^ ^IN THE WORK PUCE 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 015816 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 sealablllty 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 015817 DRA F T 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 015818 C. C. Neely 47071 --4 * * * * * ** * UNION * * * CARBIDE * *** INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 16, 1986 JTO: Mr. L. E. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle COPY TO: Mr. C. C. Neely SUBJECT: Recommended C&P Program - Phase-DUt Use of Asbestos-Containing Materials In Workplace Gentlemen: Attached Is a copy of your recommendation covering asbestos usage which I transmitted to Bob Perry. .. Thanks for your Insights and efforts'In'pulling this together. I'll keep your team posted as the recommendation proceeds through the system. Very truly yours. JES:he Attachment 4704Y UCC 015819 UNION CARBIDE CORPORATION;P. 0. Box B361 Engineering, Manufacturing, and Technology Services Central Engineering So. Chas., WV 25303 . BUSINESS CONFIDENTIAL September 30, 1986 TO: Mr. J. E. Sanders COPY TO: Mr. L. C. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle FROM: C. C. Neely SUBJECT: Final Draft of Recommended C&P Program Phase-Out Use of Asbestos-Containing Materials In Work Place Chemicals and Plastic Group Attached herewith on behalf of the Special Working Group Is a copy of the subject document dated 9/29/86. It Is a slightly fine-tuned version of the 8/28/86 version which was transmitted to you under my transmittal also dated B/2B/B6. The changes that have been made are of a clarifying rather than substantive nature. At this point, we have not made an effort to obtain broad, formal review of the subject program. However, Larry Calvert has discussed It briefly with the Maintenance APM's and MaTntenanrr Managers. In addition, Stan Clark arranged for Its review by the Safety, Health Advisory Committee (SHAC), and your staff has reviewed It. Feedback Indicates these groups to be supportive of the concept, but some have expressed concern regarding the January 1, 1989 date specified for the discontinuance of the purchase of asbestos-containing materials, believing It to be optimistic. Some of the concern relates to the following: . 1. CED's ability to revise and reissue the V&P Specifications and the Valve Manual In time to support the deadline. The responsible CED specialists have carefully reviewed this matter and believe that reissuance of these Manuals by July 1, 1988 Is realistic. This date has not been published, however. - UCC 015820 Hr. J. E. Sanders -2- September 30, 1986 2. Belief that field testing of new gasket and packing materials will be required. Such testing will not be necessary since the plan at this time Is to accommodate most of the substitutions by broadening the use of materials already In use, materials such as reinforced Teflon and GRAFOIL'". This plan has not been broadly disseminated, and we can fully appreciate the reluctance to agree to a purchasing cut-off date for asbestos-containing products without knowing what the substitutes are. We also appreciate that, once this material substitute plan Is known, there will be a natural resistance due to the higher first cost of these substitute materials. . 3. Some belief that Installers will need special training to handle the new gasket and packing materials. For reasons cited In (2), we do not believe this requirement will be significant. 4. Perhaps lack of understanding that the January 1, 1989 date Is the cut-off date for the purchase of asbestos-containing materials except as approved by a variance. 5. "Is this really necessary" attitude. The Special Working Group believes that OSHA's recently revised exposure limit of 0.2 fibers per cubic centimeter of air (was previously 2.0 fibers per cubic centimeter) add significant Impetus to Implement the proposed Recommended Program. According to Terry Hanning's September 5, 1986 memorandum (copy attached), labor union representatives do not believe that controlling the exposure limit to this lower level provides adequate protection. The above concerns notwithstanding, the Special Working Group decided to submit the subject Recommended Program to you with the January 1, 1989 date Included since we believe that, with proper communication with the key plant personnel responsible for Its Implementation, along with management support, this date Is realistic and achievable. We are submitting under separate cover a proposed CED Technology Program'which Includes request for funds to cover the Important communications aspect of the understanding, acceptance and Implementation process. Please let me know how we can be of further assistance regarding this matter. CCN:mr 43191 Attachment UCC 015821 8/28/86 DRAFT RECOMMENDED POLICY CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) SUBJECT: USE OF ASBESTOS-CONTAINING MATERIALS^)IN THE WORK PLACE PURPOSE/BACKGROUND The Corporate Charter (1.1) contains the following commitment to employees: "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 asbrestos 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 only the cost of mandatory work practices associ ated 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 building materials. UCC 015822 DRAFT 2- - 8/28/86 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 considerations of Improved servtre Ilfe a-nd sealabll 1 ty are Included. Consistent with the aforementioned commitments and the economic use of materials, C&P has concluded that positive-actions- relative to asbesto-s-contalnlng materials^) should be taken. POLICY 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 re4ul.red.t0 maintain structural and functional Integ rity. No asbestos-containing materials shall be purchased after January 1, 1989. C&P approved practices shall be ..employed for the Identification, removal, modification, and/or disposal of asbestos-containing mate rials. 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 uncoramorv.clr.ciuns.tajutes. Approval must always Include en dorsement of C&P HS&EA management. ' SCOPE This reconsnended policy applies to all C&P operated/hosted facilities. Other components of the Corporation will be apprised of Its content. DELEGATION The assignment of duties and authority to carry out the policy defined herein Is delegated as follows: To Central Engineering Department Develop and maintain engineering standards covering: _ - Identification of asbestos-containing materials; UCC 015823 DRAFT 8/28/86 -3 - Removal, modification and/or disposal of asbestos-containing mate rials; and - Use of asbestos-substitute materials. To Site Management Implement policies and practices for the Identification, removal, modification, and disposal of asbestos-containing materials. Use of CEO Standards covering asbestos substitute materials and the communication of service experience with these materials. To Manufacturing Services Monitor use of asbestos-substitute materials and the communication of service experience with these materials. To C&P HS&EA Audit compliance with governmental regulations and CED-developed standards relating to asbestos-containing materials and, where applicable, their substitutes. ' UCC 015824 C. C. Neely 2073W ?* UNION CARBIDE CORPORATION SPECIALTY PRODUCTS GROUP . James J. Polonsky ' District Sales Mgr:,, ' P. 0. Box' 94637 Cleveland, OH 44101 Ph 1-800-822-4322(0) (713)+852-9468 (H) P.O BOX S4637. CLEVELAND. OHIO A41D1 PHONE: (SIS) 529-3900 ` (BOO) B22-4322 GRAF0H Flexible Grabhite A Union Carbide Corporation Trademark Product GRAPOIL SEMINAR OUTLINE 1. Solving your packing and gasketing problems. .2 Understanding Asbestos packings or gaskets. 3. The search for an asbestos replacement. 4. Current non-asbestos offerings. 5. Characteristics of Graphite. .6 Hew GRAF0H is processed from chrystalline graphite. 7. Characteristics of GRAFGIL vs .'`Graphite .8 Cnemical resistance of GRAF0XL. 9. Fire testing and fire safety with GRAF0H/D. .10 Corrosion protection with GRAF0IL. .11 Oxidation of GRAF0H-----Misconceptions???? .12 Valves-----Packing Installation procedures and features. 13. Flanges-----Gasketing Installation procedures and features. 14. Gaskets-----GRAF0H laminate offering and SWS filler. 15. Product Offerings; Packings, gaskets, ribbons, and tapes. The seminar includes demonstrations which assist the participant in his/her understanding of the product and lasts about 90 minutes. ;.v lP, 7>L NOTE***. -t ...ijw .7' v : -v Since several of the demonstrations require the use of an open flame, your management is requested to provide a conference room in which these demonstrations may be conducted without violati-ny the safety regulations of your company. .* UCC 015825' Brand Flexible Graphite Newsletter Number Your Seal of Assurance PG 008 178 SUBJECT: Special Gasketing Techniques With GRAFOIL Flexible Graphite INTRODUCTION GRAFOIL flexible graphite is a resilient form of graphite which has excellent properties as a gasketing material. By itself, GRAFOIL flexible graphite seals about as readily as rubber. It is also fabricated into metal core laminates or into spiral wound gaskets, and significantly improves their characteristics. In general, GRAFOIL gaskets will seal the maximum pressure specified on properly designed, correctly manufactured and suitable maintained equipment. . While being flexible and resilient, GRAFOIL flexible graphite is still all graphite. It has no resins, binders or filler materials or other additives that might detract from the chemical inertness and temperature resistance of pure graphite. GRAFOIL gaskets will not cold flow, become brittle, or vulcanize to gasketing surfaces in service. The unique chemical and physical properties of GRAFOIL flexible graphite combine to make it a nearly universal gasketing material especially suitable to high temperature and cryogenic service and|or corrosive environments. GENERAL POINTS TO REMEMBER WHEN GASKETING WITH GRAFOIL FLEXIBLE GRAPHITE 1.) The f lange surfaces must t>e clean, -free of nicks, scratches, Durrs, metal fillings, scale or other foreign matter. 2.) Use a proper bolt tightening sequence to ensure a uniform load is applied to the joint (see Figure VI). The use of a torque wrench is advantageous to ensure that a uniform tensile stress is applied to each bolt. 3.) GRAFOIL Grade GHE 316 Stainless Steel Tang Metal Inserted gaskets (Catalog Section G-B817 and G-8819) should not be used between any metal surfaces that are softer than the stainless steel (i.e. aluminum, brass, bronze), or between glass or ceramic surfaces. When GRAFOIL Grade GHE gaskets are used, the metal tangs must be compressed such "that the -GRAFOIL begins to seal. Due to the minimum seating stress recommended for these gaskets (i.e. 2500 psi), the metal tangs carv-make small indentations in the softer metal of the flange face. The tangs can also create stress concentration points on glass or ceramic surfaces. 4.) GRAFOIL flexible graphite gaskets must be loaded with a net compressive unit load as shown in the Unit Load vs. Leak Pressure Curve, Figure I, and in GRAFOIL Catalog Sections G-8816 and G-B817. 5.) The initial thickness of the GRAFOIL gasket must be such that when it is compressed between two mating surfaces, the GRAFOIL is strained sufficiently at all points in the joint to seal the maximum service . pressure. If the flange surfaces are scratched, serrated, or warped, the initial gasket thickness must be large enough to completely fill and compensate for their effects when - the joint is made and the gasket is compressed. . ' OO c-,voac77 UNION CARBIDE CORPORATION On.ni/:ini >iennon leOOl E22-4322 In Ohio (216) 529-2900 TELEX: 810-<2l-0047 UCC 015826 6.) The flatness the flange surfaces is as ssential to good gasketing practice as .e proper gasket Unit load. f gasketed surfaces are perfectly flat under operating conditions, the average unit load is also the minimum unit load. If, for any reason the gasketed surfaces are not flat while in service, the gasket unit load can be less at some point or points than the amount required to seal operating or test pressures. In general, if when the flange faces are brought together (i.e. just touching and under no bolt load), a 0.001" feeler gauge can not be inserted anywhere around the circumference of the joint, then a 1|64 inch (0.015") thick GRAF0IL gasket can always be used. If this criteria can not be met, then the thicker GRAFOIL gasket will be required. IMPORTANT POINTS CONCERNING FLANGE SURFACE FINISH AND "STANDARD" SERRATIONS Under equivalent compressive unit loads, GRAFOIL gaskets will seal where surface finishes range from 5 RMS (root mean square) to 125 RMS. Within that range any RMS finish will seal as well as any other. Flanges ordered with "standard serrations" or a "standard finish" usually have finished surfaces machined in accordance with MSS Standard Practice SP-6 (1) which allows for considerable latitude in finish. The SP-6 Standard refers to AARH finishes or arithmetic average roughness. AARH values are different from RMS valves for any given surface. RMS measurements can be made with stylus tracer instruments, whereas, AARH can not. AARH finishes are evaluated only by "sight and touch" comparisons with standard specimens. The standard serrations may be concentric or spiral. If concentric, there may be up to 32 serrations per inch, and the depth of the serration may range from 0.005" to 0.015". The serration cross-section can range from a radiused "u" cut to a "v" cut. ... Flange surfaces having the maximum serrations per inch at maximum depth can leave a "saw tooth" surface with little or no flat areas between the serrations. GRAFOIL flexible graphite gaskets are not recommended for use with this type of flange finish. Spiral serrations can range from 20 to 50 per inch in number and from 0.001" to 0.006" in depth. Again, the maximum number of serrations to maximum groove depth can produce a sharp, "saw .tooth".surface. .However, in contrast with concentric serrations, a spiral serration can form a continuous leak path if the gasket material does not deform and-.seal all the way to the bottom of the groove. Consequently, the greater the depth of the spiral serration, the greater the required thickness of the GRAFOIL gasket in order to seal. The required thickness can be calculated in a manner similar to that shown in Case 3. While serrations, in general, do not help GRAFOIL gaskets to seal, GRAFOIL gaskets with their unique physical properties will seal serrations more dependably than most other materials. If a flanged joint is being designed with the intent of using GRAFOIL flexible graphite gaskets, it is recommended that the serrations and surface finish be dimensioned in detail, rather than left to the broad limits permitted by Standard Practice SP-6. . (1) Developed and approved by the Manufacturer's Standardization Society of the Valve and fittings Industry, 420 Lexington Avenue, New York, New York 10017. UCC 015827 UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES DIVISION CENTRAL ENGINEERING P. 0. BOX 8361 SOUTH CHARLESTON, WEST VIRGINIA 25303 MEMORANDUM BUSINESS CONFIDENTIAL March 27, 1987 TO: COPY: FROM: SUBJECT: CStME Personnel Mr. C. C. Neely G. B. Elder Asbestos Containing Materials RECEIVED MAR 31 1987 CCN The C&P Manufacturing Council have endorsed the program to phase out asbestos containing materials In the workplace, and Clyde Neely Is chairing a committee to Implement the policy. Attached Is a copy of the final draft of the policy for your use. The key statement Is that no asbestos containing material shall be purchased after January 1, 1989. The biggest change will occur In the area of gaskets and packing. The approach for gaskets Is to use Grafoll spiral-wound with teflon or Grafoll filler, or In some cases, reinforced teflon. The organic fiber reinforced "non-asbestos" materials do not pass fire tests and have very limited ability to maintain adequate -bolt Toads, so they are nst being considered.. Grafol1 and graphite fiber will be used for packing. The policy does not forbid the use of asbestos containing gaskets or packing and only states that we will quit buying It after January 1, 1989. However, EPA rules are making It Increasingly difficult to remove and dispose of any asbestos materials Including gaskets and packing. It makes sense to discourage the use of these asbestos materials starting now so that we minimize the removal and disposal problem. A second benefit of doing this will be to assist a change In the psychology and procedures over a longer period of time Instead of having a crisis during 1988. UCC 015828 2- I realize that the change to other gasket and packing materials cannot take place over night and that you will be using additional asbestos materials. However, please don't recommend any asbestos gaskets or packing for any new Installations and try to encourage the substitution of Grafoll and spiral-wound gaskets whenever you have the opportunity. GBE/ds 2033H UCC 015829 DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS^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 015830 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 sealablllty 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 015831 D RAFT 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 015832 C. C. Neely 47071 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 sealablllty are Included. Consistent with the aforementioned commitments arrd 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 015833 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&PHS&EA Audit compliance with governmental regulations and C&P Standard Practices relating to asbestos-containing materials and, where applicable, their substitutes. UCC 015834 C. C. Neely 47071 C. C. Neely Loc. 511 2000/3336 Tech Center UNION CARBIDE CORPpRATIUn ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES DIVISION CENTRAL ENGINEERING P. 0. BOX 8361 SOUTH CHARLESTON, WEST VIRGINIA 25303 - MEMORANDUM TO: COPY: FROM: SUBJECT: BUSINESS CONFIDENTIAL February 25, 1987 Mr. E. K. Harris- Bldg. 2000 MOC A. J. Montero Received mar 2 1987 CClf Materials of Construction Recommendations ; for IBT (Isobutyraldehyde Trlmer) Production You are preparing a technology package to make UCAR Fllmer IBT (Isobutyraldehyde trlmer). This product will be made by Haltermann, a custom processor In Houston, Texas. You asked me to provide you with a statement for the technology package regarding the materials of construction for the IBT process. The materials of construction recommended for producing UCAR Fllmer IBT are: 1. Storage of IBAL (Isobutyraldehyde) - fresh and recycled IBAL should be stored In 304 SS, 316 SS, or aluminum tanks. Steel tanks can be used but they must be lined with a compatible lining such as Plaslte 3066 or Plaslte 9500. 2. Reaction - carbon steel Is the recommended material of construction for this part of the process. Types 304 SS and 316 SS are also acceptable materials of constnictton. 3. IBAL Recovery - carbon steel Is also the material recommended for the recovery column and any equipment and piping associated with this column. Again, 304 SS and 316 SS are, also acceptable materials. 4. Flash System - carbon steel Is also the recommended material for all the equipment and piping In this system. Types 304 SS and 316 SS are also acceptable materials". 5. Refining System.^ carbon- steel Is the recommended material for this system. Type 304 SS and 316 SS are also acceptable materials. 6. Storage of IBT - carbon steel, 304 SS or 316 SS, or aluminum are can be used to store IBT. UCC 015835 received MftR 191987 CCN 7. Condensers and Coolers - carbon heat exchangers which use coolln compatible with the process stre. compatible with the cooling watei 8'. Gaskets - compressed asbestos, Te acceptable for handling the raw m 9. 0-rlng and Elastomers - the only i process streams Is EPR (also knowi temperature Is 45C (113F). Abo\ The above recommendations were based on 1. To prevent Iron contamination of the fresh and carbon steel Is not recommended. I 3/) 7 amount of water and organic acid pr .2 Although there may be some Isobutyrl acid will not Increase the corrosion 'cut*. ---9 - - neutralized In the reaction system w catalyst. Compressed asbestos gaskets are norm* service when the temperature Is above aldehyde In the stream Is greater tha will not be made all the time, compre for streams containing more that 10% i 100C. Field experience shows that 11 aldehyde to attack the binder In compr asbestos with an EPR binder will give asbestos with other binders. _____ . )' -- If you have any questions or comments concert please feel free to call. .e aoove recommendations. AJM/ds 1919H Index: B, 26, 28, 30, 32, 67, 71, 72, 81, 112, 113, 119, 120, 122, 131, 132, 138, 166, 187, 212, 273, 336 &JL UCC 015836 received . NlftR 191987 - 2 ^ . CCN 7. Condensers and Coolers - carbon steel tubes may not be acceptable for heat exchangers which use cooling water. As stated, carbon steel Is compatible with the process streams. Whether carbon steel Is or Is not compatible with the cooling water has to be determined by Haltermann. 8. Gaskets - compressed asbestos. Teflon, and grafoll gaskets are acceptable for handling the raw material and the process streams. 9. Q-rlng and Elastomers - the only elastomer recommended for handling the process streams Is EPR (also known as EPT and EPDM). The maximum temperature Is 45C (113F). Above this temperature, Teflon Is required. The above recommendations were based on the following: 1. To prevent Iron contamination of the fresh and recycled IBAL, bare carbon steel Is not recommended. Iron contamination Is affected by the amount of water and organic acid present In the aldehyde. Although there may be some Isobutyrlc acid In the IBAL, the Isobutyrlc acid will not Increase the corrosion rate of steel because It will be neutralized In the reaction system with the sodium hydroxide used as a catalyst. ___ Compressed asbestos gaskets are normally not recommended for aldehyde service when the temperature Is above 100C and the concentration of the aldehyde In the stream Is greater than about'10%. However, since IBT will not be made all the time, compressed asbestos should be acceptable for streams containing more that 10% aldehyde and at temperatures above 100C. Field experience shows that It takes several years for the aldehyde to attack the binder In compressed asbestos. Compressed asbestos with an EPR binder will give better service than compressed asbestos with other binders. __________ ___ If you have any questions or comments concerning the above recommendations, please feel free to call. * AJM/ds 1919H Index: B, 26, 28, 30, 32, 67, 71, 72, 81, 112, 113, 119, 120, 122, 131, 132, 138, 166, 187, 212, 273, 336 GJL UCC 015837 INTERNAL CORRESPONDENCE received MAR 2 6 l987 UNION CARBIDE CORPORATION t echnical center CCN PO BOX B361, SOUTH CHARLESTON, WV ;J!53G See Distribution List (SHAC) March 24, 1987 P. R. Kavasmaneck D. C. Macauley C. C. Neely* Recommended C&P Program Phase-Out of AsbestosContaining Materials In Workplace I have been Informed that the Manufacturing Council has endorsed the subject program (copy attached for your convenience). It Is the same one you reviewed In September. What seems to be happening Is that the vendors are moving ahead of us and have made gaskets and packing containing asbestos almost a special-order product. The plan to upgrade valve and piping specs by mld-1988 may have to be accelerated. I hear that the price of GRAFOIl" Products dropped considerably. A)c 7362D Attachment Letter only* UCC 015838 TO: SAFETY & HEALTH ADVISORY COMMITTEE DISTRIBUTION V. D. Dutcher D. A. Gosselln V. H. Johnkoskl C. P. Maxwell 0. P. Mukheja J. D. Nlcol R. D. Ondocsln T. P. Raby G. L. Rivera Cary, NC. 82/907 82/4 511/701 500/L4 500/P2 500/P2 82/4 . 515 UCC 015839 i * ** * * * UNION * CARBIDE * ** INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center ' South Charleston, WV 25303 October 16, 1986 RlClived OCT 2 0 1988 vW >'VI4- CCN TO:____ rsFi - Mr.,,L.. C.a.lver Mr. S. W. Clark fj - Hr 6. BrTTder Mr. R. W. Engle s.s. y}v ^r-- i M't 'C COPY TO: SUBJECT: Mr. C. C. .Neely J Cffl II n /v -vwii Recommended C&P Program - Phase-Out Use of Asbestos-Containing Materials In Workplace ^ii J. (, l&/pt?,s ifJU. ^^ Gentlemen: $ po./iOy.fi c1'~r'K - cx~' Ci P lo-T-cii ctU<. Attached Is a copy of your recommendation covering asbestos usage which I transmitted to Bob Perry. J* Thanks for your Insights and efforts In pulling this together. I'll keep your team posted as the recommendation proceeds through the system. Very truly yours, JES:he Attachment 4704Y ,, ^ ^ 4 $Bb ixQ fz) UCC 015840 * UNION * * CARBIDE * ** INTERNAL CORRESPONDENCE * Engineering, Manufacturingrand Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 14, 1986 TO: Mr. B. G. Perry COPY TO: Mr. P. 0. Franson Dr. P. R. Kavasmaneck Mr. W. G. LtlTy, J^. Mr. C. C. Neely ^ Mr. S. W. Turlcchl SUBJECT: Recommended C&P Program - Phase-Out Use of Asbestos-Containing Materials In Workplace RECEIVED OCT 2 0 ?J3o CCN Bob: In July of this year, you requested on behalf of the Manufacturing Council that a Task Group be assembled to evaluate the Implications for Chemicals and Plastics of continued use of asbestos-containing materials In the workplace. You should be aware that asbestos-containing Insulation materials were prohibited for new construction and for replacements beginning In 1976. % The Task Group, headed by Mr. C. C. Neely, Corporate Fellow Engineering Mechanics, was comprised of the following Individuals and areas of expertise. L. E. Calvert S. W. Clark G. B. Elder R. W. Engle Maintenance HeaTth/Safety Corrosion-Materials Valve and Piping Technology The Task Group has surveyed current and projected Industry practices with regard to the use of asbestos-containing materials and has evaluated current government regulations and made judgements with regard to future regulations which could Impact on the use of and cost of use of asbestos-containing materials. Additionally, the Group evaluated the availability and cost effectiveness of substitute materials. UCC 015841 ' Hr. B. G. Perry Page 2 October 15, 1986 f. ( Based on available evidence that airborne asbestos In the occupational workplace has proven to be a carcinogen and that cost effective alternative materials are available, or can be developed with relative ease, the Team has recommended that C&P continue to phase out the use of asbestoscontaining materials with-no purchase or Installation of asbestos-containing materials, without a formal ^variance, after January 1, 1989. Asbestoscontaining materials that are In use and retain their structural and functional Integrity need be replaced -only If this Integrity Is compromised, or when normal maintenance occurs. Other recommendations are contained In the attached draft of the C&P Recommended Program. " I want to thank the Task Group for their efforts In this study and for their breadth of judgement as reflected In the recommendation. Please let me know of further work you require, or of any questions you may have. JES:he Attachment 4701Y UCC 015842 ( UNION CARBIDE CORPORATION;P. 0. Box 8361 Engineering, Manufacturing, and Technology Services Central Engineering So. Chas., WV 25303 BUSINESS CONFIDENTIAL September 30, 1986 TO: Mr. J. E. Sanders COPY TO: Mr. L. C. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle . FROM: C. C. Neely SUBJECT: Final Draft of Recommended C&P Program Phase-Out Use of Asbestos-Containing Materials In Work Place Chemicals and Plastic Group Attached herewith on behalf of the Special Working Group Is a copy of the subject document dated 9/29/86. It Is a slightly fine-tuned version of the 8/28/86 version which was transmitted to you under my transmittal also dated 8/28/86. The changes that have been made are of a clarifying rather than substantive nature. At this point, we have not made an effort to obtain broad, formal review of the subject program. However, Larry Calvert has discussed It briefly with the Maintenance APM's and Maintenance Managers. In addition, Stan Clark arranged for Its review by the Safety, Health Advisory Committee (SHAC), and your staff has reviewed It. Feedback Indicates these groups to - be supportive of the concept, but some have expressed concern regarding the January 1, 1989 date specified for the discontinuance of the purchase of asbestos-containing materials, believing It to be optimistic. Some of the concern relates to the following: 1. CEO's ability to revise and reissue the V&P Specifications and the Valve Manual In time to support the deadline. The responsible CEO specialists have carefully reviewed this matter and believe that reissuance of these Manuals by July 1, 1988 Is realistic. This date has not been published, however. UCC 015843 Mr. J. E. Sanders (-2- September 30, 1986 2. Belief that field testing of new gasket and packing materials will be required. Such testing will not be necessary since the plan at this time Is to accommodate most of the substitutions by broadening the use of materials already In use, materials such as reinforced Teflon and GRAFOIL". This plan has not been broadly disseminated, and we can fully appreciate the reluctance to agree to a purchasing cut-off date for asbestos-containing products without knowing what the substitutes are. We also appreciate that, once this material substitute plan Is known, there will be a natural resistance due to the higher first cost of these substitute materials. 3. Some belief that Installe.rs will need special training to handle the new gasket and packing materials. For reasons cited In (2), we do not believe this requirement will be significant. 4. Perhaps lack of understanding that the January 1, 1989 date Is the cut-off date for the purchase of asbestos-containing materials except as approved by a variance. 5. "Is this really necessary" attitude. The Special Working Group believes that OSHA's recently revised exposure limit of 0.2 fibers per cubic centimeter of air (was previously 2.0 fibers per cubic centimeter) add significant Impetus to Implement the proposed Recommended Program. According to Terry Hanning's September 5, 1986 memorandum (copy attached), labor union representatives do not believe that controlling the exposure limit to this lower level provides adequate protection. The above concerns notwithstanding, the Special Working Group decided to submit the subject Recommended Program to you with the January 1, 1989 date Included since we believe that, with proper communication with the key plant personnel responsible for Its Implementation, along with management support, this date Is realistic and achievable. We are submitting under separate cover a proposed CEO Technology Program which Includes request for funds to cover the Important communications aspect of j the understanding, acceptance and Implementation process. Please let me know how we can be of further assistance regarding this matter. CCN:mr 43191 Attachment C. UCC 015844 ( 9/29/86 DRAFT RECOMMENDED, C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) GOAL: PHASE-OUT USE OF ASRESTOS^CONIAIMING MATERIALSCPlN THE WORK PLACE PURPOSE/BACKGROUND The Corporate Charter (1.1) contains the following commitment to employees: "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 proc^4ing ^f^aibestas-.can^tructixiQ 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 (1)"Asbestos-containing materials" Include but are not limited to Insulation, gaskets, packing, weldVng blankets, and construction products. UCC 015845 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 considerations of Improved service life and sealablllty 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^1) 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 cons1dejar tlon 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 facilities. 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 015846 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 material 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 015847 C. C. Neely 2073W UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES Central Engineering South Charleston, West Virginia UCC BUSINESS CONFIDENTIAL March 26, 1987 TO: S. W. Clark G. B. Elder R. W. Engle COPY TO: W. K. Norton, Jr. J. E. Sanders FROM: Neely SUBJECT: EON - C&P Asbestos Usage Phaseout Program Implementation The EON for the subject activity is 15063. You will recognize this to be the same EON which we used last year to cover the program development costs. CCN:at 45591/14 Joe, I told WKN that the costs collected In this account would be charged to Departmental overhead unless we (meaning JES) could find a sponsor (a'la Gerry Viera). UCC 015848 UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM March 4, 1987 RECEIVED MAR 6 1987 TO: J. E. Neff CCN CC: P. R. Kavasmaneck C. C. Neely ^ H. W. Wegert RE: C&P Asbestos Policy Proposed Technology Program The ad hoc asbestos team, chaired by C. C. Neely, has received word that the C&P Manufacturing Council has approved the policy we recommended last fall (copy attached). Now we need to address the work that CEO needs to do to support this policy (see Delegation Section of Policy and CCN's proposed program for 1987, which Is also attached). Clyde would like to meet on the morning of March 17 to review this program. Specifically, we need you to tell us about the Industrial Hygiene Group Involvement. SWC:jwc 51180 Attachments S. W. Clark UCC 015849 UNION CARBIDE CORPOF J3N' ' Engineering, Manufacturing, & Technology Services . Box 8361 South Charleston, WV 25303 - UCC BUSINESS CONFIDENTIAL (TO BE OPENED BY ADDRESSEE ONLY) February 19, 1987 TO: Mr. R. R. Bannister Mr. R. A. Conway Mr. P. D. Franson Mr. D. L. Garrison Mr. G. M. Keller . Mr. C. C. Neely*/ Mr. J. E. Sanders Mr. L. L. Simpson Mr. W. J. Simmons ' COPY TO: Mr. B. G. Perry Mr. W. G. Lilly, Jr. Mr. D. L. Runyon FROM: P. R. Kavasmaneck SUBJECT: J. E. Sanders Staff Meeting Minutes February 19. 1987 RECEIVED FEB 2 01987 CCH 1. Safety - January was a good month from the viewpoint of LHC and recordables and weather-related Incidents. We had two OTJ random events. We also had one recordable Illness, an allergy possibly related to the office environment. 2. SRA - SRA checks have been received; feedback needs to be completed by Tuesday, February 24. JES will participate In some. No announcements are planned. The event-related SRA program Is still In place. Getting the event-related SRA does not automatically eliminate an individual from consideration for the annual award. 3. Salary - The exempt budget -is^comiog "real ,-sooo" per jG. M. Keller; thre * Increase In range is 31 and budget Is 5X. Non-exempt salary budget - sentiment of the Tech Center Site Advisory Council Is that we need to be more competitive In terms of wages; we seem to be on the high side In the Valley, especially at the entry level. Total budget Is 4X; average range movement Is 2X (none at entry level); 1-1/2X for Grade 7 and IX for Grade 8. - Progression money and performance money will be available In the budget. Packages will be mailed on 2/19. 4. Asbestos - Clyde Neely's team recommended a phase-out by January 1989, and discontinue purchase. Manufacturers are actively seeking and suggesting alternatives. Bob Perry presented the recommendation to the Manufacturing Council, which accepted them, and we are to proceed with changing Engineering Standards to Incorporate this recommendation. UCC 015850 2- - JES suggested Involvement of CED (materials of construction, piping); L. E. Calvert, Maintenance Group; and Purchasing. Clyde was requested to lead a team to undertake this Implementation and propose resources and schedule. 5. Promotions - No DMT meeting was held yesterday, 2/18/87; however, promotions through Grade 11 are conceptually approved. (We need to revisit Janeshek and Delaney at a later date.) For promotions to Grades 12 and 14, JES will take up with DMT next month, but we should make plans to Include them In the 1987 salary budget. 6. Greenwich Meeting - Mr. Kennedy had three key Items to leave meeting with: 1) Know strategic Intention of Corporation. 2) Have a knowledge of key businesses. 3) Be committed to the values of the Corporation. The mission and values are Important and we need to buy Into them. Mr. Kennedy stressed the Importance of the long term while meeting short-term objectives. Also, we need to get more value for assets; operate and produce, not liquidate. The role of the Corporation Is to provide arena to be the best. Five values that need to be put In MOP'S, strategic plans, etc., are: safety; customer focus; people excellence technology; simplicity. Mr. Kennedy predicted businesses are going to be stronger, bigger In the next few years. During this time, our values will be Identified with us and we with them; we will measure everything against the best. 7. Minutes of Last Meeting - GMK has asked the Kanawha Valley Non-Exempt Job Evaluation Committee to look at secretarial job posting descriptions to Include Wang and shorthand capabilities. 8. Position Terms - PDF raised questions regarding use of titles on ^ Technical Ladder, e.g.. Engineering Consultant and Specialtst. Vicky" * Hutchison will poll JES and WGL staff to see feeling of group. 9. Rhone-Poulenc Contract - DLG brought concern to the group regarding requests for source coding for IPES, UCPC, pressure vessel programs and title to CED computer programs. DLG recommended we not share this without fee. JES also asked us to review distribution lists for reports going to Rhone-Poulenc. CCN surfaced liability Issuesregarding Engineering advice provided to R-P resulting from Incomplete control over final execution. GMK said all movement of non-exempt personnel between R-P and UCC ceased after the December 19 signing of the sales agreement. 10. India Trip - The Chemicals Unit at Trombay, India, has been phased down since last year. Utilities are functioning, but not much else. They are now getting ready to restart and DLG reviewed expansion for operating characteristics for several units he had familiarity with. UCC 015851 UNION CARBIOE CORPORATION Jr. ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES DIVISIONTM3 CENTRAL ENGINEERING P. 0. BOX 8361 / SOUTH CHARLESTON, WEST VIRGINIA 25303 MEMORANDUM ,,_ C C> TO: COPY: FROM: SUBJECT: Mr. Mr. G. Asb BUSINESS CONFIDENTIAL February 9, 1987 RECEIVED FEB 2 01987 CCN Attached Is a materials . I' Sanders and his letter stating that It was transmitted to Bob Perry. Bob should be able to tell you where It has gone after It left his hands. We would appreciate feed-back of any Information you obtain on the current status of the proposed program. GBE/ds 1910H At //a&j n/ */// A& &e>6 J>i d A. jQJpzc Ay /V)C try^c/iy yC^*t /?/?cruk*/ Ac'/Uf Ookns. AaA UCC 015852 O'/ ,, ^nd? UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES OIVISION CENTRAL ENGINEERING P. 0. BOX 8361 SOUTH CHARLESTON, WEST VIRGINIA 25303 MEMORANDUM BUSINESS CONFIDENTIAL February 9, 1987 TO: COPY: FROM: SUBJECT: Mr. J. P. Hamilton - Danbury K-3 Mr. C. C. Neely G. B. Elder Asbestos-Containing Materials In the Work Place RBCfiVED FEB UJ1987 CCN Attached Is a copy of the proposed program to phase out asbestos-containing materials. I've also attached a copy of Clyde Neely's transmittal to Joe Sanders and his letter stating that It was transmitted to Bob Perry. Bob should be able to tell you where It has gone after It left his hands. We would appreciate feed-back of any Information you obtain on the current status of the proposed program. GBE/ds 191 OH / )is>OA&e\ ivul OE'S 'ifySIks ilo^ *1 UCC 015853 (Uil Q ... yfyrvuiirfd------------ ....... __. -tfTVO^ Xfl^-- -_ UCC 015854 UCC 015855 .111 /' ' >c / diAUCy (rc\r,ve Aiy< M. v // s ? 4i',k (2 ' v777 7- 17 //; '7' A i-/ // o UftmiiJL /^ TP LyfM 7 7 / <r L /'/'/;/v'.'?2 ) X/ /' X '//> AA'.\t'jv ' \' 4l7 $y ! i! !/! : SC{1 ! - .1 2- Aj^/1 XXx. /x 7x2 'i t< X - 7U 7 r , ^ 1 ; / ; ^ r- " \ i - , ri U. t V ^ / v y'. ufa j i UCC 015856 ,y V ' , X'> ."AX. DETAIL SKETCH ENGINEERING DEPARTMENT UNION CARBIDE CORPORATION LOCATION 'INDEX Nl SITE 1 SUBJECT " JOB NUMBER ZONE DESCRIPTION DRAWN BY TMPL/vie*JTAT/OhJ - AS&ES7CXS SJAN. JZ.N' rJ&CE CHECKED BY STAN&AP& LA/3&/Z /ZATES YEA/Z /137 H88 EX/3 (V 3Z. /a 33. - NBA (V 25. 7r 24. DRAWING NUMBER AREA UNIT SYMBOL REFER TO ORAWING CATEGO/zy I NNo\a/N C-NaNE/SS To EX/STlNO AN& SpEc/T/CAT/eNO STANDAZpS X& N-A TOTALS CATE&0Y X axe> A>A totals /l81 /183 M. ACS. i m /V)< MPS. EXPENSES $M t5 4,3 /OO 3.2, 6.0 3 SO s' /SO 3.> 5&o /a,/ zso <0**3 $ 5?, O t S 0 fr/b H T8A/N/NO ASEoc/ATBO W/T/-J /MpuE MNTA7/0*J Of= NEW ASfrSsTos stANoaz.& /T81 to, HCS. $ M --- j-_ -- --- /188 to. H/z-t / 4-8 Zo-- $ A/I o.S 16? 5.4 _i EXPENSES $M 6.0 (6.0 ; c it. S.OM / f -fo 4 WORK ORDER 2ND NO, ISSUED FOR &r^V; \C\/ ) > c -.. ......xr DATE REVISION BY CKD #36*150-007 (Rev. 3-66) UCC 015857 DETAIL SKETCH ENGINEERING DEPARTMENT UNION CARBIDE CORPORATION LOCATION INDEX N SITE iR SUBJECT ' JOB NUMBER ZONE DESCRIPTION DRAWN BY /MPLEM&hJTAT/OhJ- A5&B5TOS $7Ad- . P t/s/*/i*>- CHECKED BY DRAWING NUMBER AREA UNIT SYM80L REFER TO DRAWING C&TE6t0/Z'Y m - NBW S7AKJDA&25 ; OP A^&BSTOS POP SAAB PAk/DI~iA6 EX& hJSA TOTALS /931 M. AZ9. - 4o C>0 / 4 M. Mizs 40 Oo : /OO -7 /oo A3 Zii' 2.2 XB/^SS 4M >.3: . 0.3 z -- C&< O /V/ SUPB/ZV/S/OtJ __ BO A/ZS ($2.3 TOTALS $4-S.6, m //& 2 /*>. P/zs . f G.T4 /wo./? ,. m&nrAs* _V WORK ORDER 2ND NO. 936-150-007 (Rev. 3-86) ISSUED FOR UCC 015858 DATE REVISION BY CKD _olfP_ JAR. S'(pics... - Jn tdb&yxcL ^ Qyj?tnAti/)^ Isb^Pfyc QuJ- hluk. Jlsy, wilt JLtrtlff /no, A A -- $...' & MM A / /<Ml>....y& 4 / - SOOb -/ - UCC 015859 * UNION * * CARBIDE * ** INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 Febuary 19, 1987 TO: Mr. B. 6. Perry COPY TO: Mr. P. D. Franson Mr. W. G. Lilly, ,Jr. Mr. C. C. Neely / Mr. S. W. Turlcchl SUBJECT: Asbestos Usage REC8VED FES 2 31987 CCH Bob: We are proceeding to establish plans to Implement the phase-out of asbestos-containing materials from C&P facilities. I have asked Clyde Neely to lead this effort which will require resources and Input from Maintenance groups. Purchasing, Safety and Health as well as Engineering Technology skill centers. Clyde will. In the next couple of weeks, develop a plan out lining the general steps required for this program between now and January 1989. We'll keep you posted on progress. .Very truly yours. JES:he 4898Y(4) J. E. Sanders UCC 015860 * ** * ** * UNION * * CARBIDE * ** ** * INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services -Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 16, 1986 TO: Mr. L. E. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle COPY TO: Mr. C. C. Neely SUBJECT: Recommended C&P Program - Phase-Out Use of Asbestos-Containing Materials In Workplace Gentlemen: Attached Is a copy of your recommendation covering asbestos usage which I transmitted to Bob Perry. Thanks for your Insights and efforts 4n pulling this together. I'll keep your team posted as the recommendation proceeds through the system. Very truly yours. OESrhe Attachment 4704Y UCC 015861 * UNION * * * CARBIDE * * INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 14, 1986 TO: Mr. B. G. Perry COPY TO: Mr. P. D. Franson Dr. P. R. Kavasmaneck Mr. W. G. Lilly, Jp^. Mr. C. C. Neely ^ Mr. S. W. Turlcchl SUBJECT: Recommended C&P Program - Phase-Out Use of Asbestos-Containing Materials In Workplace tcLIVED OCT 2 0 CCN Bob: In July of this year, you requested on behalf of the Manufacturing Council that a Task Group be assembled to evaluate the Implications for Chemicals and Plastics of continued use of asbestos-containing materials In the workplace. You should be aware that asbestos-containing Insulation materials were prohibited for new construction and for replacements beginning In 1976. The Task Group, headed by Mr. C. C. Neely, Corporate Fellow Engineering Mechanics, was comprised of the following Individuals and areas of expertise. L. E. Calvert S. W. Clark G. B. Elder R. W. Engle Maintenance Health/Safety Corrosion-Materials Valve and Piping Technology The Task Group has surveyed current and projected Industry practices with regard to the use of asbestos-containing materials and has evaluated current government regulations and made Judgements with regard to future regulations which could Impact on the use of and cost of use of asbestos-containing materials. Additionally, the Group evaluated the availability and cost effectiveness of substitute materials. UCC 015862 wav) *4. Mr. B. G. Perry Page 2 October 15, 1986 Based on available evidence that airborne asbestos In the occupational workplace has proven to be a carcinogen and that cost effective alternative materials are available, or can be developed with relative ease, the Team has recommended that C&P continue to phase out the use of asbestoscontaining materials with no purchase or Installation of asbestos-containing materials, without a formal variance, after .January 1, 1989. Asbestoscontaining materials that are In use and retain their structural and functional Integrity need be replaced only If this Integrity Is compromised, or when normal maintenance occurs. Other recommendations are contained In the attached draft of the C&P Recommended Program. ' I want to thank the Task Group for their efforts In this study and for their breadth of Judgement as reflected In the recommendation. Please let me know of further work you require, or of any questions you may have. JESrhe Attachment 4701Y UCC 015863 UNION CARBIDE CORPORATION;P. 0. Box 8361 Engineering, Manufacturing, and Technology Services Central Engineering So. Chas., WV 25303 BUSINESS CONFIDENTIAL September 30, 1986 TO: Mr. J. E. Sanders COPY TO: Mr. L. C. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle FROM: C. C. Neely SUBJECT: Final Draft of Recommended C&P Program Phase-Out Use of Asbestos-Containing Materials In Work Place Chemicals and Plastic Group Attached herewith on behalf of the Special Working Group Is a copy of the subject document dated 9/29/86. It Is a slightly fine-tuned version of the 8/28/86 version which was transmitted to you under my transmittal also dated 8/28/86. The changes that have been made are of a clarifying rather than substantive nature. At this point, we have not made an effort to obtain broad, formal review of the subject program. However, Larry Calvert has discussed It briefly with the Maintenance APM's and Maintenance Managers. In addition, Stan Clark arranged for Its review by the Safety, Health Advisory Committee (SHAC), and your staff has reviewed It. Feedback Indicates these groups to be supportive of the concept, but some have expressed concern regarding the January 1, 1989 date specified for the discontinuance of the purchase of asbestos-containing materials, believing It to be optimistic. Some of the concern relates to the following: 1. CED's ability to revise and reissue the V&P Specifications and the Valve Manual In time to support the deadline. The responsible CED specialists have carefully reviewed this matter and believe that reissuance of these Manuals by July 1, 1988 Is realistic. This date has not been published, however. UCC 015864 Mr. J. E. Sanders -2- September 30, 1986 2. Belief that field testing of new gasket and packing materials will be required. Such testing will not be necessary since the plan at this time Is to accommodate most of the substitutions by broadening the use of materials already In use, materials such as reinforced Teflon and GRAFOILTM. This plan has not been broadly disseminated, and we can fully appreciate the reluctance to agree to a purchasing cut-off date for asbestos-containing products without knowing what the substitutes are. We also appreciate that, once this material substitute plan Is known, there will be a natural resistance due to the higher first cost of these substitute materials. 3. Some belief that Installers will need special training to handle the new gasket and packing materials. For reasons cited In (2), we do not believe this requirement will be significant. 4. Perhaps lack of understanding that the January 1, 1989 date Is the cut-off date for the purchase of asbestos-containing materials except as approved by a variance. 5. "Is this really necessary" attitude. The Special Working Group believes that OSHA's recently revised exposure limit of 0.2 fibers per cubic centimeter of air (was previously 2.0 fibers per cubic centimeter) add significant Impetus to Implement the proposed Recommended Program. According to Terry Hanning's September 5, 1986 memorandum (copy attached), labor union representatives do not believe that controlling the exposure limit to this lower level provides adequate protection. The above concerns notwithstanding, the Special Working Group decided to submit the subject Recommended Program to you with the January 1, 1989 date Included since we believe that, with proper communication with the key plant personnel responsible for Its implementation, along with management support, this date Is realistic and achievable. We are submitting under separate cover a proposed CED Technology Program which Includes request for funds to cover the Important communications aspect of the understanding, acceptance and Implementation process. Please let me know how we can be of further assistance regarding this matter. CCN:mr 43191 Attachment C. UCC 015865 9/29/86 DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) GOAL: PHASE-OUT USE OF ASBESTOS-CONTAINING MATERIALS^)IN THE WORK PLACE PURPOSE/BACKGROUND The Corporate Charter (1.1) contains the following commitment to employees: "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 (I)"Asbestos-containing materials" Include but are not limited to Insulation, gaskets, packing, welding blankets, and construction products. UCC 015866 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 considerations of Improved service life and sealablllty 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^1) 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 conslderatlon 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 facilities. 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 015867 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 material 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 015868 C. C. Neely 2073W RECtlVLu or P 1 o '1986 UNION CARBIDE CORPORATION r. k/WASMANECK ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMEN7 HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM September 5, 1986 TO: Mr. S.W. Clark Mr. D.A. Gosselln . Mr. V.H. Johnkoskl Dr. P.R. Kavasmanecki^" Mr. J.A. Leonard Mr. J.B. Leverton FROM: T.E. Hanning SUBJECT: Asbestos Update For Your Information Mr. C.P. Maxwell Mr. J.E. Neff Mr. M.A. Patel Mr. T.P. Raby Mr. H.W. Wegert SEP 2 9 1986 CCSI Labor union representatives are currently endorsing a pro posed asbestos ban' by the Environmental Protection Agency. The unions contend that OSHA's permissible exposure limit of 0.2 fibers per cubic centimeter of air, effective July 21, provides Insuf ficient worker protection. The proposed EPA rule would ban completely, five asbestos products that have effective substitutes. These products are: roof ing felts, flooring felts, vinyl-asbestos floor tile, asbestos clothing, and asbestos/cement pipe and fittings. Other asbestos uses would be phased out over 10 years. TEH/db 6209D Terry E. /Manning Extension 5903 UCC 015869 * * * * * ** UNION CARBIDE ** * * * * * * INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Post Office Box 8361 Central Engineering Building 2000 Technical Center South Charleston, WV 25303 October 16, 1986 74 Received OCT 2 0 ecu TO: 3 COPY TO: SUBJECT: Mr. L. E. Calvert Mr. S. W. Clark (I Mr. G. B7 ET(Ter~ Mr. R. W. Engle r . jy - . ~ ( m 'i > > S.S. V] JMr. C. C. Neely (jn II (ry> n M > y-U \ Recommended C&P Program - Phase-Out Use of <L Asbestos-Containing Materials In Workplace Helpers C Gentlemen: }y Cit f f' " C4 P i(JT OT ' Attached Is a copy of your recommendation covering asbestos usage which I transmitted to Bob Perry. Thanks for your Insights and efforts In pulling this together. I'll keep your team posted as the recommendation proceeds through the system. Very truly yours. , JES:he Attachment 4704Y UCC 015870 I UNION CARBIDE CORPORATION 1300 HERCULES AVENUE. S'JIT DOT HOUSTON. TEXAS 77058 26 May 1987 RECEIVED JUN 1 1987 CCN TO: Attached List CC: Attached List SUBJECT: FINAL DRAFT OF RECOMMENDED C&P PROGRAM PHASE-OUT USE OF ASBESTOS-CONTAINING MATERIALS IN WORK PLACE - CHEMICALS AND PLASTICS GROUP In the package I sent out April 28, 1987, I made two mistakes. Please note the corrections as follows. - Paragraph two, last sentence should be 1989 not 1987. Although, as pointed out, it may not be pertinent that 1989 is the approved date. - The recommended C&P Program attached was supposed to be the revised 9/29/86 draft, not the 8/28/86 draft. I have attached the 9/29/86 document. The key change is that the 9/29/86 document is defined as a program not a policy. My apologies for the errors. LEC:ka Attachment 7212K Larry E. Calvert UCC 015871 c .r DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS' BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS0>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 015872 rr 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 sealablllty 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 015873 cr 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&PHS&EA Audit compliance with governmental regulations and C&P Standard Practices relating to asbestos-containing materials and, where applicable, their substitutes. UCC 015874 C. C. Neely 47071 DISTRIBUTION LIST Eric Baumann Jim Dement J. M. McBride Robert Gauvin Roger Hampson Doug Pridgen Tony Amatangelo R. T. Jackson R. R. Rankin C. Smith J. B. Evans J. Sidlovsky T. L. Rogstad Victor Vega Burl Mallory Bound Brook South Charleston Seadrift Montreal Bound Brook Mobile Cary, N.C. Danbury P2606 Danbury P2601 Danbury J3406 Danbury K4445 Danbury P3603 Danbury A1127 Texas City Bldg.l Star d: Andy Allen Ashton Barefoot George Elder Bart Gliatta Tom Liles C. C. Neely B. G. Perry Alec Robertson R. W. Scouler Bill Summers R. T. Worrell Woodbine Clear Lake South Charleston South Charleston. Seadrift S. Charleston Danbury M4530 Prentiss Tech Ctr. Sisterville Clear Lake Zulma Boroughs Broward Gable George Wulfert Duke Gossage George LeBlanche John Turner H. Torrellas R. E. Bollinger D. C. McCauley R. E. Graebert W. F. Gorham J. P. Grade T. L. Collins Stan Illikainen Taft Woodbine Sisterville Tech. Ctr. Moses Lake,WA Prentiss Seadrift Danbury P2595 Danbury P4 Danbury M3531 Bound Brook Toronto,Canada S. Charleston Institute Frank Bobbie S. W. Clark R. W. Engle John Wittliff S. S. Murphree W. F. Merritt Jim Polomsky) ) Ben Robinson Syl Turicchi R. 0. Spencer Bound Brook S. Charleston S. Charleston Taft Texas City Clear Lake Box 94637 Cleveland,OH Bound Brook Danbury M-4529 S. Charleston 7212K/2 UCC 015875