Document LJxZgzkzr81yNx6Oxq00YGKXd

^'O wtrsy . D NOV 14 1S86 UNION CARBIOE ** ** *** ENVIRONMENTAL PROTECTION - SOUTH CHARLESTON PLANT November 12, 1986 UC-2105 R. L. Foster C. H. Hancock Copy: J. F. Dement J. F. Dodd EPD Circulate SUBJECT: Asbestos Notification The attached is for your Information. There are a number of Issues involved which 1 will explain In more detail at a later date. In the meantime, we will be talking with the APCC (Federal Asbestos Coordinator for West Virginia) and to Carol Febbo of EPA Region Ill's Air Enforcement Branch about this, and will follow this up with a written response to Mrs. Wasserman. JLW:cp 0590W Attachment yack 3. L. Worstell UCC 006435 y* sc% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building Philadelphia. Pennsylvania 19107 RECEIVED NOV 1 2 h-, EPO Mr. D.H. Hanshew Union Carbide Corporation P.O. Box 8004 South Charleston, WV 25303 NOV 7 1986 NOTICE OF DEFICIENCY: #831410025087 Deficiency in Notice to EPA of Asbestos Demolition or Renovation Operation Dear Mr. Hanshew: This is to inform you that the notice of asbestos renovation postmarked October 14, 1986, for the Number 19 Batch Still at Mainland Chemicals Unit which was submitted to the United States Environmental Protection Agency (EPA) was incomplete. Therefore, Union Carbide Corporation has failed to comply with the requirements of 40 C.F.R. 61.146, and of Section 112 of the Clean Air Act as amended (the Act), 42 U.S.C. 7412. Pursuant to Section 112 of the Act, EPA promulgated regulations, known as the National Qnission Standards for Hazardous Air Pollutants (NESHAP) for several hazardous air pollutants, including asbestos. The NESHAP for asbestos are contained in the Code of Federal Regulations, Title 40, Part 61, Subpart M (40 C.F.R. 61.140-156). The regulations require that the owner or operator (including a contractor) of a building or facility notify EPA of plans to demolish or renovate a building containing friable asbestos material. The type and extent of information required depends upon the amount of asbestos which is to be removed. The information you are required to submit may be determined by referring to 40 C.F.R. 61.145 and 61.146. The regulations also require the notice to be postmarked or delivered to the Regional Office of EPA within a specified time before the work begins. The notice Union Carbide Corporation submitted to EPA failed to include the following required information: . procedures being used to remove the asbestos-containing material. . location of waste disposal site. UCC 006436 2 Also, the notice Union Carbide Corporation submitted to EPA was deficient because it failed to provide the EPA with a notification prior to commencement of the asbestos operation as required by 40 C.F.R. 61.146(b)(4). The scheduled starting date of the removal was stated as October 11, 1986. However, the notification was postmarked October 14, 1986. Please submit this information to this office within three (3) days of your receipt of this letter. Failure to comply with the asbestos NESHAP regulations could result in the issuance of an Order requiring compliance with the requirements, or the initiation of a civil action pursuant to Section 113(b) of the Act. Such an action can result in a civil penalty of up to $25,000.00 per day of violation. In addition, pursuant to Section 113(c)(1)(C), any person who knowingly violates the provisions of Section 112(c), which pertains to violation of certain provisions of NESHAP, is subject to fines of up to $25,000.00 per day of violation, or by imprisonment for not more than one year, or both. If you have any questions concerning this notice, please contact Carol A. Febbo, Air Enforcement Branch, at (215) 597-9325. Sincerely Air Enforcement Branch cc: Michael Bush West Virginia Air Pollution Control Commission UCC 006437 WEST VIRGINIA AIR POLLUTION CONTROL COMMISSION 1568 Washington Stmt, Eat CHARLESTON. WEST VIRGINIA 2S311 TELEPHONE: 340-2275 OR 348-3286 ASBESTOS REMOVAL NOTIFICATION ivt'IVED OCT 1 0 1986 coKtKo^coMaissiON RENOVATION---- X-- - ... - DEMOLITION ... - NAME OWNER/OPERATORUNION CARBIDE CORPORATION --- 0 V DATE-- O ct~ob e- r- 1- -0, 1986 ADDRESS/PHONE Post Office Box 8004; South Charleston, WV 25303 _______ PHONE # ( 304 ) 747-3169 NAME CONTRACTOR POWERHOUSE EQUIPMENT SERVICES______________ ADDRESS/PHONE Post Office Box 538; Winfield, Wtest Virginia 25213 '~ PHONE HI304 ..............- |' L' ' ) 757-2512 - "" " LOCATION OF FACILITY/ADDRESS 437 MacCorkle Avenue, South Charleston, WV SCHEDULED STARTING AND COMPLETION DATES OF DEMOLITION OR RENOVATION: STARTING 10-11-86 COMPLETION 10-11-86 IS FACILITY BEING DEMOLISHED UNDER AN ORDER OF A STATE OR LOCAL GOVERNMENT AGENCY? ( X ) NO ( ) YES IF YES, WHAT AGENCY - INCLUDE NAME, TITLE AND AUTHORITY: APPROXIMATE AMOUNT OF FRIABLE ASBESTOS CONTAINING MATERIAL(ACM): 500 fl^ used to cover or coat any duct, boiler, tank, furnace, structural member, etc. linear ft on pipes Estimation techniques of amounts of ACM at demolitions for quantities less than 260 linear ft and/or 160 ft^ ____ DESCRIPTION OF FACILITY: Age - 40 Size Prior Use No, 19 Batch Still_____ LOCATION OF ACM IN FACILITY AND METHODS OF PLANNED DEMOLITION OR RENOVATION: The Still is physically located at the Mainland chemicals Unit (across from Bldg. 82). The still will be removed in sections, due to its size, and will have the insulation (containing asbestos) removed east of Building 224. A Dr"C- A r\ ^ UCC 006438 PROCEDURES TO BE USED TO COMPLY WITH SUBPART M - NATIONAL EMISSION STANDARD FOR ASBESTOS (40 CFR): Procedures set forth in said regulation ( 61.147) will be adhered to in order to prevent emissions of particulate Asbestos to the air. LAB TESTING BY: Not Applicable ADDRESS/PHONE NAME/LOCATION OF WASTE DISPOSAL SITE: GOFF MOUNTAIN LANDFILL SITE APPROVED BT DNR: ( ) NO ( Y ) YES COMMENTS: Permit gWVD 005 005 509 TITLE:____________________ ' Environmental; Protection^ Coordinator In addition to the West Virginia Air Pollution Control Commission, a copy of this notice must be sent to the following agencies: U. S. Environmental Protection Agency Region III (3AM22) 841 Chestnut building Philadelph8, Pennsylvania 19107 Attn: Asbestos/NESHAP Coordinator Solid Waste Office' Division of Water Resources WV Department of Natural Resources 1260 Greenbrier Street Charleston, West Virginia 25311 Attn: Asbestos Coordinator Asbestos Control WV Health Department 4877 Brenda Lane Charleston, West Virginia 25312 Attn: Asbestos Coordinator A PCC-A R N-3/86 UCC 006439 Page 2 of 2