Document LKK0627rZZY7Ja64LDpoNMeGw

BUSINESS CONFIDENTIAL UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM September 2, 1987 TO: J. F. Dodd 0. R. Dement R. L. Foster D. A. Gosselln E. 0. Southard COPY: W. D. Bradbury J. K. Corrle T. E. Hanning P. R. Kavasmaneck D. Llebesklnd R. R. Rankin S. Rossi A. D. Williamson FROM: L. S. Hagelssen H. W. Wegert SUBJECT: Health, Safety, and Environmental Review Status of Contingency Items Asbestos Insulation Removal Upgrade-Phase I South Charleston ___________________________ This project was recommended for endorsement by CED's Health, Safety and Environmental Section Hay 19, 1987, subject to two contingency Items. These contingency Items have been resolved as follows: 1. Maintenance Procedures XVIII Provisions for Asbestos Material Removal and Disposal Safety be revised to be In compliance with the latest QSHA Standards 29 CFR Parts 1910.1001 and 1926.58. The Maintenance Procedures dated February 1987 have been reviewed by Terry Hanning. In general, the procedures are good. Some minor comments by Terry are noted In red In the attached copy of the procedures (0. F. Dodd only). (Note that the February 1987 version of these procedures was not made available to the project HS8tE reviewers In May 1987.) 2. Procedure XVI11 be revised In accordance with the environmental concerns listed below: The procedure does not refer to review of State Air Pollution Regulation No. 15 which deals with notification of the West Virginia Air Pollution Commission. UCC 002239 2- - BUSINESS CONFIDENTIAL The procedure does not refer to state requirement to notify the West Virginia Department of National Resources before land filling. The procedure does not refer to NESHAPS 40 CFR 61.152 (Disposal .Container Labels) or 40 CFR 61.156 (Warning Signs at Landfill). However, the procedure does refer to OSHA warning label requirements and these are probably equivalent to the NESHAPS requirements. The procedure should clarify this Issue, particularly the signs required at the landfill. All three environmental contingencies are related to the written procedures for handling asbestos. The revised procedures. Asbestos Handling No. XVIII, dated 2/87 are very well written and adequately address the environmental concerns. One way the procedures could be strengthened Is to add a short section on requirements to be an acceptable site for asbestos disposal. This suggestion should not be considered a contingency Item. LSH: HWW: mw 8107D UCC 002240