Document LZLxXrOd8Gjnavb4OgRLY7kX

iX . Sarf UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES Central Engineering / South Charleston, West Virginia UCC BUSINESS CONFIDENTIAL Ju RIVkj APR 8 S87 M. P. McCREADy COPY TO: FROM: S. G. W. B. Clark Elder J^L * 'i^6?Py/Tlya*1 y"l y y, ^ R. W. Engle S. S. Murphree V. 1: W. G. Lilly, Jr. B. G. Perry D. L. Runyon J. E. Sanders S. W. Turicchi -y C. C. Neely ,r y A*t 5 1` ' /mf /Zc-r&lU^ l CC --*> <Haj SUBJECT: Phaseout Use of Asbestos-Containing Materials in Work Place Chemicals and Plastics Group Confirming my telephone conversations with you, I am pleased to report that our Vice-President, Mr. B. G. Perry, and the Manufacturing Council have endorsed our proposed program dated 9/29/86 (copy attached for convenient reference). Mr. Sanders has. In turn, requested that we reactivate our Task Group and commence developing plans to implement the program. (See J. E. Sanders' memorandum dated February 19, 1987, copy attached.) I accordingly am pleased that those of you on the original Task Group have expressed willingness to continue your participation. It Is also a pleasure to welcome Sharon Murphree as a new member of the Task Group representing the purchasing function. Of course. It is recognized that we each will probably need the assistance of others In order to accomplish our portion of this assignment. We need to have a meeting soon In order to develop an overall program, schedule, and budget for our activities. I have accordingly arranged for a meeting as follows: DATE: Tuesday, March 17, 1987 TIME: 8:30 a.m. PLACE: Building 2000, Room 2505 UCC 019660 Memo -2- March 2, 1987 A proposed agenda Is attached. You will note that, except for the Important aspect of obtaining general understanding and acceptance of the program by key plant personnel, the agenda Is simply based on the duties listed In our recommended program that are assigned to the Central Engineering Department. Your comments on this proposed agenda are earnestly solicited. I look forward to a productive first meeting. Please let me know If something comes up that will not allow you to attend. CCNrat Attachments 47071 C C. iluLtlt C. C. Neely/ UCC 019661 PROPOSED AGENDA MARCH 17, 1987 MEETING IMPLEMENTATION PROGRAM TASK GROUP PHASEOUT OF ASBESTOS-CONTAINING MATERIALS IN WORK PLACE CHEMICALS AND PLASTICS GROUP 1. Cal 1 to Order 2. Adoption of Agenda 3. Announcements 4. Develop and Maintain C&P Standard Practices 4.1 Identification of Asbestos-Containing Materials Standard practices covering this activity are primarily the responsibility of the Industrial Hygiene Group. Stan Clark is assigned lead responsibility and will report on proposed activities (see Footnote 1). 4.2 Replacement of Asbestos-Containing Insulation as Required to Maintain Structural and Functional Integrity Perhaps CED can develop some criteria for establishing how to recognize when the structural integrity of insulation has deteriorated sufficiently to become a health hazard. George Elder is assigned lead responsibility and will report on proposed activities (see Footnote 1). 4.3 Removal, Modification, and/or Disposal of Asbestos-Containing Materials Standard Practices covering this activity are also primarily the responsibility of the Industrial Hygiene Group. Stan Clark is assigned lead responsibility and will report on proposed activities (see Footnote 1). 4.4 Use of Asbestos-Substitute Materials 4.4.1 George Elder has lead responsibility for establishing which asbestos-substitute materials are acceptable (health effects as well as functional acceptability shall be considered) and will report on proposed activities (see Footnote 1). UCC 019662 t 2- - AGENDA (Cont'd) 4.4.2 Rex Engle has lead responsibility for modifying the Valve and Piping Specifications to Include asbestos-substitute materials and will report on proposed activities (see Footnote 1). 4.4.3 Clyde Neely has lead responsibility for revising the Pressure Vessel and Tank Specifications and will report on proposed activities (see Footnote 1). 4.4.4 Purchase of Asbestos-Substitute Materials Sharon Murphree has lead responsibility for the purchase of the substitute materials and will report on planned activities (see Footnote 1). 4.5 Variance Procedure to Cover Consideration of Uncommon Circumstances Presumably each plant will use its own variance procedure; however, ideas from the group on this subject will be solicited. 5. Conducting On-Site Seminars at Institute, Seadrift, Sistersvi11e, South Charleston, Taft, and Texas City As indicated in the Task Group's September 29, 1986, memorandum entitled "Proposed Technology Program in 1987 In Support of Existing Operations" (copy attached), we recognized the importance of this activity since the cooperation of each location is essential to the success of the program. Clyde Neely will lead a discussion regarding this subject, with a consensus agreement on the desired program being the objective. 6. Other Business Items 6.1 Next Meeting Date 7. Adjournment ------------------x------------------ xx 1) Proposed activities will Include preliminary outline of overall program and associated schedule and budget. It may be appropriate to request that specialist directly responsible for doing the work be present. UCC 019663 UNION CARBIDE CORPORATIONP. 0. Box 8361 Engineering, Manufacturing, and Technology Services So. Chas., WV 25303 Central Engineering 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 Oraft 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 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 019664 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 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 019665 DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS*1>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 019666 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 sealability 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 019667 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&P HS&EA Audit compliance with governmental regulations and C&P Standard Practices relating to asbestos-containing materials and, where applicable, their substitutes. UCC 019668 C. C. Neely 47071 KtA'U-1 v UNION CARBIDE CORPORATION SEP 10 1965 ?.H KAVASM.A\'ECK ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH. SAFETY AND ENVIRONMENTAL TECHNOLOGY south CHARLESTON WEST VIRGINIA MEMORANDUM I September 5, 1986 ^ >V :v \ - * 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 Kcnvir SEP z2 gj !- CCj 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. /Wanning Extension 5903 UCC 019669 *** UNION CARBIDE *** ** * * * INTERNAL CORRESPONDENCE Engineering, Manufacturing, and Technology Services Central Engineering Technical Center Post Office Box 8361 Building 2000 South Charleston, WV 25303 Febuary 19, 1987 TO: Mr. B. 6. Perry COPY TO: Mr. P. D. Franson Mr. M. G. Lilly, ,Jr. Mr. C. C. Neely / Mr. S. W. Turlcchl SUBJECT: Asbestos Usage RECEIVED FEB 2 3 1987 ecu 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 019670 UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES Central Engineering South Charleston, West Virginia UCC BUSINESS CONFIDENTIAL September 29, 1986 TO: Mr. J. E. Sanders COPY TO: Mr. L. E. Calvert Mr. S. W. Clark Mr. G. B. Elder Mr. R. W. Engle FROM: C. C. Neely SUBJECT: Proposed Technology Program In 1987 In Support of Existing Operations In am submitting herewith an additional program In the subject category, this one In support of the work associated with the Implementation of the proposed new Standard covering the phase-out of asbestos-containing materials In the work place. Our estimate of costs Includes the following: A total of approximately one man year of work relating to the selection of suitable non-asbestos gasket/packing materials as a function of service conditions, and revising the affected standards (or developing new standards) accordingly. This work will be conducted primarily In the Materials and Valve and Piping Skill areas. At this point we do not envision the wholesale use of new gasket/packing materials, but rather a broader use of currently used materials (e.g., reinforced Teflon, GRAFOIL"). Approximate cost: $64,500 Printing and distribution of the revised standards. Approximate cost: $12,500 Conducting on-site seminars at Institute, Seadrlft, Slstersvllle, South Charleston, Taft and Texas City to explain the basis for the revised gasket/packing material selection. These seminars are recommended In view of our belief that simply reissuing the various standards with revised gasket/packing materials will not result In timely understanding and acceptance of the revised gasket/packing material specifications. Approximate cost: $16,000 UCC 019671 Mr. J. E. Sanders -2- September 29, 1986 We would be pleased to provide additional Information If needed. CCN:mr 00021 Attachment Special Work Group on Phase-out of Asbestos-Containing Materials UCC 019672 rrtOPOSED CED TECHNOLOGY PROGRAM EuR 1987 IN SUPPORT OF EXISTING OPERATIONS Work Associated with Implementation of C&P Recommended Program Phase-Out Use of Asbestos-Containing Materials In the Work Place Objectives: (1) To obtain understanding and acceptance of the Recommended C&P Program by key plant personnel. (2) To develop C&P Standard Practices covering: Identification of asbestos-containing materials Removal, modification and/or disposal of asbestos-containing materials; and Use of asbestos-substitute materials Brief Description: The primary means of obtaining U/A of key plant personnel would be by on-site seminars and written follow-up. C&P Standard Practices development work would proceed In usual manner. Results Expected and Schedule: Would promote smooth transition to non-asbestos containing materials. Most of CED's work would be complete by July 1, 1988. Best Judgment of Costs: $93,000 43071 UCC 019673 UNION CARBIDE CORPORATION ENGINEERING. MANUFACTURING. AND TECHNOLOGY SERVICES Central Engineering South Charleston, West Virginia UCC BUSINESS CONFIDENTIAL ' April 6, 1987 TO: L. E. Calvert S. W. Clark G. B. Elder R. W. Engle S. S. Murphree COPY TO: R. R. Allen H. N. Baylor D. J. Dickson P. D. Franson P. R. Kavasmaneck J. G. Keeler W. G. Lilly, Jr. B. G. Perry J. E. Sanders S. W. Turlcchl FROM: C. C. Neely SUBJECT: Minutes of Task Group Meeting of March 17, 1987 Phaseout Use of Asbestos-Containing Materials In Work Place Chemicals and Plastics Group Following Is an Executive Summary of the action/agreements resulting from the subject meeting. The detailed minutes prepared by the responsible Task Group member are attached for those who desire additional information. Executive Summary The "heart" of the C&P Group asbestos-usage phaseout program Is the requirement that no asbestos-containing products be purchased after January 1, 1989. Consistent with this date, the Task Group agreed last fall when preparing the proposed program that the affected valve, piping, and process vessel Standard Practice documents must be revised to show substitute materials by July 1, 1988, and manpower estimates were made accordingly. However, because of the rapid (and very likely, continuing) reduction of suppliers of asbestos-containing materials due to liability Insurance coverage problems. In combination with the desire of key plant personnel to cease using these materials at an early date, the Task Group UCC 019674 Meeting Minutes -2- April 6, 1987 recommends that the responsible CEO skill areas complete the required revisions to the affected Standard Practice documents by September 30, 1987. Action H. N. Baylor R. R. Allen This accelerated schedule will require additional technical assistance In the Piping Technology skill area. Preliminary discussions with R. R. Allen and R. W. Engle regarding the possibility of an accelerated schedule were held on March 23, 1987. Arrangements to obtain the needed technical assistance should now be made. Action J. E. Sanders The total CEO cost of the accelerated program In 1987 over and above planned and budgeted T&S programs Is estimated to be $34,000, much less than our earlier $93,000 estimate which was developed last September on the basis that much more work would be required. Funding for this activity is needed. Action P. D. Franson D. J. Dickson The Task Group requests the assistance of the Machinery Technology Group In identifying what actions. If any, are needed to assure that the broadly advertised aramid fiber nonasbestos asbestos gasket substitutes are not used In machinery Items (e.g., pumps, compressors) for our process units. One of the major reasons these materials are generally considered unsuitable for gaskets Is because they will not pass fire tests. The perception Is that machinery manufacturers are using these materials without our know ledge and consent. Any costs associated with this request will be In addition to the $34,000 mentioned above. Action J. E. Sanders The Task Group requests advice as to where the now-approved asbestos-usage phaseout program documents will reside. It needs a permanent "home" within the TMS manuals system. S. W. Clark suggested It be Included In Section 8 of the Safety Health manual - this Is the Operation and Maintenance Section. The meeting agenda was based on the duties listed In our recom mended program that are delegated to the Central Engineering Department. These duties are listed below along with a brief summary of the action/ agreements reached: Agenda Number Responslbl11ty Duty and Actlon/Aqreement 4.1 S. W. Clark/C&P Industrial Ident1f1cat1on_of Asbestos Hygiene Department ContalnlngjnaterjaU^ C&P (Terry Hanning) Industrial Hygiene Department estimates completion of Criteria Document 4Q87. No cost to CED. UCC 019675 Meeting Minutes - 3- April 6, 1987 Agenda Number Responsibility Duty and Actlon/Aqreement 4.2 G. B. Elder Reglacement of_Asbestos-Contaln1ng Insuiat1on_as Reguired_to Maintain Structural_and_Functional_ Integ rity. Responsibility of each location; CED-prepared criteria not required. 4.3 S. W. Clark/C&P Industrial Removal, _Mod|f|cation, _and/or Hygiene Department D1sposal_of As be s tos-Con taj/ijng (Terry Hanning) Materials. Procedures already In place at all locations; no further action required. 4.4.1 G. B. Elder (Materials) Use of_Asbestos-Subst1tute Gas kets/Packing. Extended use of GRAFOILTM, spiral-wound with GRAFOILTM or TEFLON"* fillers or reinforced TEFLONTM will cover our needs for now. Internal program of testing other non asbestos substitute gasket materials not needed; will rely on test data developed by Materials Technology Institute (we are member) at no additional cost to CED. A concern was raised regard ing the control of the use of the aramld-relnforced "nonasbestos" asbestos-substitute materials for gaskets In machinery Items (e.g., pumps, compressors, etc.). These materials will not only not pass fire tests but will also perform poorly as gaskets because of their propensity to cold flow. The perception Is that the vendors are making these substitutes without our knowledge and consent. 4.4.2 R. H. Engle (V&P Specs) Two-to-three man-months of work Is required to revise and Issue valve manual and V&P Specifications. Can accomplish this with In-house staff by original July, 1988, target date; however, will prob ably need technical assistance to meet required September 30, 1987, completion date. Approximate additional cost to CED $20,000. UCC 019676 . Meeting Minutes -4- April 6. 1987 Agenda Number Responslbl11 tv Duty and Actlon/Aqreement 4.4.3 C. C. Neely (COP Specs) Modest additional manpower re quired to revise specs; however, printing/distribution cost of unplanned revision of COP Specs in 1987 not Included In T&S budget. Estimated additional cost to CEO: $8,000. 5 C. C. Neely Conduct! ng_on-s i te_semi^nars at major filants_not_requ1red; Key plant personnel do not need to be "sold" on need to quit using asbestos-containing materials in favor of more costly substitutes. They are fed up to here with even more costly monitoring, record keeping, disposal requirements for asbestos-containing materials, etc.; and hence, are desirous of having Standard Practice documents available to allow them to cease using these materials prior to the mandated January 1, 1989, cutoff date. 6 G. B. Elder <H. G. Clem) Iden11f1 cat1on_of Asbestos-Free insulation^ ~W111 prepare Location Practices for Inclusion in Insula tion Manual as appropriate by end of third quarter. Estimated cost to CED: $6,000. 6.1 C. C. Neely Next_Meeting^ Unless the need for an earlier meeting is Identified, the next meeting of the Task Group will be held on August 4, 1987, at the South Charleston Technical Center In Room 3505. All members are requested to mark their calendars accordingly. The detailed minutes are attached for those Interested In more complete information. Respectfully submitted. CCN:at Attachments 43141 C. C. Neely for the Task Group UCC 019677 ONION CARBIDE CORPORATION 'ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY South Charleston, West Virginia BUSINESS CONFIDENTIAL MEMORANDUM March 23, 1987 TO: c. c. Neely COPY: FROM: L. E. Calvert S. W. Clark G. B. Elder R. W. Engle P. R. Kavasmaneck S. S. Murphree J. E. Neff T. E. Hanning RECEIVED MAR 2 4 1987 CCN SUBJECT: Asbestos Implementation Task Group March 17 Meeting Minutes Clyde, The following information is being forwarded for issue as part of the subject minutes and represents those items tagged for responsibility by the Industrial Hygiene contact on the Asbestos Implementation Task Group. Also please find attached SH-256, Removal and Handling Asbestos-Containing Materials, which is a Standard Practice of the C&P Safety/Health Technology Manual. Section 2.6 of this standard deals with the EPA regulations for removal and handling of asbestos materials and has not been updated with respect to recent EPA asbestos proposals. The sections dealing with OSHA regulations have been updated. SH-256 has been volatile and will be revised when needed as part of my responsibility as a member of the Safety/Health Standards Team. Identification of Asbestos-Containing_Materials A goal of the asbestos task group is to establish a program so that asbestos will not be purchased after January 1, 1989. A C&P criteria ( guideline document ) for the identification of asbestos-containing materials is needed as part of the overall program. A consensus of C&P Industrial Hygiene Departments will be sought as a basis for the criteria. The criteria will provide recommended techniques and when to use them, pricing, timing and accuracy of results, and other subjective information. Polarized light or scanning electron microscopy are two identification techniques that can provide fast and accurate confirmation for the presence of asbestos. This assignment will have the following estimated schedule and cost. Schedule: 4Q 1987. Cost: None, cost will be part of normal Safety/Health Standards Team Work. UCC 019678 2- Removal. Modification, and/or Disposal of Asbestos-Containing Materials The need for a protocol to sample asbestos at the new 0.2 fibers per cubic centimeter of air exposure level was discussed. The protocol would be used to establish asbestos exposure data from the storage ( binders may deteriorate and release asbestos ), cutting and changing out of asbestos gaskets and packing. After discussion with Industrial Hygiene representatives, the need to develop a generic test protocol for asbestos exposure is not warranted since the OSHA Asbestos Standard clearly defines the sample taking method that must be used. The Plant Industrial Hygienist is familiar with this method and can quickly outline a technician's job duties in taking air samples during storage, cutting and changing out of asbestos gaskets and packing. Additionally, the Plant Industrial Hygienist will be able to supply other recent asbestos exposure data from the plant monitoring strategy program, if available and applicable. This action will have the following estimated schedule and cost. Schedule: Sample taking can proceed immediately with the support of the location Industrial Hygiene area. Cost: None, resources are outside this task group. Sincerely, Teerrry aa.. Hanning 20000/3882288 Unicom 8-721-5903 UCC 019679 o i INTER DIVISION $H-266 PAGE 1 OF 7 DECEMBER 1986 REMOVAL AMO HANDLING ASBESTOS-CONTAINING INSULATION MATERIAL 1 GENERAL , 1.1 This Practice provides a procedure for the safe removal and handling of asbestos-containing Insulation maUrlal and compliance with OSHA regulation 29 CFR 1910.1001 and 1926.68 and EPA regulation 40 CFR bl Subpart M. The purpose of the Practice Is to ensure the safety and health of employees directly Involved with performing the wort and of others, either In the laaedlate area or downwind, who nay be exposed to residual dust/fibers. Insulation maUrlal containing asbestos Is no longer Insulted by Uct; therefore, the concern of this Practice Is to control renovation and demolition operations Involving the removal of old. asbestos-conulnlng Insulation; In these activities OSHA SUndard 29 CFR 1926.SB is applicable. For additional deUlls, review the OSHA Sundards. All Insulation materials approved through the use of (ICC Insulation Standards have been specified asbestos-free since 197t>. 2 STAMPARDS * 2.1 Permissible Exposure Limits 2.1.1 Employee 8-hour time-weighted average exposure to airborne concentrations of asbestos fibers shall not exceed 0.2 fibers, longer than 6 micrometers, per cubic centlmeur of air. # 2.1.2 An action level of 0.1 fibers, longer than 6 micrometers, per cubic centimeter of air has been set which triggers the monitoring, medical, and employee Information and training requlreawnts. 2.2 Wort Practices 2.2.1 Insofar as practicable, demolition, removal or handling of asbestos-conulnlng Insulation shall be performed while the material Is In a sufficiently wet sUU to prevent emission of airborne fibers exceeding exposure limits prescribed In 2.1.1 and 2.1.2. See Section 2.7.3 for the specific EPA regulations that control wort practices. Wherever feasible, the employer shall esubllsh negative-pressure enclosures before coamenclng removal, demolition, and rennovatlon operations. 2.2.2 Caution signs shall be posted at all approaches to areas which auiy conUln excessive concentrations of airborne asbestos fibers so that an employee may read the signs and Uke necessary protective sups before enuring the area. The signs shall state: DANGER-ASBESTOS; CANCER AND LUNG DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS AMli PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA In addition to these signs, legible signs warning of the health hazards of asbestos shall be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the exposure limits listed In Section 2.1.1. See Section 2.0.4.4 for additional requirements for posting signs. Whenever feasible, a negative pressure enclosure must be esUbllshed before commencing removal, demolition or rennovatlon operation. Air exhausUd from the enclosure must pass through a HEP fllUr (See 29 CFR 1920.S8). 2.2.2.1 An appropriate barricade, using caution or barrier tape for example, shall be erected around the perimeter of outdoor areas as a supplemenUry, protective measure to discourage unauthorized entry. C \ 22.6.1.2 UCC 019680 * SH-26b PACE 2 OF 7 DECEMBER 1WO TANOARO PRACTICE INTER OIVttlON 1.1.3 Insofar as practicable, removed Insulation shall be wetted and placed directly Into labeled plastic bags (or other suitable containers) for disposal at an approved landfill. Otherwise, place plastic sheeting beneath the job site, Rlst spray the renoved Insulation with water, leaded water, or wetting agent and then place In plastic fog*. Mien wet Methods of removal /cleanup are lapractlcal, e.g., when temperatures are below freezing, vacwaring or sweeping aay serve as an affective alternate cleanup method. Sweeping compound shall be applied to the wort area to prevent dust generation when sweeping. See Sections R.7.3.7 and 2.7.4 for specific wort practice requirements. 2.2.4 Label Specifications - Container caution labels shall be printed In letters of sufficient slae and contrast as to be readily visible and legible. Where feasible. Installed asbestos-containing products shall also contain a visible label. The label shall state: BANGER - CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST; CANCER AND LUNG DISEASE HAZARO Where feasible. Installed asbestos containing products should be labeled In accordance with 2.2.4. 2.2.5 Seoul ated Areas - Employers must Identify as regulated areas any locations In their workplaces where there nay be occupational exposures to airborne concentrations of asbestos above the PEL. Only authorized persons, with proper respiratory protection, may enter regulated areas which must be clearly posted. Eating, drinking, and waking are prohibited In regulated areas. 2.2.0 Nousekeeping - All external surfaces In any place of employment shall be maintained free of accumulation of asbestos fibers. Special attention should be given to cleaning scaffolds used In demolition work. Clean-up of asbestos dust Is prohibited with compressed air, dry-sweeping or any dry clean-up process. 2.2.7 Waste Disposal - Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos-contaminated disposable clothing, that Is consigned for disposal and which may produce airborne concentrations of asbestos fibers In excess of permissible exposure limits, shall be collected and disposed of In sealed leak-tight containers to an approved landfill. See Section 2.6.4 for specific disposal requirements. ' 2.2 Personal Protective Equipment 2.2.1 Respiratory Protection Employees engaged In the spraying (wetting-downj of asbestos, the removal; In the demolition of pipes, structures, or equipment covered or Insulated with asbestos; and In the reaaval or demolition of asbestos Insulation or coverings shall be provided with respiratory equipment based on the air concentration In Table 1 and selected from ' among those approved by the Nine Safety and Health Administration, Department of the Interior, or the National Institute of Occupational Safety and Health, Department of Health and Human Services described In 30 CFR Part 11. Compliance with exposure limits prescribed In 2,1 Permissible Exposure Limits, shall not be achieved by the use of respirators, except:, 1. Ourlng the Interval necessary to Install or Implement feasible engineering and work practice controls, 2. In work operations such as maintenance and repair activities or other activities which the employer establishes that engineering and work practice control procedures are not feasible, 3. In work situations where feasible engineering and work practice controls are not yet sufficient to reduce exposure to or below the PEL, 4. In emergencies. Where respirators are permitted the employer shall provide a powered, air purifying respirator In lieu of any negative pressure respirator specified In Table 1 whenever: 22.5.1.2 a. An employee chooses to use this type of respirator; and b. This respirator will provide adequate protection to the employee. UCC 019681 INTER OtVIElON TABLE 1 RESPIRATORY PROTECTION FOR ASBESTOS. TREWOLITE. AMTHUPHYLLITE. AN) ACT1M0L1TE FIBERS Airborne Concentration of Subject Materials or Combination of Those Materials * Required Respirator SM-2S6 fASE 3 OF 7 OECEMER 1966 1. Mot In excess of 2 f/cc (10 x PEL) 1. Half-emsk air-purifying respirator equipped with hlgh-efflclency filters. 2. Not In excess of 10 f/cc (60 x PEL) 1. Full facepiece air purifying respirator hlgh-efflclency filters. 3. Not In excess of 20 f/cc (100 x Pa) 1. Ar\y powered air-purifying respirator equipped with high efficiency filters. .2 Any supplled-alr respirator operated In continuous flow mode. 4. Not In excess of 200 f/cc (1000 x Ptl) 1. Full facepiece supplied air respirator operated In pressure demand mode. 6. Greater than 200 f/cc 1. Full facepiece supplied air respirator (greater than 1.000 x PEL) or operated In pressure demand mode equipped unknown concentration) - with an auxiliary positive pressure self-contained breathing apparatus. I 2.3.2 Special Clothing - The employer shall provide and require use of special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed. Contaminated clothing must be stored In closed containers suen as sealed lockers. It should be changed dally. 2.3.3 tfrfllene Facilities and Practices - At any fixed place of employment exposed to concentrations of asbestos fibers In excess of permissible exposure limits, the employer shall provide change rooms for employees working regularly at the place. Two separate lockers or containers shall be provided each employee, so separated or Isolated as to prevent contamination of the employee's street clothes from Ms tart clothes. Employees exposed to asbestos during their wort shift must shower before leaving the plant and must not leave wearing contaminated work clothing. Employees working In asbestos areas must have ready access to filtered air lunchrooms and must wash their face and hands prior to eating or smoking. Protective clothing must mot be worn In the lunchroom. 2.3.4 Laundering - Laundering of asbestos-contaminated clothing shall be done so as to prevent the release of airborne asbestos fibers In excess of prescribed exposure limits. Those performing laundering of asbestos-contaminated clothing must be Informed of all requirements listed In Section 2.3. Personal Protective Equipment. Contaminated clothing shall be transported In sealed Impermeable containers and labeled In accordance with Section 2.2.6, Label Specifications. If disposable coveralls are used, they should be placed Into containers wltn asbestos for disposal. I i 22.6.1.2 L UCC 019682 SH-250 PAGE 40F 7 'DECEMBER* 1964 gjpqjjP ' INTER OIVIDION 1.4 Industrial Hygiene Responsibility 1.4.1 Monitoring - Employee exposure monitoring shall ba conducted to data mine compliance status with regard to Remissible exposure Units and respiratory protection requirements. Envlromental/Area monitoring shall bo conducted along the periphery of the restricted area to assure that fugitive emissions exceeding pemlsslble exposure Halts do not extend past the donarested area. Saaples shall be collected using 26 mm dlamter nixed cellulose filters and a 60 am extension cowl. Samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the anployees. Monitoring Is required at least every 6 nonths for employees whose exposures to asbestos Is at or above the action level. Where construction standard 1926.68 Is applicable, dally Monitoring is required unless anployees use supplied air respirators In a positive pressure node. Saaples nust be analyzed using a phase contrast nlcroscope calibrated using a phase shift test slide and equipped with a Walton-Beckett graticule. The filter sanples nust be prepared using acetone-triacetln clearing solution and be counted In accordance with the "A" rules contained In the NIOSH 7400 nethod. ` 2.6 Training 2.5.1 All anployees who are exposed to airborne asbestos concentrations In excess of the exposure Unit listed In Section 2.1.2 with or without the use of respirators shall participate In a training progran at the tine of or prior to Initial asslgnnent and at least annually afterwards that Includes these Information topics: 1. Health affects associated with asbestos exposure. 2. Relationship between exposure to asbestos and moklny In producing lung cancer. 3. Mature of operations which could result In exposure to asbestos and necessary protective steps to nlnlnlze exposure Including, as applicable, engineering controls, work practices, respirators, housekeeping and protective clothing. ... . . 4. Purpose, proper use, fitting Instructions, and limitations of the respirators used to protect against asbestos fibers. 6. Review of all provisions contained In 29 CFR 191b.1001, Asbestos. . 6. Purpose for and description of the asbestos medical surveillance program. 7. Instructions for handling spills as well as emergency and clean-up procedures. 2.6.2 Training records shall'be maintained by the location and shall be readily available to all affected employees and to OSHA personnel upon their request. 2.6 Medical Surveillance 2.6.1 Medical surveillance shll be provided to all employees where exposure, without regard to the use of respirator. Is at or above the action level for 30 or more days per year. 2.7 Federal EPA Regulation, 40 CFR 61, Hazardous Air Pollutants; Subpart M - national Emission Standard for Asbestos 2.7.1 Applicability - These requirements apply to the demolition of structures or renovation of equipment and piping that Involves removal of Insulation that contains friable asbestos materials. Friable asbestos material means ary material containing more than 1 percent asbestos by weight that hand pressure can crumble, pulverize, or reduce to powder when dry. Demolition means the wrecking or taking out of ary load-supporting structural member of a facility together with ary related handling operations; on the other hand, renovation means to alter one or more facility components In ary way without taking out load-supporting structural members. Planned renovation operations Include scheduled and unscheduled operations In which the 22.6.1.2 UCC 019683 o I l ! l. INTER DIVISION SH-2S6 PAGE 6 OF 7 0CCEM6ER ,1906 Mount of friable asbestos material that trill bo raaoved or stripped within a given tlae period can be estimated or predicted based on operating experience. Adequately wetted weans sufficiently nixed or coated with water or an aqueous solution to prevent dust ewlsslons. 2.7.2 Key notification Requirements . 1. Tlalng - The EPA aust be notified with a written notice of Intention to demolish or renovate according to these tlalng requlrenents: a. As early as possible before renovation begins If planned, but not necessarily scheduled, renovation operations are predicted to Involve the stripping or reaovlng of at least 260 linear feet on piping or 160 square feet on other facility coaponents of friable asbestos aatertals within a year. b. At least 10'days before a deaolltlon operation that Involves at least 260 linear feet on piping or 160 square feet on other facility coaponents of friable asbestos aatertals. c. At least 20 days before a deaolltlon operation that Involves less than 260 linear feet on piping or 160 square feet on other facility coaponents of friable asbestos aatertals (EPA requires further advance notice for these deaolltlons that are shorter In duration). . d. As early as possible before a structurally unsound facility In danger of laalnent collapse Is demolished under an order of a state or local govemaent agency. 2. Text of notification Letter - A suggested notification letter for the deaolltlon and/or renovation of facilities containing friable asbestos aaterlal per requlrenents of 40 CFR 61, Subpart M, Section 146 (c). Is: fora of notification NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURtS, EQUIPHEUT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION 1. Name of Owner Union Carbide Corporation 2. Address of Owner 3. Description of Facility (Location Street Address of facility being demolished or renovated). Various buildings, equipment and piping used In manufacture and distribution of chemicals and plastics and also age, site and prior use of these facilities. 4. Estimate of Quality of Asbestos Approximate amount of friable asbestos material present In the facility and explanation of techniques of estimation If estimate for demolition operation is less than 160 square feet or 260 linear feet. 6. Scheduled Start and Completion Dates 6. Nethod(s) of Demol1t1on/Renovatlon 7. Compliance Procedures How EPA regulations will be followed____________________________ N. D1 sposal SI te -N--a-m---e--and location of site where asbestos waste material w ill be deposited Only parts 1 through 4 are necessary for demolition operations Involving less than 2t0 linear feet or 160 square feet of friable asbestos material. The naae, title, and authority of the State or local government representative who oroers the demolition should be added to the notification for demolition of structurally unsound facilities. Some states. Including Georgia. New Tort, North Carolina, and California, also require notification of demolition and/or renovation operations Involving friable asbestos materials. 22.6.1.2 t UCC 019684 SH-266 FACE 6 OF 7 DUMBER n*> Iw 7TT INTER OIVIEION 2.7.3 Ke Rawoval Requirements - For planned demolition operation or for the total of kMhIN renovation operations In which at least 260 linear feet or 160 square feet of asbestos noterial Is ranoved: , 1. Friable asbestos materials shall be removed before a demolition or renovation operation If the operation nould likely break up or preclude access to the asbestos nateiials for subsequent raaoval unless the asbestos Materials are on a facility component encased In a ante rial such as concrete or are adequately netted whenever exposed. 2. If a facility conponent Is covered or coated with asbestos Materials and Is rawoved In sections or units. It shall be carefully lowered, not dropped or thrown, to the ground level and shall have any exposed asbestos Materials adequately wetted while cutting or disconnecting. 3. netting Is not required during renovations If the EPA Is requested to confine that wetting would unavoidably dawage equlpwent. If the EPA conflrws this, then a local exhaust ventilation and collection aysteu Must be used to collect asbestos particulates. The exhaust tystan Must exhibit no visible ewlsslons to the outside air or be designed and operated according to 40 CFR 61.164. 4. After sections or units of piping or equIpMent with asbestos Materials have been taken out of the facility, the asbestos Materials during stripping shall be adequately wetted or shall be collected by a ventilation and collection systew as specified In 2.7.3.3. 6. Dust-tight chutes or containers shall be used to lower asuestos Material rawoved or stripped wore than 60 feet above ground level and not rawoved In units or sections. 6. All friable asbestos Materials that have been reuoved or stripped shall remain adequately wet until collected for disposal. ... . 7. If the ambient temperature Is below 0*C, then the only wetting requirements are those specified In 2.7.3.4 and 2.7.3.6. Equipment or piping coated or covered with asbestos materials shall be removed to the maximum extent possible. 8. For demolition of a structurally unsound facility under the order of a State or local government agency, the portion of the facility that contains friable asbestos materials shall be adequately wetted during the wrecking operation. The wetting requirements specified In 2.7.3.4, 2.7.3.6, 2.7.3.6, and 2.7.3.7 shall also apply to any emergency demolitions. 2.7.4 Key Disposal Requirements ! Visible emissions shall not occur during the collecting, transporting, or disposal of any asbestos-containing waste material unless the air-cleaning methods specified In 40 CFR Part 61.164 are used to collect asbestos fibers before they escape to the outside air. 2. The disposal method for collecting and transporting asbestos-containing waste materials shall be approved prior to use by the EPA, unless either of these two EPA-approved methods are used: a. Form all asbestos-containing waste material Into nonfrfable pellets or other shapes, or b. Adequately wet and seal while wet In leak-tight containers all asbestos-containing waste material. The waste containers shall be labeled according to Section 2.2.4. i > 22.6.1.2 UCC 019685 INTER DIVISION SH-2S6 PAOE 7 OF 7 0ECEhBER*19> 3. The disposal site for asbestos-containing waste material shall have no visible emissions, or the disposed material shall be covered within *4 hours with at least six Inches of nonasbestos-cootalnlng material or with an effective resinous or petroleum-based dust suppression agent (waste crankcase oil Is not acceptable.) Alternative ethods for controlling asbestos missions wust have EPA approval before being laplemented. 4. Cither a natural barrier or a fence shall adequately deter (as determined by the CPA upon request and supply of appropriate Information) public access to the waste disposal site. If fenced, then warning signs (20" x !<*") shall be posted at all entrances and at Intervals no greater than 330 feet along the perimeter of the sections of the site where asLestos-contalnlng material Is deposited. The signs shall state: ASBESTOS WASTE DISPOSAL SITE 00 NOT CREATE DUST BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH *.b AUDITS 2.6.1 Each location shall periodically audit this procedure to ensure understanding and compliance. UCC 019686 22.6.1.2 UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES CENTRAL ENGINEERING P. 0. BOX 8361 SOUTH CHARLESTON, WEST VIRGINIA 25303 to***- MEMORANDUM 4*2 BUSINESS CONFIDENTIAL March 23, 1987 TO: FROM: SUBJECT: Mr. C. C. Neely G. B. Elder Input to Minutes, March 17 Meeting on Phase-Out of Asbestos-Containing Materials RECEIVED MAR 2 5 1987 CCH Item 4.2, Replacement of Asbestos-Containing Insulation as Required to Maintain Structural and Functional Integrity. Abestos-contalnlng Insulation becomes a hazard when the weather barrier becomes damaged or other conditions such as powdering of the Insulation allows asbestos particles to become airborne. Corrective action would be removal of the Insulation or sealing the barrier to prevent airborne dust. The Task Group agreed that each location Is responsible for and aware of the problem and that a criteria from the Task Group Is not desirable. Item 4.4, Use of Asbestos-Substitute Materials 1. Insulation a. Insulation materials that do not contain asbestos are the only materials currently specified and used, so no action Is required. 2. Gaskets a. Suitable substitutes are available and already accepted In the specifications (Grafoll, Spiral-wound with Teflon or Grafoll, reinforced Teflon). b. Aramld-relnforced "nonasbestos" materials do not pass fire tests and have limited ability to maintain preload. A crash program to test these materials Is not justified and a program currently sponsored by the Materials Technology Institute has promise of providing an Inexpensive way to test such materials In the future. UCC 019687 2- - c. New materials that may be Introduced as asbestos substitutes will be tested as a normal technology activity. 3. Packing a. Grafoil and graphite-fiber packing will be adequate, so no action Is required. 4. Machine Gaskets a. These gaskets are bought as sets for the machines and substitutes are selected by the machine manufacturer. Item 6, Identification of Asbestos-Free Insulation. a. Harold Clem's memorandum (attached) lists Identifiers currently being used In Insulation to show that It does not contain asbestos. b. Harold Clem Is polling the C&P locations to determine If they are currently using Identification tapes, embossed or color-coded metal weather barriers or other methods to Identify Insulation containing asbestos and/or Insulation free of asbestos. Location Practices documenting the Identification codes will be Issued In the Insulation Manual as appropriate. Schedule: Complete poll of Identification codes - May 15. Issue Location Practices - September 30. Budget: $6000. GBE/ds 2006H UCC 019688 .BUSINESS CONFIDENTIAL UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM February 13, 1987 TO: G. B. Elder, 511^ RECEIVED 19 1987 CC: D. D. Barnette, 512 R. L. Boggess, 514 0. E. Boley, 380 D. L. Carrick, 519 A. W. Keene, 510 G. H. Reinhart, 312 L. E. Calvert, 511 S. W. Clark, 511 R. W. Engle, 511 T. E. Hanning, 511 D. J. Hymel, 515 R. W. Maddox, 511 D. D. Miller, 512 C. C. Neely, 511 M. Patel, 511 MOC FROM: H. G. Clem SUBJECT: IDENTIFICATION CODE FOR ASBESTOS-FREE INSULATION This report is in response to your letter on asbestos identifica tion concerns with insulation in our plants. Three primary issues, integral asbestos-free visual coding for insulation materials, weather barrier coding, and asbestos identification tests are discussed under separate headings: 1. Integral Non-Asbestos Identification of Calcium `Silicate Pipe and Block Insulation All of our approved vendors for calcium silicate pipe and block Insulation have visual Identification dispersed throughout the white product In the form of either gold colored mica flakes or black fibrous material to Indicate that the Insulation Is asbestos-free as shown below: 0037J UCC 019689  * 0037J 2- - Calcium Silicate Insulation Manufacturer Asbestos-Free Identification Kaylo 10-AF Owens-Corning Fiberglas Corp. Mica Flakes Thermo-12 Manville Corp. Mica Flakes Super Cal temp NA FABCO Black Fibers Manufactuers of expanded perlite. Material Spec. 4, also have asbestos-free visual identification. The current approved material, Goodtemp 1500 from the Howred Corporation, has a uniform pink color throughout the material. Celotemp 1500, a formerly approved insulation that is no longer being manufactured, contained mica flakes like the current calcium silicates. Since apparently only solid white compositions like the early calcium silicates, 85% magnesia, and insulating cements for steam piping and boilers contained significant percentages of asbestos fibers, manufacturers of most other insulation materials have not adopted an asbestos-free coding system. Insulations with distinc tive characteristics or appearance like cellular glass (UCC Spec. 1), polyurethane foam (UCC Spec. 3 and 7), performed fiber glass (UCC Spec. 6), flexible plastic foam (UCC Spec. 12), and mineral wool (UCC Spec. 14 and 40) never contained asbestos. Of course, since the use of mica flakes and other visual coding was not widespread until the mid 1970's, most insulation in older units may require laboratory testing for possible asbestos content before replacement or modification. 2. Asbestos-Free Visual Indicator for Metallic and Mastic Weather Barriers You asked for a durable visual indicator for metallic and mastic weather barriers to indicate that the insulation underneath did not contain asbestos. I have found that several methods are being used in the petrochemical industry, but there is no universal standard on this important subject. A summary of asbestos-free Identification methods related to weather barriers Is listed below: Surface Texture Variations: Reportedly, Tennessee Eastman, Eastman Kodak, and Amoco have adopted the use of a "stucco embossed" texture finish In either flat or 3/16" corrugated configuration for aluminum or stain less steel weather barriers on all Insulation replacement projects. This method provides a distinctive visual coding that contrasts with the older smooth finish metal weather barrier sheet material. UCC 019690 -3- 0037J Surface Texture Variations - Cont. Only minor changes are required In Installation procedures with this approach, and planned or Inadvertent painting of the weather barrier will not affect the visual Identifica tion characteristics. The method Is not applicable to mastics or plastic weather barriers, however. Color Coding: This procedure Involves the use of factory finished weather barrier In a specific color to Indicate that the Insulation Is asbestos-free. The colors most used for this purpose are white, green and blue. To be effective, this method would require coordination with existing UCC safety color coding in the plants. Identification Tapes: This method utilizes making tapes applied over standard weather barrier materials to Indicate that the insula tion either contains asbestos or Is asbestos-free. E.I. DuPont de Nemours A Co. (Inc.) uses this method. A copy of the DuPont specification entitled "Identifi cation for Installed Asbestos-Bearing Insulation" Is attached for reference. This type of Identification tape Is available from several suppliers. The DuPont tape features fade proof Ink lettering and background with a clear polypropylene coating for chemical resistance and durability. The asbestos code lettering Is combined with arrows to show the direction In which the indi cated Insulation runs. The primary advantage of Identification tapes Is that any type of weather barrier may be marked whether n$w or exist ing. Entire sections of plant units can be defined as asbestos-free with this technique. The main disadvantage of tapes is that they may be Inadvertently painted over or removed during routine maintenance activities. Various versions of asbestos-free Identification tapes are available from graphics label suppliers. In most cases, pressure sensitive vinyl Is used for the tape material. Unlike the DuPont specification tape, the "ASBESTOS FREE INSULATION" labels and direction arrow tape are usually separate Items, not combined. The blue background/white lettering is the same In most Instances. UCC 019691 -4- 3. Asbestos Identification Methods The Identification and monitoring of asbestos fibers from insulation or other sources is the responsibility of UCC Industrial Hygiene Groups at our various locations. According to Mr. Manhel Patel at the Tech Center, several test methods are available to identify asbestos including colorametric test kits, microscopic examination with polarized light, scanning electron microscopy and trans mission electron microscopy. However, the colorametric technique is not as reliable as the microscopic methods because it only detects Iron and magnesium from bulk samples; interference from related compounds can affect test results. The microscopic methods are approved by OSHA, EPA and NIOSH and represent the best current procedures available. It is apparent that devising a better way to identify asbestos that meets government approval will be difficult. If quicker results are needed at our plants on insulation replacement jobs, consideration should be given to pre sampling the existing insulation well ahead of any planned work. Conclusions and Recommendations The visual asbestos-free coding methods of our calcium silicate and expanded perlite suppliers, ie mica flakes, black fibers, etc., will be included in our UCC Material Specifications 2 and 4 as suggested by Don Miller of the Institute Plant. This may provide some valuable assist ance In the field identification of Insulation materials. Concerning the visual asbestos-free coding of weather barriers, it appears that no single Identification procedure may be suitable for all conditions in our plants and other facilities such as laboratory buildings. One of the main problems is the diverse types of weather barriers encountered; aluminum, stainless steel, PYC, fiberglass laminate sheet, and mastics. Some differences are also evident in our options when we are replacing asbestos containing insulation versus simply labeling or marking a "good" existing asbestos-free system. Current asbestos and asbestos-free Insulation coding procedures at UCC locations range from no Identification marking to marking all asbestos containing Insulation with labeling tape and entering a code for asbestos replacement jobs in the computerized work orders for storage and retrieval. Before we Introduce a UCC recommended practice or standard on weather barrier 0037J UCC 019692 A -5- identification coding, a poll or request for comments should be solicited from plant insulation representatives and other responsible parties. To assist in the proposed poll, actual samples of identification tapes and embossed metal weather barrier would also be sent to each respondent. If there are further questions or comments, please call me. HGC:es ATTACHMENT 18495 INDEX: 6, 7, 10, 23, 28, 30, 32 42, 43, 44, 44A, 62, 71, 81 112, 120, 121, 122, 127, 138 142, 180, 307, 318, 351 0037J H. G. Clem UCC 019693 -< .)* t* 225 IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION THERMAL INSULATION STANDARD ENGINEERING SPECIFICATION ISSUED THIS PAGE REVISED STANOARO REAFFIRMED JULY 1975 APRIL 1984 APRIL 1984 Page 1 of 2 1. SCOPE 1.1 This specification provides information for a stan dardized method of placing identification on installed insulation which contains free asbestos fibers or insu lation ofiunknown asbestos content. 1.2 This specification is applicable only for identi fying installed insulation which has a questionable free asbestos fiber content. Obviously, materials such as cel lular glass, glass fiber, mineral wool, polyurethane foam, and polystyrene foam do not contain asbestos fibers and, therefore, do not need to be marked for identification. 1.3 Follow this specification only at locations where 6uch identification is required by the operating de partment and the plant does not have a conflicting estab lished identification procedure. 2. CONDITIONS installed, do not require identification. At turnover, the local construction organization is to notify the plant that the facility is free of materials containing free asbestos fibers. 4.2 Condition II. Individual insulated lines or equip ment pieces in clearly defined additions in which no insulation containing free asbestos fibers was installed, do not require identification. In lieu of marking individ ual lines or equipment pieces, place strips of tape strate gically along the plane that defines the building addition. Locate the tape on selected columns, beams, walls, or ceilings, to clearly identify the plane at which the asbestos-free insulation starts. Apply two parallel 6trips of tape. Position one piece of tape with the arrows orientated to indicate that, from that point on, all insu lation is nonasbestos. Position a second piece of tape with the arrows orientated to indicate that, from that point back, the insulation may contain free asbestos fibers. - 2.1 From an installed insulation viewpoint, specific areas on a site are classified as follows: 2.1.1 Condition I. New facilities on which no in sulation containing free asbestos fibers was installed. This could be an entire site or a segregated building on a site. 2.1.2 Condition II. New additions to existing buildings which can be clearly defined by designated column lines or a defined plane through the building. The addition does not contain any insulation containing free asbestos fibers. 2.1.3 Condition III. Existing areas which are modified by the addition of insulated lines or equipment. 4.3 Condition III. Individually mark all new insulated lines and equipment pieces installed as additions or modifications in existing areas to indicate insulation as bestos content. Where asbestos-free insulation is in stalled on a pipeline, place a strip of tape around the circumference of the finish at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a tie-in is made to a line insulated with a material of unknown asbestos content, identify the junction of the insulation by parallel pieces of tape around the circumference of the finish. Position one piece of tape to indicate that, from that point on, the insulation is asbestos-free. Place a second piece of tape with the arrows orientated to indicate that, from that point on, the insulation may contain free asbestos fibers. 2.1.4 Condition IV. Existing areas in which exist ing insulation is being replaced. 3. TYPE OF IDENTIFICATION For identification, place strategically located strips of appropriately marked tape around the circumference of the pipe finish or on the equipment finish. Position the tape so as to indicate the type of insulation used with the arrows pointing down the line in the direction in which the indicated insulation runs (see Figure 1). 4. PLACEMENT OF IDENTIFICATION WHEN REQUIRED 4.1 Condition I. Individual insulated lines or equip ment pieces in new facilities or segregated buildings in which no insulation containing free asbestos was 4.4 Condition IV. Where insulation is being replaced in an area of unknown asbestos content, by asbestos-free insulation, identify the replacement insulation by a strip of tape placed around the circumference of the pipe finish or at strategic locations on equipment pieces. Where a line running from wall-to-wall is reinsulated, place a piece of tape at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a portion of the insulation is replaced, identify the junction of the existing and replacement insulation by parallel pieces of tape around the circumference of the finish. Place one piece of tape to indicate that, from that point on, the insulation is asbestos-free. Place a second piece of tape with the arrows orientated to indi cate that, from that point on, the insulation may contain free asbestos fibers. fti lAmuurrrFF wo ?s UCC 019694 SN 218 P Pagi 2 IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION This Pigs Riv April 1984 5. HANDLING INSULATION " When handling, fabricating, or removing insu lation in the absence of positive knowledge that it is asbestos-free, assume that it contains free asbestos fibers, and follow S4T. 6. TAPE 6.1 Spiclflcstions (* Figure 1) I. Supplied in rolls. b. Pressure-sensitive contact cement backing -- developed for aircraft use. C. M -- 90 tape material -- developed for aircraft use. d. Provide slit in release paper for ea6y removal. I. ASB letters and arrow red, repeated on 3-inch intervals, on white background. NA letters and arrow blue, repeated on 3-inch intervals, on white background. Letters are approximately 1-inch high. 7. TAPE SUPPLIERS (PARTIAL LIST) Davis Printing Co P. O. Box 6% Camden, SC 29029 (803)432-1901 Top Flight Corp 16S East 9th Avenue York, PA 17404 (717) 843 - 9901 TAB Westline Division of Thomas & Betts Corp 220 South Rose Street Los Angeles, CA 90012 (800)421-8618 Sheriden Safety Supply 7029 Huntley Road Suite E Columbus, OH 43229 (614)888 - 8040 York Tape and Label Corp P. O. Box 6805 Columbia, SC 29260 (803) 788 - 2635 226 Tap* Legend: ASB Asbestos Bearing NA s Nonasbestos Bearing FIGURE 1 - TAPE FOR IDENTIFICATION UCC 019695  < ) PIPING TECHNOLOGY MINUTES FOR INCLUSION IN ASBESTOS TASK FORCE GENERAL MEETING MINUTES 4.3 1 Addressing Section 4.4.2 of the agenda listed in C. C. Neely letter dated 3/2/87 . . . R. H. Engle presented proposed plans Car modifying the Valve and Piping Specifications using strictly GRAFOIL n products as the only replacement for asbestos. First step would entail developing new UCC "V-numbers" for those valves which are currently listed with asbestos packing and/or bonnet gaskets and no GRAFOIL n alternate. Piping Technology will maintain the old numbers unique to aid in identification of existing valves. Once the new numbers are developed, they will be transferred to the affected piping specification sheets. Secondly, as with the valves, the existing specification names will be maintained unique by cancelling the existing suffix letters and starting with the next available letter e.g., 1C2 though 1C2E will be listed as "cancelled" and the new listing will be started at "1C2F". The acceptable linejaasket alternate for the asbestos ring will be the 1/16" thick GRAFOIL n GHE and the acceptable replacement filler for spiralwound gaskets will be GRAFOIL n Grade GTB. . The proposed schedule would target July 1988 for completion of issues to the manual; the proposed asbestos program would not be reviewed through normal Technology Manuals Standards (TMS) channels due to the .nature of the changes. Piping Technology believes there to be 2-3 man- months ( $5000.00/man-month) of work involved in the transition. Approximate printing/distribution cost would run in the $5000.00 range. An accelerated schedule may become necessary if vendors confirm earlier reports of supply problems and would definitely extend the estimated time into 3 man-months because additional technical manpower would be required. Sherry Murphree will continue to feedback on market conditions. ' R. N. Engle/pae March 24, 1987 AJ4.-RHE UCC 019696 * HANG TO: C. C. NEELY - Location 511 From: S. S. Murphree - Loc. 515 Secretary - Anita Thaxton - 721-4802 Purchase of Asbestos - Substitute Material The Chemicals and Plastics Division agreements for gasket and packing materials are due for renegotiation In second quarter 1987. The procurement plan and request for quotes have been Issued. Bids are now being received and new agreements are expected by June 1, 1987. The traditional method of predicting quantities, material types, and dollars for price agreements Is past history and anticipated future activity. Our past history of gasket and packing usage shows a heavy dependance on asbestos at very low prices. We are already seeing a changeover to the Grafoil and teflon based material. The new agreements will be based on anticipated Increased usage of these materials and dramatic decreases in asbestos use. Our expenditures will increase due to higher priced asbestos replacements, higher priced asbestos, and increased activity of a wide variety of materials. Many of our traditional gasket and packing manufacturers are no longer in the asbestos business (Johns-Manvi1le, John Crane, Allpax, etc.). The manufacturers who currently handle asbestos do not have assurance from their liability carriers that coverage will continue beyond the next twelve months. Parker Seals has announced July, 1987 as their cutoff date for asbestos manufacture. We have no certainty that asbestos will be available thru January, 1989. From the purchasing viewpoint new standards for gasket and packing should be expedited to the nearest feasible deadline. After new gasket and packing standards are determined a tremendous effort will be required in the plant storerooms, purchasing groups, and maintenance departments. The effort will be three-fold: 1. Alternates to stocked and purchased material will be determined for each applIcation. 2. New descriptions and usages will be determined and changes made. Major C & P locations have 2000 to 3000 separate line Items. A plan for changeover from old to new material will be required. 3. Training and communications will be needed for every end user. It Is estimated that the effort for maintenance and materials management will require four to six months of work at each location. Sherry S. Murphree 3/30/87 RECEIVED MAR 3 01987 CCN UCC 019697