Document N21Xo0rR8B8vZvR6vpebaYv38

k/y'Oi- Jf PLAINTIFF'S EXHIBIT SUBJECT: Sistersville Plant Philosophies and Guidelines for Maintaining/ Removing Asbestos Insulation UC-4072 Following is the Sistersville Plant's philosophy concerning asbestos insulation: "The Plant does not intend to enter into a program for the wholesale removal of installed insulation for no other reason than that it contains asbestos." Reasoning: In many cases the risks created by the removal would far exceed any which would arise if the insulation were left in place effectively sealed. Maintenance Guide!ines: (1) If the installed asbestos insulation has damage that can be patched, and sealed, do it rather than complete removal. (2) If the installed asbestos insulation can be effectively sealed, do it versus replacement. (3) If a repair job.on pipe, equipment! or a tank requires the removal of asbestos insulation in order to get at the work, then replace the asbestos insulation with approved, non-asbestos type insulation. Proper procedures must be followed during the removal, and proper disposal methods used for the asbestos insulation. (4) Maintenance Coordinators should fill out their Shop Order requests with all the above in mind. Information and Clarification: The Sistersville Plant is 30 years old, and being that old the piping and other equipment were originally insulated with asbestos. Much of the asbestos has been removed and safely disposed of in the landfill as repairs and replacements have occured. No insulation containing asbestos has been purchased since 1973, but asbestos still remains. Some of you have expressed concern that plant personnel are continually exposed to airborne asbestos fibers from unsealed insulation and dust from the entire plant surface. Monitoring conducted in a number of Plant locations, including some having unsealed asbestos nearby, has shown below the detectable limit of the analytical method. Sampling downwind of asbestos removal operations shows the same nondetectable levels. We believe this is because the insulator mechanics carefully follow the procedures that have been developed to prevent contamination of the environment and themselves while removing asbestos. UCC 022432 'j. , vdfeO^dL JLoj&J, (hom^M 4i a J^y^^fi jUjlte&L^jQeiJ^ nz&n.- AitMt&MtL JaJjU^ \jjx' JixMxmL C. UCC 022433 . UNION CARBIDE CORPORATION_________ ________ Silicones and Urethane Intermediates Sistersville, WV MEMO TO: W. V. Summers COPY TO: A. W. Boyd Department Heads 1st Line Maintenance Supervisors 2nd Line Maintenance Supervisors Maintenance Coordinators DATE: July 18, 1984 SUBJECT: Sistersville Plant Philosophies and Guidelines for Maintaining/Removing Asbestos Insulation Following is the Sistersville Plant's philosophy concerning asbestos insulation: "The Plant does not intend to enter into a program for the wholesale removal of installed insulation for no other reason than that it contains asbestos." Reasoning: ^ 13 42 In many cases the risks created by the removal would far exceed any which would arise if the insulation were left in place ( effectively sealed. Maintenance Guidelines: (1) If the installed asbestos insulation has damage that can be patched, and sealed, do it rather than complete removal. (2) If the installed asbestos insulation can be effectively sealed, do it versus replacement. (3) If a repair job on pipe, equipment, or a tank requires the re moval of asbestos insulation in order to get at the work, then replace the asbestos insulation with approved, non-asbestos type insulation. Proper procedures must be followed during the re moval, and proper disposal methods used for the asbestos insula tion. (4) Maintenance Coordinators should fill out their Shop Order re quests with all the above in mind. Clarification of the Safety 8 Health Insulation Capital Project: "This project provides for the upgrade of critical insulation in the Steam Plant and Monomers Areas. Existing exposed asbestos insula tion will be repaired or replaced to insure a weatherproof system and correct the safety and health concern of exposed airborne asbestos." UCC 022434 Sistersville Plant Philosophies Guidelines for Maintaining/Removing Asbestos Insulation Page 2 of 2 Many believe this project was for the "elimination of asbestos insulation" and this is not the case. It turns out that much of the insulation is beyond repair, and for this reason is being replaced. GWW/tas t George W. Wulfer^y Maintenance/Materials Management Dept. Head UCC 022435 i i