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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION VI 1600 PATTERSON. SUITE 1 tOO
DALLAS. TEXAS 75201
February 11, 1974
E. S. Martin, Plant Manager Shell Chemical Company P. 0. Box 2633 Deer Park, Texas 77536
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HOUSTON H.Vfl j Dear Mr. Martin: tfU'.ltVM)
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This is in follow up to the plant inspection conducted your facility on January 31, 1974, by myself and other
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During the inspection, problem areas were discovered which, if unattended to, could lead to possible violations
of the asbestos emission standard promulgated on April 6, 1973.
One problem area is at the chlorine plant cell renewal If /W site. The inside area was being hosed down at the time of the
.inspection; a commendable and I assume routine practice. On the outside area however, clumps of debris which are suspected of being asbestos were sighted. Plant personnel stated that the spi11 age most likely occurred when bags of asbestos were beingHEransported from the main stcucAg^ area to the cell renewal area. Since the path used to transport the asbestos to its destination is an outdoor path, adequate care must be taken to ensure that the asbestos fibers do not become air & borne or spilled on the ground.
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Another area of concern is at the main storage area for asbestos. The stockpile of bags is exposed and therefore subject to breezes which can cause asbestos particles to become airborne. Again, adequate precaution must be taken to prevent this.
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Your prompt attention to these matters is urged to prevent any possible violations of the asbestos emission standard from occuring.
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Should any questions arise, please contact me by letter to this office or by telephone at (214) 749-2142.
Sincerely, Qa,*,a. Gary A. Bernath Investigation & Support
Branch Enforcement Division cc: Mr. F. G. Reitz, Manager Safety and Training Shell Chemical Company P. 0. Box 2633 Deer Park, Texas 77536
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