Document QMvM4L593Rg1axg0xeq6B3NjL

-If-2 unm division to (Name) Division Location Linde Environmental Coordinators Date June 6, 1977 Originating Dept. SAFETY, HEALTH AMD ENVIRO.NMENTAL AFFAIRS ' OLD SAW MILL RIVER RD., TARRYTOWN, N.Y. 10591 Copy to R. J. Conkling M. G. Manetti L. G. Attached is a C & P memorandum which outlines their plans for removal of asbestos insulation and EPA notification requirements. This information may be helpful if you find that it is necessary to remove some asbestos insulation from your plant operations. Please advise me if you are planning any such asbestos removal work. JMC:hk Attach. J. M. Cleverdon ep^v- i i) 4 5/ INTERNAL CORRESPONDENCE UNION CARBIDE CORPORATION nuC FJ..VM- ,,,T lZ -% - - T" 270 PARK AVENUE;rNEW YORK, NEW YORK 10017 To {Name) Division Location c. 9* A R. C. G. 11Allenbach Loc. Andrews Beverly at #615 #322 #250 yj. M. Cleverdon ai #323 . Gavj A. Fitzgerald-Woodbine, . Copy to R. A. Hardison Loc. #742 R. C. Odewald It #358 R. L. Patterson It #781 Date Originating Dept. Answering letter date Subject May 20, 1977 Health, Safety and Environmental Affairs 22 cc . F. D. Bess It #514 Attached is a self-explanatory report which summarizes work done by the C & P Division to provide assistance to their plants regarding the removal and disposal of asbestos-con taining insulation. The information may be of assistance to some of you in developing your own plans. FMC:gc Attachment F. M. Charles rt I U 4 b fcj ATTACHMENT I Excerpts from EPA Hazardous Air Pollutant Regulation ENVIRONMENTAL PROTECTION AGENCY REGULATIONS ON NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (40 CFR 61; 38 FR 8820, April 6, 1973: Amended by Code of Federal Regulations,Volume 40, Revised as of July 1, 1976; 41 FR 27967, July 8. 1976; 41 FR 33264, August 9, 1976; 41 FR 34629, August 16. 1976; 41 FR 36918, September 1, 1976; 41 FR 40108, September 17, 1976; 41 FR 40467, September 20, 1976; 41 FR 43I4S. September 30. 1976; 41 FR 44860, October 13. 1976; 41 FR 46559. October 20. 1976; 41 FR 53017, December 3. 1976; 41 FR 5475R December 15. 1976; 41 FR 56805, December 30, 1976) Subpart A--General Provisions 61.01 (a) AU requests, repoits. applications, submittals, and other communications to Oio Administrator pursuant to this pavt. .shall be submitted in duplicate and ad- .tressed to the appropriate Regional Of- !lco of tho Environmental Protection Agency, to the attention ol the Director, Enforcement Division. The regional of fices are as follows: .. Region t (Connecticut, Maine. New ITarapelilre. Massachusetts. Rhode Island. Ver mont) , John F. Kennedy Federal Building, Boston, Massachusetts 022U3. Region II (New York. New Jersey. Puerto Rico, Virgin Islands). Federal Otlico Build ing. 30 Federal Plaza (Foley Square), Now York, N.Y. 10007. Regina III (Delaware. District of Columbia, PonnaylvBiiln. Maryland, Virginia. West Vir ginia). Curtis Building, Sixth and Walnut Streets, Philadelphia, Pennsylvania 19:00. Region IV (Alabama, Florida, Georgia, Mlv- nlsilppl, Kentucky, Nonli Carolina, South Onrollnn, Tennessee). Suite 300, 1431 I'coch- leo Street, /.tlauta. Georgia 30309. Region V (Illinois. Indiana. Minnesota. Michigan. Ohio, Wisconsin). 1 North Wacker Drive. Chicago. Illinois BlMOO. Region VI (Arkansas, Louisiana, New Mnxtco. Oklahoma, Texas), 1000 Patterson Hirest. Dallas, Texas 70201. Region VIt (lews. Kansas. Missouri, Ne- taiwiurl OH 100.i.raska). 1733 llallhuuio Street, Kansas City, IIjUIsii VIII (Colorado, Montana. North Da kota, South Dakota, Utah, Wyoming), 198 Lincoln Towers, 1890 Lincoln Street, Denver, Colorado 80203. Region IX (Arizona, California, Hawaii, Nevada. Guinn, Atnerlcau Samoa), 100 Cali fornia Street, San Francisco, California 941U, Region X (Washington, Oregon, Idaho, Alaska). 1300 Sixth Avenue, Seattle, Wash ington 08101. ` (b) Section 112(d) directs the Admin istrator to delegate to each State, when appropriate, the authority to Implement and enforce the Rational emission stand ards for hazardous air poliutonts for sta tionary sources located In such State. All information required to lie submitted (o' EPA under paragraph (a) of thl.f gpctlon, must also be submitted to the. ap propriate Stale Agency of any Stale to wlitoh this authority hits been delegated (provided, that each specific delegation may exempt sources from a certain fed eral or Stab! reporting requirement) .Thr appropriate mulling address, for those Slates whose-dclcgotion request has been approved Is as follows: F-California: Bay Aren Air Pollution Control District, 939 EQIa Street, Ban Francisco. CA 94100. Snr.rnmentn County Air rollutlnn Control District. 3701 Branch Center Road, Sacra mento. CA 95827. (1.) State of Georgia, Environmental TTo- tcctlon Division. Dcpsrtmenfof Natural Ro- aources. 270 Washington Street. S.W At- lauta, Georgia 30334. (> ` (HR)--New Tor*:: New York State Depart ment of Environmental Conservation,so Wolf Hoad, Albany, New York 13233, attention: Division or Atr'Beaourccs. (40 FR 48347, Ociober 15. 197S| (II) North Carolina Environmental Man a.tcniciit Commission. Department of Natural and Economic Resources, Division of Envi ronmental Management. r.O. Box 27G37, Ftrv* lcii-.li. Notn Carolina 27GI1. Attention: Air Quality Section. Subpart B--National Emission Standard for Asbestos 61.22 Einiision slnmluril. (d) Demolition and renovation: The requirements of this paragraph shall apply to any owner or operator of a demolition or renovation operation who intends to demolish any Institutional, commercial, or Industrial building (in cluding apartment buildings having more than four dwelling units), structure, facility. Installation, or portion thereof which contains any pipe, duct, boiler, tank, reactor, turbine, furnace, or struc tural member that is Insulated or fire proofed with friable asbestos material, except ns provided in paragraph <d) (1) of this section: or who intends to reno vate any institutional, commercial, or in dustrial building, structure, facility, in stallation, or portion thereof where more Ilian 80 meters (ca. 2CO feet) of pipe in sulated or fireproofed with friable as bestos material arc stripped or removed, or more than 15 square meters Cca. 160 square feet) of friable asbestos material used to Insulate or firepri-of any duct, boiler, tank, reactor, turbine, furnace, or structural member are stripped or re moved. (2) Written notice of Intention to de molish or renovate shall be provided to the Administrator by the owner or opera tor of the demolition or renovation oper ation. Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demo lition. or as early as possible prior to commencement of emergency demolition subject to paragraph (d>(G> of this sec tion, and as early os possible prior to commencement of renovation. Such no tice shall include the following informa tion: (i) Name of owner or operator. (ii) Address of owner or operator. (iii) Description of the building, struc ture. facility, or installation Itv lie de molished or renovated. Including the size, ar.e, and prior use of the structure, and the approximate amount of friable asbestos material used for insulation nud fireproofing. (ivi Address or location of the build ing. structure, facility, or installation. (v) Scheduled starling and comple tion dates of demolition or renovation. (vi) Nature of planned demolition or renovation and method is' to be em ployed. (vii) Procedures to be employed to meet the requirements of this paragraph and paragraph ij> of this section. (viii) The name and address or loca tion of the waste disposal site where the friable asbestos waste will be deposited. (lx> Name, title, and authority of the Stale ov local governmental representa tive who has ordeivil it demolition which Is subject to ptiragt'Upli (ill Ifi) of this section. 1S c: 4> cr CD 61.25 Waste disposal sites, (b) Warning signs shall be displayed at all entrances, and alone the propci l> line of the site or along llic pcrin.elcr of the sections of the site where asbestoscontaining waste material is deposited, at intervals of 100 m <ca. 330 ft) or less except as specified in paragraph (d> ol this section. Signs shall be posted In such a manner and location that a person may easily vend the legend. The warni-tr signs required by this paragraph slid! contonn to the requirements of 20" x I t" upright formal signs specified in 2D Cl'It IDlO.M.aldm4) and Ihi; paragraph. Tit.* signs shall display tin- followin': legend in the lower panel, uitb litter n/.*s and styles of a visibility at least equal to those specified ui this paragraph. Asuri.xos W*-`.rr Disi'os.o. Sirx Do Not Create Dust Rrcatbln;: AxheM.x Is Hazardous to Your Health Notation 1" Sans Serif. G.alilc or D'.ock 1" Sans.Serif, Gothic or Ulozk li Toirit G.it'dr Spacing between line* shall be at least equal to the height of the upper of tin* tun liiii't (5) The EPA regulation applies to any work done at a facility whether by company or contract personnel. Company personnel involved with contractors should assure that notification responsibility is assigned to the contractor in the work specification, or performed by the company. 4. A i U4bb 3- plastics. An estimated xx square feet and yy lineal feet of insulation to be removed. (4) Address of Site (Same as item 2 above) (5) Scheduled Start and Completion Dates (Either calendar year or other specified dates)__________ (6) Nature of planned demolition or renovation and methods employed Demolition of obsolete facilities and renovation of existing faci1ities. (7) Procedures employed Insulation wetted before removal, lowered to ground, disposed in a site which is (fenced or protected by natural barrier or covered daily). (8) Name and address of disposal site (Either same as 1 and 2 above or information for contractor site) (9) Agency ordering demolition Not applicable. GENERAL NOTES (1) The regulation applies to friable asbestos which would mean insulation containing more than one percent asbestos by weight which can be reduced to powder, when dry, by hand pressure. Any insulation purchased prior to 1975, containing asbestos as reinforcement, would meet the definition of friable asbestos and be subject to the regulation. New insulation does not contain asbestos. (2) A standard text for a notification letter and a format for the notice (filled in with standard responses or indication of the type of response) are included. (3) For locations with a reasonable amount of continuing activity involving insulation removal, paperwork would be minimized and made more routine if notification were made annually (in December for the coming year) using a best estimate of insulation quantities involved. Other locations may find that annual notification is unnecessary. (**) Recognize that an Occupational Safety and Health Standard, 29 CFR, Chapter XVII, Section 1910.1001, "Toxic and Hazardous Substances" impose certain requirements for personnel equipment, clothing, monitor ing, and medical examinations in work areas involving exposure to asbestos dust. There is a certain amount, but not total overlap with the EPA requlation. ' *(**) i f| L. K L 2. (d) The area is fenced and (20 x Ht inch) warning signs are posted at least every 330 feet. [See Attachment I, 61.25] REQUIREMENTS - EPA NOTIFICATION Timing - EPA and applicable States are to be notified either: (a) Annually, or (b) 10 days prior to planned demolition or renovation, or (c) As soon as possible after beginning an unplanned (emergency) removal project. The above notification requirement applies whenever the total amount exceeds 160 square feet of equipment or 260 lineal feet of pipe insula tion. Office to be Notified - [See Attachment 1, 61.0^*1 Federal: Director, Enforcement Division Environmental Protection Agency (Regional Office City Address) State: (Applicable only in the following C&P states) California (Sacramento County) (Bay Area) Georgia New York North Carolina Suggested Text of Notification Letter - The attached notification relative to the demolition and/or renovation of facilities .containing friable asbestos insulation is provided per requirements of AO CFR 61, Subpart B, Section 61.22 (d) . Please contact the writer if there are questions concerning informa tion contained in the notification. Signed Form of Notification [ See also Attachment I - 61.22] ^ NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION ^ 4 fc> 3 (1) Name of Owner ______ Union Carbide Corporation (2) Address of Owner ________(Location Street Address) __________________ (3) Description of Facility Various buildings, equipment and piping used in manufacture and distribution of chemicals and GUIDANCE FOR COMPLIANCE WITH EPA ASBESTOS REGULATION 1. REGULATION AND APPLICABILITY Regulation - 40 CFR 61, Subparts A and B ApplicabiIity - To the demolition of structures or renovation of equip ment and piping that involves removal of more than 160 square feet or 260 lineal feet of insulation containing more than one percent asbestos by weight, either in a single project or a predictable series of projects over the course of one year that are additive to this amount. OVERALL REQUIREMENTS OF REGULATION Practices - Comply with defined removal and disposal practices. Notification - Provide timely notification of EPA. KEY REQUIREMENTS - REMOVAL PRACTICES (1) Insulation shall be removed prior to demolition where the demolition would likely damage and expose insulation. (2) Insulation must be wetted prior to removal and kept wet until disposal is accomplished. (3) Insulation on pipe or equipment which is to be removed in sections must have exposed surfaces wetted and kept wet during dismantling. (4) Stripped insulation must not be dropped or thrown to the ground. Dust tight containers or chutes must be used for lowering insulation removed that is more than 50 feet above ground level. KEY REQUIREMENTS - DISPOSAL PRACTICES (1) No visible emissions of insulation are allowed in transport to the disposal site. (2) No visible emissions may result from disposal operations. (3) For disposal areas one of the following requirements must be met: (a) A six-inch earth cover is provided over disposed insula tion within 24 hours. (b) An effective resinous or petroleum-based dust suppression agent is applied at the end of each operating day. ' u4b2 (c) A natural barrier adequately deters publ'ic access to the site. INTERNAL CORRESPONDENCE DRAFT HEM!CALS AND PLASTICS * P. O. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 See Attached Distribution List Date May 9, 1977 Originating Dept. SHARE Subject Guidance for Compliance with EPA Asbestos Regulation Gentlemen: Enclosed is an outline providing guidance for compliance with Environmental Protection Agency regulation, 40 CFR 61, Hazardous Air Pollutants, as it applies to the removal and disposal of asbestos-containing insulation and the notification of appropriate regulatory agencies. The outline summarizes key requirements of the regulation and suggests a standard format for use in notifying regulatory agencies. It is recommended that current location procedures be reviewed and any appropriate changes implemented to conform with specified removal and disposal requirements. It is also suggested that locations within the same EPA Region coordinate the timing for initial notification of the proper regulatory agencies to make the submissions reasonably concurrent (August 1 might be a realistic target date). It is further suggested that larger locations will find that annual notifica tion on a calendar year basis (in early December of the prior year, except for 1977) using the best estimate of expected activity will minimize their paper work. The EPA regulation is in addition to an OSHA standard governing worker exposure (29 CFR, Chapter XVII, Section 1910.1001). However, only EPA requires notifi cation of removal and disposal activities. The cost impact of modifying proce dures to meet EPA regulations appears to be quite variable throughout Chemicals and Plastics, but would seem to be in the range of $100,000 - $200,000 annually. Any requests for clarification of the plan requirements should be directed to Mr. D. G. Moshier of the Maintenance Operations Team. Copies of the regula tion can be provided upon request (they may be found in the Environment Reporter at 121:0461). Sincerely, RAH/w R. A. Huber Maintenance Operations'-Manager a i U 4- B 1 Mr. R. A. Huber, et al -2- ,May 9 1977 One proposed deviation from the previously indicated action plan is to eliminate the final step of discussing the intended procedure with an EPA Regional Office following implementation at locations, but prior to official notification of the agency as required in the regulation. Upon reflection, it is the opinion of the writer (but not discussed with the team) that this is an unnetessary complication of the program, with no commensurate benefit. Addressees may also wish to comment on this point. Sincerely, F. D. Bess FDB/klw Attachment 'HOC INTERNAL CORRESPONDENCE hemicals and plastics (Nime) Mr. R. A. Huber _ 5]! Mr. R. D. Stief - 511 g. t u-- tAPrt ^ 8A977 P. O. BOX 8361, SOUTH CHA F. W* WEST VIRGINIA 25303 D' May 9, 1977 Originating Dept. SHARE opy to Mr. F. M. Charles - NY0.22* Mr. N. W. Gaines - 511 Mr. R. C. Hieronymus - 51.1 Mr. R. T. Kramer - 512 Ms. M. G. Manetti - NY0,46 Mr. A. E. Montagna - NY0,21 Mr. D. G. Moshier - 511 Mr. R. E. Peele - 511 Mr. E. C. Powell, Jr. - 511 Mr. T. P. Raby - 312 Mr. M. D. Seymour - 511 Mr. B. H. Thomas - 511 Mr. D. T. Watters- 511 Subject EPA Asbestos Regulation Proposed Guidance Letter for Location Compliance Gentlemen: Enclosed is the draft of a transmittal letter and attachments intended to explain and provide guidance to plant personnel relative to the requirements of the EPA Regulation on Hazardous Pollutants as it applies to asbestoscontaining insulation removal and disposal and notification of the proper regulatory agency. The information and approach were developed by Messrs. Kramer, Moshier, Powell, Seymour, and the writer in several meetings over the past few months. The enclosure represents the recommended course of action by this group. Mr. Powell indicated by letter of March 25 to the writer that Jim Rapp of the Texas City Maintenance Department believes that the added cost burden of compliance will be several times that indicated by the Institute Plant. There fore, the incremental cost estimated in the transmittal letter has been increased from past values. We request review and suggested modifications from addressees by June 1, 1977. Following appropriate changes, it is recommended that Mr. Huber issue the letter to Location Maintenance Supervision, Plant Managers, and Location Occupa tional Health Coordinators. It is also recommended that Mr. Stief issue the guidance (with appropriate transmittal letter modifications) to the proper Construction and Engineering Department personnel (including those who are involved in contract specifications). Despite our intentions to make the guidance concise, the product is still lengthy. Reviewers are requested to suggest deletions or modifications to reduce the content, as well as any format changes that would make, the product more nearly conform to related procedural manuals. < U4b9 PROGRAM COORDINATORS - ENVIRONMENTAL AFFAIRS (LINDE) J. Badman - Gas Products Production - 8th floor, N.Y. L. M. Cowden - LOC. 819 - (Speedway) W. A. Faust - LOC. 815 - (Tonawanda) F. J. Guskey - LOC. 805 - (Florence) L. M. Heinlein - LOC 817 - (Speedway) R. Miller - Advanced Systems P. 0. Box No. 41490 Indianapolis, Indiana 46241 G. A. Rees - Welding Flux Plant P. 0. Box 747 Niagara Falls, N.Y. 14302 D. J. Teston - Linde Welding Materials Middle Road P. 0. Box 710 Ashtabula, Ohio 44004 A. R. Wandelt - LOC. 802 - (Piscataway) W. M. Wilson - Theodore, Alabama Z. K. Zaremba - P. 0. Box 11486 Chickasaw, Alabama 36611 -