Document QXLGmQBNjQJ6962od8gQvDXQR

Shell c.i Company Shell Chemrcai Company Interoffice Memorandum APRIL 14, 1980 PLAINTIFF'S EXHIBIT FROM: R. P. FRUTIGER TO: G. C. ANDERSON SUBJECT: REPAIR OF ASBESTOS INSULATION He have reviewed the subject DPMC-North project with Head Office Operations Safety & Health to determine what criteria should be used in identifying asbestos insulation that needs maintaining from a health standpoint, and whether those areas identified as needing repair as part-of our project were consistent with this criteria. The OSHA Standard 1910.1001 {h>(i) requires "All external surfaces in any place of employment shall be maintained free of accumulations of loose asbestos fibers if, with their dispersion, there would be an excessive concentration." In addition, because of the low level (0.1 fibers/ml. of ->r) at ^hish OSnA requires medical exams, particular care must be taken in controlling work areas where there is a high level of foot traffic. In reviewing our project, I believe the criteria we used was consistent with the above OSKA requirements. Although the three(3) years projected for completion of the job could be construed by regulatory officials as too long, I believe it's reasonable and something that we could defend. Anacortes initiated a similar project about a year ago following Head Office approval. They have completed about 60% of the work to-date. They are using a contract maintenance crew of about ten(10) with a Shell foreman providing the supervision. Please let me know if you need additional information. cc: North Management Team HUT - 084478 DPMC-10594 SMISC00003725