Document RpbB66bz7nw4kzjBQMo7DV1Qz

UNION CARBIDE CORPORATION 010 RlDGEBuRV ROAD. DANBURY CONN 06817 LAW DEPARTMENT SE6EIv ED APR 2 t 1987 E. K. 'JENSEN THIS DOCUMENT IS PROTECTED BY THE ATTORNEY/CLIENT AND BY THE ATTORNEY WORK PRODUCT PRIVILEGES RECEIVED April 21, 1987 APR 2 3 1987 E. K. JENSEN TO: J. J. Nietz FROM: D. R. Crowell IL RE: Vermiculite I have reviewed your letter of April 7, 1987 and Nick DiFranco's letter to you of April 17, 1987 and concur with Nick's concern about terminating the vermiculite testing for the remaining cold boxes. Without actual sampling data from each cold box, the probability of successfully defending any legal challenges, including OSHA citations, workers compensation claims, and third party claims, will be substantially reduced because we will not be in a position to conclusively demonstrate that the vermiculite in the untested cold boxes did not contain impermissibly high levels of asbestos. While I concur in sections a, b and c of your recommendations, I believe that the more prudent course of action would be to do the testing in the remaining 59 cold boxes. Additionally, should any of the 54 remaining cold boxes exceed permissible levels of asbestos, any future removal operations would be subject to the requirements of the OSHA asbestos standard, 29 C.F.R. 1910.1001, including monitoring and use of engineering controls and personal protective equipment during removal operations. DRC/nc cc: M. D. Brower N. A. DiFranco E.K. Jensen R.S. Kramer M.G. Manetti W.M. Therrien D.E. White A 10572 UCC 009985 VC-4197