Document VGXd9R1j748gQ9j1X0ddOgk2K

ipO' f ^Y fcr*- UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICES Central Engineering South Charleston, West Virginia UCC BUSINESS CONFIDENTIAL April 6. 1987 .RtCEiVtD APR 7 ttft? , ' 301 PR KAVASMANECK TO: L. E. Calvert S. W. Clark G. B. Elder R. W. Engle S. S. Murphree tch COPY TO: FROM: SUBJECT: R. R. Allen H. N. Baylor D. J. Dickson Franson R. Kavasmaneck J. G. Keeler W. G. Lilly, Jr. B. G. Perry 3. E. Sanders S. W. Turlcchl ?1 RECErvBD APR 2 3 1387 C. C. Neely Minutes of Task Group Meeting of March 17, 1987 Phaseout Use of Asbestos-Containing Materials In Work Place Chemicals and Plastics Group ^ Y'`- Following Is an Executive Summary of the action/agreements resulting from the subject meeting. The detailed minutes prepared by the responsible Task Group member are attached for those who desire additional Information. Executive Summary The "heart" of the C&P Group asbestos-usage phaseout program is the requirement that no asbestos-containing products be purchased after January 1, 1989. Consistent with this date, the Task Group agreed last fall when preparing the proposed program that the affected valve, piping, and process vessel Standard Practice documents must be revised to show substitute materials by July 1, 1988, and manpower estimates were made accordingly. However, because of the rapid (and very likely, continuing) reduction of suppliers of asbestos-containing materials due to liability Insurance coverage problems, In combination with the desire of key plant personnel to cease using these materials at an early date, the Task Group UCC 005974 Meeting Minutes 2- - April 6, 1987 recommends that the responsible CED skill areas complete the required revisions to the affected Standard Practice documents by September 30, 1987. Action H. N. 8aylor R. R. Allen This accelerated schedule will require additional technical assistance In the Piping Technology skill area. Preliminary discussions with R. R. Allen and R. H. Engle regarding the posslbtllty'of an accelerated schedule were held on March 23, 1987. Arrangements to obtain the needed technical assistance should now be made. Action J. E. Sanders The total CED cost of the accelerated program In 1987 over and above planned and budgeted T&S programs is estimated to be $34,000, much less than our earlier $93,000 estimate which was developed last September on the basis that much more work would be required. Funding for this activity Is needed. Action P. D. Franson 0. J. Dickson The Task Group requests the assistance of the Machinery Technology Group In Identifying what actions, If any, are needed to assure that the broadly advertised aramld fiber nonasbestos asbestos gasket substitutes are not used in machinery items (e.g., pumps, compressors) for our process units. One of the major reasons these materials are generally considered unsuitable for gaskets Is because they will not pass fire tests. The perception Is that machinery manufacturers are using these materials without our know ledge and consent. Any costs associated with this request will be In addition to the $34,000 mentioned above. Action J. E. Sanders The Task Group requests advice as to where the now-approved asbestos-usage phaseout program documents will reside. It needs a permanent "home" within the TMS manuals system. S. W. Clark suggested It be Included In Section 8 of.the laafety Health~mahual'"thTs~Ts ~the Opera tl on "an d Maintenance Section' The meeting agenda was based on the duties listed In our recom mended program that are delegated to the Central Engineering Department. These duties are listed below along with a brief summary of the action/ agreements reached: _ Agenda Number Responslbl11ty ? Duty and Actlon/Agreement 4.1 S. H. Clark/Q&P Industrial Ident1ficatIon_of Asbestos Hygiene Department J Contal nlngjnatenals^ C&P erry Hanning)------- Industrial Hygiene Department estimates completion of Criteria Document 4Q87. No cost to CED. JLsu - h) 5 cj UCC 005975 0^ p Meeting Minutes -3- April 6, 1987 Agenda Number Responsibility Duty and Action/Agreement 4.2 G. B. Elder Reg1acement of_Asbestos-Conta1n1ng insuiat1on_as Regui.red_to Maintain Structural_and_Funettonal integ rity. Responstbl1ity of each location; CED-prepared criteria not required. 4.3 ^S. W.Xlark/c&P Industrial Removal,.Modification,.and/or Hygiene Department Disposai.of Asbestos-Containing TTerry HR arming) Materials. Procedures~already In place at all locations; no further action required. 4.4.1 G. B. Elder (Materials) Use gf_As.bestos-Substitute Gas kets'/Packing. Extended use of GRAFOILTM, spiral-wound with GRAFOILTM or TEFLONTM fillers or reinforced TEFLONTM will cover our needs for now. Internal program of testing other non asbestos substitute gasket materials not needed; will rely on test data developed by Materials Technology Institute (we are member) at no additional cost to CED,. A concern was raised regard ing the control of the use of the aramid-reinforced "nonasbestos" asbestos-substitute materials for gaskets in machinery items (e.g., pumps, compressors, etc.). These materials will not only not pass fire tests but will also perform poorly as gaskets because of their propensity to cold flow. The perception is that the vendors are making these substitutes without our knowledge and consent. 4.4.2 R. H. Engle (V&P Specs) . Two-to-three manTmonths of work Is required to revise and issue valve manual and V&P Specifications. Can accomplish this with In-house staff by original July, 1988, target date; however, will prob ably need technical assistance to meet required September 30, H87, completion date. Approximate additional cost to CED $20,0$. UCC 005976 Meeting Minutes -4- April 6, 1987 Agenda Number Responsibility Duty and Actlon/Agreement 4.4.3 C. C. Neely (COP Specs) Modest additional manpower re quired to revise specs; however, printing/distribution cost of unplanned revision of COP Specs In 1987 not Included in T&S budget. Estimated additional cost to CEO: $8,000. . 5 C. C. Neely Conduct1ng_on-s1te_sem1nars at ma^or 1 ants_not_requlred; Key plant personnel do not need to be "sold" on need to quit using asbestos-containing materials in favor of more costly substitutes. They are fed up to here with even more costly monitoring, record keeping, disposal requirements for asbestos-containing materials, etc.; and hence, are desirous of Jiaving Standard Practice documents available to allow them to cease using these materials prior to the mandated January 1, 1989, cutoff date. 6 G. B. Elder (H. G. Clem) Iden11f1 cat1on_of Asbestos-Free Ins.ul_at1on^ Will prepare Location Practices for Inclusion In Insula tion Manual as appropriate by end of third quarter. Estimated cost to CED: $6,000. 6.1 C. C. Neely Next_Meet1ng^ Unless the need for an earlier meeting is Identified, the next meeting of the Task Group will be held on August 4, 1987, at the South Charleston Technical Center In Room 3505. All members are requested to mark their calendars accordingly. The detailed minutes are attached for those Interested In more complete Information. Respectfully submitted, CCN:at Attachments 43141 C. C. Neely for the Task Group UCC 005977 ONION CARBIDE CORPORATION ENGINEERING, MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY South Charleston, West Virginia BUSINESS CONFIDENTIAL MEMORANDUM March 23, 1987 TO: C. C. Neely COPY: FROM: L. E. Calvert S. W. Clark G. B. Elder R. W. Engle P. R. Kavasmaneck S. S. Murphree J. E. Neff T. E. Hanning ft** 4.$ RECEIVED MAR 2 41987 CCN SUBJECT: Asbestos Implementation Task Group March 17 Meeting Minutes Clyde, The following information is heing forwarded for issue as part of the subject minutes and-cegresents-those items tagged for responsibility by theflndustrial Hygiene contact)on the Asbestos Implementation Task Groups ' " -----------' Also please find attached SH-256, Removal and Handling Asbestos-Containing Materials, which is a Standard Practice of the C&P Safety/Health Technology Manual. Section 2.6 of this standard deals with the EPA regulations for removal and handling of- asbestos materials and has not been updated with respect to recent EPA asbestos proposals. The sections dealing with OSHA regulations have been updated. SH-256 has been volatile and will be revised when needed as part of my responsibility as a member of the Safety/Health Standards Team. Identification of Asbestos-Containing Materials A goal of the asbestos task group is to establish a program so that asbestos will not be purchased after January 1, 1989. A C&P criteria ( guideline document ) for the identification of asbestos-containing materials is needed as part of the overall program. A consensus of C&P Industrial Hygiene Departments will be sought as a basis for the criteria. The criteria will provide recommended techniques and when to use them,.pricing, timing and accuracy of results, and other subjective information. Polarized light or scanning electron microscopy are two identification techniques that can provide fast and accurate confirmation for the presence of asbestos. This assignment will have the following estimated schedule and cost. Schedule: -4Q 1987. Cost: None, cost will be part of normal Safety/Health . Standards Team Work. ' UCC 005978 ~2~ Removal. Modification, and/or Disposal. of_ Asbestos-Containing Materials The need for a protocol to sample asbestos at the new 0.2 fibers per cubic centimeter of air exposure level was discussed. The protocol would be used to establish asbestos exposure data from the storage ( binders may deteriorate and release asbestos ), cutting and changing out of asbestos gaskets and packing. After discussion with Industrial Hygiene representatives, the need to develop a generic test protocol for asbestos exposure is not warranted since the OSHA Asbestos Standard clearly defines the sample taking method that must be used. The Plant Industrial Hygienist is familiar with this method and can quickly outline a technician's Job duties in taking air samples during storage, cutting and changing out of asbestos gaskets and packing. Additionally, the Plant Industrial Hygienist will be able to supply other recent asbestos exposure data from the plant monitoring strategy program, if available and applicable. This action will have the following estimated schedule and cost. Schedule: Sample taking can proceed immediately with the support of the location Industrial Hygiene area. Cost: Hone, resources are outside this task group. Sincerely, Terry a. Hanning 2000/3S28 Unicom 8-721-5903 UCC 005979 TANOARO PRACTICE INTER DIVISION KNOW. AMO HAHOUNG AS6EST0S-CONTAINING INSULATION MATERIAL SK-2S6 PAGE 1 OF 7 QECEMDEft 1966 1 general ,, 1,1 TM* Practice provides. a procedure for the ufe removal and handling of asbestos-containing luulatlon Mterlal and core* tlance with OSHA regulation 29 CFR 1910.1001 and 1920.56 and EPA regulation 40 CFB 01 Subpart M. The purpose of the Practice K to ensure the nitty and health of auplo/ees directly Involved with perforalng the wort and of other*, either In the Immediate area or downwind, who way he expoted to ratiduel dust/fibers, Insulation material containing asbestos Is no longer Installed by UCC; therefore, the concern of this Practice Is to control renovation and demolition operations Involving the removal of old, asbestos-containing Insulation; In these activities OSHA Standard 29 CFR 1926.56 Is applicable, for additional details, review the OSHA Standards. All Insulation materials approved through the Use of UCC Insulation Standards have been specified asbestos-free since 197b. 2 'STANDARDS 2.1 Permissible Exposure Units 2.1.1 Employee 8-hour time-weighted average exposure to etrborne concentrations of asbestos fibers shell not exceed 0.2 fibers, longer then 5 mlcroemters, per cubic centimeter of elr. , 2.1.2 An action level of 0.1 fibers, longer than 6 micrometers, per cubic centimeter of air has been tat which triggers the monitoring, medtcel, and employee Information and training requirement*. 2.2 Wort Practices 2.2.1 lnsofer as practicable, demolition, removal or handling of asbestos-containing Insulation shall he performed while the material frTw r Stffftctently wet etate So prevent amission of airborne fibers exceeding exposure limits prescribed In 2.1.1 end 2.1.2. See Section 2.7.6 for the specific EPA regulations that control wort practices. Wherever feasible, the employer shall establish negative-pressure enclosures before coamenclng removal, demolition, and rennovatlon operations. 2.2.2 Caution signs shall be posted at all approaches to areas which may contain excessive concentrations of airborne asbestos fibers so that an employee may read the signs and take necessary protective steps before entering the area. The signs shill state: DAMttt-ASeeSTOS; CANCER AND lUHG DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS AMU PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA In addition to these signs, legible signs warning of the health hazards of asbestos shell he provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the exposure limits listed In Section 2.1.1. See Section 2.t.4.4 for additional requirements for posting signs. Whenever feasible, e negative pressure enclosure must be established before coauenclng removal, demolition or rennovatlon operation. "Air exhausted Trom the enclosure must pass through e HEP filter (See 25 CFR 1926.58). 2.2.2.1 An appropriate barricade, using caution or barrier tape for exalte, shall be erected around the perimeter of outdoor areas as a supplementary, protective measure to discourage unauthorized entry. UCC 005980 22.5.1.2 TAMOARD PRACTICE SH-250 PAGE 2 OF 7 DECEMBER 1966 INTER DIVISION 2.2.3 Insofar m practicable, rawed Insulation the11 be netted end pieced directly into labeled pleetfc begs (or ether soluble containers) Per disposal at an approved landfill. Otherwise, place plastic sheeting beneath the Job site, nlst spry the moved insulation with water, wended water, or wetting agent and then place In plastic fog** When wet methods of removal/clesnup are Inpractlcal, e.g., when tewpereture* are below freeslng, vacwaring or sweeping way serve as an effective alternate cleanup aethod. Sweeping conpound shall be applied to the work am to prevent dust generation when sweeping. See Sections .7.3.7 and .7.4 for specific work practice requlrwwntt. 4 Label Specifications - conulner caution labels shall be printed In letters of sufficient size and contrast as to be readily visible and legible. Where feasible. Installed asbestos-containing products shall also contain a visible label. The label shall sUte: : DANGER - CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST; CANCER AND LUNG DISEASE HAZARD Where feasible, insUlled asbestos containing products sliould be labeled In accordance with 2.2.4. 2.2.S Peculated Areas * Employers wist Identify as rcguletad areas any locatlons-ln thelr workplaces where there way be occupational exposures to airborne concentrations of asbestos above the PEL. Only authorized persons, with proper respiratory protection, nay enter regulated areas which wist be clearly posted. Eating, drinking, end smoking are prohibited In regulated areas. 2.2.0 Housekeeping - Atl external surfaces In any piece of ewplgywent shall be maintained free of accuwiletlon of asbestos fibers. Spectsl attention should be given to cleaning scaffolds used In demolition work. Clean-up of asbestos dust Is prohibited with coapressed air, dry-sweeping or any dry clean-up process. 2.2.7 Neste Disposal - Asbestos waste, scrap, debris, begs, containers, equipment, and asbestos-contestnated disposable clothing, that Is consigned for disposal end which say produce airborne concentrations of asbestos fibers In excess of permissible exposure Units, shall be collected end disposed of in sealed leak-tight containers to an approved landfill. See Section 2.6.4 for specific disposal requlraents. * 2.3 Personal Protective Eoulpwent 2.3.1 Respiratory Protection - Eaployees engaged In the spraying [wetting-downj of asbestos, the removal; In the demolition of pipes, structures, or equipment covered or Insulated with asbestos; and in the removtl or demolition of asbestos Insulation or coverings shell he provided with resplretoiy equipment based on the elr concentration In Table I and selected from among those approved by the Mine Safety end Health Administration, Department of the Interior, or the Hatlonal Institute of Occupational Safety and Health, Department of Health and Maun Services described In 30 CFR Part II. Compliance with exposure limits prescribed In 2.1, Permissible Exposure Units, shall not be achieved by the use of respirators, except:,. .. 1. During the Interval necessary to Install or leplcment feasible engineering end work practice controls. 2. In work operations such as maintenance end repair activities or other activities which,the c^iloyer establishes that engineering end work practice control procedures ere not feasible, ! 3. In work situations where feasible engineering end work practice controls are not yet sufficient to reduce exposure to or below the PEL, 4. In emergencies. Where respirators ere permittea the cnplqyer shell provide e powered, elr purifying respirator In llau of any negative pressure respirator specified In Table 1 whenever: 22.5.1.2 a. An eaplqyec chooses to use this type of respirator; and b. This respirator wilt provide adequate protection to tbe employee. UCC 005981 STANDARD PRACTICE u INTER DIVISION SH-256 PAGE 3 OF 7 DECEMBER 1M6 *' TABLE 1 RESPIRATORY PROTECTION FOB ASBESTOS. TRENOLITE, ANTHBPHYtLlTE, AMD ACT1NOL1TE FIBERS Airborne Concentration of Subject Materials or Combination of These Materials Required Respirator 1. Not In excess of l f/cc (10 x PEL) 2. Not In excess of 10 f/cc (SO x PEL) 1. Half-mask air-purifying respirator equipped with htgb-efftctency filters. 1. Full facepiece air purifying respirator high-efficiency filters. X Not In excess of 20 f/cc (100 x PEL) 1. Any powered air-purifying respirator quipped with high efficiency filters. 4. Not In excess of 200 f/cc (1000 x PEL) 2. Any supplled-air respirator operated In continuous flow mode. 1. Full facepiece supplied air respirator operated In pressure demand mode. 4, Greater than 200 f/cc (greater than 1,000 x PEL) or unknown concentration) ' 1. Full facepiece supplied air respirator operated In pressure demand mode equipped with en auxiliary positive pressure self-contained breathing apparatus. 2.3.2 Special Clothing - The employer shall provide and require use of special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, end foot coverings for any employee exposed. Contaminated clothing must be stored In closed containers seen as sealed lockers. It should be changed dally. 2.3.3 Hyolene Facilities and Practices - At any fixed place of e^lqyment exposed to concentrations of asbestos fibers In excess of permissible exposure limits, the employer shall provide change roams for employees working regularly at the place. Two separate lockers or containers shall be provided eech employee, so separated or Isolated as to prevent contamination of tne employee's street clothes from Ms work clothes. Employees exposed to asbestos during their work shift must shower before leaving the plant and must not leave wearing contaminated work clothing. Employees working In asbestos areas must have ready access to filtered air lunchrooms and must wash their face end hands prior to eating or smoking. Protective'Clothing eust not be worn in the lunchroom. 2.3.4 Laundering - Laundering of asbestos-contaminated clothing shell be done so es to prevent the release of airborne asbestos fibers In excess of prescribed exposure limits. Those performing laundering of asbestos^ontamlnoted clothing must be Informed of all requlrements listed In Section 2.3, Personal Protective Equipment. Contaminated clothing ahatt be transported in sealed Impermeable containers end labeled in accordance with Section 2.2.4, Label Specifications. If disposable coveralls are used, they should be pieced Into containers wltn asbestos for disposal. ' L I 'L 22.4.1.2 UCC 005982 PACE 4 Of 7 DELEMEA 1966 ' INTER DIVIRION 2.4 Industrie! Hygiene Responsibility ' '' 2.4.1 Monitoring - Employee exposure Monitoring (lull b conducts to determine co^llance itiun with regard to penrtsslble exposure limits end respiratory protection requirements. Envlrowental/Ares monltorlnf Shell be conduct*! along the perlpheqr of the restricted area to assure that fugitive emissions exceeding permissible expsure Units do not extend patt the dentrested area. Sauples shall be collected using 2S ta dimeter nixed cellulose filters and a H m extension cowl. Smples shall be of such frequency and pattern es to represent with reasonable accuracy the levels of exposure of the euplqyees. Monitoring Is required et least every 6 aonths for employees uhose exposures to esbestos Is at or above the action level. Where construction standard 1926.66 Is applicable, dally monitoring is required unless employees use supplied elr respirators In a positive pressure node. Smples oust be analyzed using a phase contrast microscope calibrated using a phese shift test slide and equipped with a Walton-backett graticule. The filter smples must be prepared using ecetone-trlecetln clearing solution and be counted In accordance with the *A" rules contained In the N10SH 7400 method. * 2.5 Training 2.5.1 .P ' All employees who ere exposed to alitorno asbestos concentrations In excess of the exposure limit listed In Section 2.1.2 with or without the use of resol retort shell participate In a training program at the time of or prior to Initial assignment end et least annually afterwards that Includes these Information topics: 1. Health effects associated with esbestos exposure. 2. Relationship between exposure to esbestos and smoking in producing lung cancer. 3. Nature of operations which could result In exposure to asbestos end mecesseiy protective steps to minimize exposure Including, es applicable, engineering controls, wort practices, respirators, housekeeping and protective clothing. . .... . , . 4. Purpose, proper use, fitting instructions, and limitations of the resplrstors used to protect against asbestos fibers. 6. Review of all provisions contained In 29 CFR lSlb.lUUl, Asbestos. . 6. Purpose for and description of the asbestos medical surveillance program. 7. Instructions for handling splits as well as emergency end clean-up procedures. 2.5.2 Training records shsll'be maintained by the location and shall be readily available to all affected employees end to OSHA personnel upon their request. 2.6 Hedlcsl Surveillance 2.6.1 Medical surveillance shll be provided to all employees where exposure, without regard to the use of respirator. Is at or above the action level for 30 or more days per year. 2.7 Federal EPA Regulation. 40 CFR 61. Hazardous Air Pollutants; Subpart H - National Emission Standard for Asbestos 2.7.1 Applicability - These requirements spply to the demolition of structures or .renovation of equipment end piping that Involves removal of Insulation that contains friable asbestos materiels. Friable asbestos material means any material containing more than 1 percent asbestos hy weight that hand pressure can crwhle, pulverize, or reduce to powder when dry. Demolition means the wrecking or taking out of any load-supporting structural menber of a facility together with any related handling operations; on the other hand, renovation means to alter one or more facility components In any way without taking out load-supporting structural members. Planned renovation operations Include scheduled end unscheduled operations In which the 22.6.1.2 UCC 005983 STANDARD PRACTICE INTER DIVISION SH-256 PAGE b OF 7 DECEMBER ,1966 mint of friable asbestos material that will be removed or stripped within a given tlee period can be estimated or predicted bated on operating experience. Adequately wetted weant sufficiently nixed or coated wltb water or an aqueous solution to prevent dust eolations. ^ 2.7.2 Key notification Requirements . 1. Tlolna - The EPA oust be notified with a written notice of Intention to demolish or renovate according to these tlnlng rtqul rements: a. As early as possible before renovation begins If planned, but not necessarily scheduled, renovation operations are predicted to Involve the stripping or rwaovlng of at least 260 linear feet on piping or 160 square feet on other facility components of friable asbestos Materials within a year. b. At least lo'days before a demolition operation that Involves at least 260 linear feet on piping or 160 square feet on other facility components of friable asbestos materials. c. At least 20.days before a demolition operation that Involves less than 260 linear feet on piping or 160 square feet on other facility components of friable asbestos materials (EPA requires further advance notice for these demolitions that are shorter In duration). . d. As early as possible before a structurally unsound facility In danger of Imminent collapse Is demolished under an order of a state or local government agency. 2. Text of Notification letter - A suggested notification letter for the demolition and/or renovation of facilities containing friable asbestos material per requirements of 40 CFR 61, Subpart M. Section 146 (c). Is: Form of Notification NOTICE OF IWTEMT TO DEMOLISH OR RENOVATE STRUCTURES. EQUIPMENT OR PIPING INVOLVING FKIABCE ASBESTOS INSULATION ' .1. Name of Owner 2 Address of Owner Union Carbide Corporation________ (Location Street Address of facility being demolished or renovated). 3. Description of Facility Various buildings, equipment and plplno used In manufacture end distribution of chemicals and plastics and also age, sire end prior use of these facilities. 4. Estimate of Quality of Asbestos Approximate amount of friable asbestos material present In the facility and explanation <rf techniques of estimation If estimate for demolition operation Is less than 160 tguare feet or 260 linear feet. .6 Scheduled Start and Completion Oates .6 Method(s) of Demolttlon/Renovatton . 7. Compliance Procedures .6 Disposal Site How EPA regulations will be followed , Name and location of site where asbestos waste material will be deposited ' Only parts 1 through 4 are necessary for demolition operations Involving less than 260 linear feet or 160 aquare feet of friable asbestos material. The name, title, and authority of the State or local govement representative who oroers the demolition should be added to the notification for demolition of atructurally unsound facilities. Some states. Including Georgia, Hew Tort, North Carolina, and California, also require notification of demolition and/or renovation operations Involving friable asbestos materials. UCC 005984 22.6.1.2 RTANOAflO PRACTICE SH-266 PAGE 6 OF 7 INTER DIVISION 2. 7.3 Key Removal Requirements For planned demolition operation or for the total of scheduled renovation operations In which at least 160 linear feet or 160 square feet of asbestos material Is removed: , # 1. Friable asbestos Materials shall be rimoved before a demolition or renovation operation If the operation wuld likely break up or preclude access to the asbestos Materials for subsequent reMoval unless the asbestos Materials are on a facility coMponent encased In a Material such as concrete or are adequately vetted whenever exposed. 2. if a facility component is covered or coated with asbestos Materials and Is riMoved In sections or units. It shall be carefully lowered, not dropped or thrown, to the ground level and shall have aqy exposed asbestos Materials adequately wetted while cutting or disconnecting. ! 3. Netting Is not required during renovations If the EPA Is requested to conflrh that wetting would unavoidably danege equlpnent. If the EPA confine this, then a local exhaust ventilation and collection systen Must be used to collect asbestos particulates. The exhaust systen Bust exhibit no visible eMlsslons to the outside air or be designed and operated according to 40 CFR 61.164. 4. After sections or units of piping or equipMent with asbestos Materials have been taken out of the facility, the asbestos Materials during stripping shall be adequately wetted-or shall be collected by a ventilation and collection systen as specified In 2.7.3.3. 6. Dust-tight chutes or containers shall be used to lower asbestos Material ranwved or stripped wore than 60 feet above ground level end not removed In units or sections. 6. All friable asbestos Materials that have been removed or stripped shall remain adequately wet until collected for disposal. . .. 7. and 2.7.3.6. possible. If the eMblent tetperiture is below 0*t, then the only wetting requirements are those specified In k.7.3.4 Equipment or piping coated or covered with asbestos materials shall be removed to the maximum extent 6. For demolition of a structurally unsound facility under the order of a State or local government agency, the portion of the facility that contains friable asbestos Materials shall be adequately wetted during the wrecking operation. The wetting requirements specified In 2.7.3.4, 2.7.3.S, 2.7.3.6, and 2.7.3.7 shall also apply to any emergency demolitions. 2.7.4 key Disposal Requirements 1. Visible emissions shell not occur during the collecting, transporting, or disposal of any sbestos*conta1n1ng waste materiel unless the air-cleaning methods specified 1n 40 CFR Pert 61.164 are used to collect asbestos fibers before they escape to the outside elr. 2. The disposal method for collecting end transporting asbestos-containing waste materials shall be approved prior to use by the EPA, unless either of these two EPA-approved methods are used: a. Fora all esbestos-contelnlog waste Material Into nonfrtable pellets or other shapes, or b. Adequately wet and teal while wet In leak-tight containers all asbestos-containing waste Material. The weste containers shall be labeled according to Section 2.2.4. 22.6.1.2 UCC 005985 STANDARD PRACTICE INTER DIVISION SK-fcb6 page 7 up 7 December*isue 3, The disposal site for asbestos-containing waste material shall haw no risible amissions, or the disposed Material shell be covered within k4 hours with at least six Inches of nonasbestos-cosulnlng Material or with an effective resinous or petroleta-based dust suppression agent (waste crankcase oil Is not acceptable.) Alternative Methods for controlling asbestos enisslons Must have EPA approval before being livlenented. ' 4. Either a natural barrier or a fence shall adequately deter (as determined by the EPA upon request and supply of appropriate Information) public access to the waste disposal site. If fenced, then warning signs (20* x In") shall be posted at all entrances and at Intervals no greater than 330 feet along the perineter of the sections of the Site where asbestos-containing material Is deposlteo. The signs shall state: ASBESTOS HASTE DISPOSAL SITE DO NOT CREATE DUST BREATHING ASBESTOS 1$ HAZARDOUS TO YOUR HEALTH .b AUDITS 2.6.1 Lech location shall periodically audit this procedure to ensure understanding and compliance. UCC 005986 kk.b.1.2 UNION CARBIDE CORPORATION ENGINEERING, MANUFACTURING, AND TECHNOLOGY SERVICED JiyiSTHM ^ -- CENTRAL ENGINEERING P. 0. BOX 8361 SOUTH CHARLESTON, WEST VIRGINIA 25303 4*4* a*v4A.| MEMORANDUM 1A BUSINESS CONFIDENTIAL March 23, 1987 TO: FROM: SUBJECT: Mr. C. C. Neely G. B. Elder Input to Minutes, March 17 Meeting on Phase-Out of Asbestos-Containing Materials RECEIVED MAR 2 5 J98; ecu Item 4.2, Replacement of Asbestos-Containing Insulation as Required to Maintain Structural and Functional Integrity. Abestos-contalnlng Insulation becomes a hazard when the weather barrier becomes damaged or other conditions such as powdering of the Insulation allows asbestos particles to become airborne. Corrective action would be removal of the Insulation or sealing the barrier to prevent airborne dust. The Task Group agreed that each location Is responsible for and aware of the problem and that a criteria from the Task Group is not desirable. Item 4.4, Use of Asbestos-Substitute Materials 1. Insulation a. Insulation materials that do not contain asbestos are the only materials currently specified and used, so no action Is required. 2. Gaskets a. Suitable substitutes are available and already accepted In the specifications (Grafoll, Spiral-wound with Teflon or Grafoll, reinforced Teflon). b. Aramld-relnforced "nonasbestos" materials do not pass fire tests and have limited ability to maintain preload. A crash program to test these materials Is not justified and a program currently sponsored by the Materials Technology Institute has promise of providing an Inexpensive way to test such materials In the future. UCC 005987 2- - c. New materials that may be Introduced as asbestos substitutes will be tested as a normal technology activity. 3. Packing a. Grafoll and graphite-fiber packing will be adequate, so no action Is required. 4. Machine Gaskets a. These gaskets are bought as sets for the machines and substitutes are selected by the machine manufacturer. Item 6, Identification of Asbestos-Free Insulation. a. Harold Clem's memorandum (attached) lists Identifiers currently being used In Insulation to show that it does not contain asbestos. b. Harold Clem Is polling the C&P locations to determine If they are currently using Identification tapes, embossed or color-coded metal weather barriers or other methods to Identify Insulation containing asbestos and/or Insulation free of asbestos. Location Practices documenting the Identification codes will be Issued In the Insulation Manual as appropriate. Schedule: Complete poll of Identification codes - May 15. Issue Location Practices - September 30. Budget: $6000. GBE/ds 2006H UCC 005988 BUSINESS CONFIDENTIAL UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM February 13, 1987 TO: G. B. Elder, 511^ CC: D. D. Barnette, 512 R. L. Boggess, 514 J. E. Boley, 380 D. L. Carrick, 519 A. W. Keene, 510 G. H. Reinhart, 312 L. E. Calvert, 511 S. W. Clark, 511 R. W. Engle, 511 T. E. Hanning, 511 D. J. Hymel, 515 R. W. Maddox, 511 D. D. Miller, 512 C. C. Neely, 511 M. Patel, 511 MOC . FROM: H. G. Clem SUBJECT: IDENTIFICATION CODE FOR ASBESTOS-FREE INSULATION RECEIVED .FEB. 19.1987. This report is in response to your letter on asbestos identifica tion concerns with insulation in our plants. Three primary issues, integral asbestos-free visual coding for insulation materials, weather barrier coding, and asbestos identification tests are discussed under separate headings: 1. Integral Non-Asbestos Identification of Calcium ~Silicate Pipe and Block Insulation All of our approved vendors for calcium silicate pipe and block insulation have visual identification dispersed throughout the white product in the form of either gold colored mica flakes or black fibrous material to indicate that the insulation is asbestos-free as shown below: 0037J UCC 005989 0037J 2- - Calcium Silicate Insulation Manufacturer Asbestos-Free Identification Kaylo 10-AF Owens-Corning Fiberglas; Corp Mica Flakes Thermo-12 Manville Corp. Mica Flakes Super Cal temp NA PABCO Black Fibers Manufactuers of expanded perlite. Material Spec. 4, also have asbestos-free visual identification. The current approved material, Goodtemp 1500 from the Howred Corporation, has a uniform pink color throughout the material. Celotemp 1500, a formerly approved insulation that is no longer being manufactured, contained mica flakes like the current calcium silicates. Since apparently only solid white compositions like the early calcium silicates, 85% magnesia, and insulating cements for steam piping and boilers contained significant percentages of asbestos fibers, manufacturers of most other insulation materials have not adopted an asbestos-free coding system. Insulations with distinc tive characteristics or appearance like cellular glass (UCC Spec. 1), polyurethane foam (UCC Spec. 3 and 7), performed fiber glass (UCC Spec. 6), flexible plastic foam (UCC Spec. 12), and mineral wool (UCC Spec. 14 and 40) never contained asbestos. Of course, since the use of mica flakes and other visual coding was not widespread until the mid 1970's, most insulation in older units may require laboratory testing for possible asbestos content before replacement or modification. 2. Asbestos-Free Visual Indicator for Metallic and Mastic Weather Barriers You asked for a durable visual indicator for metallic and mastic weather barriers to indicate that the insulation underneath did not contain asbestos. I have found that several methods are being used in the petrochemical industry, but there is no universal standard on this important subject. A summary of asbestos-free identification methods related to weather barriers is listed below: Surface Texture Variations: Reportedly, Tennessee Eastman, Eastman Kodak, and Amoco have adopted the use of a "stucco embossed" texture finish In either flat or 3/16" corrugated configuration for aluminum or stain less steel weather barriers on all Insulation replacement projects. This method provides a distinctive visual coding that contrasts with the older smooth finish metal weather barrier sheet material. UCC 005990 -3 - 0037J Surface Texture Variations - Cont. Only minor changes are required in installation procedures with this approach, and planned or inadvertent painting of the weather barrier will not affect the visual identifica tion characteristics. The method is not applicable to mastics or plastic weather barriers, however. Color Coding: This procedure involves the use of factory finished weather barrier in a specific color to indicate that the insulation is asbestos-free. The colors most used for this purpose are white, green and blue. To be effective, this method would require coordination with existing UCC safety color coding in the plants. Identification Tapes: This method utilizes making tapes applied over standard weather barrier materials to indicate that the insula tion either contains asbestos or is asbestos-free. E.I. DuPont de Nemours 4 Co. (Inc.) uses this method. A copy of the DuPont specification entitled "Identifi cation for Installed Asbestos-Bearing Insulation" is attached for reference. This type of identification tape is available from several suppliers. The DuPont tape features fade proof ink lettering and background with a clear polypropylene coating for chemical resistance and durability. The asbestos code lettering is combined with arrows to show the direction in which the indi cated insulation runs. The primary advantage of identification tapes is that any type of weather barrier may be marked whether new or exist ing. Entire sections of plant units can be defined as asbestos-free wtth this technique. The main disadvantage of tapes is that they may be inadvertently painted over or removed during routine maintenance activities. Various versions of asbestos-free identification tapes are available from graphics label suppliers. In most cases, pressure sensitive vinyl Is used for the tape material. Unlike the DuPont specification tape, the "ASBESTOS FREE INSULATION" labels and direction arrow tape are usually separate items, not combined. The blue background/white lettering is the same in most Instances. UCC 005991 -4 - 3. Asbestos Identification Methods The identification and monitoring of asbestos fibers from insulation or other sources is the responsibility of UCC Industrial Hygiene Groups at our various locations. According to Mr. Manhel Patel at the Tech Center, several test methods are available to identify asbestos including colorametric test kits, microscopic examination with polarized light, scanning electron microscopy and trans mission electron microscopy. However, the colorametric technique is not as reliable as the microscopic methods because it only detects iron and magnesium from bulk samples; interference from related compounds can affect test results. The microscopic methods are approved by OSHA, EPA and NIOSH and represent the best current procedures available. It is apparent that devising a better way to identify asbestos that meets government approval will be difficult. If quicker results are needed at our plants on insulation replacement jobs, consideration should be given to pre sampling the existing insulation well ahead of any planned work. Conclusions and Recommendations The visual asbestos-free coding methods of our calcium silicate and expanded perlite suppliers, ie mica flakes, black fibers, etc., will be included in our UCC Material Specifications 2 and 4 as suggested by Don Miller of the Institute Plant. This may provide some valuable assist ance in the field identification of insulation materials. Concerning the visual asbestos-free coding of weather barriers, it appears that no single identification procedure may be suitable for all conditions in our plants and other facilities such as laboratory buildings. One of the main problems is the diverse types of weather barriers encountered; aluminum, stainless steel, PVC, fiberglass laminate sheet, and mastics. Some differences are also evident in our options when we are replacing asbestos containing insulation versus simply labeling or marking a "good" existing asbestos-free system. Current asbestos and asbestos-free insulation coding procedures at UCC locations range from no identification marking to marking all asbestos containing Insulation with labeling tape and entering a code for asbestos replacement jobs In the computerized work orders for storage and retrieval. Before we introduce a UCC recommended practice or standard on weather barrier 0037J UCC 005992 -5- identification coding, a poll or request for comments should be solicited from plant Insulation representatives and other responsible parties. To assist in the proposed poll, actual samples of identification tapes and embossed metal weather barrier would also be sent to each respondent. If there are further questions or comments, please call me. HGC:es ATTACHMENT 18495 INDEX: 6, 7, 10, 23, 28, 30, 32 42, 43, 44, 44A, 62, 71, 81 112, 120, 121, 122, 127, 138 142, 180, 307, 318, 351 0037J H. G. Clem UCC 005993 22S IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION THERMAL INSULATION STANDARD ENGINEERING SPECIFICATION ISSUED THIS PAGE REVISED STANDARD REAFFIRMED JULY 1975 APRIL 1984 APRIL 1984 Page 1 of 2 1. SCOPE 1.1 This specification provides information for a stan dardized method of placing identification on installed insulation which contains free asbestos fibers or insu lation ofunknown asbestos content. 1.2 This specification is applicable only for identi fying installed insulation which has a questionable free asbestos fiber content. Obviously, materials such as cel lular glass, glass fiber, mineral wool, polyurethane foam, and polystyrene foam do not contain asbestos fibers and, therefore, do not need to be marked for identification. 1.3 Follow this specification only at locations where such identification is required by the operating de partment and the plant does not have a conflicting estab lished identification procedure. 2. CONDITIONS installed, do not require identification. At turnover, the local construction organization is to notify the plant that the facility is free of materials containing free asbestos fibers. 4.2 , Condition ll. Individual insulated lines or equip ment pieces in clearly defined additions in which no insulation containing free asbestos fibers was installed, do not require identification. In lieu of marking individ ual lines or equipment pieces, place strips of tape strate gically along the plane that defines the building addition. Locate the tape on selected columns, beams, walls, or ceilings, to clearly identify the plane at which the asbestos-free insulation starts. Apply two parallel strips of tape. Position one piece of tape with the arrows orientated to indicate that, from that point on, all insu lation is nonasbestos. Position a second piece of tape with the arrows orientated to indicate that, from that point back, the insulation may contain free asbestos fibers. - 2.1 From an installed insulation viewpoint, specific areas on a site are classified as follows; 2.1.1 Condition I. New facilities on which no in sulation containing free asbestos fibers was installed. This could be an entire site or a segregated building on a site. 2.1.2 Condition II. New additions to existing buildings which can be clearly defined by designated column lines or a defined plane through the building. The addition does not contain any insulation containing free asbestos fibers. 2.1.3 Condition III. Existing areas which are modified by the addition of insulated lines or equipment. 4.3 Condition III. Individually mark all new insulated lines and equipment pieces installed as additions or modifications in existing areas to indicate insulation as bestos content. Where asbestos-free insulation is in stalled on a pipeline, place a strip of tape around the circumference of the finish at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a tie-in is made to a line insulated with a material of unknown asbestos content, identify the junction of the insulation by parallel pieces of tape around the circumference of the finish. Position one piece^.ofiape-to indicate that, from that point on, the insulation is asbestos-free. Place a second piece of tape with the arrows orientated to indicate that, from that point on, the insulation may contain free asbestos fibers. 2.1.4 Condition IV. Existing areas in which exist 4.4 Condition IV. Where insulation is being replaced ing insulation is being replaced. in an area of unknown asbestos content, by asbestos-free 3. TYPE OF IDENTIFICATION insulation, identify the replacement insulation by a strip of tape placed around the circumference of the pipe For identification, place strategically located strips of appropriately marked tape around the circumference of the pipe finish or on the equipment finish. Position the tape so as to indicate the type of insulation used with the arrows pointing down the line in the direction in which the indicated insulation runs (see Figure 1}. finish or at strategic locations on equipment pieces. Where a line running from wall-to-wall is reinsulated, place a piece of tape at the points where the pipe goes through a wall or partition. Orient the arrows to indicate that the line inside the room has asbestos-free insulation. Where a portion of the insulation is replaced, identify the junction of the existing and replacement insulation 4. PLACEMENT OF IDENTIFICATION - by parallel pieces of tape around the circumference of WHEN REQUIRED the finish. Place one piece of tape to indicate that, from that point on, the insulation is asbestos-free. Place a 4.1 Condition I. Individual insulated lines or equip second piece of tape with the arrows orientated to indi ment pieces in new facilities or segregated buildings in cate that, from that point on, the insulation may contain which no insulation containing free asbestos was free asbestos fibers. UCC 005994 SUBCOMMITTEE HO. SS 1 r SN 218 P Pago 2 IDENTIFICATION FOR INSTALLED ASBESTOS-BEARING INSULATION ' . 1( This Page Rev April 1984 226 -- 5. HANDLING INSULATION " When handling, fabricating, or removing insu lation in the absence of positive knowledge that it is asbestos-free, assume that it contains free asbestos fibers, and follow S4T. 6. TAPE 6.1 Specifications (see Figure 1) a. Supplied in rolls. . b. Pressure-sensitive contact cement backing -- developed for aircraft use. C. M -90 tape material -- developed for aircraft use. d. Provide slit in release paper for easy removal. a. ASB letters and arrow red, repeated on 3-inch intervals, on white background. NA letters and arrow blue, repeated on 3-inch intervals, on white background. Letters are approximately 1-inch high. 7. TAPE SUPPUERS (PARTIAL LIST) Davis Printing Co P. O. Box 6% , Camden, SC 29029 (803)432-1901 Top Flight Corp 165 East 9th Avenue York, PA 17404 (717) 843 - 9901 . T & B Westline Division of Thomas & Betts Corp 220 South Rose Street Los Angeles, CA 90012 (800)421-8618 Sheriden Safety Supply 7029 Huntley Road Suite E Columbus, OH 43229 (614)888 - 8040 York Tape and Label Corp P. O. Box 6805 ' Columbia, SC 29260 ' (803)788 - 2635 Top* Ltjeni: ASB Asbestos Bearing NA 1 Nonasbestos Bearing . FIGURE l - TAPE FOR IDENTIFICATION UCC 005995 PIPING TECHNOLOGY MINUTES FOR INCLUSION IN ASBESTOS TASK FORCE GENERAL MEETING MINUTES Addressing Section 4.4.2 of the agenda listed in C. C. Neely letter dated 3/2/87 ... R. W. Engle presented proposed plans far modifying the Valve and Piping Specifications using strictly GRAFOIL,r products as the only replacement for asbestos. First step would entail developing new UCC "V-numbers" for those valves which are currently listed with asbestos packing and/or bonnet gaskets and no GRAFOILtn alternate. Piping Technology will maintain the old numbers unique to aid in identification of existing valves. Once the new numbers are developed, they will be transferred to the affected piping specification sheets. Secondly, as with the valves, the existing specification names will be maintained unique by cancelling the existing suffix letters and starting with the next available letter e.g., 1C2 though 1C2E will be listed as "cancelled" and the new listing will be started at "1C2F". The acceptable linerfiasket alternate for the asbestos ring will be the 1/16" thick GRAFOILtri GHE and the acceptable replacement filler for spiralwound gaskets will be GRAFOIL n Grade GTB. . The proposed schedule would target July 1988 for completion of issues to the manual; the proposed asbestos program would not be reviewed through normal Technology Manuals Standards (TMS) channels due to the .nature of the changes. Piping Technology believes there to be 2-3 man- months ( $5000.00/man-month) of work involved in the transition. Approximate printing/distribution cost would run in the $5000.00 range. An accelerated schedule may become necessary if vendors confirm earlier reports of supply problems and would definitely extend the estimated time into 3 man-months because additional technical manpower would be required. Sherry Murphree will continue to feedback on market conditions. ' R. M: Engle/pae March 24, 1987 AJ4-.RNE UCC 005996 WANG TO: C. C. NEELY - Location 511 *) dcjbdt 4.4 From: S. S. Murphree - Loc. 515 Secretary - Anita Thaxton - 721-4802 Purchase of Asbestos - Substitute Material The Chemicals and Plastics Division agreements for gasket and packing materials are due for renegotiation in second quarter 1987. The procurement plan and request for quotes have been issued. Bids are now being received and new agreements are expected by June 1, 1987. The traditional method of predicting quantities, material types, and dollars for price agreements Is past history and anticipated future activity. Our past history of gasket and packing usage shows a heavy dependance on asbestos at very low* prices. We are already seeing a changeover to the Grafoil and teflon based material. The new agreements will be based on anticipated increased usage of these materials and dramatic decreases in asbestos use. Our expenditures will increase due to higher priced asbestos replacements, higher priced asbestos, and increased activity of a wide variety of materials. Many of our traditional gasket and packing manufacturers are no longer in the asbestos business (Johns-Manvi1le, John Crane, Allpax, etc.). The manufacturers who currently handle asbestos do not have assurance from their liability carriers that coverage will continue beyond the next twelve months. Parker Seals has announced July, 1987 as their cutoff date for asbestos manufacture. We have no certainty that asbestos will be available thru January, 1989. From the purchasing viewpoint new standards for gasket and packing should be expedited to the nearest feasible deadline. After new gasket and packing standards are determined a tremendous effort will be required in the plant storerooms, purchasing groups, and maintenance departments. The effort will be three-fold: 1. Alternates to stocked and purchased material will be determined for each application. 2. New descriptions and usages will be determined and changes made. Major C & P locations have 2000 to 3000 separate line items. A plan for changeover from old to new material will be required. 3. Training and communications will be needed for every end user. It is estimated that the effort for maintenance and materials management will require four to six months of work at each location. Sherry S. Murphree 3/30/87 RECEIVED tflftR 3 01987 CCN UCC 005997