Document XReO0e3DwD1m3wRE37zGLzMEx

FILE NAME: Mead (MEAD) DATE: 1974 Feb 12 DOC#: MEAD019 DOCUMENT DESCRIPTION: Memo with EPA and OSHA Regulations CEMENT ASBESTOS PRODUCTS COMPANY Ragland* Alabama j. R. Carpenter , February 12* 1974 FROM* Bob. Baker SUBJECTS Ragland Plant Status - EPA and GSHA Regulations Specific SPA Regulations Applying to the Ragland Plant X. Air A, In the Federal Register Volume 38 Number 66* Title 40* Part 61 National Emission Standards for Hazardous Air Pollutants* paragraph 61.22c states that there shall be . no visible emissions to the outside air and in paragraph 61,23 states the requirements of air cleaning equipment., SPA also requires approval Of future construction and modifications of our'dust system. , , " B, At present*-the Ragland Plant- is. in violation of' ' the EPA requirements since there is "no provisions of collecting the dust when a . ,fche .plantases an open dump which 'allows-asbestos -vaste' to 'become "ai-rborne. In order to comply with the regulations, the Ragland Plant will either have to recycle the dust collector waste or contain it in an impermeable container.-and practice sanitary land fill procedures at the dump. . > , II, Solid Waste A,- .-At-present ;the -EPA has -"-not .'promulgated a specific regulation-on asbestos-solid-waste*-.but-.rel-ies-.on -the -.OSHA regulation that any asbestos waste be collected and disposed of in sealed impermeable Containers, '.It appears immanent that future EPA regulations will require asbestos-waste to , be treated as sanitary landfill* that, is* spreading the waste in thin layers, compacting the waste and applying cover material at the end of each operating' day. ' B, Should the sanitary landfill regulation be promulgated the. Ragland operation would, either have to buy a bulldozer or employ an outside contractor to accomplish the work. At present* we are in violation of the EPA regulations since we do hot seal our waste in.impermeable*-containers. . ` ' Mc.uk/aBHBjavsamMaa MEAB/HEJDERSON00324 2 III. hiquid .Waste * . A. It has been proposed .that regulations require 95% ' removal of significant wastewater pollutant 'by July 1, 1977 and no discharge by July 1, 1983 B. At present the liquid waste 'from the Ragland Plant is about 100 gpm. The Ragland Plant now employs two settling basins and discharges, 'the effluent into a small creek which flows into .the Coosa River. In order to comply with the SPA regulation, the Ragland plant plans to add a.'pump below .the basins and discharge 'into a holding lake. The holding ,lake water will then be used as make up water for the plant. Specific OSHA Regulations on Asbestos 'in which the Ragland Plant is not in compliance. I. OSHA Regulations A. - OSHA requires the permissible exposure to airborne asbestos fiber to be, an 8 hour time weighted-average airborne , concentration riot to'exceed 5 -fibers, longer than `5 micrometers, per cubic'centimeter of -air with a ceiling of 10.fibers. B. Effective J u l y '1, 1976, the permissible timeweighted exposure shall not exceed 2. fibers longer"than ,5'micrometer's, per cubic centimeter of-air. A ceiling-con centration of 10 fibers is not to be exceeded at any time, C. Ail power tools', such as grinders at finish line, lathee, are to have local exhaust ventilation. * : . > * . . D, B a g s -re--not to-be -opened'-without being.,ventilated. ' E; Special.,clothing is to be provided when employee is exposed to concentrations above the ceiling limits* * F. Change'rooms are to be provided .for employees exposed to ceiling limits, 5. Two separate lockers are to b e provided in order to 'separate work clothes from.street clothes. > MEAD/HENDERSON00325 3 E. Caution signs and labels are to be posted in areas where airborne concentrations are in excess of exposure limits. Caution labels are to be affixed to waste containing asbestos, F. Asbestos is to be disposed of in impermeable con tainers, Q. -External surfaces are to be free of accumulation of fiber. The following is an area estimate of what is needed to be in compliance with the OSBA asbestos regulations, 2, Fiber Warehouse A, A clean up vacuum cleaner system is needed to clean up asbestos spills. B, A new fiber"charging system needs to be designed so the bags will be opened under a negative pressure and have a 'means of placing the opened bags into a sealed impermeable container for disposal. . C, The reclaim dust collector needs some rework, "D, She kollargahg dust collector needs to be tied into the reclaim system. . * S." The crusher system, has a number of leaks that needs repair. ' . ,22. .Batch Area A. .The kallargang needs to-be under a negative pressure and doors will be required on the kollargahg hopper. B. The fiber silo turntable needs to be enclosed and placed under a negative pressure. C. The fiber conveyor needs to be enclosed, and placed Under a negative pressure. ..... D. The area needs a vacuum, cleaner for clean upl S \The d o p i n g into' the pulper will, require some vredesign and .a*dust -collection sys tem. MEAD/HENERSON<)0326 4 III. Pipe Machine Ko asbestos dust problems. IV.' Coupling Lathes and Coupling Cut-off ' * A. Since the coupling lathes and the coupling cut-off use wet material a separate dust collector should be employed apart from the other dry lathes,. B. A means of picking"up shaving should b e designed and avoid letting asbestos waste hit the floor. V. Finishing Line A. H e w hoods and hoppers need to be designed. B. One or two new dust collectors should be purchased with capacity to handle both finishing lines. C A vacuum cleaner for clean up will be required. VI. Dry-Lathes A. Ne w pick up points need to be `designed. S* Exhaust piping should be tied into the finishing line dust collector and recycled. tj C. A vacuum cleaner for clean up will be required. VII. Cut-off Saw . - 7 A. A new cut-off saw needs to be designed using a wet system. " jtfX&X? .-'-Special- change-.rooms' ned\-.to.-be:-iprovided.for--mpl6yees when .'tbdy * -exposed .to-sddncentr-atibns -ib'vxde-s's .of-pfmi-ssible limits. IX. Employees are to be provided with two separate lockers to prevent contamination of the employee's street clothes from-his work clothes,- . Miscellaneous Violations. I. The Ragland Plant has a number of violations with- respect -to,;Subpart D walking-working -surfaces. .The Maintenance - Department i . correcting -violations -as time-permits - , 5 II. The office-and shop needs emergency battery operated lighting system. Ill, The Ragland Plant needs to purchase a noise level meter and correct areas of high noise levels. IV. Traffic "lanes need to he marked throughout the plant. V. Some of the machine guarding is in violation of the regulation and is being reworked by maintenance as time permits, VI, There are a number of violations of; the national Electric Code and a complete study of the plant's electrical system needs to be done, . IVIEAD/HENDERSONC0327 %