Document YDjpZ3Bq8mQpDk39QXYaqOODO

~V Ccnments on "Operations Procedure for Asbestos Removal* ATfeT Bell Laboratories aaie May 10/ 1984 from C. P. Lichtenwalner MB 77621 1F-110 X5399 H. R. Fitch: With regard to your April 3* 1984, Maaorandun for Record an "Operations Procedure far Asbestos Removal" we have noted sev eral areas that were not addressed that we feel are essential to assure employee health and oorplianoR with regulatory require ments. 1. Protective clothing should be worn to prevent contamination of personal clothing and dispersion of asbestos-containing debris throughout the build ing and to the hones of the enployees. 2. All respirators used must have NICfiHABHR approval for asbestos-containing dusts. 3. Any wastes containing asbestos mist be sealed in ispenneahle containers, appropriately labelled, and disposed of in an approved landfill. Waste manifests and landfill receipts must be retained to verity carpiiance with EPA regulations. 4. Procedures should specify removal of respirators as final step of work operations. 5. Meticulous clean-up of any work area is required to prevent dispersion of asbestos. We reconmend covering work area with disposable plastic drop cloths (to be removed as asbestos contaminated waste) and subsequent vacuuning of area with a HEPA filter equipped vacuum cleaner restricted in use for asbestos operations. 6. An adwstM program manager should be appointed to oversee all asbestos jobs including pre-survey and post-survey checkout of all work. 7. Occupants and all other personnel not wearing respirators and protective clothing must be restricted frcm areas while work is proceeding. PLAINTIFF'S EXHIBIT ATT-269 Lift 001531 H. R. Fitch - 2 If work is being performed in an area used as part of the supply or return air, the fans should be shut down, the area sealed, or the work performed cwt-of-hours during minimal occupancy of the building. 9. Representative work operations should be monitored to assess exposure levels. 10. All individuals performing work requiring disturbance of asbestos-containing materials must be trained in: a. proper removal procedures, b. proper use of respirators, and c. hazards of asbestos. 11. Any work involving removal of more than 260 lineal feet of pipe or more than 160 ft2 of surface area requires notification of EPA (and probably other regulatory agen cies. ) You may want to consider the attached "Procedures for Work Requiring Handling or Disruption of Asbestos-Containing Materials" which has been developed as a guideline for work operations with slight or minimal disruption of asbestos-containing material. If you need any further information please let us know. Sincerely, ) P. A. Huggins r< u MB-77621-CPL-jve C. P. Licfctasalner Copy to: W. W. Crawford D. Rainer W. j. Schxeibeis G. M. Wilkening A<r//VW LLA 001532