Document YGMkkjgJdv0zdJjo5Y9vjmEk
IMEItNAL CORUESPOi\OE.\CE
JNION CARBIDE CORPORATION
CHEMICALS AND PLASTICS
P. 0. BOX 3370, BROWNSVILLE, TEXAS 78520
To<Nm.l K- G. Townsend Company
Brownsville Plant
Location
Copy to
Dte December 18, 1979
Originating Dept.
Answering letter date
Subject
EP:Technician Work Schedule
Shown on the attached yearly, schedule sheets are the cyclic duties of the EP Technician. Other typic&l*routine duties are supervising collection of EP and NPDES samples, collecting special samples, over seeing operation of process sewer.system, drum cleaning station and managing evaporation ponds-and"solid waste disposal.
The EP Technician is responsible for preparing trip tickets for special shipments (such as asbestos) add assuring that- correct procedures ..are followed.
JRB:mfw Attachment
tHeddy Butler
<* '
DE 004884
EP AUDITS SCHEDULE
EP SURVEYS AND MISCELLANEOUS
ASSIGNMENT
WORK ASSIGNMENTS FOR EP TECHNICIAN
ASSIGNED COMPLETION
DATE
DATE
Wav -
DE 004888
WORK ASSIGNMENTS FOR EP TECHNICIAN
MANUALS TO BE KEPT EVERGREEN
EP Procedure manual Waste Water Treatment Manual Drum Cleaning Procedure Manual Texas Air Control Board regulations manual RCRA regulations manual
'OIC GOVERNMENT REPORTS
reports to EPA and TDWR .industrial Solid Waste Summary to TDWR Trip Ticket summary to TDWR PCB report (kept on file)
Monthly Annual Monthly Annual
DE 004889
DE 004890
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SUBJECT: AIR POLLUTION CONTROL A:.7) REPORTING PROCEDURE
1/29
I. PURPOSE: To establish guidelines for reporting and controlling emissions of smoke,
hydrocarbons, and chemical vapors in significant amounts. NOTE: Steam is not-considered an emission and is not addressed in this
procedure.
II. DEFINITIONS: . V1
fceportable emissions are defined as discharges of significant amounts of
smoke or organic vapors or hazardous chemicals. This includes leaks, venting,
ruptures, overflows or misdirected flows and stack emissions.
Guidelines as to significant amounts:
1. Visible emissions (smoke, white or black) from any stationary flues
exceeding an opacity of 201 averaged over a 5-minute period.
2. Any visible emission (except steam) from a waste gas flare for more *R_
than five minutes in any 2-hour period.
3. Abnormal venting of hydrocarbons of 100 pounds or more in 24 hours.
4. Hazards of chemical emissions include, but are not limited to:
fire, explosion,.personnel injury or health and air pollution.
III. NOTIFICATION REQUIREMENTS A. Major Upsets The Texas Air Control Board shall be notified by standard TACB form as soon as possible of any major upset condition which causes or may cause an excessive emission to the atmosphere. The S.1I.A.R.E. Department Head will be responsible for submitting this. form.
Vr-' r --------- -- -
.1 00.01
DE 004891
SUBJECT: AIR POLLUTION CONTROL AND REPORTING PROCEDURE (Cont'd) III. NOTIFICATION REQUIREMENTS (Cont'd)
B. Maintenance The Texas Air Control Board shall be notified in writing, by the
S.H.A.R.E. Department, at least 10 days prior to any planned mainte nance, startup, or shutdown which will or may cause an excessive emission. If.10 days notice cannot be given due to an unplanned . occurrence, notice will be given by the S.H.A.R.E. Department as soon as practical prior to the occurrence. C. Fire Pit Training
When fire pit training is planned that will result in visible smoke, the Fire Protection anil Equipment Safety Specialist will notify the S.H.A.R.E. Department at least 10 days in advance of the occurrence when possible. The S.H.A.R.E. Department will notify the Texas Air Control Board and the local U.S. Coast Guard Station.
IV. RESPONSIBILITY FOR CONTROL A. Each department shall establish a written set of emission control and cleanup instructions for its products and processes. B. Each supervisor shall instruct all personnel under his direction in the handling of emissions and require that every incident be reported and documented.
V. EMERGENCY ACTION
A. In the case of unanticipated visible, hydrocarbon, or hazardous material
emissions the employee's initial responsibility is to protect the personn
andequipment involved and then take appropriate action to control the
emission, spill and hazards per departmental instructions, then report,
the incident.
1.00.02
DE 004892
// /o
SUBJECT: AIR POLLUTION CONTROL AND REPORTING PROCEDURE (Cont'd)
VI. IN-PLANT REPORTING A. When the extent of an emission exceeds the allowable limit an excessive emission report form will be prepared and distributed to the S.K.A.R.E. Department and the Department Head of the unit concerned,-within the same 24 hours period. In addition, if the emission occurs during a normal work day (8:00 A>M.. ~ 4:30 P.M.)
/
' a verbal report will be given to the S.H.A.R.E. Department. The Shift Coordinator/Supervisor is responsible for the reports.
B. The S.H.AI^.E. Department Head or K. G. Townsend will prepare and mail the standard TA.CB report form to TACB at Harlingen after . review with the Operating Department Head. If necessary, due to the magnitude of the emission and after conferring with the Managers' Department, the TACB at Harlingen may be notified of the emission by phone.
C. A report form will be sent to the S.H.A.R.E. Department at least 15 days prior to any planned maintenance, s.tartup or shutdown which will or may cause an excessive emission. If 15-days notice cannot be given, notice shall be as soon as practical. The operating department is responsible for this report.
1.00.03
> 004893
EXCESSIVE EMISSION REPORT
7/78
This, report is to be filled out by the Shift Coordinator/Supervisor in the event of any excessive emission to the air due to unit upsets, startup or shutdown, or required maintenance, whether planned or unplanned. The original of the report should be kept at the Shift Coordinator office. One carbon copy to be sent to the S.H.A.R.E. Department and one carbon- copy to the concerned operating department.
WHAT SHOULD BE REPORTED?
Visible emissions (smoke, etc.) from any flue, stack or flare that continues for a duration of five minutes or more. This includes a source which has a visible emission intermittently over any two-hour period for a cumulative time of five minutes or more.
Hydrocarbons .venting from any process system column, still, etc., due to any of the above-mentioned reasons and emitting 100 pounds or more in any 24-hour period.
Time and date occurred: '
Unit and source of emission: ._____________________________________________________ ___________
What was emitted: _____________________________ .
f
Duration of emission:
______ .____________________________
Amount emitted: ___________;__________________________ ~ _______________
Reason or cause; Maintenance [
{
Malfunction 1
I
Nature of problem: _____________________________________________ ;_______________
Emission or anticipated emissions: Physical and Chemical composition.
Rate and Concentration ________
__________
Measures (to be) taken to minimize quantity and duration of emissions:
l (V
Measures (to be) taken to prevent recurrence: -__________ _____________________________________________
DATE
SIGNED
Form $526-354
1.00.04
PE 004894
r
SUBJECT: AIR POLLUTION EPISODE PLAN
V ^v
I. PURPOSE
To provide a uniform and effective Air Emission Episode plan for the Brownsville plant.
DISCUSSION: The Texas Air Control Board requires that any owners or operators of a stationary source emitting 100 tons or more per year of certain air contaminants shall have an emission reduction plan . This plan will be initiated if an Air Pollution Episode is declared for one or more air. rcontaminants and applies to the geographical area of the Brownsville plant. The Texas Air Control Board may declare an emergency if atmospheric conditions due to air contaminants reach a level which creates an emergency requiring immediate action to protect human health or safety. The air contaminante controlled by this regulation and relating to the Brownsville plant are Nitrogen Dioxide emitted from the boilers (1 thru 4) and carbon monoxide emitted from Reaction 1 and Reaction 2 via the exhausting column and partial condenser vents.
The Texas Air Control Board has classified Air Pollution Episodes into two categories. Level 1 and Level 2. The Brownsville Plan outlines action to be taken should the Texas Air Control Board,..with the con currence of the Governor, declare an Air Pollution Episode exists.
II. POLICY
NITROGEN DIOXIDE LEVEL I
Action to be taken if an Air pollution Episode Level 1 is declared for Nitrogen Dioxide
The Energy System Department Head will:
1. Determine the existing emissions of nitrogen dioxide from the boilers and report this information to the SHARE Department Head.
2. Inmediately identify and implement all reasonable available methods to reduce the emissions of nitrogen dioxide from the boilers and report action taken and emission reductions obtained to the SHARE Department Head.
3. Prepare to shut down boilers in anticipation that a Level 2 Episode be declared for nitrogen dioxide.
NITROGEN DIOXIDE LEVEL 2
, Action to be taken if an Air Pollution-Episode Level 2 is declared for Nitrogen Dioxide.
1.05.01
DE 004895
SUBJECT: AIR POLLUTION EPISODE PLAN
2 -78
II. POLICY (CON'T)
NITROGEN DIOXIDE LEVEL 2 (CON'T)
The Department Head of Energy System will prepare to shut down one or more boilers if the Exectutive Director, T.A.C.B. orders these boiler sources to curtail or ceasq operations. Close coordination and communication between Plant Management, Energy System and SHARE Department will be required during all Air Pollution Eposides.
CARBON MONOXIDE LEVEL I
Action 'to be taken if an Air Pollution Episode Level I is declared for Carbon Monoxide.
The Department Head of the Reaction Unit will:
1. Determine the existing emissions of carbon monoxide from the reaction units and report this information to the SHARE Department Head.
2. Immediately identify and implement all reasonable and available methods to reduce the emission of carbon monoxide from the Reaction units and report action taken and emission reductions obtained to ' the SHARE Department Head.
3. Prepare to shutdown one or both of the Reaction Units in anticipation that a level 2 episode be declared for carbon monoxide.
CARBON MONOXIDE LEVEL 2
Action to be taken if an Air Pollution Eposide Level 2 is declared for Carbon Monoxide.
The Department Head of the Reaction Department will prepare to shutdown one or both of the Reaction Units if the Executive director TACB orders the Reaction emission sources (exhausting column vents) to curtail or cease operations. Close coordination between Plant Management, Reaction Department personnel and the .SHARE Department must be required during all Air Pollution Eposides.
The SHARE Department will coordinate all communication between the Texas Air Control Board personnel and Plant Management. In case of an Air Pollution Episode notification after hours or on a weekend or holiday the SHARE Depart ment Head will be notified at once by the Shift Coordinator.
NOTE: A.
Level 1 and Level 2 values are controlled by The Texas Air Control Board.
B. Boilers #5 and #6 are excluded as a result of low emission capability.
Reference:
Texas Air Control Board, "Regulation VIII, Control of Air
Pollution Episodes", March 5, 1975.
i fv r
DE 004896
UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS
P..O. BOX 3370, BROWNSVILLE. TEXAS 78570
September 7, 1979
Re: Demolition - Asbestos
Mr. Cecil Bradford Texas Air Control Board 8520^Shoal Creek Blvd. Austin, IX 78758
Dear Mr. Bradford:
The attached notification relative to the demolition of facilities containing friable insulation is provided per requirement of 40 CFR 61, Subpart B, Section 61.22 (d).
Please contact the writer if there are any questions concerning information contained in the notification.
Very truly yours.
KGT:mfw Attachment
K. Gran Townsend
CC: Mr. Robert J. Guzman Texas Air Control Board Matz Bldgl,' 511-1/2 E. Jackson Harlingen, TS. 78550
DE 004897
UNION CARBIDE COoRrPpOoRrAation CHEMICALS AND PLASTICS
P. O. BOX 3370, BBOWNSVILLE. TEXAS 73S20
September 7, 1979
Re: Demolition - Asbestos
Mr. Cecil Bradford Texas Air Control Board 8520 Shoal Creek Blvd. Austin, TX 78758
Dear Mr. Bradford:
The attached notification,relative to the demolition of facilities containing friable insulation, is provided per requirement of 40 CFR 61, Subpart B, Section 61.22 (d).
Please contact the writer if there are any questions concerning information contained in the notification.
Very truly yours
KGTrmfw Attachment
K. Gran Townsend
CC: Mr. Robert J. Guzman Texas Air Control Board Matz Bld$;, 511-1/2 E. Jackson Harlingen, TX 78550
BCC: Heddy Butler J. D. Dockins R. C. Glock R. E. Theisen L. T. Windel
pE 004898
Form of Notification [See also Attachment 1 - 61.22]
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner _______ Union Carbide Corporation
(2) Address of Owner
(Location Street Address)
(3) Description of Facility _________Various buildings, equipment
.and piping used in manufacture and distribution of chemicals
and plastics. An estimated xx square feet and yy lineal feet
of insulation to be removed.______
(4) Address of Site _______ (Same as item 2 above)
(5) Scheduled Start and Completion Dates
(Either calendar
year or other specified dates)
(6) Nature of planned demolition or renovation and methods employed Demolition of obsolete facilities and renovation of existing
facilities.
(7) Procedures employed Insulation wetted before removal, lowered-
to ground, disposed in a site which is (fenced or protected by
natural barrier or covered daily).
(8) Name and address of disposal site (Either same as 1 and 2 above
** or information for contractor site)
(9) Agency ordering demolition
Not applicable
DE 004899
Form of Notification
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner
Union Carbide Corporation
(2) Address of Owner
(3) Description of Facility
(4) Address of Site (5) Scheduled Start and Completion Dates
(6) Nature of planned demolition or renovation and methods employed
(7) Procedures employed
(S) Name and address of disposal site
,,
(9) Agency ordering demolition
--...........
DE 004900
Waste Systems'
BROWNING-FERRIS INDUSTRIES
September 30, 1982
Mr. Bill Davies Union Carbide Corp. Coatings Material Division P.O. Bax 3370 Brownsville,. Texas 78520
Dear Bill, '
I have discussed the routine collection of asbestos along with solid waste at your service location with Bill Clay, Texas Dept, of Health, Region 8 Solid Waste Division, Larry Smith, Texas Dept, of Water Resources and Mr. Torres Texas Air Quality Control.
I explained to them Union Carbide does not generate more than 20 cubic yards . per year and the asbestos is wet and placed in plastic bags for disposal.
They do not have problan with this method of collection, you will not have to separate the asbestos.
Sincerely Yours,
A District manager
cc: Bill Clay, p.E. T.D.H. Solid Waste Division Larry Smith - Texas Dept, of Water Resources E. Torres - Texas Air Quality Control
RIO GRANDE DISTRICT - SOLID WASTE SYSTEMS STAR ROUTE BOX 6 BROWNSVILLE. TEXAS 78521 - (51.2) 831-9361
DE 004901
Form of Notification [See also Attachment 1 ~ 5 61.22]
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR
PIPING INVOLVING FRIABLE ASBESTOS INSULATION
_________________________
(I) Name of Owner _________ Union Carbide Corporation
(2) Address of Owner
(Location Street Address)
(3) Description of Facility
Various buildings, equipment
and piping used in manufacture and distribution of chemicals
. and plastics. An estimated xx square feet and yy lineal feet
of insulation -to be removed.
-
W Address of Site
(Same as item 2 above)
(5) Scheduled Start and Completion Dates ______ (Either calendar
year or other specified dates)
___________________________________
(6) Nature of plannee demolition or renovation anc' methods employed Demolition of obsolete facilities and renovation of existing
faci 1 i ties.__________________________ _________________ ________________________________ (7) Procedures employed Insulation wetted before removal, lowered
to ground, disposed in a site which is (fenced or protected by
natural barrier or covered daily).
(8) Name and address of disposal site (Either same as 1 and 2 above
or information for contractor site)
(9) Agency ordering demolition
Not applicable
DE 004902
Form of Notification
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner
Union Carbide Corporation
(2) Address of Owner ____________________________________________________
(3) Description of Facility _____________________________________________
(4) Address of Site ________________________ (5) Scheduled Start and Completion Dates (6) Nature of planned demolition or renovation and methods employed
(7) Procedures employed
(8) Name and address of disposal site (9) Agency ordering demolition
DE 004903
UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS
P. O. BOX 3370, BROWNSVILLE. TEXAS 7#SZ0
November 19, 1979
Re: Demolition - Asbestos
Mr. Cecil Bradford Texas Air Control Board 8520 Shoal Creek Blvd. Austin, IX 78758
Dear Mr. Bradford:
The attached notification relative to the demolition of facilities containing friable insulation is provided per requirement of 40 CFR 61, Subpart B, Section 61.22 (d) .
Please contact the writer if there are any questions concerning information contained in the notification.
Very truly yours
HB:mfw Attachment
L. T. Windel
CC: Mr. Robert J. Guzman Texas Air Control Board Matz Bldg., 511-1/2 E. Jackson Harlingen, IX 78550
- BCC: Heddy Butler^ A. L. Barefoot R. C. Glock R. E. Theisen K. G. Townsend
DE 004904
Form of Notification
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner
Union Carbide Corporation
(2) Address of Owner P. 0. Box 3370, Brownsville, TX 78520
(3) Description of Facility Approximately 600 lineal feet of 1-1/2 inch pipe covered with asbestos containing insulation which is in the
southeast section of the plant
____________________
(4) Address of Site State Hwy. 48, Port of Brownsville______________ (5) Scheduled Start and Completion Dates 12/3/79 through 12/10/79
(6) Nature of planned demolition or renovation and methods employed Renovation of condensate line
(7) Procedures employed Insulation wetted before removal, lowered to . ground, placed in labeled plastic bags, and disposed in an approved site
(8) Name and address of disposal site Brownsville City Landfill
(9) Agency ordering demolition NA
DE 004905
fljzJULj -- F> l-(
INTEItNAL COllItESPO.VDKNCK ---------------------------------------------------------------------------------------------
UNION CARBIDE CORPORATION
CHEMICALS AND PLASTICS
p. o. box 3370. brownsville. texas 78520
To (Name) Company
Location
Mr. F. D. Bess, 511 R. R. Rankin, 515 K. G. Townsend, 526
one June 26, 1979
Originating Dept. Answering letter date
Subject
Asbestos Disposal
Copy to
Mr. K cl Clock, w/o attachments
Gentlemen:
Attached is correspondence with the State related to asbestos disposal. We now have permission to use the Brownsville Municipal dump for asbestos disposal provided trip tickets are used.
Very truly yours,
,zC
L. T. Windel
L TW/gr
Attachments
-.wsr:
DE 004906
UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS
P. O. BOX 3370. BROWNSVILLE. TEXAS 7*5*0
May 7, 1979
Mr. Allan M. Seils Self Reporting Section Industrial Solid Waste Disposal Permits Texas Department of Water Resources P. O. Box 13246, Capitol Station Austin, Texas 7871 1
Re: Union Carbide Corporation Brownsville Plant Solid Waste .Registration 31108
Dear Mr. Seils:
We would like to update our solid waste registration, #31108, with the Texas Department of Water Resources, issued August 10, 1977, by the addition of asbestos as a generated solid waste. We request your comments and suggestions on our proposed disposal method.
The small quantity of asbestos waste is mainly old insulation containing approximately i57o asbestos which is removed from time to time when equipment alterations or repairs are made. No new asbestos insulation is used in the plant.
The insulation is removed wet, placed in plastic bags, sealed and labeled in accordance with OSHA rules. The sealed bags of asbestos are collected on-site until there is enough for a load (approximately 1 or 2 cubic yards - every 3 or 4 months).
We propose to send the bagged asbestos to the Brownsville City landfill. The officials in charge of the landfill have agreed to accept the asbestos wastes and dispose of them properly. Your comments on this method of disposal are requested.
Both the Brownsville Union Carbide plantsite and Brownsville City landfill are located in the Brownsville Navigation District'. The asbestos would be hauled by a Brownsville Navigation District collection truck to the landfill site. The collection truck would contain only the asbestos
(
DE 004907
2
Mr. Allan M. Seils Texa.s Department of V/aier Resources
May 7, 1979
in sealed, properly labeled bags and the truck driver would be given instructions concerning the hazard and handling of this material. .Landfill personnel would be notified prior to each shipment. We need to know if a trip ticket (Ind. Waste Shipping - Control Ticket) is required to accompany each truck carrying asbestos to this site.
Summarized, we are requesting you to include asbestos in our solid waste registration and advise us about our proposed disposal method.
If you or your staff need any other information to evaluate this request,, please feel free to contact me at (512) 831-4501, extension 324 or K. G. Townsend, extension 228.
Very truly yours,
L. T. Windel Department Head Environmental Protection Department
LTW/gr/
cc: Mr. John Sturgis, Texas Department of Water Resources, Weslaco, Texas
bcc: K. G. Townsend, Union Carbide Corporation, Brownsville, Texas
DE 004908
TEXAS DU \-
M OP WAT Ell RESOURCES ' <" cngrcss Avenue
Austin, Texas
TEXAS WATER-DEVELOPMENT BOARD A. L. Black. Chairman
W. 0. Bankston Milton T. Potts John H. Garrett George W. McCleskey Glen E. Roney
Harvey Davis
Executive Director
June 15/1979
TEXAS WATER COMMISSION Felix McDonald, Clia it min Dorsey B. Hardeman Joe R. Carroll
Mr. L.T. Windel Department Head Environmental Protection Department Union Carbide Corporation Chemicals & Plastics Division P.0.'Box 3370 Brownsville, Texas 78520
Dear Mr. Windel:
RE: `Solid Waste Registration 31108
Pursuant to the request in your letter dated May 7, 1979, this is to transmit the enclosed change to Registration 31108. This document should be retained with the original Notice of Regis tration previously transmitted.
We note that the management methods detailed in your letter appear to adequately protect the environment from airborn ex posure to asbestos particles.
Please be aware that shipping tickets should be used for each truckload of this waste.
If you have any questions or comments you wish to make concerning this action, please feel free to contact E. Moody Pickard of our Solid Waste Unit at AC512/475-2041.
Very truly yours.
Jay Snow, P.E., Head solid Waste Unit
EMP/mlk Enclosure cc: TDWR District 11 Office - Weslaco
P.O. Box 13087 Capitol Station Austin, Texas 78711 Area Code 512/475-31 87 DE 004909
CHANC.:- TO NOTICE OF REGISTRATION
Industrial Solid Waste Generation/Disposal (This document modifies and becomes part of this record as described below)
REGISTRATION NO:
31108________ COMPANY NAME: Onion Carbide Corp.
The above referenced Notice of Registration is to be changed to reflect the addition of waste no. 6.
SECTION I: (Add'waste no. 6) WASTES GENERATED CLASS
6. Asbestos insulation
CODEDISPOSITION I 179390.
Off-site
SECTION II: (Add waste no. 6) 6. 179390 - insulation containing asbestos
SECTION III: (No change)
SECTION IV: (No change)
EMP/mlk
TDWB.0S02
Date: June 15, 1979 DE 004910
ADDITION OF SODIUM HYDROXIDE 207. AND SOLIDS FOR TANKS TO OUR TDWR DISPOSAL REGISTRATION
\ DE 004911
UNION CARBIDE CORPORATION COATINGS MATERIALS DIVISION P O BQX 3370. eRONSV:i.LE. TEXAS 73530
October 30, 1980
Re: Update Solid Waste Generation TDWR Reg. No. 31108
Mr. Jay Snow Solid'Waste Section Texas* Department of Water Resources P. 0. Box 13087, Capitol Station Austin, TX 78711
Dear Mr. Snow;
We would like to update our solid waste registration #31108 with the addition of 'two generated items; #7 sodium hydroxide solution approximately 207. and ;?8 solids from tanks and production vessels. These two items will be placed in the on-site surface impoundment or disposed of off-site with an approved waste disposal company.
Annual generated quantities are approximately 200,000 lbs. of the caustic solution and 2,000 lbs. of the solids from the storage tanks and process vessels.
If you or your staff need any ocher information to evaluate this request, please feel free to contact me at 512-831-4501, extension 2324 or K. Gran Townsend, extension 2228.
Very truly yours
KGT:mfw
L. T. Windel Department Head Environmental Protection Dept.
cc: John Sturgis, TDWR, Weslaco, Texas
c
asbestos procedure
I. PURPOSE: To protect 'Plant.personnel from the danger of breathing asbestos fibers
released from friable (dusty) asbestos containing materials.
II. DISCUSSION: Inhaled asbestos fibers are considered to be carcinogenic(cancer causing).
Asbestos containing material in the Plant includes old in-place insulation,
gaskets,' packing, Transite, and asbestos cloth. No new asbestos insulation
material will be purchased or installed. Efforts will be made to find
alternate non-asbestos containing material to replace any asbestos material capable of emitting fibers or dust. Materials in which the asbestos is secured
by a bonding agent or coating are less of a hazard unless they are sanded or
drilled.
III. RESPONSIBILITIES:
A. SHARE: 1. Advise maintenance of disposal methods and write trip tickets for off
site asbestos disposal. 2. Conduct air monitoring in the area of asbestos insulation.removal.
3. Notify EPA ten days before removal of more than 80 meters of asbestos
pipe insulation or 15 square meters of insulation on a boiler, reactor
or similar equipment.
B. OPERATING DEPARTMENTS:
_ 1. Responsible for proper and safe handling of any asbestos insulation,
packing, gaskets or other asbestos containing material present in the
--
unit. 2. Notify SHARE Department of intended asbestos insulation removal. It
must be reported to the EPA Regional Administrator ten days prior if it io>o
exceeds 80 meters of pipe covering or 15 square meters of boiler or
reactor covering.
DE 004913
III. RESPONSIBILITIES (Cont'd) C. MAINTENANCE: '1. No asbestos containing insulation will be installed in the Plant. 2. Follow maintenance asbestos procedure for removing old asbestos insulation. Essentially, don't make dust. Only handle it wet. Don't drop insulation or insulation covered members. Ref. Maintenance Procedure #MF-II-6.2). 3. Personnel doing asbestos insulation removal will wear protective clothing and respirators. ' 4. 'Seal all asbestos wastes (wet insulation) in plastic bags, label with asbestos, warning labels, and store in asbestos holding area (old wire cage incinerator in the N.E. section of the plant). 5. When there is sufficient asbestos waste to make a load, contact SHARE Department for disposal instructions. An industrial waste shipping control ticket will have to accompany each load leaving the plant. D. STORES: 1. No asbestos-containing insulation will be purchased.
2. Efforts will -be made not to purchase other asbestos containing materials that are capable of emitting dust and fibers.
3. Store all"asbestos packing, gaskets, etc., in tied plastic bags where practical.
4. Label shelves and storage areas where asbestos materials are kept with asbestos warning label.
5. All clean-up in asbestos material area will be done with a vacuum sweeper or under wet conditions to avoid dust in the air.
6. Waste asbestos material such as gasket material, ends of packing rolls, vacuumed dust, etc., will be sealed in plastic bags, labeled with asbestos warning label and stored in asbestos waste storage area.
DE 004914
ASBESTOS MAINTENANCE PROCEDURE DE 004915
I It I
department
PROCEDURE
PLANT 526
II FIELD MANUAL
PROPER HANDLING & DISPOSAL OF ASBESTOS
r'KOnr
t .
PAGE 1 OF 3
DATE 1/79 (WLD)
1. SCOPE
The purpose of this procedure is to make known to all employees
the health hazards and required work procedures for removing and
disposing of insulation containing asbestos, allowing this task to
be performed within the limits as prescribed by OSHA, article
1910.93a, ASBESTOS, dated October 25, 1978.
2. PROCEDURE
3.1 All personnel, whenever removing asbestos insulation, shall
wear protective clothing -- rain slicker suit or paper disposable
type coveralls.
3.2 Cotton or rubber work gloves shall be worn while handling
asbestos. 3.3 Each employee working with or in the immediate area where the
asbestos is being removed, shall wear a 3-M disposable type respira
tor. These shall be changed as the users feel necessary or daily
depending on use.
3.4 Foot gear worn should be of a type that can be washed or
vacuumed at completion of job or daily basics.
4. HANDLING & DISPOSING
4.1 * Asbestos shall always be handled, cut, removed, and disposed
of in a wet state sufficient to prevent the emission of airbomed
fibers.
4.2 Asbestos waste, scrap, debris, bags, containers, equipment,
and asbestos-contaminated, clothing, consigned for disposal, shall be
van.--,--:
collected and disposed of in sealed impermeable bags. are in Stores specially for this purpose.
These bags
DE 004916
PROCEDURE
II
PAGE -! Or
PLANT 526
FIELD MANUAL
OATE 1/79 (VLD)
Proper Handling & Disposal of Asbestos
4.3 OSHA approved labels shall be affixed to each bag containing
the waste asbestos. A "stick-on" type label is available in Stores.
These labels shall read:
IH`Uinh'i'
. co.-nira isstsios hjik
1BI8 CRUTIKC MST j
iiuniMuusittBnriuT cwu swots uonrxiH
4.4
5. 5.1
Bags of waste asbestos shall be held in the Salvage Yard "cage" for proper disposal. WORK PRACTICES & PRECAUTIONS
When asbestos is being removed, barricade the work area by erecting rope guardrails. Caution signs shall be posted at the work site, located at a distance which will allow an employee to take necessary protective steps before entering the area. These signs shall read:
ASBESTOS
DUST HAZARD
AVOID BREATHING DUST WEAR ASSIGNED PROTECTIVE
EQUIPMENT DO NOT REMAIN IN AREA UNLESS
YOUR WORK REQUIRES IT snuaikt iwRij nn an m
IIUIMIIIIIMIUUI
5.2 Notify the Industrial Hygiene Dept, Ext. 228 or 337 before
commencing to remove asbestos so air sampling monitoring of the
atmosphere can be arranged.
T)E 004917
DE AF.TKEN' PROCEDURE
II
PLANT 526
FIELD HANUAL
Proper Handling & Disposal ofAsbestos
?ROC PAGE 3 OF 3 DATE 1/79 (WLD)
5.3
6. 6.1 6.2 6.3 7. 7.1
An excellent level of housekeeping Must be maintained including cleaning of all surfaces maintained free of accumulation of asbestos fibers. Area should be wet cleaned or vacuum cleaned. Never use a broom, brush, or blow with air. CUTTING ASBESTOS SIDING OR PIPING
Employees cutting asbestos siding or piping shall wear 3-M dust respirators.
Special circular saw equipped with a vacuum unit shall be used. All scrap, waste, and vacuum bag accumulation shall be disposed of per paragraph 4. RESPONSIBILITY It shall be the craft foreman's responsibility to see that all . regulations, in regards to handling and disposing of asbestos are followed.
'tunjrv-
DE 004918
(
ASBESTOS DISPOSAL REGULATIONS 40 CFR61 AND UCC HANDLING AND DISPOSAL PROCEDURES
C
rccv<\*
DE 004919
. i.vn:it.\AL count si*o.mu:nck
UNION. CARBIDE CORPORATION
CHEMICALS AND PLASTICS
to (Name) Company Location
Mr. F. D. Bess, 511
Subiect
copy to
,c. jGlock, w/o attachments Mr. J. D. Martin, 510
KGr I Asbestos Disposal
Dear Doug:
Attached are procedures from UCC Maintenance Operations {Dick Huber's letter), OSHA regulations and Brownsville Plant Maintenance practices related to asbestos handling. There appears to be inconsistency between EPA disposal requirements and OSHA guidelines.
We currently package asbestos as described in the attached procedure and dispose of the packaged material in the Brownsville city dump.
The City dump has no warning signs as required by the EPA procedure. Should we dispose of this material on-site or continue our current practice? Your guidance would be appreciated.
,,. Very truly yours,
ETW/gr Attachments
L. T. Windel
DE 004920
INTERNAL CORRESPONDENCE
K`>'r ^rs
I. &i
5c^J
=
5
i
7>r -t=r
CHEMICALS AND PLASTICS
P. O. BOX 8361. SOUTH CHARLESTON. WEST VIRGINIA 25303
jo (N.m)
See Attached Distribution List
dic June 22, 1977
Ora9mting Oepl
Subicci
Guidance for Compliance with EPA Asbestos Regulation
Gentlemen: 1
Enclosed is an outline providing guidance for compliance with Environmental Protection Agency regulation, 40 CFR 61, Hazardous Air Pollutants, as it applies to the removal and disposal of asbestos-containing insulation and the notification of appropriate regulatory agencies.
The outline summarizes key requirements of the regulation and suggests a standard format for use in notifying regulatory agencies.
It is recommended that current location procedures be reviewed and any appropriate changes .implemented to conform with specified removal and disposal requirements. It is also suggested that locations within the same EPA Region coordinate the timing for initial notification of the proper regulatory agencies to make the submissions reasonably concurrent (August 1 might be a realistic target date).
It is further suggested that larger locations will find that annual notifica tion on a calendar year basis (in early December of the prior year, except for 1977) using the best estimate of expected activity will minimize their paper work.
The EPA regulation is in addition to an OSHA standard governing worker exposure (29 CFR, Chapter XVIry Section 1910.1001). However, only EPA requires notifica tion of removal and disposal activities. The cost impact of modifying proce dures to meet EPA regulations appears to be quite variable within Chemicals and Plastics, but would seem to be in the range of $100,000 - $200,000 total, on an annual basis.
Any requests for clarification of the plan requirements should be directed to Mr. -D. G. Hoshier of the Maintenance Operations Team. Copies of the regula tion can be provided upon request (they may be found in the Environment Reporter at 121:0461).
Sinzftrely,
RAH/w
R. A. Huber Maintenance Operations Manager
DE 004921
GUIDANCE FOR COMPLIANCE WITH PA ASBESTOS REGULATION
REGULATION AND APPLICABILITY
Regulation - 40 CFR 61, Subparts A and B Applicabi1ity - To the demolition of structures or renovation of equip
ment and piping that involves removal of more than 160 square feet or 260 lineal feet of insulation containing more than one'percent asbestos by weight, either in a single project or a predictable series of projects over the course of one year that are additive to this amount.
OVERALL REQUIREMENTS OF REGULATION
Practices - Comply with defined removal and disposal practices. Notification - Provide timely notification of EPA.
KEY REQUIREMENTS - REMOVAL PRACTICES
(1) Insulation shall be removed prior to demolition where the demolition would likely damage and expose insulation'.
(2) Insulation must be wetted prior to removal and kept wet until disposal is accomp!ished.
(3) Insulation on pipe or equipment which is to be removed in sections must have exposed surfaces wetted and kept wet during dismantling.
(4) Stripped insulation must not be dropped or thrown to the ground. Dust tight containers or chutes must be used for lowering insulation removed that is more-than 50 feet above ground level.
KEY REQUIREMENTS - DISPOSAL PRACTICES
(l) No visible emissions of insulation are allowed in transport to the
disposal site. ~{Z) No visible emissions may result from disposal operations.
(3) For disposal areas one of the following requirements must be met:
(a) A six-inch earth cover is provided over disposed insula
tion within 24 hours. (b) An effective resinous or petroleum-based dust suppression
agent is applied at the end of each operating day. (c) A natural barrier adequately deters public access to the
site.
_
DE 004922
(d) The area is fenced and (20 x 14 inch) warning signs are posted at least every 330 feet. [See Attachment 1, 61.25]
REQUIREMENTS - EPA NOTIFICATION
Timing - EPA and applicable States are to be notified either:
(a) Annually, or (b) 10 days prior to planned demolition or renovation, or (c) As soon as possible after beginning an unplanned (emergency)
removal project.
The ab'ove notification requirement applies whenever the total amount for the project or time period exceeds 160 square feet of equipment or 260 lineal feet of pipe insulation.
Office to be Notified - [See Attachment 1, 5 61.04]
Federal:
Director, Enforcement Division Environmental Protection Agency (Regional Office City Address)
State:
(Applicable only in the following CSP states) California (Sacramento County) (Bay Area)
Georgia New York North Carolina
Suggested Text ofNoti f ication Letter
The attached notification relative to the demolition and/or renovation of facilities containing friable asbestos insulation is provided per.requirements of 40 CFR 61, Subpart B, Section 61.22 (d).
Please contact the writer if there are questions concerning information contained in the notification.
Signed _____________________________
DE 004923
Example of TACB 10 day prior notification of asbestos removal. TACB is enforcing EPA AO CFR 61, Hazardous Air Pollutants as it
APPLIES TO ASBESTOS.
X)E 004924
itUUllL.* L\:ALilL.rJ
UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS
P. O. BOX 3370. BROWNSVILLE. TEXAS 7BS20
September 7, 1979
Re: Demolition - Asbestos
Mr. Cecil Bradford Texas Air Control Board
&550-Shoa-1--.Creek-Blvd.- & 3 3 O
Austin,* IX 78758
2.^0
Dear Mr. Bradford:
The attached notification relative to the demolition of facilities containing friable insulation is provided per requirement of 40 CFR 61, Subpart B, Section 61.22 (d).
Please contact the writer if there are any questions concerning information contained in the notification.
Very truly yours.
KGT:mfw Attachment
K. Gran Townsend
CC: Mr. Robert J. Guzman Texas Air Control.Board Matz Bldg. ,-51-l-rE7-2- E. Jackson Harlingen, TX 78550
&CC:
"Jr.
6.L. 1^^*"
DE 004925
Form of Notification
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner
Union Carbide Corporation
(2) Address of Owner
(3) Description of Facility
(A) Address of Site (5) Scheduled Start and Completion Dates (6) Nature of planned demolition or renovation and methods employed
(7) Procedures employed
(8) Name and address of disposal site (9) Agency ordering demolition
DE 004926
Form of Notification [See also Attachment 1 - 5 61.22]
NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION
(1) Name of Owner _______ Union Carbide Corporation
(2) Address of Owner
(Location Street Address)
(3) Description of Facility _________Various buildings, equipment
and piping used in manufacture and distribution of chemicals
and plastics. An estimated xx square feet and yy lineal feet
of insulation to be removed.______
(k) Address of Site _______ (Same as i tern 2 above)
(5) Scheduled Start and Completion Dates
(Either calendar
year or other specified dates)
(6) Nature of planned demolition or renovation and methods employed Demolition of obsolete facilities and renovation of existing
facilities.
(7) Procedures employed Insulation wetted before removal, lowered
to ground, disposed in a site which is (fenced or protected by
natural barrier or covered daily).
(8) Name and address of disposal site (Either same as 1 and 2 above
or information for contractor site)
(9) Agency ordering demolition
Not applicable
DE 004927
GENERAL NOTES
(U_
The regulation applies to friable asbestos which would mean insula tion containing more than one percent asbestos by weight which can be reduced to powder, when dry, by hand pressure. Any insulation purchased prior to 1975, containing asbestos as reinforcement, would meet the definition of friable asbestos and be subject to the regula tion. New insulation does not contain asbestos.
(2) A standard text for a notification letter and a format for the notice (filled in with standard responses or indication of the type of. response) are included.
(3) For locations with a reasonable amount of continuing activity involv ing insulation removal, paperwork would be minimized and made more routine if notification were made annually (in December for the coming year) using a best estimate of insulation quantities involved. Other locations may find that annual notification is unnecessary.
(4) Recognize that an Occupational Safety and Health Standard, 2$ CFR, Chapter XVII, Section 1910.1001, "Toxic and Hazardous Substances" impose certain requirements for personnel equipment, clothing, monitor ing, and medical examinations in work areas involving exposure to asbestos dust. There is a certain amount, but not total overlap with the EPA regulation.
(5) The EPA regulation applies to any work done at a facility whether by company or contract personnel. Company personnel involved with contractors should assure that notification responsibility is assigned to"the contractor in the work specification, or performed by the company.
(6) it is suggested that disposal sites for asbestos be fenced (but not posted) even where another approved alternative requirement is being met to avoid future problems from uncovering the material inadvertently.
DE 004928
Excerpts fro.~ ::
zu.-aous Air Pollutant Regulation
ENVIRONMENTAL PROTECTION AGENCY REGULATIONS ON NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
(40 CFR 61; 38 FR 8820, April 6. 1973. Amended by Code of Federal Regulations.Volume 40, Revised as of July l, 1976; 41 FR 27967, July 8. 1976; 41 FR 33264. August 9, 1976; 41 FR 34629. August J6, 1976; 41 FR 36918. September 1, 1976; 41 FR 40108, September 17. 1976; 41 FR 40467. September 20. 1976; 41 FR 43148, September 30, 1976; 41 FR 44860, October 13. 1976; 41 FR 46559, October 20, 1976; 41 FR 53017, December 3. 1976; 41 FR 54758, December 15, 1976; 41 FR 56805, December 30. 1976)
Subvert A--General Provisions
. 61,04 Addrae. (a) All requests, reports, applications,
ubmlttals. and other communications to he Administrator pursuant to this part, hall be submitted In duplicate'and Odirsised to the appropriate Regional Ofice of the Environmental Protection teener, to the attention of the Director, Enforcement Division. The regional oflees are as follows:
Region X (Connecticut, Maine. New BeJp* hire, Masaacbuactla. Rhode Ialaae, Vermost), John F. Kennedy Federal Building, Bonoc. Masaachuaetta 02203.
Region IX (Near York. New Jersey, Puerto
aioo, Virgin lilandt). Federal OlQce BuUd*
ng, 20 Federal Plaza (Foley Square}, New tork. N.Y. 10007.
Region XU (Delaware, District at Columbia, >ennaylvauia, Maryland, Virginia. Weat Virpnla). Curtis Building. Sixth and Walnut
J'.reeu. Philadelphia, Psunsylvonla 10100. `on IV l Alabama Florida. Georgia. Mle-
u ,1, Kentucky. North Carolina, South' Carolina, Tennenece), Suite 300. 1421 Paaeh.see Street. Atlanta, Georgia 30300.
Region V (Dllnola. Indiana. Mlnneaota, vdeblgan, Ohio, Wlacoualn), 1 North Wacker 3r1ve, Chicago. Illinois 00003.
Region VI (Arkansas. Louisiana, New deilco, Oklahoma, Texas), 1000 Fwttanon itteal. Dallas, Texas 70301.
Region VII (Iowa. Xanaaa. Mlaaourl. Na> reek*), 1700 Baltimore Street, Xanaaa City. Jtaeouri 03100.
Region VXIX (Colorado, Montana. North Dw-
tuta. South Dakota, Utah. Wyoming). Iff Jncoln Towers, 1000 Unooln Street, Denver, Colorado *0303.'
Region IX (Arizona, California, Hawib, levada. Guam, American Samoa). 100 CitP ornla Street. San Francisco, California 04111.
Region X (Washington, Oregon, jn--yy vlaaka), 1300 Sixth Avenue, Baattla, Vfgao*
ngtnn eoioi.
tT<b)<;BecUoa-H2(d) directs the `Adminisimtor'to'delegkte'to each Sto'tei'Srben? appropr'lite.'-,tlie^authprity-tf> lmplern-entj and enforce the national ernissioQslaivdarda for hazardous a|r pollutantslor sta tionary sources^ located In such State. A U.lnformaaon^^i'uirca'foTe^ubmUied to-EPA'5mdei`rgtSgra?hffi.irf.lHIrtBg} tlon,rmuColo-fce;*ubmIttd-!lo the ab? proprtate'BfaterAgehcyrOf.aifF Btale^tt which thli.authorltyTias beendelegabw (prbvldeiJ,- that "eocHapeclfle'delegation may exempt sources from a certain fed eral or StatA reporting requirement). Thr > ' oprlatn. moiling address for ttaoaa
SUtes whooo delegation request feu beep approved Is as rollout:
B-CtlUornte; *y Art* Air Pollution Costrot DUtrict*
*W KDU StTMt. Bon rrmXbCUCO, CA M100.
Ber*mento County Air Pollution Control District. 3701 Branch C*ntr Ro4, Bun* rsesto, OA 9M27.
i4-j ouk or OeorjU, Ksnrontoental pro*
tteilnn Division. Depsrtmeht'of Natural Ra-
pource*. 270 Wblogto& Bota 6 W. At-
laota. O+orfl* 30234,
,>
(HK)--Nrw Tot*: Now Torlc State Depart*
meat of XaviroWBontel Co&rvaUoB.S0 Wolf Albany. New Tork 12233. attention;
Dirtaioa of AfcrJUiowtxo.
(40 FR 48347, Ociobet IS, 19751
(It) North Carolina Environmental Man moment Commission, Department of Natural
and Economic Resources. Division of Envi
ronmental Management. P.O. Box 27G37. Ra leigh. North Carolina 37811. Attention: Alt Quality Section.
Subpart B--National Emission Standard tor Asbestos
S 61.22 Emission standard.
(d) Demolition and renovation: The requirements of this paragraph shall apply to any owner or operator of a demolition or renovation operation who Intends to demolish any institutional, commercial, or Industrial building (In cluding apartment buildings having more than four dwelling units), structure, facility, installation, or portion thereof which contains any pipe. duct, boiler, tank, reactor, turbine, furnace, or struc tural member that Is insulated or Areproofed with friable asbestos material, except as provided In paragraph (d) (l> of this section; or who Intends to reno vate any institutional, commercial, or In dustrial building, structure, facility, in stallation. or portion thereof where more than 80 meters (ca. 280 feet) of pipe In sulated or Areproofed with friable as bestos material are stripped or removed, or more than 15 square meter* (ca. 160 square feet) of friable asbestos material used to Insulate or Areproof any duct, boiler, tank, reactor, turbine, furnace, or structural member are stripped or re-
Written notice of intention to'demolish;'br renovate' shall be' provided -to the' Administrator by the owner or opera tor of the demolition or renovation oper ation. Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demo
lition. or as early as possible prior to commencement ol emergency demolition subject to paragraph (d)(6) of this sec tion. and as early as possible prior to commencement of renovation. Such no tice shall include the following Informa
tion: f(l).: Name of owner or operator. i(ll>7 Address of owner or operator. tf{U) Description of the building, struc-
turer'facillty. or installation to be de
molished or renovated. Including the size. age. and prior use of the structure, and the approximate amount of friable asbestos material used for insulation and AreprobAng.
fiv> Address or location of llic bulldlpg.struclure. facility, or installation.
Ffv). Scheduled starting and cornpletKn'dates of demolition or renovation.
riyl). Nature of planned demolition or remvfction and methodfs) to be em
ployed. Jyll) Procedures to be employed to
meerthe requirements of tills paragraph and paragraph <j) of this section.
{vUj) The name and address or Iocstlonnbi'the waste disposal site where the
friable asbestos waste will be deposited. Ox) Name, title, and authority of the
Stat?or local governmental representa
tive who has ordered a demolition which Is subject to paragraph (d)(6) of this section.
g 61.2S WeMc disposal silex.
(b) Warning signs shall be displayed at all entrances, and along the property line of the site or along the perimeter of
the sections of the site where asbestoscontaining waste materia! Is deposited,
at intervals of 100 m tea. 330 ft) or lcs* except as specified in paragraph id ol this section. Signs shall be posted In such a manner and location that a person my easily read the legend. The warnlnr signs required by Hus paragraph shall
conform to the requirements of 20" x 14" upright format signs specified in 29 CFH 1910.145(d) (4) and this paragraph. The signs shall display fur fallowing legend in the lower panel, with letter sizes and styles of a visibility at least equal to
those specified in this paragraph,
LEO NO
'AsorSTOS Waste Durnsu. StTT
Do Not CrcUe Dust
Breathing Is Hazardous to Yout lleilth
Notation
1'* Sans Serif. Gv.tuic or Dloefc
Sans Serif. Gothic or Block
H Point Got'Ur
Spacing between lmt s shall b: at leas'
eo':a' - w height '
u'.ner of Ur
DE 004929
1^:8304
REFHRENCr ?i'. '
Tabic 2 :
<CJ Methods o/ compliance-- il > i
gincering methods. (1) Engineering cci.
(hour Uis*
Ac&apubl* mkiUnum puk abt troll. Engineering controls, such as. be.
AccrpuW*
th acceptable c*JMnr eoitecoira* not limited to. isolation, enclosure, ex
Malarial
weighted *vr*f*
llm(
tien lor an (-hour shut.
eoncenwttofi --... --
Concentration
Mduartalmtiounm
haust ventilation, and dust collection,
shall be used to meet the exposure limns prescribed in paragraph (b) of this
section.
R**can* (237.t-1961)......... ..
10 p p m......... .... 34 p D m............ . 60 p p .................. lOmlnulu.
turyllium and beryllium coeopounJ* 3f Al............
. ?A | Al*.............. 10 mluulti.
(217. 1970). Cadmium turn# (ZJ7.6-1970)...............
3 mf.Al1............
(11> Local exhaust ventilation, (c)
Local exhaust ventilation and dust col lection systems shall be designed, con
Cadmium dnU (Z77.HI70)............................. Cirbon dlsulAd* (237.1-llrtl)................... 30 p.p.tt......... 60 p p m............ . too p p.m............. CitUsr. laUachttride {227.17-I907)................ 10 p.pjo............. 36 p p tr............. . TOO p.p a....... A minute* to
any * boon.
F.tbylan# dlbromld* (237.3M970).......... TOp.p-m......... 60p pjn............. . 60 p.p.ffl.............. 1 minutes. Ethylene dlchJortde (Z37.3M06B).............. Iftp.p.m..... ... 100 p.p m.......... . 300 p p.m............ 6 minutes In
*ity 3 hours.
Formaldehyde (237.16-1067)..... ....................
30 minutes.
nydrcweit rfuniMe (217.3A-ul0>......................
VMOMdeaS dul (Z37.*U69>......... ............. 3.6 tnr Al*........
Lead and III Inorcanlccempouudl (2J7.11> 0.2 uif.Al*........
1M9). Methyl eWorld* (237.K-1960)..........................
100 p.p.m.........
200 p.p.m.......... too p.p.m............
1 minutes Is any 3 bout*.
Matbylana CWorid* (ZJ7J-196I).................... 600 p.pJ&......... 1,000 p.p.m........... 3.000 p.p-m____ 6 minute* ia
U7 2 hours.
structed, Installed, and maintained in accordance with the American National Standard Fundamentals Governing the
Design and Operation of Local Exhaust
Systems. ANSI Z9.2-1971, which Is In
corporated by reference herein. (b) See 11910.8 concerning the avail
ability Of ANSI Z9.2-1971, and the maintenance of a historic file in connec
tion therewith. The address of the Amer ican National Standards Institute Is
Orvino (alkyl) mercury (23TJ0-1966).......... 0.01 mcJM*... 0.0t mcTM *............ Styrene (237.1J-1966)...........a...........-........... loo p.p.m......... 300 p.pjQ. ............. . 600 p.pA........... I mlsuU* la
any 3 hours.
Trichloroethylene (237.1^1*67)................ .
I mlautts ta
any 7 hours.
Tatrachloroathylaaa (237,23-1967)...................------ do...... ......... .....da................... .......... do............... 6 minute* is
soy 3 boors.
Toluana (237.12*1967)................ Bydre*n suUde (237J-1M6).
. 600 p.p.m
lOmlnut**.
20 p.p.m................ .. 60 p.pja........... . IQmtnuia* ooe*
only U oo
given in i 1910.100. (Ill) 'Particular foofj. All hand-op
erated and power-operated tools which may produce or release asbestos fibers
in excess of the exposure limits pre
scribed In paragraph (b) of this section, such as, but not limited to, saws, scorers,
Mareary (237.1-1971)...................................... Chromic acid tad chromate* (237.7*1971)
1 m*V10M .
....do *....
other maaiurbio tpo*UM occurs.
abrasive wheels, and drills, shall be pro
vided with local exhaust ventilation ;ystems in accordance with subdivision (11) of this subparagraph.
(2) Work practices--(1) Wet methods.
Table 2-J--Mineral Dusts
Substance
Mppcl Mc/M
Aerodynamic diameter (unit dciutty sphere)
Percent peutof selector
Insofar as practicable, asbestos shall be
handled, mixed, applied, removed, cut. scored, or otherwise worked in a wet
Silk*: Crystalline: Ouaru (rtiNrmblr)................
1 l0rot/M*
3
26 36 60 1C
90 state sufficient to prevent the emission
76 of airborne fibers in excess of the ex
60 35
posure limits prescribed in paragraph
0 (bl of this section, unless the usefulness
Quarts (total dust)
SlOt+4
of the product would be diminished The measurements under this note refer to tbe us* of thereby.
Vw
CrlitobalUe: Us* H tb# value calculated bom the
count or mass formulae lor
quarts Tndymitc: Dm H tb* vatu*
fatrulated born the tor*
%SiOl+2
an A EC Instrument. If the resptrabk fraction of coal i In il ml i minim if n HiII die Ajrur* correspondutf
bat of 3.4 Mc/M* bt tbe tablr^or cuol dust Is 44
5 1910.1001 Asbestos.
(a) DfAnitinnr js4\t the purpose of
(ill Particular products and opera tions. No asbestos cement, mortar, coat
ing. grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers
mule* lor quarts. Amorphous, mrtudlnf natural
dtatomaeeous e*nh.............
was section, (1) "Asbestos" Includes in which they are shipped, without being
30 Omf/M' chrysolite, amoslte. croddolite, tremo- either wetted, or enclosed, or ventilated
lite, anthophyllite, and actmollte.
so as to prevent effectively the release of
%StO>
(2) "Asbestos fibers" means asbestos airborne asbestos fibers in excess of the
SQtcates (less than 1% crys
talline slUca):
Mica..........................................
Soapstone................................
30
Talc (non-ashesU/S'lorm) ..
20*
Tatc(Ahrous). Use asbestos limit .... .........................
Treraatite (aee talc, flbroiu)
Portland cement..............
60
Oraftfilte (natural)....................
U
CimI dust (mutable traelfca
ku than 1% 31Oil........................................
For more than 1% 510i..
30
3.4mf/M* or
Wm*Al
lorn or Nubaace Dust:
Respirable bacllOfl.........
Total duat.................... ..
%SIO*+2
II 10
lSmt/M*
Note: Convent** Uetan***
mppefx3*.3mllUan pankk* per cubic meter
pulklo per cp.
Millions of particles per cubic Mot at air, based oo
lmpinger samples counted by Ilfbl-fleld technics.
1 The pvrtntaca of crystalline ultra ta the formula
Is the amount determined bom air-borne samples, ex
cept In thoM Instances ta which other methods bava been
Stmwn to be apptwabk.
t
> As determined by the membian* flltae method at
tXXPliaae contrast niiftilficaOon.
* llolh cunt-enifaikiu and prrrcitt quarts lor tha ap|U-
eattoft ol tliia built w* to lie d*Mtrmln^d Ironi tha fraction
PwwIih* a
with lli* tallowing characievoiks:
Conuinuif < 1% quarts: If > 1% quarts, uso quarts
fibers longer than 5 micrometers.
(b) Permissible exposure to airborne concentrations of asbestos fibers--(1) Standard effective July 7. 1912. The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than 5 micrometers, per cubic centimeter of air. as determined by the method pre scribed in paragraph (e) of this section.
(2) Standard effective July 1. 1976.
The l-hour time-weighted average air borne concentrations of asbestos fibers to which any employee may be exposed
shall not exceed two fibers, 'longer than & micrometers, per cubic centimeter of air. as determined by the method pre scribed in paragraph te) of this section.
(3) Ceiling concentration. No em ployee shall be exposed at any time to airborne cencentratlons ol asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter ol air. as determined by the method pre
limits prescribed in paragraph (b) of this section.
(Ill) Spraying. demolition, or removal. Employees engaged In the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment In accord ance with paragraph (d) (2) (111) of this section and with special clothing in ac cordance with paragraph (d> (3) of this section.
(d) Personal protective equipment-- (1) Compliance with the exposure-limits--,.^1; prescribed by paragraph (b> of this sec tlon may not be achieved by the use o! respirators or shift rotation of em
ployees. except:
(I) During the time period necessary
to install the engineering controls and to institute the work practices required by paragraph (c> of this section:
(II) In work situations in which U>-'
limit. scribed in paragraph ie> of this section. methods prescribed in paragraph (cj
Occupot>onol Sofetyk& Heolth Reporter
r~)SH a
ISec. 1910.1001 (dl(1) fii)] r C C-t-c-Q Usr
28
DE 004930
TOXIC SUBSTANCES
31 fv:
this section 'are either technically not feasible or feasible to an extent insulllcirnt to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of Uiis
section: or (iii) In emergencies. :iv> Where both respirators and per
sonnel rotation are allowed by subdivi
sions (i>. (ill. or (ill) of this subpara graph. and both are practicable, person nel rotation shall be preferred and used.
(2) Where a respirator is permitted by
----subparagraph (1> of this paragraph, it " shall be selected from among those ap
proved by the Bureau of Mines. Depart ment of the Interior.'or the Nntlonal In stitute for Occupational Safety and Health, "Department of Health. Educa
tion. and Welfare, under the provisions of 30 CFR Part 11 437 Fit. 6244. Mar. 25. 1972). and shall be used in accordance with subdivision* (D.(U). (ill), and (iv)
of this subparagraph.. (I) Air purifying respirators. A reusa
tne salely or health of the employee or ether employees will be impaired by his
use ot a respirator Such employee shall be rotated to another lob or given the
opportunity to transfer to a different po
sition whose duties lie is able to perform with the same employer, in the same geo
graphical area and with the same senior ity. status, and rate of pay he had just
prior to su:h transfer, if such a different position Is available.
(3> Special clothing: The employer shall provide, and require the use of, spe
cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em
ployee exposed to airborne concentra tions of asbestos fibers, which exceed the
ceiling level prescribed in paragraph (b) of this section.
(4) Change rooms: (1) At any fixed
place of employment exposed to airborne concentrations of asbestos fibers in ex
cess of the exposure limits prescribed in paragraph (b) of this section, the em
(ID Sampling frequency and patterns After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section.
(3' Environmental monitoring-- (I) samples shnll be collected from areas ot a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted In
an open-face filter holder. Samples shall be taken for the determination of the 8-
hour time-weighted average airborne concentrations and of the celling con centrations of asbestos fibers.
ble or single use air purifying respirator, -or a respirator described In subdivision
(li) or (iii) of this subparagraph, shall be used to reduce the concentrations of
airborne asbestos fibers in the respiratorbelow the exposure limits prescribed in paragraph (b> oi this section, when the i,. -celling or the 8-hour tlme-wclghtcd nver-
-iii-age airborne concentrations of asbestos fibers are reasonably expected to exceed - no more than 10 times those limits.
(II) Powered air purifying respirators.
A full facepiece powered air purllying
respirator, or a powered air purifying respirator, or a respirator described in
subdivision (ill) of this subparagraph,
shall be used to reduce the concentra
tions of airborne asbestos fibers-in the respirator below the exposure limits pre served in paragraph (b) of this section, when the ceiling or the 8-hour time-
weighted average concentrations of
asbestos fibers are reasonably expected to exceed 10 times, but not-100 .times, those limits.
(III) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres
ployer shall provide change rooms for employees working regularly at the place.
(ID Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from bis work clothes.
(Ill) Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air borne asbestos fibers in excess of the ex posure limits prescribed in paragraph lb)
of this section. (b> Any employer who gives asbestos-
contaminated clothing to another person for laundering shall inform such person of the requirement In (a) of thts.subdivision to effectively prevent the releasi
of airborne asbestos fibers in excess/df the exposure limits prescribed in paragraph (b) of this section.
(c> Contaminated clothing shall be transported in sealed Impermeable bags, or other closed. Impermeable containers, and labeled In accordance with\para-
graph (g) of this section. (e) Method of measurement. All
(ii) Sampling frequency and patterns.
After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no ense shall sampling be at Intervals-greater than C months for
employees whose exposures to asbestos may reasonably be foreseen "to exceed the exposure limits prescribed In para graph (b) of this section.
14) Employee observation of monitor ing. Affected employees, or their rep-, resentatives. shall be given a* reasonable nonarcnntiy in r^-rr-r rny mnnitnrjnf retuweiTSy"this paragraph andsKSTl ccess to the records thereof.
(g) Caution signs and labels. (1) tion signs. (1) Posting. Caution signs\
shall be provided and displayed at each
location where airborne concentrations of asbestos fibers may be In excess of the exposure limits prescribed in paragraph i (b) of this section. Signs shall be posted/ at such a distance from such a location so that an employee may read the :
sure-demand. supplied-air respirator shall be used to reduce the concentra
terminations of airborne concentrations of asbestos fibers shall be made by the
lake necessary protective step$ fore g th- nrrn mnitff'Mfy the
tions of airborne asbestos fibers, to the membrane filter method at 400-450 X signs. Signs shall be posted at all ap
respirator below the exposure limits pre
scribed in paragraph (b) of this section, when the ceiling or the l-hour time-
(magnification) (4 millimeter objective)
with phase contrast illumination. (f) Monitoring--(1) Initial determi
proaches to areas containing excessive concentrations of airborne asbestos
fibers.
weighted average airborne concentra nations. Within 6 months of the publi (li). Sign specifications. The warning
tions of asbestos fibers are reasonably cation of this section, every employer signs required by subdivision (I) ot this
expected to exceed 100 times those limits. shall cause every place ot employment subparagraph shall conform to the re
(iv) Establishment of a respirator pro where asbestos fibers are released to be quirements of 20". x 14" vertical format
gram. (a) The employer shall establish monitored in such a way as to determine signs specified in i 1910.145(d)(4). and
a respirator program hi accordance with whether every employee's exposure to to this subdivision. The signs shall dis
the requirements of the American Na asbestos fibers is below the limits pre play the following legend In the lower
tional Standards Practices for Respira scribed In paragraph <b> of this sec panel, with letter sizes and styles of a
tory Protection. ANSI Z88.2-1969. which tion. If the limits are exceeded, the em visibility at least equal to that specified
is incorporated by reference herein.
ployer shall immediately undertake a in this subdivision.
b. See 41910.6 concerning-the avail ability of ANSI Z88.2-1969 and the main
tenance of an historic flic In connection
therewith. The address of the American
compliance program In accordance with paragraph (c) of this section.
(2) Personal monitoring--(1) Sam ples shall be collected from within the
Leyena Asbestos................
Notation
I" 6nni Srrlf. OotMc or Bloex.
National Standards Institute Is given in 4 1910.100.
(c)No employee shall be assigned to tasks requiring the use of respirators if.
based upon his most recent examination, an examining physician determines that
breathing zone of the employees, on
membrane filters of 0.8 micrometer po rosity mounted In an open-face filter holder. Samples shall be taken for the
determination of the 8-hour tlme-
'wnjthtcd average airborne concentra
Oust Hazard..........__
Avoid Breathing Dust... Wear. Assigned Protective
Equipment. Do Not Remain In Area
VI" Sans Serif. Oothlc o r Block
Vf Gothic. >4" Gothic.
Vi" Oothlc
the employee will be unable to function tions and of the celling concentrations of Unless Your Work Re
normally wearing a respirator, or that asbestos fibers.
quires It.
1-20-77
Copyright 8 1977 by The Bureou of Notionol Affbirs, Inc. ISec. 7910.1001fg)(lltii)j
19
DE 004931
31. 306
REFERENCE FILE
Legend
' Notation
. tj) Mediccl examinations--111 Gei lartr.alion related to occupations! ex
Bretihint Aibntoa Dust 14 point Oothle. erat. The employer shall provide or nxfice posure to asbestos fibers
Ut| Be Htzirsoui To
available at his cost, medical examina |S-. 1910.93a jUiIvvI si 36 TR 23207.Dcvcm-
four Httb.
tions relative to exposure to aspdstos re lvt 7. 1971. av eiiiciyvncv n-mpourv suml-
.pacing between-Unes snail be at least quired by this paragraph
wd. ivviictl sv pcnnnncni sljndsrd at 37 I K
equal to the height ot the upper of any
;2> Preplacement. The employer shall 11313. lime 7, 1972. rlccmc July 7. 1972.
two lines.
provide or make ovallabLfto each of his rcilvvirnalvii See. 1910.1001 si 40 I-'R 23072
(2) Caution labels--(1) Labeling. Cau employees, within 30 calendar days fol May 28. I975|
tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris,
and other products containing asbestos libers, or to their containers, except that no label is required where asbestos fibers
lowing his first employment in an occupation exposed to r.lrborne con centrations of asbestos fibers, a compre
hensive mcdlcalekamlnatlon. which shall Include, as a inlnimum. a chest roent
S 1910.1002 Coal lu pitch volatiles; in terpretation of term.
A uc<J in See. 1910 I0IK) (Table Z-l). nul tar pitch volatiles Include the fused poly
have-been-iQpctiflcd by a bonding agent, genogram (pOstcrior-antcrIor H x 17 cyclic hydrocarbons which volatilize
coating, binder* or other material so that Inches), a /lstory to elicit symptom from the distillation residues of coal,
during any reasonably foreseeable use. atology of respiratory disease, and petroleum, wood, and other organic mat
handling, storage, disposal, processing, or pulmonoty function tests to Include ter.
transportation, no airborne concentra forced vital capacity (FVC) and forced |37 l-R 24749 LITclIivc November 21. 19721
tions of asbestos fibers In excess of the expiratory volume at l second (PEV,.,).
exposure limits prescribed in paragraph (bl of this section will be released.
(ill Label specifications. The caution labels required by subdivision (|) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state:
CaOTIOH
"(3\j Annual examinations. On or be-
for/January 31. 1973. and at least an nually thereafter, every employer shall
ovide, or make available, comprehen-
ilve medical examinations to each of his employees engaged in occupations ex
posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest
1910-1003 4-Nitrobiphcnyl.
(a) Scope and application. (1) This section applies to any area In which 4-Nitrobiphenyl, Chemical Abstracts Service Registry Number 92933 is manu factured, processed, repackaged, re leased, handled, or stored, but shall not apply to transshipment In sealed con tainers, except for the labeling require
Contains Asbestos Fibers
roentgenogram (posterior-anterior 14 x ments under paragraphs (e)(2), (3), and
Avoid Creating Dust
17 Inches), a history to elicit symptom (4) ot this section.
Breathing Asbestos Dust May Cause
atology of respirator}' disease, and
(2) This section shall not apply to
Serious Bodily Harm
pulmonary function tests to Include solid or liquid mixtures containing less
ih) Housekeeping--(1) Cleaning. All forced vital capacity (FVC) and forced than 0.1 percent by weight or volume pf
external surfaces In any plnee of employ expiratory volume at 1 second (FEV,.).
ment shall be maintained free of accu mulations of asbestos fibers if. with their ri-eno-fo-i ih'-r- t""1'' Kf an excessive
concentration.
<4> Termination of employment. The
employer shall provide, or make avail able. within 30 calendar days before or after the termination of employment of
'2i Waste disposal. Asbestos waste, any employee engaged in an occupation
..rap. debris, bags, containers, equip [exposed to airborne concentrations of
ment. and asbestos-contaminated cloth
ing, consigned for disposal, which may produce in any reasonably foreseeable
use, handling, storage, processing, dis
ibestos floers, a comprehensive medical xamination which shall Include, as a
nlnimum, a chest roentgenogram (pos-
erior-anterlor 14 x 17 inches), a history
posal. or transportation airborne concen l } elicit symptomatology of respiratory
trations of asbestos fibers in excess of the < iseasc. and pulmonary function tests exposure limits prescribed in paragraph tf> Include forced vital capacity (FVC)
lb) of this section shall be collected andl| ) i nd foorrccee<d expiratory volume at 1 second disposed of In sealed impermeable bags, II/fev,.). moooorrTrrdodisosrsnr.ti-hstEooheJtvrlariLenaldLlrgnyotbmysreeeelmpLqmdeeu;partilIsropmienoyildptneiagearbi--rnlsymehottedahirallilfbseomilxnesrjevalacOicirontopitntohnaetnarmrie.niioneRedrrneeertcsocca~..]lf1.1/`tcepholxoeraf(yd5tmeeai)emnin.cRppaeeiltofic,woyeenaintedhtehiesqtahxusiaasrmtebep'qeianeurrnaiearetcgieoodrxranadpsoms.h'fNinswoehaidontmhwyiienndtehlatcmhcaaett at least 20 years and shaU be made av*il> 'p*sl UytBt perlod'
4-Nitroblphenyl. (bl Definitions. For the purposes tif
this section: (1) "Absolute fitter" is one capable of retaining 99.97 percent of a
mono disperse aerosol of 0.3 m particles.
(2) "Authorized employee" means an employee whose duties require him to be In the regulated area and who has been specifically assigned by the employer.
(3) "Clean change room" means a
room where employees put on clean
clothing and/or protective equipment in an environment free of 4-Nltroblphenyl. The clean change room shall be con
tiguous to and have an entry from a
shower room, when the shower room
facilities are otherwise required in this section.
(4) '(Closed system" means an opera
tion involving 4-Nitrobiphenyl where
containment prevents the release of 4Nitrobtphenyl Into regulated areas, non-
regulated areas, or the extemal'envlronment.
able upon request to the Assistant Sec retary of Labor for Occupational Safety
and Health, the Director of the National Institute for Occupational Safety and
Health, and to authorized representa tives of either.
11910.1001 (i)(I) amended al 41 lrK 11503. March 19. 1976|
(6) Medical records--(1) Mainte nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained by
employers for at least 20 years.
(5) "Decontamination" means the In activation of 4-Nltroblphenyl or Its safe disposal.
(6) "Director" means the Director, National * Institute lor Occupational Safety and Health, or any person di rected by him or the Secretary of Health, Education, and Welfare to act for the
(2) Employee access. Every employee (it) Access. The contents ot the rec Director.
and former employee shall have reason ords of the medical examinations
(7) "Disposal" means the safe re
able access to any record required to be required by this paragraph shall be made moval of 4-Nitroblphenyl from the work
maintained by subparagraph (li of this available, for Inspection and copying, environment
paragraph, which indicates the em to the A*il.t:inl SrcrtLlry of Libor :;r
(8) "Emergency" means an unforsecn
ployee's own exposure to asbestos fibers. Urcuii;itio:i.i! Hr.lav .in'! 1*im!'..i the circumstance or set of circumstances re
(3) Employee notification. Any em ployee found to have been exposed at any
time to airborne concentrations of asbes-
's fibers in excess of the limits prelbed In paragraph (b) of this section
snail be notified in writing of the expo
D.rccior at NliJ.'jH. n> njthr.nm! )il:v:.,
ci.ms and ir.vcical consultant'- ol tilin'! of llti-m. ami. uiai.'i the ieq*:t:! of an r::i-
pluyse c-r tormcr employee, to l:i* l.tiyti:i:;ii Any I'J-yMri.n: who conduct; a iiudiral r-x-.'innaiioii rtqtnri'o by this
sulting In the release of 4-Nltroblphcnyl which may result In exposure to or con
tact with 4-Nitrobiphenyl.
(9) "External environment" meiins any environment external to regulated
sure as soon as practicable but not later paragraph shall furnish to the employer and nonregulated areas.
- than 5 d3ys ot the finding. The employee of the examined employee all the infor
(10) "Isolated system" means a -fully
shall also be timely notified of the cor mation specifically required by this enclosed structure other than the vessel
rective action being taken.
paragraph, and any other medical ln- of containment of 4-Nitroblphenyl,
Occupoiiona! Solely & Heolth Reporter
. ISec. 1910.1003(b) 110)1
m
E>E 004932
& F&
n&-
INTERNAL CORRESPONDENCE
BROWN-& ROOT, INC. P.O. Box 3370, Brownsville, Texas 78520
To (Name) Company Location
Copy
All Brown L Root Foremen Brownsville Plant
B. dock
/
G. Townsend/
jC*r
Date September 16, 1976 Originating Dept. Answering Letter'Date Subject DISPOSAL OF ASBESTOS
MATERIAL
1. All asbestos scrap and cleanings will be placed in Plastic Bags or other approved sealed containers. (Wet Material)
2. All containers of asbestos will be labeled in accordance with OSHA 1910 93 A
(We will use our "Stick on" label)
3. Stock pile all containers until we get'one or two dumpster loads to carry to the Port Dump.
4. Contact ^he Port the day before we plan to dispose of material.
Contact at Port: Capt. Gay
Phone:
831-4068
I would like for you or one of your Area Supt's be the person to contact Capt. Gay at the Port.
ALB/og
Thanks,
Ql
'/,{!'
A. L. Barefoot !
004933
AGREEMENT WITH BROWNSVILLE CITY LANDFILL TO RECEIVE ASBESTOS INSULATION
DE 004934
P. O. BOX 911
BROWNSVILLE, TEXAS 78520
DEPARTMENT OF PUBLIC HEALTH
December 5, 1979
K. Gran Townsend Environmental Protection Box 3370 Brownsville, Texas 71310
Dean. Ur. Townsend:
Attached is the letter rom Texas, Department o $ Health in regard to asbesto4, waste. As, you see they approve o& the disposal ofa asbestos in a landfill. There are several requirement* however, they can be eaiily met.
Before you bring asbestos fior disposal please call so I may coordinate and instruct they landfill employees in the proper procedure. The site to be used or the asbestos is at the new landfill site. This site is currently inaccessable. We expect to be in the neio site this mosith i& the weather permits.
Please call ii I can be oi further service.
Yours truly.
TLM/ams End. 1
Health Director
DE 004935
('
R.iyninnd T. Mime, M.D. Gimmosinru-r A. M. Donnell, |r,, M.D., M.P.H. Deputy Commissioner
NUV 2 3 1973
Texas Department of Health
1100 West 49th Street Austin, Texas 78756
(512)458-7111
Mr. Thomas Lamotte
Health Director P. 0. Box'911` Brownsville, Texas
78520
Subject:
Solid Waste - Cameron County City of Brownsville (Ebony) - Permit No. 1273 Acceptance of Asbestos
Members of the 8ojrd
Robert D. Morcton, Chjirnun William J. Foran, Vicc*Chairmjn Roderic M. Bell, Secretary Johnnie M. Benton IL Eu$rnc Brown Sitter Bernard Marie Bor/;mc><r Ramiro Gmn CJurlct Max Cole Francis A. Conley Ben M. Durr William J. Edwards Raymond C. Carrett Bob D. CIjjec Blanchard T. Hollins Laurancc N. Nickey Joe N. Pyle Kidurd W. RjKsda*e Isadore Roosth
Dunr Mr. !nmoctc:
We have received your October 11, 1979 letter requesting approval to accept asbestos waste. Your request is approved, subject to the following conditions:
1. . The generator shall provide personnel acquainted with the danger of asbestos to place the waste in the trench, unless the waste is in well-sealed barrels.
2. The site operator shall supervise the placement of the waste at the disposal site and give approval before covering.
3. In accordance with the National Emission Standards for Hazardous Air Pollutants, the asbestos is to be buried upon rcccy>_t with at least six inches of compacted earth. Tht* only exception to immediate cover is in the event a drum is accidently punctured, then a 24-hour delay is permissible to allow dust to settle.
4. The waste generator is responsible for the cleanup of any accidental spills within 24 hours of occurrence.
" 5. The site operator is to construct any berms or dikes necessary to divert runoff away from the trench.
6. The site operator shall keep records in accordance with the Texas Department of Water Resources order 7T*-ll25-t for all shipments of industrial (Class I) asbestos wastes.
DE 004936
Mr. Thomas Lnmotte City of Brownsville (Ebony) - Permit No. 1273 Page 2
7. The site operator shall file a monthly Special Waste Receipt Summary with the Texas Department of Health. If no special wastes are received, return the summary marked "NO SHIPMENTS RECEIVED". Copies of the Special Waste Receipt Summary are enclosed and additional copies may be obtained upon request.
8. In order to avoid excavation into the asbestos waste, the operator shall prepare an Affidavit to the Public at the time the asbestos disposal pit is closed. The affidavit shall show the exact metes and bounds of the area under which the asbestos is buried; and the site operator shall file this affidavit with the deed records in the County Clerk's office. A certified copy of the recorded deed supplement must be provided to this office within 30 days of recordation.
Mr. Jay Snow of the Texas Department of Water Resources stated in the enclosed copy of a May 4, 1979, letter to Mr. Bob Love that municipal landfills are suitable for the disposal of asbestos wastes and the Department of Water Resources would generally have no objection to a request filed with the Texas Department of Health for the disposal of asbestos wastes in municipal solid waste facilities.
We are enclosing a supply of Special Waste Receipt Summary forms. If you have any further questions concerning this matter, please feel free to contact Ms. Caroline Reynolds here in Austin or Mr. Hector Herrera, P.E., Regional Director of Environmental and Consumer Health Protection, P. 0. Box 592, Harlingen, Texas 78550; telephone number (512)423-0130.
Director Division of Solid Waste Management
CR:lac Enclosures
cc: Region 8, TDH Cameron County Health Department Brownsville City Health Officer Texas Department of Water Resources, Solid Waste Unit Texas Department of Water Resources, Enforcement and Field Support
DE 004937
ASl'.l'.S'i'Oa DISPOSAL
Asbestos disposal is-now rcgiil a ted by the To:;!.-: Air Control Hoard in accordance with the National lenission Standards for Hazardous Air Pollutants. Thu board should be notified prior to any asbestos disposal. Attached is an excerpt from these Standards which describes the requirements for asbestos wasce disposal sites. Asbestos from industries must be sent to an industrial waste disposal site under the jurisdiction of the Texas Department of Water Resources, unless prior written approval is received from the Texas Department of Health to dispose of the waste in a municipal solid waste site. 'The attached copy of a May 4, 1979, letter from Mr. Jay Snow states thac the Department of Water Resources believes that municipal landfills arc. suitable for the disposal of asbestos. Requests Tor approval to accept either municipal or industrial asbestos in a municipal solid waste site niust'be submitted by the site operator in accordance with Section F-2.*5 of the Department's regulations.
The waste generator, must contact the operator of a municipal solid waste site which is willing to acct-.pt waste thac will require special handling. Then the Site Operator must request approval of this Department before accepting this special waste.
The Department makes the following recommend;]cions for the guidance of sice operators preparing operat ional plans:
1. Recommended hauling procedure -
a. The generator should provide personnel, who arc acquainted with the danger of asbestos, to transport the waste and place it in the trench, unless barrels ace well-sealed. Polyethylene sheet tied over barrels and easily removable lids are not considered suitable, because they can become dislodged during transport or handling and allow unauthorized air emissions.
b. The site operator should supervise placement and give approval before covering.
c. In accorddhce with the National Emission Standards for Hazardous Air Pollutants, the asbestos waste is to he buried upon receipt with at least six inches of compacted >-arih.
d. The only exception to immediate rover would be in the event a drum is accidentally punctured, then up to a 24-hour -delay is permissible to allow dust to settle, before coverbegins.
e. "Ihe generator is responsible for rl-.-an-up of any ac.ci>\:'.tnl. spills witliir. 24 hours of occurrence.
f. The site operator is io construct any diPes; necessary to divert r:nof! away from the ircm-h.
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Sit*' requirements The area in which nsbcscos-contninine waste is to be placed should meet this Department's requirements in Subsection E-3.3e(4) for the protection of groundwater, including permeability, and shall be at least three feet above the water table. A slit trench is rccontncnded.
Recorii-keepinp, Asbestos has been classified Class I by the Texas Department of Water Resources. The site operator is to keep records in accordance with the Texas Department of Water Resources order 75-1125-1.
Sice Closure The operator shall prepare an Affidavit to the Public showing the exact metes and bounds of the area under which the asbestos is buried and record this instrument with the deed records in the County Clerk's office. A certified copy of the recorded deed supplement must be provided to this office within 30_ days of recordation.
Further recommendation If the disposal is on a continuing basis, warning signs should be displayed at intervals of 300 feet or less along the perimeter of the areas of land where asbestos-containing waste is being or has been deposited. The signs should be posted in such a manner and location that a person may easily read the legend: ASBESTOS WASTE DISPOSAL SITE DO NOT CREATE DUST BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH The warning signs should be 20" x 14" in an up-right format, with letter_si7.es and styles of a visibility at least equal to those described in paragraph 61.25(h) of the National Emission Standards for Hazardous Air Pollutants.
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nay 4, 1970
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Mr. Dob Love, E.il.S. Texas AiT Control Board 8520 Shoal Creek Blvd. Austin,`Texas 78750
Dear Mr. Love:
RE: Telephone Conversation 04-02-79
As a fo.llow-up to our recent telephone conversation, this i r; to aquaint you with the Department's practice's regarding the di r.pos l). of asbestos wastes.
The Department's waste classification (indicating degree? of hazard) and corresponding handling and disposal requirements vary in rela tion to the form of the waste material. Asbestos, a naturally occuring mineral, is inert and insoluablc, but has betn shown to present health hazards when in particulate form. Asbestos fibers immersed in an artificial or natural binder materia] arc inert and pose no threat to human health or the environment. This form normally receives a Class III industrial solid waste designation.
The fibrous form, however, is hazardous and thus is routinely de signated Class I. This form requires special precautions in its management. The asbestos fibers should be containerized in barrels fiber drums, or jyuitable plastic linns and covered with soil imme diately upon arrival a t a land fill"!Municipal land fills a`t suit able for this purpose and the Department of Wai.ec Resources would generally have no objection to a request Filed with the Texas Department of health For the disposal of ashesles wastes in muni cipal solid waste facilities.
For your informal i on J am enclosing tin i;ejMiLi-.-ni of 'run.rules regulating the transportation of iliable asbestos and
of commercial r.i Les permi tied by the Ik-irLinenf of Wafer for the disposal of Class r, II* or I I.J wastes.
. . it. io a list
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Mr . Iiob I.nvc, iH. r>. S . May 4, 1?7!>
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If you have any-qitcc I tons or comments, please ieel free to cali Mr. Moody Fickard of the Solid Waste bn it at AC 512/475 2041. Sincerely, Jay Snow, P.E.., Head Sptid Waste Unit EMP/mlk . cc: .Jac'.t Carmichael, i'.:'.
Texas Department of Heal Lh
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