Document YrNkYG9NO1Dwdgp8pG4LkOQ8y

.folM/ r*fr. L ' <^r t r'" ' * UNION * CARBIDE AA AA A INTERNAL CORRESPONDENCE SPECIALTY CHEMICALS DIVISION LOCATION 514 South Charleston, WV 25303 TO: H. W. Wegert G. M. Whipple COPY: J. R. Dement J. F. Dodd FROM: 0. K. Corrie DATE: July 7, 1987 SUBJECT: Environmental Review of the Attached is the revised South Charleston Plant Maintenance Safety Procedure XVIII - Asbestos Handling. As indicated in Dennis Hanshew's letter of May 6, 1987, also attached, I trust that you will find that the revised procedure addresses the concerns you outlined in your review report dated October 30, 1986. As your endorsement of the South Charleston Plant Asbestos Insulation Upgrade Project was contingent upon those concerns being satisfied, I am requesting that you notify J. R. Dement and J. F. Dodd of your final endorsement or of any additional concerns you may have. 0KC:mb Attachment 0517a UCC 006674 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: XVIII DATE: 2/87 PAGE 1 Of-20______ A. PURPOSE To provide protection to plant and community personnel from the hazards of asbestos and to assure compliance with all plant, state and federal regulations. Asbestos releases to the environment, including air, ground and water, are covered by Superfund regulations. A release of one pound or more of asbestos to the environment (air, ground, or water) must be reported by the plant Environmental Protection Department to the National Response Center, Washington, D.C., the West Virginia Department of Natural Resources, if to the ground or water, and to the West Virginia Air Pollution Control Commission if to the air. Any incident requiring a report to a government agency also requires notification of Division and Corporate officers. This is a mandatory procedure and applies to all maintenance personnel and any person who removes asbestos. B. DEFINITIONS 1. Asbestos - A fire resistant fibrous mineral used in fireproofing. Insulation, brake linings, floor tile, ceiling tile, roofing, and siding which in dust form may be Inhaled to produce a debilitating lung disease called "asbestosis". 2. Exposure Limits - Maximum quantities of airborne asbestos fibers to which a worker may be exposed, by law. Present OSHA permissible exposure limit (PEL) (June, 1986): During an eight-hour period, the time-weighted average shall not exceed 0.2 fibers, longer than five micrometers, per cubic centimeter of air. 3. Action Level - An airborne concentration of asbestos, tremolite, anthophyllite, actinolite, or a combination of these materials of 0.1 fiber per cubic centimeter (f/cc of air calculated as an eight hour time weighted average). 4. Regulated Area - An area established by the employer to define where airborne concentrations of asbestos exceed or can reasonably be expected to exceed the permissible exposure limit. High-efficiency particulate air (HEPA) filter - A filter capable of trapping and retaining at least 99.97 percent of all monodispersed particles of 0.3 micrometers in diameter or larger. UCC 006675 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO,: XVIII DATE: 2/87 PAGE 2 of 20 B. DEFINITIONS (continued) 6. Renovation - The modifying of any existing structure or portion thereof where exposure to airborne asbestos, tremoiite, antophyllite, actlnollte may result. 7. Demolition - The wrecking or taking out of any load supporting structural member and any related razing, removing, or stripping of asbestos, tremoiite, antophyllite, or actinolite products. C. RESPONSIBILITIES 1. Craftsperson - It is the responsibility of any person working with asbestos to know the health hazards involved and take all necessary precautions to protect themselves, others, and the environment. Each craftsperson shall: a. Attend/understand the asbestos training (TRAINS 514-3022 and 514- ) b. Wear protective equipment as required c. Follow this procedure d. Challenge improper methods and actions by others e. Review the HSDS for asbestos 2. First Line Supervisor - It Is the responsibility of the job supervisor to: a. Provide training for all subordinates In the health hazards and proper safeguards of asbestos removal and disposal as outlined in this procedure. b. Assure compliance with this procedure for all jobs under his/her supervision. c. Notify the Safety/Health Department, extension 2434, of each job to provide monitoring opportunity. Initial IH monitoring must be performed on jobs where negative pressure respirators are used. d. Notify the plant Environmental Protection Department as required (see D.l.c.). e. File a completed checklist upon job completion and distribute as indicated on the checklist. UCC 006676 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: XVIII DATE: 2lW PAGE 3 of 20 C. RESPONSIBILITIES (continued) 3. Area Superintendent - It is the responsibility of the Area Superin tendent of the geographic area in which the job occurs to audit all asbestos stripping jobs performed by Maintenance Department insulators and consisting of 160 or more square feet or 260 or more linear feet of insulation. The Area Superintendent(s) with responsibility for Insulators shall audit asbestos stripping jobs as required to assure compliance with this procedure. 4. Competent Person - It is the responsibility of the competent person to Identify or to cause identification of existing asbestos and to take prompt corrective actions to eliminate or reduce the hazards of asbestos. The duties of the competent person Include the establish ment of negative - pressure enclosures, ensuring their Integrity, and controlling entry to and exit from the enclosures, supervising any employee exposure monitoring required by the standard, ensuring that all employees working within such an enclosure wear the appropriate personal protective equipment, are trained in the use of appropriate methods of exposure control, and use the hygiene and decontamination procedures specified in the standard; and ensuring that engineering controls in use are in proper operating condition and are functioning properly. D. PROCEDURE 1. Job Sequence a. Examine job for asbestos content. Consider sampling and analysis for content if time permits. If there is uncertainty regarding the presence of asbestos, the material shall be treated as if it is asbestos. b. Notify the designated competent person. ` c. Notify the plant Environmental Protection Department, ext. 3144, to ensure enough lead time for governmental notification. See the attached Environmental Asbestos Removal Notification Requirements in Appendix I & II for specifics. d. Notify the owner of the equipment and/or piping to be stripped. Contact the Safety/Health Department to schedule monitoring. e. Obtain necessary permits/permission (HWP and/or MC/LO). NOTE; A Class B Hazardous Work Permit Is required per S/H - Procedure 2.3. , UCC 006677 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: XVIII DATE: 2/67 PAGE 4 of 20 D. PROCEDURE (continued) 1. Job Seauence (continued) f. Check with the Plant EPD Department to ensure waste disposal site has been established. g. Place proper barricades and warning signs. h. Don proper protective equipment (clothing and respiratory protectionXsee D.7. and D.8.). 1. Prepare the work area (see D.2.). j. Strip insulation (see D.3., D.4., and D.5.). k. Remove asbestos to appropriate containers for disposal (See D.10.). l. Clean up the work area (see D.6. and D.IO). m. Remove coveralls and place in labeled bags for disposal D.6.). (See n. Remove barricades and signs. o. Clear permits and notify owner of job completion. p. Complete checklist and distribute. UCC 006678 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: XVIII DATE: 2/87 PAGE 5 of 20 D. PROCEDURE (continued) 2. Respiratory Protection a. Employees engaged in the handling or removal of asbestoscontalning material will wear NIOSH approved respiratory protection. Employees must have received medical qualification for wearing 7 respiratory protection within the previous 12 months. Employees must have received qualitative fit testing for the type of respirator they are using within the previous six (6) months and must have received training for S/H Procedure 2.19 and the type of respirator being used within the previous 12 months. b. The following respirators are approved for use in asbestos service at the South Charleston Plant: o Half mask air-purifying respirators with-high efficiency filters (HEPA) Survivair R #1090-00 or North Safety Equipment #7500-8. Mask bodies are the Survivair^ Series 2000 and the North Model 7700-30M. Initial IH monitoring must be conducted on all employees wearing these respirators. I o Full-face powered air purifying respirators (PAPR) approved by the Safety/Health Department may be used. Only the RacalR "Powerflow" with a HEPA filter is approved for South Charleston personnel. Contractors and other non-plant personnel are not limited to this model, but may use other PAPRs for asbestos application. Initial IH monitoring is also required for employees who wear PAPR's. o Full facepiece supplied air respirators operated in the pressure demand mode and equipped with an auxiliary positive pressure self-contained breathing apparatus (SCBA) are to be used in emergency situations and at asbestos levels above 1,000 times the permissible exposure limit. No industrial hygiene monitoring of wearer is required if SCBAs are used, although area monitoring may be required. Approved respirators are shown in Table I. UCC 006679 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 6 of 20 D. PROCEDURE (continued) 3. Protective Clothing - Small Scale , a. Protective clothing consisting of gloves, disposable overshoes or rubber boots and hooded disposable coveralls which have been taped at wrist and ankle openings to ensure proper seal will be used on all small scale jobs involving the handling or removal of asbestos containing material. b. Before leaving the barricaded area, the protective clothing worn by the employee must be removed and properly disposed of in properly labeled disposal bags. If rubber boots are used they shall be washed and cleaned prior to leaving the barricaded area. c. Employees involved in small scale asbestos removal work must wash their face and hands prior to eating or smoking. d. Employees involved in small scale asbestos removal work during their work shift must shower before leaving the plant e. If a glove bag ruptures, the employee must shower immediately after completion of the glove bag job. 4. Protective Clothing --Large Scale a. Protective clothing consisting of gloves, disposable overshoes or rubber boots and hooded disposable coveralls which have been taped at wrist and ankle openings to ensure proper seal will be used on all large scale jobs involving the handling or removal of asbestos containing material. b. Protective clothing shall be removed prior to exiting the regulated area and placed in labeled bags for disposal. If rubber boots are used they shall be washed and cleaned prior to leaving the regulated area. c. Employees involved in large scale asbestos removal work must exit the regulated area and shower prior to eating or smoking. d. Work clothing used by insulators will be stored in separate lockers away from their street clothing. UCC 006680 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 7 of 20 D. PROCEDURE (continued) 4. Protective Clothing - Large Scale (continued) e. Employees involved in large scale asbestos removal work must shower before leaving the regulated area. The showers shall be contiguous both to the work area where asbestos removal is being conducted and the clean change rooms unless the location is not feasible. f. When contiguous shower facilities are infeasible, employees must clean worksuits with HEPA equipped vacuum before proceeding to remote shower or employees remove contaminated worksuits and don clean worksuits before going to remote shower. Contaminated clothing must be removed and placed into properly labeled bags. 5. General Practices a. No asbestos removal work is to be initiated without wearing proper respiratory protection and industrial hygiene monitoring. b. When partial removal of asbestos is required, for whatever reason, exposed ends or edges of any insulation left in place shall be sealed. c. Insofar as practical. Insulation containing asbestos shall be thoroughly wetted before removal to prevent the release of airborne fibers. Plastic shall be used to enclose the area being stripped and the removed insulation shall be mist-sprayed with water. Strip the insulation and carefully place into labeled plastic bags. d. Wetting of asbestos insulation shall be done in such a manner as not to wash the fibers into the ground, trenches, sewers, or waterways. e. All enclosed and bagged insulation must not be dropped to the around. It should be carefully lowered to avoid loss of asbestos to the environment. UCC 006681 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING -NO.: DATE: PAGE XVIII 2/87 8 of 20 D. PROCEDURE (continued) 6. Preparing the Work Area a. The work area is to be roped off with yellow barricade tape during the course of any work involving asbestos and all movable objects shall be removed from the work area to prevent unnecessary contaminations. Warning signs are to be posted at each barricaded area to warn any employee desiring to enter the area so he/she can take the necessary precautions. Warning signs are to state: DANGER - ASBESTOS: CANCER AND LUNG DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA. The barricade tape and warning signs are to remain in place until the job is complete. b. Where feasible, establish negative pressure enclosures before commencing removal, demolition, and renovation operations (large scale jobs). Consideration shall be given to enclosing small jobs (less than 5 feet). Note: Inability or impracticality of enclosing structures within a single enclosure does not by itself mean that enclosures are infeasible. In such a case, the feasibility of several smaller enclosures must be considered. If it is physically possible to establish the smaller enclosures, then they are to be constructed and the removal is to be done section by section. c. Access to regulated areas shall be limited to authorized persons. Approval must be obtained from the Plant Industrial Hygienist prior to initial entry and from the competent person for entry at the beginning of each workday. d. The work area shall be covered with plastic sheeting to contain the asbestos. Over grating, this will prevent the asbestos from filtering through into other work areas and exposing other employees to the hazards of asbestos. On slagged areas, this will prevent mixing of asbestos with the slag, allowing easier cleanup and will not leave asbestos residues on the ground. e. Necessary precautions will be taken to ensure that asbestos does not enter sewers or trenches or any waterway. UCC 006682 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 9 of 20 D. PROCEDURE (continued) 7. Stripping Insulation - Small Scale a. Remove from the work area all objects that are non-essential and are movable to protect them from asbestos contamination. b. Objects that cannot be removed from the work area must be covered completely with 6-mil thick polyethylene plastic sheeting before the task begins. Contaminated objects must be cleaned with a High Efficiency Particulate Air (HEPA) filtered vacuum or be wet wiped before they are removed from the work area or completely encased in the plastic. c. The employees who are performing the removal must wear proper protective clothing (see D.7), proper respiratory protection (see D.9) and be monitored for personal exposure. ' d. Install a glove bag so that it completely covers the pipe or other structure where asbestos work is being done. Glove bags are installed by cutting the sides of the glove bag to fit the size of the pipe where the asbestos is to be removed. Attach the glove bag to the pipe by folding the open edges together and secure them with tape. All openings in the glove bag must be sealed with duct tape or equivalent. The bottom seam must also be sealed with duct tape to prevent leakage. e. Met the asbestos containing material that is to be removed. Hetting agents must be continually used throughout the work period to ensure that any dry asbestos-containing material exposed in the course of the work is wet and remains wet until final disposal. f. The removed asbestos material from the pipe or other surface that has fallen into the enclosed bag must be thoroughly wetted with a wetting agent (applied with an airless sprayer through a pre-cut port or applied through a small cut in the bag). g. After removal of the layer of asbestos containing material, the pipe or surface must be thoroughly cleaned with a wire brush and wet wiped with a wetting agent until no traces of the asbestos containing material can be seen. h. Any asbestos containing insulation edges that are exposed must be encapsulated to ensure no release of fibers upon removal of the glove bag. UCC 006683 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 10 of 20 D. PROCEDURE (continued) 7. Stripping Insulation - Small Scale (continued) i. Upon completion of the small scale job, a vacuum hose from a HEPA filtered vacuum must be Inserted into the glove bag through the port to remove any asbestos-containing air in the bag. When the air has been removed from the bag, the bag should be squeezed tightly, twisted, and sealed with tape, to keep the asbestos material safely in the bottom of the bag. The HEPA vacuum can then be removed from the bag and the glove bag itself can be removed from the work area to be disposed of properly. 8. Stripping Insulation (Large Scale) A negative pressure enclosure and hygienic area must be constructed for all large scale jobs If feasible. The feasibility of enclosure shall be determined by the competent person and the owning Department Head. An example of how a negative pressure enclosure and how a hygienic area is constructed is provided in Appendix III. 9. Cleanup a. All asbestos Insulation will be bagged in the area in which it is removed. Careful handling to avoid creating dust and airborne fibers is imperative. b. Insofar as practical, removed insulation shall be wetted and placed directly into labeled plastic bags. Otherwise, place plastic sheeting beneath the job site, mist spray the removed insulation with water and then place in plastic bags. When wet methods of removal/cleanup are impractical, e.g., when temperatures are below freezing, vacuuming may serve as an effective alternate cleanup method. NOTE: HEPA equipped vacuums must be used. c. All external surfaces shall be maintained free of accumulation of asbestos fibers. Special attention should be given to cleaning scaffolds used in stripping work. d. If asbestos insulation adheres to removed jacketing material and cannot be completely removed, the jacketing material shall also be placed in labeled bags for disposal. UCC 006684 .MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PUNT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 11 of 20 D. PROCEDURE (continued) 9. Cleanup (continued) e. Sealed bags of asbestos-containing material shall be placed in specially-marked plastic tubs, other temporary containers, or dumpsters at the job site. If plastic tubs or other containers are used, they are to be taken to the specially-marked dumpsters and emptied as they are filled. All bagged material shall be removed from the job site and placed in dumpsters each day. 10. Disposal Bags All asbestos-containing material, including contaminated gloves, disposable coveralls, and respirator cartridges shall be placed and sealed in Impermeable plastic bags properly labeled as below: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD ORM-C Disposal bags shall be made available in all asbestos work and change areas where contaminated clothing is removed. 11. Disposal bv Trucking a. The insulator supervisor shall notify the Trucking Department to have asbestos dumpsters emptied. Dumpsters must be securely covered and free of water or they will not be admitted to the permitted landfill. b. Non-RCRA hazardous waste manifests will be prepared and retained by the Trucking Department and approved by the Environmental Protection Department. Before exiting the plant with waste asbestos material, truck drivers must have in their possession a properly prepared manifest as prescribed by the Plant 514 Haste Disposal Procedure. UCC 006685 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 12 of 20 D. PROCEDURE (continued) 12, Emergency Removal of Asbestos The minimum employee protection required for removal of asbestos under emergency conditions is air supplied respirators equipped with positive pressure demand capabilities and disposable coveralls which have been properly fitted and sealed. No industrial hygiene monitoring will be required under emergency situations. The work area shall be barricaded and warning signs shall be in place. E. TRAINING 1. All maintenance personnel shall receive annual training covering the following information prior to or at Initial assignment. The training shall be documented in the TRAINS program (514-3022). a. The health effects associated with asbestos exposure. b. The relationship between asbestos exposure and smoking in producing lung cancer. c. OSHA exposure limits. d. The nature of operations which could result in asbestos exposure and the necessary protective steps to minimize exposure. e. The purpose and limitations of the respirators used to protect against asbestos exposure. f. The appropriate work practices for performing the asbestos job. 2. All employees expected to be exposed to airborne asbestos at or above the action level of 0.1 fibers/cc, whether protected by respirators or not, shall receive annual training in this procedure (Maintenance Safety Procedure XVIII). The training shall be documented in the TRAINS program (514- ), shall meet the training requirements of 29 CFR 1926.58, and shall include the following information topics: a. Health effects associated with asbestos exposure. b. Relationship between exposure to asbestos and smoking in producing lung cancer. UCC 006686 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PUNT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XV} II 2/87 13 of 20____ __ E. TRAINING (continued) 2. c. Nature of operations which could result in exposure to asbestos and necessary protective steps to minimize exposure including, as applicable, engineering controls, work practices, respirators, housekeeping and protective clothing. d. OSHA exposure limits. e. Purpose, proper use, fitting instructions, and limitations of the respirators used to protect against asbestos fibers. f. Review of all provisions contained in 29 CFR 1910.1001, Asbestos. g. Purpose for and description of the asbestos medical surveillance program. h. Instructions for handling spills as well as emergency and clean-up procedures. i. The importance of preventing releases of asbestos to the environment and the potential consequences of failing to do so. j. The proper use of protective clothing. k. Appropriate work practices for performing an asbestos job. 3. Available training aids to be used as resources: 514 Lesson Plans manual S/H Department approved video for item 1. F. AUDIT It shall be the responsibility of each Area Superintendent involved in asbestos material removal to schedule a quarterly audit of this procedure. A suggested audit form is attached (same as checklist). UCC 006687 MAINTENANCE SAFETY MANUAL SOUTH CHARLESTON PLANT SUBJECT: ASBESTOS HANDLING NO.: DATE: PAGE XVIII 2/87 14 of 20 G. Contractor Requirements Contractors who perform asbestos removal projects shall comply with all requirements of 1926.58 (Asbestos Construction Standard - 1986), South Charleston Plant Safety and Health Procedures and the South Charleston Plant Provisions for Asbestos Material Removal and Disposal. The contractor will be responsible for informing and training his employees on the potential hazards of asbestos as specified in the construction standard. The plant Industrial Hygienist shall review and approve the contractor's procedures for asbestos removal operations prior to initiation of large scale projects and must be informed of any asbestos removal task prior to their arrival in the plant. 0017T UCC 006688 CHECK LIST FOR ASBESTOS REHQVAL/DISPOSAL AREA ZONE _______________________ BLDG __________ UNIT __________ DATE OOB DESCRIPTION _______________________________________________________________ ESTIMATED LINEAL FEET REMOVED OOB SUPERVISOR NAMES OF PEOPLE INVOLVED IN ACTUAL JOBS _________________ _ Safety/Health Department notified Plant EP Department notified Competent person notified Proper Environmental Notifications made (APCC, EPA, DNR, & Health Department) Negative pressure enclosure in place Hygienic area in place Barrier tape used Warning signs used Protective clothing used Respirators used Drop cloth used Asbestos wetted during stripping Proper disposal - (bags to landfill) Proper clean-up (area housekeeping) Barricades down (after clean-up only) YES NQ N/A COMMENTS Completed copy to: Area Supt-------Competent Person ____ Audit performed by: UCC 006689 TABLE 1 RESPIRATORY PROTECTION FOR ASBESTOS. TREMOLITE. AND ACTINOLITE FIBERS Airborne Concentration of Subject Materials or Combination of these Materials Required Respirator 1. Not in excess of 2 f/cc (10 X PEL) 2. Not in excess of 10 f/cc (50 X PEL) 3. Not in excess of 20 f/cc (100 X PEL) 4. Not in excess of 200 f/cc (1000 X PEL) 5. Greater than 200 f/cc (greater than 1000 X PEL) or unknown concentration) 1. Half-mask air-purifying respirator equipped with high-efficiency filters. 1. Full facepiece air purifying respirator high-efficiency filters. 1. Any powered air-purifying respirator (PAPR) equipped with high efficiency filters. 2. Any supplied-air respirator operated in continuous flow mode. 1. Full facepiece supplied air respirator operated in pressure demand mode. 1. Full facepiece supplied air respirator operated in pressure demand mode and equipped with an auxiliary positive pressure selfcontained breathing apparatus. It UCC 006690 APPENDIX I Environmental Asbestos Removal Notification Requirements The HVAPCC has developed an Asbestos Removal Notification form (Appendix ID) that is to be used for all asbestos demolition/renovation projects within the State of West Virginia. The WVAPCC has specified that notices of asbestos demolition/renovation shall be delivered to WVAPCC as follows: 1) At least 10 days before demolition begins, if such demolition involves friable asbestos materials in the amounts of at least 260 linear feet on pipes or at least 160 square feet on other facility components, 2) At least 20 days before demolition begins, if such demolition involves friable asbestos materials in the amounts of less than 260 linear feet on pipes and less than 160 square feet on other facility components, 3) At least 1 day before demolition begins, if such demolition is being conducted under order of a State of local government agency because of the danger of imminent collapse, 4) At least 1 day before renovation begins, if such renovation involves friable asbestos materials in the amounts of at least 260 linear feet on pipes or at least 160 square feet on other facility components, and 5) At least 1 day before renovation begins, if such renovation involves friable asbestos materials in the amounts - such that the predicted additive amounts over a period of time (not to exceed one year) - are at least 260 linear feet on pipes or at least 160 square feet on other facility components. All completed Asbestos Removal Notification forms are to be approved by the Environmental Protection Coordinator, J. L. Worstell. In order to meet all the above notification requirements, EPD must receive the completed Asbestos Removal Notification form at least 5 working days prior to the WVAPCC's required delivery date for notification of the demolition/renovation project. At the same time EPD must be given an estimate of the total amount of asbestos waste in units of cubic yards. There will be NO EXCEPTIONS to this policy, excluding demolitions conducted under order of State or local government agencies because of the danger of imminent collapse. UCC 006691 WEST VIRGINIA AIR POLLUTION CONTROL COMMISSION 1558 Washington Stmt, Earl CHARLESTON, WEST VIRGINIA 25311 TELEPHONE: 348-Z275 OR 348-3286 ASBESTOS REMOVAL NOTIFICATION APPENDIX II Page 18 RENOVATION DEMOLITION .......-- DATE . NAME OWNER/OPERATOR_________________________________________________ ADDRESS/PHONE_____________________________________________________________ PHONE # {) NAME CONTRACTOR_______________________________________________________ ADDRESS/PHONE_____________________________________________________________ PHONE # () LOCATION OF FACILITY/ADDRESS SCHEDULED STARTING AND COMPLETION DATES OF DEMOLITION OR RENOVATION: STARTING COMPLETION IS FACILITY BEING DEMOLISHED UNDER AN ORDER OF A STATE OR LOCAL GOVERNMENT AGENCY? { ) NO ( ) YES IF YES, WHAT AGENCY - INCLUDE NAME, TITLE AND AUTHORITY: APPROXIMATE AMOUNT OF FRIABLE ASBESTOS CONTAINING MATERIAL(ACM): ft2 used to cover or coat any duct, boiler, tank, furnace, structural member, etc. linear ft on pipes Estimation techniques of amounts of ACM at demolitions for quantities less than 260 linear ft and/or 160 ft2 ______________________________________________ ___ DESCRIPTION OF FACILITY: Prior Use Age__________ Size _________ LOCATION OF ACM IN FACILITY AND METHODS OF PLANNED DEMOLITION OR RENOVATION: _____ ____________________ ________ __ UCC 006692 Pfltfp 1 of 9. Page 19 PROCEDURES TO BE USED TO COMPLY WITH SLBPART M - NATIONAL EMISSION STANDARD FOR ASBESTOS (40 CFK): LAB TESTING BY:_______________________ ADDRESS/PHONE________________________________ NAME/LOCATION OF WASTE DISPOSAL SITE: SITE APPROVED BY DNR: COMMENTS: ( ) NO ( ) YES Permit SIGNATURE: TITLE: In addition to the West Virginia Air Pollution Control Commission, a copy of this notice must be sent to the following agencies: U. S. Environmental Protection Agency Region III (3AM22) 841 Chestnut building Philadelphia, Pennsylvania 19107 5 Attn: Asbestos/NESHAP Coordinator Solid Waste Office Division of Water Resources ' WV Department of Natural Resources 1260 Greenbrier Street Charleston, West Virginia 25311 Attn: Asbestos Coordinator Asbestos Control WV Health Department 4877 Brenda Lane Charleston, West Virginia 25312 Attn: Asbestos Coordinator APCC-ARN-3/86 UCC 006693 Page 2 of 2 APPENDIX III CONSTRUCTION OF NEGATIVE PRESSURE ENCLOSURE AND HYGIENIC AREA A. Constructing the enclosure - When all objects have been removed from the work area or covered with plastic, all penetrations must be sealed with 6-mil plastic and tape to prevent airborne asbestos from escaping into outside areas. Penetrations that require sealing are typically around electrical conduits, telephone wires, water supply and drain pipes. ' B. Establish a single entrance for access and egress to the work area. Seal all other entrances with 6-mll plastic and tape. C. All exposed surfaces such as support columns, ledges, and other surfaces should also be covered with plastic sheeting prior to the construction of the walls. D. Next a thin layer of spray adhesive should be sprayed along the walls surrounding the enclosed work area and a layer of polyethylene plastic sheeting should be attached to the adhesive and taped. The entire inside surface of all wall areas are covered in this manner. E. Finally, the sheeting covering the walls is extended across the floor area until it meets In the center of the area, where it is taped to form a single layer. F. A final layer of plastic sheeting is then laid across the plastic covered floor and up to the walls about two (2) feet. This layer provides a second layer of plastic sheeting over the floor which can then be removed and disposed of easily. G. After construction of the enclosure, a ventilation system must be installed within the enclosure which is equipped with HEPA filters. A sufficient amount of air should be exhausted to create a negative pressure of 0.02 inches of water. NOTE: No asbestos tasks are to be performed without . wearing proper respirator protection and industrial hygiene monitoring. H. Constructing the hygienic area - Contiguous if feasible to the negative pressure enclosure, hygiene facilities which are to be used to decontaminate asbestos-exposed workers, equipment, and clothing before the employees leave the work area must be made available. UCC 006694 APPENDIX III (continued) CONSTRUCTION OF NEGATIVE PRESSURE ENCLOSURE AND HYGIENIC AREA (continued) I. The hygiene facilities shall consist of a clean change room, a shower, and an equipment room. The clean change Is an area In which employees can remove their street clothing and don their respirators and disposable protective clothing. J. The shower should be contiguous with both the clean and dirty change rooms and must be used by all workers leaving the work area. Note: All employees must shower and change clothes prior to leaving the worksite. K. The equipment room (dirty room) should be lined with 6--ml 1 plastic in the same way as was done In the work area. The shower room and the clean change room do not have to be lined with plastic material. L. After the structure has been checked and approved by the Competent Person or the Plant Industrial Hygienist, the removal project can be initiated. UCC 006695 . (< Y r \ </t* South Charleston Plant ^ 8 1987 MA,^AHCF ofpt N VI It ON M liS 'IW *. K(>TH( TION Bldg. 406 - 2nd. Floor South Charleston, WV 25303 TO: J. R. Dement DATE: May 6, 1987 COPY: J. R. Solce J. L.Worstell EPD Staff (Circulate) SUBJECT: ENVIRONMENTAL CONCERNS FROM THE HEALTH, SAFETY, AND ENVIRONMENTAL REVIEW INSULATION UPGRADE PROJECT. SOUTH CHARLESTON REFERENCE: MEMO TO J. R. DEMENT FROM H. W. WEGERT & G. M. WHIPPLE DATED 10-30-86 I have reviewed the subject memo, in conjunction with the Maintenance Safety Procedure XVIII - Asbestos Handling, and have the following comments about Messers Wegert's and Whipple's concerns: CONCERN 1 - No reference to WVAPCC Regulation 15: PageJ^-of Safety Procedure XVIII Is a checklist for asbestos removal/disposal which specifically asks If: Proper Environmental Notifications made ___ YES ___ NO ___ N/A (APCC, EPA, DNR, and Health Department) /7 Appendix I on page J-& of Safety Procedure XVIII lists the required delivery times for asbestos notifications. Appendix II on pages and^ Is a copy of the WVAPCC Asbestos Removal Notification form. Although there Is no specific mention of "Regulation 15", I believe Safety Procedure XVIII adequately addresses the requirements of Regulation 15. UCC 006696 2 CONCERN 2 - No reference to the State requirement of notification to the DNR prior to landfilling asbestos: /& /<? Appendix II (pages J-? and J&f Is the WVAPCC Asbestos Removal Notification form. This page of the form states that In addition to the WVAPCC, copies of the form must be sent to EPA, DNR, and the Health Department. It Is the practice of the EPD to send the notification form to those four agencies. There are no known regulatory requirements that DNR or the Department of Health be notified of asbestos removal projects. Notification to the DNR and to the Department of Health of' asbestos removal projects has always been done as a courtesy. Again, Safety Procedure XVIII adequately addresses all notification requirements. CONCERN 3 - No reference to NESHAPs 40 CFR 61.152 and 61.156, pertaining to disposal container labels and warning signs at landfills. 61.152(b)(1v) of NESHAPs outlines a label to be used on disposal containers: CAUTION * CONTAINS ASBESTOS AVOID OPENING OR BREAKING CONTAINER BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH However, 61.152{b)(iv) further states in part, "Alternatively, use warning labels specified by___ (OSHA) -------" 61.156(b) and (c) state that a landfill must have: 1) A natural barrier to deter access by the general public, or 2) warning signs and fencing, or 3) covered the waste asbestos with at least 6 Inches of non-containing asbestos materials at least once every 24 hours. Thus, the NESHAPs regulation does not automatically require warning signs at all landfills. However, most landfills that accept asbestos wastes do have warning signs (as does Goff Mountain Landfill, which Is Plant 514's present asbestos disposal site). In summary, Safety Procedure XVIII is more than adequate from an environmental viewpoint. I believe the Health, Safety, and Environmental Review team reviewed a 4th Q or earlier draft of Safety Procedure XVIII - not the final review draft dated February, 1987. UCC 006697 3 To Insure that disposal needs for the Insulation upgrade project are met, EPD needs an estimate (In cubic yards) of the disposal loads. This estimate should be broken down Into a monthly schedule. In accordance with Safety Procedure XVIII, an estimate of the disposal load in cubic yards Is a prerequisite for obtaining an approved Asbestos Removal Notlflcaqatlon from EPD. As noted In previous correspondence to you from J. L. Worstell (dated October 27, 1986, and January 28, 1987,) EPD recommends that no additional large-scale Insulation removal jobs be undertaken until a suitable disposal site Is available. Goff Mountain will soon phase out accepting asbesto Insulation on a routine basis (except for chemical-saturated Insulation). Purchasing has recently contacted several landfills to obtain Information on availability, standards, cost and etc. However, as of this date no alternative landfill has been located. DHH/rls 0093H Dennis H. Hanshew UCC 006698 106 Dept. No. ACCIDENT/INCIDENT REPORT South Chorleston Plont (See Safety/Health Procedure #2) ^/j-- Report No. 106-069-87 Department: Polyol S Dote Reported: 5/21/87 Location: 643-644 tanks - N.W. 103 Dote of Occurrence: 5/21/87 Time: ApprOX. 0500 Description of Accideni^cjent^) #1 Rx was dumping to 643 tank which was covered in plastic for Asbestos insulation removal. Contractors were checking the job prior to working and smelled a strong odor. OC Remit: Check Applicable Squares j o CD Injury CD Spill/Emission QOH Exposure (OSHA Reg. Substance) Qfl Incident (Near-Miss) > Fire/Explosion O Product Contamination (3 Other OH related Incident fDOther _......... . .. LU Q Equipment Damage CD Production Loss Q_ =3 (/> Basic Cause: Check Applicable Squares HI Pfrfqrmgnce Error < a CD Knowledge/Skill CD Execution/Motivation 5 D Physlcat/Mental (See back of report) Procedure Error JO Lack of/In adequate Eauipment/Material/Focility Error 0 Improper Design 0 Inadequate Maintenance 0 Normal Wear & Tear Immediate Action Taken & Suggestions to Prevent Recurrence: Activated sprinkler system on N.W. end of 103 and monitored. Informed Emergency Director and set up road barricades. Isolate tanks from use when needing to be covered with plastic for asbestos removal. Signature: T. A. Stinespring Data: 5/21/87 Loss Analysis: ESTIMATED $ LOSS (If Material Loss Occurred, Check Applicable Squares) MAJOR LOSS AREA: A. $ B. $ c. $ D. $ a u<i E. $ x F. $ -...........- Material Loss Lbs. Lost To; O Air Loss Severity Potential: 0 Critical Product Contamination (Mixup, Rerun, 0 Landfill Ground 0 Serious D Minor i hi. O Process Sewer Probable Recurrence: FJre/Fxplosion Lass G Coaling Water Sewer 0 Powerhouse 0 Frequent 0 Occasional Resulted In': O Rare Equipment Damage Loss 0SCWTW Upset/Diversion Production Lass -Bus inass Inter ruption ($ Gross Margin Loss) 0 Permit Violation Community/Agency Contact TOTAL VALUE OF LOSS Composition of Material Loss 0 Runaway Reaction 0 Fuel-Oxidizer Present 0 Vapor Cloud 0 Start-up or Shut down Activity 0 Boiler Control Failure Z111 Additional Action: What additional action is planned to avoid this type occurrence in the s.I- future? Include both immediate and long range plans, studies, assign 0< ments, etc. Responsibilities? Completion dotes? Attach additional a. sheet if necessary. uai Refer to attached. Accountability. Target Date For Completion rv ] i---------^ ko TT.. OCheck square if o Review Board will convene Signature:. Consider-is this a confined space? jm1 cappUCC 006699 UNI N CARBIDE CORPORATION SOUvd CHARLESTON PUNT (514) "Informal" REVIEW BOARD ANALYSIS Please route and review as shown. Signify vour U/A by Initialing: DEPARTMENT HEADS ___________________ MANAGERS DEPARTMENT _______________________ SAFETY DEPARTMENT (Last) A/I Report No. 106-069-87 Description Accountable Dept. PolyolsBuilding. Potential Loss Severity: Critical Serious Minor Probability of Recurrence: Frequent LOSS ANALYSIS: +$_ 103 Date of Incident 5/21/87 Actual Loss Severity: Critical ____ Serious ____. Minor X Occasionally Rarely X Material Loss Extra Utilities Missed Sales (Var. Margin) Equipment Damage (Replace/Repair) Cleanup Costs TOTAL LOSS ATTACH SKETCH OR PICTURE. IF POSSIBLE INCIDENT SUMMARY A plastic enclosure around tank 643/644, installed for asbestos removal, filled with a vapor mixture of nitrogen with a low level of Propylene Oxide present. The vapor occurred while transferring the reactor contents (crude flex polyol) to the lower tank (Tank 643). INVESTIGATION/SEQUENCE OF EVENTS Military Time Event - 5/18/87 Vents on tanks were found to be enclosed. . 5/20/87 Contractor adjusts plastic enclosure to not contain the vents, but only clears top tank,(Tank 644) vent. 5/21/87 a.m. Operator transfer 1 Rx to Tank 643 (bottom). 5/21/87, 0430 Contractor arrives at unit to begin removal work. While awaiting initiation of "B" HWP and upon job inspection on site, contractors notice oxide odor at the tank. 5/21/87, 0600 Shift group uses fire water/sprinkler until space under the plastic enclosure weathers off. UCC 006700 PRIHARY CAUSE Material was transferred into a tank that vented inside the plastic enclosure. Preparation was not adequate and the vents were not checked. CONTRIBUTING FACTORS (If anv) 1. Communication from and within the Polyols staff was not adequate enough to control hazards that could arise with the asbestos removal job and the enclosed area. 2. A confined space viewpoint was not applied. ACTION TO PREVENT RECURRENCE Action - 1. Discuss what constitutes adequate communications. and coordination. 2. Arrange meeting with Maintenance Department, Safety Department and Operations to discuss and define plastic enclosure around vessel as it pertains to confined space procedures. Resp. DHO DHO Completion Date Complete 5/4/87 Complete 5/22/87 REVIEWED BY: REVIEW BOARD Chairman D* H* 0tt Member T.A. Stinespring Member E. G. Novakoski Member J. G. Givens 5/13/85 3109W ____________ Date of Investigation Member F. McCartyMember Member R. G. HullMember 5/21/87 Member Member UCC 006701  /' ' ti...jtCr & TV'- ** S,J ***& * UNION * INTERNAL CORRESPONDENCE RCElV&) CARBIDE * * * *T JUN 1 1987 SPECIALTY CHEMICALS DIVISION ^'WTENANCF Bldg. 82-902 dept. South Charleston, WV 25303 TO: FROM: Attached Distribution List C. R. Rotthoff DATE: May 27, 1987 ORIG. OEPT: ' HS&EA Personnel Safety SUBJECT: Asbestos Negative Pressure Enclosures Our focus regarding asbestos has been to protect workers from the asbestos health hazard. Recent telephone conversations Indicate that asbestos negative pressure enclosures can contain hazardous atmospheres when the enclosed system has leaks or vents which discharge Into the enclosure. Operation of the enclosure exhaust blower typically prevents the accumulation of vapors and/or oxygen depletion within the enclosure. When the exhaust blower has been shut down for an extended time, a hazardous atmosphere can form within the enclosure. The application of confined space entry procedures to asbestos negative pressure enclosures Is necessary to help ensure workers safety. If you have any questions, please contact me. Regards, C. R. Rotthoff CRR/rhw 3307K (5/27/87) Attachment \ UCC 006702 DISTRIBUTION LIST SCO SAFETY/HEALTH TRANSMITTALS S/H PERSONNEL DOMESTIC E. L. Ooerfleln S. T. Eberhardt D. J. Esposito W. P. Fethke S. E. Galbreath J. D. Keough C. H. Mason J. H. Miller D. R. Newman J. E. Plkula 0. M. Regent R. J. Romagnoll M. J. Shoger D. A. Watson - 380 - 312 - Amerchol, Mamaroneck, NY - 323 -Amerchol, Edison, NJ - 312 - Baltimore - CPI - Mobile - 323 - Baltimore - 507 - 514 - Savannah S/H PERSONNEL INTERNATIONAL L. G. Colella G. Garnlca D. Galllzzl N. Klkawoda F. Storms - Sao Paulo - Mexico City - Reggio - Union Showa, KK - Tokyo - Oelfzljl S/H MANAGERS. DOMESTIC J. M. Cleverdon R. J. Cybulskl R. K. Dodge S. W. Drake J. B. Evans 0. A. Gosselln J. G. Gottstlne C. H. Hancock E. B. Harris V. H. Johnkoskl D. Llebesklnd J. S. Magee L. W. Phalr T. P. Raby J. R. Vogel E. T. Voss A. Walker - 500/R1 - Amerchol, Edison, NJ - Savannah - 514 - 500/K4 - 514/82 - Mobile - 512 - 323 - 514/82 - 5Q0/K3 - Seton R&D - 380 - 514/82 - 312 - CPI - 500/K3 S/H MANAGERS. INTERNATIONAL J. A. del Agulla A. Geutjes G. S. Iversen R. Jelasl A. Morgagni J. W. Peavy M. W. Ranney B. M. Reldl J. Zapata-CId CRR/rhw 3307K (5/27/87) - Santo Domingo - Lelderdorp - Hycel - Reggio - Termoll - Oelfzljl - Tokyo - Cotla - Aratu UCC 006703 SPECIALTY CHEMICALS DIVISION SOUTH CHARLESTON PLANT ENGITEERING November 7, 1986 received OV1086 MAINTENANCE DEPT. TO: D. A. Gosselin R. G. Link S. Rossi M. J. Shoger E. D. Southard J. L. Worstell CC: W. D. Bradbury SUBJECT: South Charleston Plant Insulation Upgrade Outline of Project Gentlemen: The Insulation Upgrade Outline of Project (0/P) is attached for your review. This plantwide Insulation Asbestos Upgrade Project is a high-priority Safety/Health Program. The total cost is $3.3MM Capital and $1.4MM 838 Expense. Please note that the required Health, Safety, and Environmental review by the Engineering, Manufacturing, and Technology Services Department has been completed and is incorporated into the 0/P. Please return any comments directly to me by November 13. The finalized 0/P will then be transmitted by the Director of Engineering to the functional Vice-Presidents for approval. Please call if you have any questions. \ JFD/wdm Ext. 3469 Attachment 2301G seph F. Dodd UCC 006704 SOUTH CHARLESTON PLANT ENGINEERING SPECIALTY CHEMICALS DIVISION OUTLINE OF PROJECT SOUTH CHARLESTON PLANT INSULATION UPGRADE SOUTH CHARLESTON, WV November 7, 1986 UCC 006705 i OUTLINE OF PROJECT SOUTH CHARLESTON PLANT INSULATION UPGRADE TABLE OF CONTENTS I -P--A-G--E-I. INTRODUCTION 1 II. SUMMARY 1 III. SPONSOR'S OBXCTIVES 1 : IV. FACILITIES 2 V. ENVIRONMENTAL PROTECTION/OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS 3 i VI. SUPPORTING FACILITIES 3 VII. PROJECT PLAN 4 VIII. SCHEDULE 4 IX. COST ESTIMATE A. Summary B. Basis for Estimate C. Cash Flow 4 X. COST ALLOCATIONS TO DIVISIONS 5 XI. APPENDIX 6 o Health, Safety, and Environmental Review by Engineering, Manufacturing, and Technology Services Department o Division/Profit Center Cost Allocations Summary UCC 006706 I. INTRODUCTION Much of the insulation in the South Charleston Plant is asbestos and is in poor condition. Exposed asbestos presents a safety and health hazard associated with airborne particulate asbestos. II. SUMMARY * The asbestos insulation throughout the South Charleston must be upgraded to comply with the Occupational Safety and Health Administration (OSHA) standards. The project is estimated to cost $4.7MM over a three-year period: $3.3MM capital and $1.4MM removals 838 expense. The plan is to remove asbestos from idle equipment, replace damaged insulation with an approved type, and seal all remaining asbestos insulation. This project will be implemented over a three-year period with completion in 1989. The justification of this project is Occupational Health. The present OSHA Asbestos Standard, 1910.1001, now specifies 0.2 fibers/cc as the maximum allowable exposure over an eight-hour period. The figure refers to fibers greater than five micrometers in length. III. SPONSOR'S OBJECTIVE The basic objective of this project is to upgrade the asbestos insulation throughout the South Charleston Plant to comply with OSHA Standards. Completion All insulation upgrade to be complete by December 1989. Project is high priority and must be executed on a continuous basis over the three-year period with only curtailment during the bitter cold winter months. Safety/Health All Division Safety/Health Guidelines must be following during asbestos removal/disposal, repair, and covering. UCC 006707 2- - Government Regulations Plant will be in compliance with all applicable OSHA and U.S. Environmental Protection Agency (EPA) Regulations at project completion. IV. FACILITIES The asbestos insulation upgrade encompasses the following units and the work schedule on a priority basis follows: Phase 1 No. 2 Steam Plant Portion Water Treating Unit Phase 2 (Manufacturing Units) Chemical Mixing Upper Island Mainland PVA Resins Solvent Vinyls Polyols Specialty Catalyst Specialty Chemicals Middle Island Oxide Adducts Phase 3 Complete Water Treating Unit Utility Distribution Distribution Bulk Terminal Maintenance Some of the work has already been authorized for removing asbestos insulation from idle equipment and lines; the work is not part of this major capital project. These projects are listed below: Project Approval Cost Status No. 2 Powerhouse Solvent Vinyl Resins Specialty Chemicals Division Units Upper Island Chemical Complex Oxide Adducts 10/85 1/86 1/86 -- Total $111,000 17,000 182,000 Complete Complete On-going 26,000 WOR To Dan 10/9/86 100,000 WOR to Dan by 11/13/86 $436,000 UCC 006708 -3- V. ENVIRONMENTAL RROTECTIQN/OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS This project will correct an Occupational Health concern by replacing or sealing exposed asbestos insulation throughout the Plant. When the insulation is being replaced or removed, Safety and Health Guidelines will be followed which includes: installing rope barricades and clearing the area of plant personnel, posting of warning signs, proper bagging and disposal of insulation, and monitoring of surrounding work areas. In addition, assuring that contractor personnel adhere to guidelines such as: wet clean-up, wearing of appropriate respirators, wearing and disposal of proper protective clothing, etc. This project will be in compliance with all applicable OSHA and EPA Regulations. The EPA will be notified that the removal of asbestos insulation could occur at the South Charleston Plant. The required Health, Safety, and Environmental review of the project was completed on October 30, 1986, by the Engineering, Manufacturing, and Technology Services Department; the project is endorsed contingent upon the following: 1. Maintenance Procedure XVIII Provisions for Asbestos Material Removal and Disposal Safety will be revised to be in compliance with the latest OSHA Standard 29 CFR 1910.1001. 2. Procedure XVIII will be revised in accordance with the environmental concerns listed in the review. A copy of the complete review is attached in the Appendix section. VI. SUPPORTING FACILITIES A. Distribution The project will have no effect on Distribution facilities. B. Energy Systems The project will have no effect on Energy Systems requirements. However, Energy Conservation will be improved with this insulation upgrade. C. Safety and Environmental Considerations See Section V above. UCC 006709 -4- VII. PROJECT PLAN The project survey, or scope, was prepared by the Maintenance Department over the last year. The priority of work is shown in the Facilities Section on page 3. Insulation specification consultation will be supplied by Engineering. Field construction by an outside contractor or the Central Engineering Construction Group, will be supervised by the Maintenance Department. Project Management, including cost control and reporting, will be provided by Plant Engineering. The project organization follows: Steering Committee Assistant Plant Manager Maintenance Superintendent General Project Manager Project Team Maintenance Coordinator/Supervisor Project Manager S. Rossi J. R. Dement J. F. Dodd L. B. Hewitt J. R. Maier VIII. SCHEDULE Key dates are: Outline of Project Approval CBP Approval Mechanical Completion December 1986 February 1987 December 1989 IX. COST ESTIMATE A. Summary o Labor o Materials o Engineering/Maintenance* o Contingency Total Capital $1,950,000 860,000 160,000 330,000 $3,300,000 838 Expense $1,140,000 50.000 70.000 140,000 $1,400,000 * Insulation specification consultation, project management and field coordinator of contractor. UCC 006710 t -5- B. Basis for Estimate The estimate for the Phase I work is based on a detailed scope and budget pricing obtained from a local insulation contractor. The remaining work is based on an insulation survey of each operating unit and estimating the associated man-hours and materials required. The total man-hour estimate is 101,000 hours of work. C. Cash Flow Capital 838 Expense 1987 1988 1989 $1,100,000 ,1,100,000 1 100,000 $ 466,000 466.000 468.000 Total $3,300,000 $1,400,000 X. COST ALLOCATIONS TO DIVISIONS The project costs are allocated to tenant divisions based on the 1987 plant period cost allocations furnished by the Plant Controller. For example, costs for insulation work on steam lines in the Energy Systems area would be allocated plantwide to those profit centers on a steam usage basis. The overall project allocations to divisions follows: Division Percent Costs Capital Expense Specialty Chemicals Solvents & Coatings Industrial Chemicals 73.12 21.80 3.08 $2,479,000 720.000 101.000 $1,052,000 305,000 43,000 Total 100.00 $3,300,000 $1,400,000 These costs are spread equally over three years (1987, 1988, and 1989). The individual profit center cost breakdown for each division is shown in the Appendix section. JFD 11/07/66 2301G UCC 006711 6- XI. APPENDIX UCC 006712 TO: OATE: Hay 6, 1987 COPY: J. R. Solce J. L.Worstell EPD Staff (Circulate) SUBJECT: ENVIRONMENTAL CONCERNS FROM THE HEALTH, SAFETY, AND ENVIRONMENTAL REVIEW INSULATION UPGRADE PROJECT. SOUTH CHARLESTON REFERENCE: MEMO TO J. R. DEMENT FROM H. W. WEGERT & G. M- WHIPPLE DATED 10-30-86 I have reviewed the subject memo, In conjunction with the Maintenance Safety Procedure XVIII - Asbestos Handling, and have the following comments about Messers Wegert's and Whipple's concerns: CONCERN 1 - No reference to WVAPCC Regulation 15: Page 14 of Safety Procedure XVIII Is a checklist for asbestos removal/dlsposal which specifically asks If: Proper Environmental Notifications made ___ YES ___ NO ___ N/A (APCC, EPA, DNR, and Health Department) Appendix I on page 16 of Safety Procedure XVIII lists the required delivery times for asbestos notifications. Appendix II on pages 17 and 18 Is a copy of the WVAPCC Asbestos Removal Notification form. Although there Is no specific mention of "Regulation 15", I believe Safety Procedure XVIII adequately addresses the requirements of Regulation 15. UCC 006713 2- - CONCERN 2 - No reference to the State requirement of notification to the DNR prior to landfilling asbestos: Appendix II (pages 17 and 18) Is the WVAPCC Asbestos Removal Notification form. This page of the form states that In addition to the WVAPCC, copies of the form must be sent to EPA, DNR, and the Health Department. It Is the practice of the EPD to send the notification form to those four agencies. There are no known regulatory requirements that DNR or the Department of Health be notified of asbestos removal projects. Notification to the DNR and to the Department of Health of asbestos removal projects has always been done as a courtesy. Again, Safety Procedure XVIII adequately addresses all notification requirements. CONCERN 3 - No reference to NESHAPs 40 CFR 61.152 and 61.156, pertaining to disposal container labels and warning signs at landfills. 61.152(b)(1v) of NESHAPs outlines a label to be used on disposal containers: CAUTION CONTAINS ASBESTOS AVOID OPENING OR BREAKING CONTAINER BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH However, 61.152(b)(1v) further states in part, "Alternatively, use warning labels specified by ....(OSHA) ...." 61.156(b) and (c) state that a landfill must have: 1) A natural barrier to deter access by the general public, or 2) warning signs and fencing, or 3) covered the waste asbestos with at least 6 Inches of non-containing asbestos materials at least once every 24 hours. Thus, the NESHAPs regulation does not automatically require warning signs at all landfills. However, most landfills that accept asbestos wastes do have warning signs (as does Goff Mountain Landfill, which Is Plant 514's present asbestos disposal site). In summary, Safety Procedure XVIII is more than adequate from an environmental viewpoint. I believe the Health, Safety, and Environmental Review team reviewed a 4th Q or earlier draft of Safety Procedure XVIII - not the final review draft dated February, 1987. UCC 006714 3 To Insure that disposal needs for the Insulation upgrade project are met, EPD needs an estimate (in cubic yards) of the disposal loads. This estimate should be broken down Into a monthly schedule. In accordance with Safety Procedure XVIII, an estimate of the disposal load In cubic yards Is a prerequisite for obtaining an approved Asbestos Removal Notlficaqatlon from EPD. As noted in previous correspondence to you from J. L. Worstell (dated October 27, 1986, and January 28, 1987,) EPD recommends that no additional large-scale insulation removal jobs be undertaken until a suitable disposal site Is available. Goff Mountain will soon phase out accepting asbesto insulation on a routine basis (except for chemical-saturated Insulation). Purchasing has recently contacted several landfills to obtain Information on availability, standards, cost and etc. However, as of this date no alternative landfill has been located. DHH/rls 0093H Dennis H. Hanshew UCC 006715