Document ZBzjVqmk3D9kmrkQMNoypwV0d

T INTKIINAL COIIHKXIMINDKNCK UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS To iNami Company Location Mr. F. D. Bess, 511 Anawcring latitf data Asbestos Disposal Mr. R. C. Glock, w/o attachments Mr. J. D. Martin, 510 Dear Doug: Attached are procedures from UCC Maintenance Operations (Dick Huber's letter), OSHA regulations and Brownsville Plant Maintenance practices delated 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 J LTW/gr Attachments L. T. Windel , DE 009539 I INTERNAL CORRESPONDENCE Jtfc*** ; ---------------------- ---------------g^FgJ CHEMICALS AND PLASTICS * P. 0. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 is (Nm) See Attached Distribution List >i June 22, 1977 Ongmtmg Otpl. m>i*<i Guidance for Compliance with EPA Asbestos Regufation Gentlemen: Enclosed is an outline providing guidance for compliance with Environmental Protection Agency regulation, 40 CFR 6l, 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 XVII, 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 Hr. D. G. Moshier 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). Sinrfrely, RAH/w R. A. Huber Maintenance Operations Manager DE 009540 GUIDANCE FOR COMPLIANCE WITH EPA ASBESTOS REGULATION I. REGULATION AND APPLICABILITY Regulation - kO CFR 61, Subparts A and BApplicability ~ 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 accomplished. (3) Insulation on pipe or equipment which is to be removed in sections must have exposed surfaces wetted and kept wet during dismantling. (k) 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. (2) 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 2k 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 009541 2. (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 above 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, S 61.04] Federal: Director, Enforcement Division Environmental Protection Agency (Regional Office City Address) State: (Applicable only in the following C&P states) California (Sacramento County) (Bay Area) * Georgia New York North Carolina Suggested Text of Notification Letter The attached notification relative to the demolition and/or renovafion of facilities containing friable asbestos insulation is provided per. requlrements of 40 CFR 61, Subpart B, Section 61.22 (d). Please contact the writer if there are questions concerning information contained in the notification. S i gned __ DE 009542 3. Form of Notification [See also Attachment 1 * S 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 pipinq 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 year or other specified dates) (Either calendar (6) Nature of planned demolition or renovation and methods employed Demolition of obsolete facilities and renovation of existing faci1ities. (7) Procedures employed Insulation wetted before removal, lowered to qround, 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 009543 GENERAL NOTES (J) .'he 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. (A) Recognize that an Occupational Safety and Health Standard, 29 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 009544 ATTACHMENT I Excerpts from EPA Hazardous 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 1, 1976; 41 FR 27967, July 8. 1976; 41 FR 33264, August 9, 1976; 41 FR 34629, August 16, 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 46SS9, October 20. 1976; 41 FR S3017. December 3, 1976; 41 FR 54758, December IS, 1976; 41 FR 56805, December 30. 1976) Subpart A--Central Provisions } 41.04 Address. (a) All requests, reports, applications, nibmlttala, and other communications to the Administrator pursuant to this part, .hall be aubmllted in duplicate and adgreased to the appropriate Regional Ot ic* of the Environmental Protection Agencr, to the attention of the Director, enforcement Division. The regional of* dees are as follows: Region 1 (Connecticut. Stain*, Knr Hasp* bus. Maaeechueetl*. Rhode Irian*. Ter. mont). Jobs F. Kennedy Ptderal BuUSlng, Boston. Maeeechueeete 02303. Region II (New Tort. New Jersey, Puerto itloo. Virgin IilsnOe), Pedorsl Once BulMtog, M Federal Plaza (Foley Bquare), Nov Vert, N.T. 10007. Region IQ (Delaware. DUiriet at Columbia, Penneylnme. Merylend, Virginia. Weei Vir ginia) , Curtla Building, Sixth and Walnut Streets, PhUadelpbia. Pennsylvania 1S10S. Region IV [Alabama, Florida. Georgia. SShw deelppl, Kentucky, North Carolina, South Carolina. Tanneeaea). Suita 300, 1421 Peach tree Street. Atlanta. Georgia 30302. Region V (mmole. Indiana, Mlnaeeote, Mleburan, Ohio, wiaeouatn), 1 North Wackar Drive. Chicago, nilnela SOSOS. Region VI (Arkaneaa. Louisiana, Stew Uestco, Oklabome. Tesae), 1400 FaSUtssa street. Dailae, Texas 7S30I. Region VII (Iowa, final, Missouri, Ne braska). 17SS Baltimore street, ----------City. Mueouri UI0S. Region VHt (Colorado, Mootana. North Da kota, South Dakota, Utah, Wyoming), 1*4 Lincoln Towels, 1SS0 Ilaooln Street, Denver, Gotoredo (0303. Region DC (Arizona. California, Hawifi, Nevada, Guam, American Samoa). 100 Gam fornla Street, San Francisco, California Mill, Region X (Waahlogton, Oregon, p*-y, Alaska), 1300 Sixth Atanua, Seattle, Waaningtna SS101. ' (b) Section 112(d) directs ths 'Admin istrator to delegate to each State, whan appropriate, the authority to implemsnt and enforce the national emlstloq stand ards for hazardous air poUutantsTor sta tionary source#, located in such Staton All information required to be submitted to'EPA under paragraph (a) of thUttir. tion,.must also be submitted to the appropriata State Agency of any Stale to whtoh this authority has been delegated (provided, that each specific delegation may exempt sources from a certain fed eral or 8tail reporting requirement). The appropriate - mailing address for those States whoa*delegation request Pas beta approved it at follows: fLCiiUortU: Bay Am Air MhrtlM Ooatral CktmL in tti* mrwt, ana mioco, ca Him* ft*cr*mnto County Air Nonunion Control DUtriet Ttoi Branch Cantar Boai. 8>rra manto, CA IWT. a Biit# ot wfta BovtronmtnUI *ro- taction Division. Depsrtmvftt'of Natural ft** joureea 370 Waehlbgtea Street, S.W. AS- laata. Oeorgu 10334. , (BK)--New Tetfe; New Tort SUte Depart ment ef avln--untai ConeervsUoc, SO Wolf Road, Albany. New Tort 11333. auenUocV DlxMon or ASrJteScmreea (40 FR 48347, October IS. 197S| (n> North Carolina environmental Man agement Commission, Department ef Natural and Economic Resource,. Division of Envi ronmental Management, P.O. Bos 27337, Ra- lelgh. North Carolina 37(11. Attenuon: Alt Quality Section. Subpsrt B--National Emission Standard for Asbestos | (1J1 Eiahiloa standard. (d> Demolition and renovation: Tho raquiremmts 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, faculty, Installation, or portion theraof which contains any pipe, duct, boiler, tank, reactor, turbine, furnace, or struc tural member that Is Insulated or fire proofed with friabla asbestos material, except as provided in paragraph (d) (1) of this section: or who Intends to reno vate any Institutional, commercial, or In dustrial building, structure, facility. In stallation, or portion thereof where mors than 80 meters (ca. 280 feet) of pipa in sulated or fireproofed with friable as bestos material are stripped or removed, or mors than IS square meters (ca. ISO square feet) of friabla asbestos material used to insulate or fireproof any duet, boiler, tank, reactor, turbine, furnace, or sr-tr-u.c. tu ral member are stripped or r- (2) Written notice of Intention to de molish or 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 leaat 10 days prior to commencement of demo lition. or as early as possible prior to commencement of emergency demolition subjoet to paragraph (d)(8) of this sec tion. and as early as possible prior to commencement of renovation. Such no tice thaU Include the following informa tion: (I) Name of owner or operator. (II) Address of owner or operator. (ill) Description of the building, struc ture, facility, or installation to be de molished or renovated. Including the size. age. and prior use of the structure, and the approximate amount of friabla asbestos material used for insulation and fireproofing. (Iv) Address or location of'the build ing. structure, facility, or Installation. <v) Scheduled starting and comple tion dales of demolition or renovation. <vi> Nature of planned demolition or renovation and method (s) to be em ployed. (will Procedures to be employed to meet the requirements of tills paragraph and paragraph <j) of this section. (viii) The name and address or loca tion of the waste disposal site where ths friable asbestos waste will be deposited. (lx) Name, title, and authority of the State or local governmental representstire who has ordered a demolition which is subject to paragraph (d)(6) of this section. | 61.25 Waste disposal sites. (b> Warning signs shall bt displayed at all entrances, and along the propel tv line of the site or along the perimeter of the sections of the stte where asbestoscontaining waste material is deposited, at Intervals of 100 m (ca. 330 ft) or less except as si>celfled In paragraph id) ol this section. Signs shall be posted In such a manner and location that a person msy easily read the legend. The wamPir. signs required by this paragraph ahull conform to the requirements of 20" x 14" upright format signs specified In 29 CFR 1910.145(d)(4) anti Ihts paragraph. The signs shall display the following legend In the lower panel, tilth letter sizes and styles of a visibility at least equal to those specified In this paragraph. LSCKAO 'AaazsTOS Wastz Diskisai. arts Do Not Create Dust Breathing AsbeeV.-* Is Hazardous to Your Health Notstlon 1" Sans Serif. Ootlile or Block V Sens Serif. Online or Block 14 Point Gothic 8paclng lielwcen Hum shall be at least equal :* il.i: height '' upper of the DE 009545 DISTRIBUTION LIST Location Bound Brook Brownsvi1le Elk Grove Institute Marietta Niagara Falls Seadrlft Sistersville South Charleston Taft Technical Center Texas City Torrance Latex Plants Distribution UCCI Plant Manager R. A. DeCoudres W. W. McManus J. 0. Zimmerman H. J. Karawan C. A. Wales G. C. Merz D. L. Gorls A. W. Boyd C. A. Kell T. L. Rapp J. W. Biddle D. L. Engle J.' A. Grady H. L. Robinson Plant Mainterance Manager Asst. Plant Manager P. A. Schultz J. L. Goodson A. L. Barefoot R. C. Clock EP/0H Coordinator G. R. Stringer L. T. Wlndel * --; P. Barna C. E. Rogan, Jr. T. J. Oliver G. W. Bartlett R. L. Shomo C. A. McNeill R. G. Link L. W. Phair R. N. Bates A. G. Stephens W. E. Shackelford - T. 0. Blum J. S. Knight J. M. Stogdon - - R. A.- Mendez D. L. Brucker R. L. Foster R. G. Hul 1 C. C. Duffield V. D. Dutcher J. A. Helm D. G. Olds L. E. Carlson J. L. Worstel 1 A. W. Carlson 0. L. White G. F. Hurley J. B. Leverton J. P. Alexander K. G. Morlock A. R. Randall J. E. Stevens V. Vega F. D. Bess - 511 N. W. Gaines .* 511 R. C. Hieronymus - 511 E. 0. Hull,HD - 511 R. T. Kramer - 512 M. G. Manettl - NYO.W A. E. Montagna - NY0,21 D. G. Moshier - 511 R. E. Peele - 511 E. C. Powell, Jr. - 511 T. P. Raby - 312 M. D. Seymour -511 R. D. Stief - 511 B. H. Thomas - 511 D. T. Watters- 511 DE 009546 31:8304 REFERENCE FILE Table Z-2 MtUcfcl garni liaa mkM sveriff ActtpUbU etlanc concentration AcMpubU muUna. pMk itti th ittKUUi ctttux caonmui- imi twin Maui ihflt. ----" - CooceotratMi Manama dumkM Xrnmi (Zir.ft-tfN).................................Itp.B.tt............. np9.m............. op.p.m............ 10 minutes. ......Uorgftiuen^aiMt beryllium eeapeunds 2*-/M*.............. *H-/M*................ Iftmlautea. Cadralumtome (Z3?4-lt?ft)........................ ft.1 to$JUK--.. 9 m./M*............... Cadmium duu (U7 *IW>......................... 9.3 snf-/N'............0 m*VN............ Carbon disulfide (ZJT.ft-naft)......................JOp.p.m.............. lOp.pm.............. j *......Carbon tetrichiarfcle (ZJT.IT-lftftT).............. Iftppjo...............Sipp*.............. aoop.p.m......... Do. ftmtauteaia enyebaun. F.lhylen* dlbremlde (Z174MI70).............. p.p............... Mop*.............. pp....,,.. ftmtmitaa. tlhylent dkhlortde (U7.)I-IW)................Np.p*..............Idippm............. 200 p.p.a....... ralnutee to ForaiaMrhvile (237.1ft1K7)..................... ftp.p.a............. ftpp. I0PP4O.......... 10mayinuIbtews.ra. nydreaen fluoride (ZJ?.2fi-l*ft)..........................dt................................. Fluoride m dust (/47.*>tMi)..................... 24 mg /W*............................ . Lw] end lit Inorganic compound* (Z27.1 I- 9.3 utfJM*.--...................... tUtf). Methyl chtortda (Z37.1ft-19)...................... lttp.p.*......... p|.. MathyWne Chloride (2374-ltM)................ ftOftp.pja......... I,ft0ft p.pja. 900p.p... 3,coop.p.a ftmkuitseU wrlfemn. ft molaru2tebaotmon. OItyrgnaonoe((aZlk3y7l).1mMerMcu)r.y..(..2.I.7..J.2..-.1..S..M..)........... fltOifftltpm.gpJjaU......... J0O.01Omp.*pJjMa..*.. p.pji*:: ftmlautoiU Trichloroethylene (237.1MM7)........... ......... do.................do....... MOp.p.m.. any (bams, ft mlautaa to nyftbauii. Tatraehloroethyleoo (Ztt.23-I9ftr).~.................. do..... ................do..........................do...-......... (mlautmte nr I boon. Toluono (Z37.12-IB071............................... 300 p.pj*........ 200 p.p.aa. WOp.p.B..... 10 BUM!too. Hydrogen sulfide (Z27.2-1MD.......................... ...................SOp.p.m.. 10 p.pja......... 10 minutes e*ce nlyUoe ather moMttf* ObW IIPCNTI Mercury (Z37.2-MT1)................................ Chromic add and chromates (237.7-1*71) lmgVlOM. ___ do *.... Table Z.J--Mineral Dual* Subsuoea MPPel* Mg/M* Silks: CrrstslUns: gusra (mplnbta)............ 210 1 10a %SIOi+ft ftSIOt+3 Quarts (total dust)............... 30mc/M* Cnstofcalits: UsaHtha vtlu* rslculstcd from tha foum or mast lorsiuL* lor quart! Todymut: Dm H Uia Talus t ak uUtcd from Iht tor* muia* (or quarts. Amorphous, mcludlnf natural dlatomactous earth................. %StO*+2 3D BUlcstas (lw than i% ay> taJllru slUea): Mica..................................... Soapuona.................... Tak (non-asbestos-fora) .. Tale (fibrous). Uss asbsuot limit .............................. Treaollte (saa tale, fibrous) Finland cement............... Oraphiu (natural)............. Coal duu (rmiitrabte (racUaa kis than ft% KlOi)................. Tot more than ft% 210s............ %$10> 2D 22 30* to u liat/M* ar 10a(/M* Inert or Nuisance Dual: Xesntrabla (ratten.......... Total dust........................ %*IOi+* Ift (Cl/M* 0 Uag/M* Note: Conrrnloo taeMt- mpperxftft.3*mllUoa particles per fubfcmeim particles par y tapMiUtHr.mnimWptpMwctakuKn.uptfrbrrcUubgiht tbiMld^talclrbn.tUo.m4 m Tb. pmnuit tl animiM tuka u u>. knwJ* b tha amount dtualn<4 baa ab-harao atapltg a- pc In tho.. Insunm la wtilch other bantam mown to ba applicable. i ' daurmifte1! by iheMmbrene filter mathad at tftOxpliaM contrast magrUAeatloa. Holh concentration and percent auoru lor tha aPPU* cation ef ihu bail! an to ba determined (ran the (ractloo pvalnc a Mails'W'lnr villi the blbwiiig duncuniki: Containing < 1% quarts; It > l% quant* u*e quarts Aerodynamic dlameur (unit dausltjr sphere) Percent paeslnj arlector 2 Ift 21 7ft 2ft 0 LO n 10 0 Tha mcasunmtnta undv this note nfcr to tha tut H an AEC lnnnimtm. If tha mpirabk traction of coal du*ur<eicrmmcnmtpmtt&E tha ftgura eorrtsponding fiat of 2-4 Mg/M> lit Uit labD^x coal dust U 44 ftlg/M>. { 1910.1001 Aibcttot. <*) Deliruffnnt .^r the purpose at section. <1) "Asbestos" Includes chrysolite, smoslte, croddoUte, treraoUte, anthophyllite, and actlnollta. (2) "Asbestos fibers" means asbestos fibers lonjer than S micrometers. (b) Permlttible exposure to airborne concentrations o/ asbestos fibers--(1) Standard effective July 7. 1972. The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than S micrometers, per cubic centimeter ot air, as determined by the method pre scribed In paragraph (e) ot this section. (2) Standard effective July 1. 197$. The 8-hour tune-welihted average air borne concentrations ot asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air. as determined by the method pre scribed in paragraph (e> of thii section. (3) CefUnp concentration. No em ployee shall be exposed at any time to airborne cencentratlons of asbestos fibers In excess of 10 fibers, longer than S micrometers, per cubic centimeter of air. as determined by ihe method pre scribed In paragraph it' ot this section. it) Methods ot compliance--(i) fingineertng methods. (1) engineering eontrots. Engineering controls, such as, but not limited to. Isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed In paragraph (b) of this section. (II) Local exhaust ventilation, la) Local exhaust ventilation and dust col lection systems shall be designed, con structed. Installed, and maintained In accordance with the American National Standard Fundamentals Qovemlng tha Design and Operation of Local Exhaust Systems. ANSI Z9.2-1871. which Is In corporated by reference herein. <b> See i 1910.4 concerning the avail ability ot ANSI Z9.2-1971, and tha maintenance ot a historic file in connec tion therewith. Hie address of the Amer ican National Standards Institute Is given In i 1910.100. (fill Particular foots. 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, abrasive wheels, and dnila, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision (11) of this subparagraph. (2) Work practices--(1) Wet metlkods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut scored, or otherwise worked In a wet state sufilelent to prevent the emission of airborne fibers in excess of the ex posure limits prescribed In paragraph <b> of this section, unless the usefulness of the product would be diminished thereby. (til 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 In which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers In excess of the limits prescribed In paragraph (b) of this section. (III) Spraying, demolition, or removal. Employees engaged In the spraying of asbestos, the removal, or demolition of pipes, structures, or equlpmsnt covered or Insulated with asbestos, and In tha 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 tha expo*urt-U*LlU_ prescribed by paragraph (b> ot this (ac tion may not be achieved by the use of respirators or shift rotation of em ployees. exeept: (I) During the time period necesrarr to Install the engineering controls and to Institute the work practices required by paragraph (c> ot this section; (II) In work situations In which tha methods prescribed In paragraph (c) of Occupational Safaly & Hvoith Reporter OJW A [Sec. 1910.1001(d)(1)(H)] 28 DE 009547 n. r n TOXIC SUBSTANCES S 104 31:8305 this section an either technically not feasible or feasible to an extent tnsutfl- the safety or health of the employee or other employees will be Impaired by his cient to reduce the airborne concentra use of a respirator Such employee shall (11) Sampling frequency and patterns. After the Initial determinations required by subparagraph (1) of this paragraph, tions of asbestos fibers below the limits be rotated to another Job or given the samples shall be of sueh frequency and prescribed by paragraph (b) of this section: or (111) In emergencies. (Iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (1>. (II). or (111) of this subpara graph. and both an practicable, person nel rotation shall be preferred and used. (2) When a respirator Is permitted by -subparagraph (1) of this paragmph. It shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior.'or the National In opportunity to transfer to a different po sition whose duties he 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 sueh 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 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 8 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--(1) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations ot asbestos fibers which may reach the stitute for Occupational Safety and Health. Department of Health. Educa tion. and Welfare, under the provtslonsof tions of asbestos fibers, which exceed the celling level prescribed In paragraph (b) of this section. breathing son* of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted In 30 CFR Part II (3T PJt. 8244, Mar. 2$, 1972). and shall be used In accordance with subdivisions (1). (11). (Ill), and (tv) of this subpangnph. (I) Air purifying respirators. A reusa ble or single use air purifying resolrmtor, or a respirator described In subdivision (U) or (lit) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers In the respirator below the exposure limits prescribed In paragraph (b> ot this section, when the celling or the g-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. (II) Powered ofr purifying respirators. A full facepiece powered air purifying 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 scribed in paragraph (b) of this section, when the ceiling or the l-hour time- weighted average concentrations of asbestos fibers are reasonably expected to.exceed 10 times, but not 100 .times, those limits. (4) Chance 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 ployer shall provide change rooms for employees working regularly at the place. (II) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination or the employee's street clothes from his work clothes. (III) 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 (b> of this section. (b) Any employer who gives asbestos- an open-face filter holder. Samples shall be taken for the determination of the Ihour time-weighted average- airborne concentrations and of the celling con centrations of asbestos fibers. (U) Sampling frequency and patterns. Alter the Initial determinations required by subparagraph (I) 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 case shall sampltnc be at intervals greater than 6 months (or employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (4) Employee observation of monitor ing. Affected employees, or their rep contaminated clothing to another person resentatives. shall be given a reasonable for laundering shall Inform such person -rr....... -")' In **"r"t any monltorlne of the requirement In (a) of this subdi tejUiiwirEy this paragraph and shall Jfcva vision to effectively prevent the releasp, -access to the records thereof. ot airborne asbestos fibers In excesa/df (g) Caution signs and labels. (1) CauV the exposure limits prescribed In para tion signs. (1) Posting. Caution signs! graph (b) of this section. / shall be provided and displayed at each (c) Contaminated clothing wall be location where airborne concentrations transported in sealed Impermeable bags, of asbestos fibers may be In excess of the or other closed, impermeable containers, exposure limits prescribed In paragraph j (111 > Type "C" suppiied-air respirators, and labeled In accordance wlttn para (b) of this section. Signs shall be posted/ continuous flow or pressure-demand graph (g) of this section. N. at such a distance from such a locatloiv class. A type "C" continuous flow or pres sure-demand, suppiied-air respirator shall be used to reduce the concentra tions of airborne asbestos libera In the (e) Method of measurement. All so that an employee may read the slras terminations of airborne concentrations "and, take necessary protective stepg^be- of asbestos fibers shall be made by the fllll iTmilllg till III f TM*rlr-tL-4<Z the membrane filter method at 400-450 X signs. Signs shall be posted at all ap respirator below the expoaure limits pre (magnification) (4 millimeter objective) proaches to areas containing excessive scribed In paragraph (b) of this section, with phase contrast illumination. concentrations ot airborne asbestos when the ceiling or the 8-hour time- (f) Monitoring--(1) Initial determi fibers. weighted average airborne concentra nations. Within 8 months ot the publi (11) Sign specifications. The warning tions of asbestos fibers are reasonably cation of this section, every employer signs required by subdivision (I) of 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 sueh a way as to determine signs specified In 11910.145(d)(4). and- a respirator program In accordance with whether every employee's exposure to to this subdivision. The signs shall dis the requirements of the American Na tional Standards Practices for Respira asbestos fibers Is below the limits pre scribed In paragraph (b) of this sec play the following legend in the lower panel, with letter sixes and styles of a tory Protection. ANSI Z88.3-1989, 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 11910.8 concerning the avail ability of ANSI Ztl.2-1989 and the main tenance of an historic file In connection compliance program In accordance with paragraph (c) ot this section. (2) Personal monitoring--tl) Sam tegena Notation AsMetos.............................. T' Sana Ocrlt. Oetblc or therewith. The address of the American ples shall be collected from within the lock. National Standards Institute Is given In i 1910.100. breathing zone ot the employees, on putt Biurd. membrane filters of 0.8 micrometer po Sant Bartf, Oothle or (c) No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examination, rosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8-hour time- Avoid Braatblnf Duct... K".Oothte. Wear Atalgnad Frotaetlva K" Ootble. Equipment. an examining physician determines that weighted average airborne concentra Do Hot Remain In Area K" Ootble. the employee will be unable to function tions and of the celling concentrations ot UnlMt Tour Work Re normally wearing a respirator, or that asbestos fibers. quire* It. 1*2077 Copyright O 1977 by Tht Bureau *1 Notional Affairs, Inc. IS*- 1i10.100t(|MlH)i 19 DE 009548 31:008 REFERENCE FILE Irftxi NoteClou Breathing Asboetae Bust >4 point Oothie. way m naMwi t Tout Health. Spacing between line* mail be at least (J) Medical examinations--(1) Gen trot. The employer shall provide or metke available at his cost, medical examina tions relative to exposure to nspatoe re quired by this paragraph. equal to the belcht of the upper oI any (3> Freplacement. The employer shall two lines. provide or make available to each of his (3) Caution labels--(l> Labeling. Cau employees within 30 calendar days fol tion labels shall be affixed to all raw lowing his first employment In an materials, mixtures, scrap, waste, debris, occupation expose^ to rirbome con and other products contalnlnc asbestos centrations of asbestos fibers, a compre libers, or to their containers, except that hensive medical examination, which shall no label Is required where asbestos libers include, as a minimum, a chest roent have bcen-ijipdincd by a bondlnc agent, genogram (nostcrior-anterlor 14 x IT coatliig. binder' or other material so that Inches), a .history to elicit symptom during any reasonably toreseeable use, atology of respiratory disease, and handllnc, storage, disposal, processing, or pulmonam function tests to Include transportation, no airborne concentra rorced vital capacity (FVC) and foreed tions of asbestos fibers In excess of the expiratory volume at 1 second (FEVn). exposure limits prescribed In paragraph (b) of this section will be released. tit) Label specifications. The caution labels required by subdivision <11 of this subparagraph shall be printed In letters of sufficient size and contrast as to be readily visible and legible. The label shall i state: ctmow "(3/ Annual examinations. On or befora January 31. 1973. and at least an nually thereafter, every employer shall lde. or make available, comprehen- Ive medical examinations to each of his 'employees engaged In occupations ex posed to airborne concentrations of as bestos fibers. 8uch annual examination shall Include, as a minimum, a chest Contains Asbestos Plbsis roentgenogram (posterior-anterior 14 x Avoid Creating Bust 17 inches), a history to elicit symptom Breathing Asbestos Bust May Causa* Serious BodUy Harm (hi Housekeeping--(1) Cleaning. All external surfaces In any place of employ atology of respiratory disease, and pulmonary function tests to Include forced vital capacity (PVC) and forced expiratory volume at 1 second (FEV,,). ment shall be maintained free of accu mulations of asbestos fibers If. with their THirrriinn th'rrr g""1-1 V -- ----- cpriEentratlon. (3) Waste disposal. Asbestos waste, 'scrap, debris, bags, containers, equip ment, and asbestos-contaminated cloth ing. consigned for disposal, which may produce in any reasonably foreseeable use. handling, storage, processing, dis posal, or transportation airborne concen trations of asbestos fibers In excess of the exposure limits prescribed In paragraph (b) of this section shall be collected andj disposed of In sealed Impermeable bags, or other closed,' impermeable containers TlJ Aluu iMeepnry--Ul LSpOlure records. Every employer shall maintain rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at least 30 years and shall be made avail 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. 11910.10010X1) amended at 41 FR 11505, March 19. 1976| (4> Termination of employment. The employer shall provide, or make avail able. within 30 calendar days before or after the termination of employment of any employee engaged In an occupation exposed to airborne concentrations of ibestos fibers, a comprehensive medical xamtnatlon which shall Include, as a nlnlmum, a chest roentgenogram (poserlor-anterlor 14 x 17 Inches), a history > elicit symptomatology of respiratory i lsease, and pulmonary function tests t > include forced vital capacity (FVC) i nd forced expiratory volume at 1 second .). (3) Recent examinations.'No medical examination Is required of any em ployee, If adequate records show that the employee has been examined In ac cordance with this paragraph within the past 1-year period. (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 30 years. (3) Employee access. Every employee and former employee shall have reason able access to any record required to be maintained by subparagraph (li of this (11) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, for inspection and copying, paragraph, which indicates the em ployee's own exposure to asbestos fibers. (31 Employee notification. Any em ployee found to have been exposed at any tlme'to airborne concentrations of asbes tos fibers In excess of the limits pre scribed in paragraph (b> of this section shall be notified In writing of the expo sure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely notified of the cor rective action being taken. to the A'ststnnl Secretory of I/ibor icr Occupational Safety and Healt.i i!:i D.rvclur of MUSH, in authorun! pl:v:.isi-uu and iv.ccical cunvjkan;'- ol titnri of llu-m. unit, upon tl;c leant: i ol a:i ruiI't'jyte cr :ormcr einplojce. to Ills I'.riyiltuiii Any pi:;-: lci.tr. who conducts a maliral w.'iunation rtquirco by tins paragraph shall furnish to the employer of the examined employee all the Infor mation specifically required by this paragraph, and any other medical In formation related to occupational ex* poaure to asbestos liber*. (See. 1910.93j initio! aI 36 FR 23207. Decem ber 7- 1^1, as rmcryen-y temporary sijiul" pctmancnl standard ai 37 I R I131B. June 7. 1972, elective July 7. 1972: teik-sicnateil See. 1910.1001 al 40 f'R 23072 May 28. 197S| | 1910.1002 Coal tar pilch volatile* | inlerpreution of term. As used in See. 1910 l(HM) (Table Z-l). coal tar pitch volatiles Include the fused poly cyclic hydrocarbons which volatilise from the distillation residues of coaL petroleum, wood, and other organic mat ter. 137 I K 24749 Lifeline November 21. 1972| | 1910.1003 4-NitrobiphenyL (a) Scope and application, (l) This section applies to any area In which 4-Nitroblphenyl, 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 ments under paragraphs (e)(3), (3), and (4) of this section. (3) This section shall not apply to solid or liquid mixtures containing less than 0.1 percent by weight or volume of 4-NUrobiphenyl. (b) Definitions. For the purposes of this section: (1) "Absolute filter" Is one capable of retaining 99.97 percent of a mono disperse aerosol of 0.3 *m particles. (3) "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 fscllltles an otherwise required in this section. (4) "Closed system" means an opera tion Involving 4-Nitroblphenyl where containment prevents the release of 4Nltroblphenyl Into regulated areas, nonregulated areas, or the external environ ment. (5) "Decontamination" means the in activation of 4-Nltroblphenyl or 1U safe disposal. (6) "Director" means the Director, Nations! * Institute for Occupational Safety and Health, or any person di rected by him or the Secretary of Health. Education, and Welfare to act for the Director. (7) "Disposal" means the safe re moval of 4-Nitroblphenyl from the work environment. (S) "Emergency" means an unforseen circumstance or set of circumstances re sulting in the release of 4-Nltroblphenyl which may result In exposure to of con tact with 4-NltroblphenyL (9) "External environment" means any environment external to regulated and nonregulated areas. (10) "Isolated system" means a fully enclosed structure other than the vessel of containment of 4-Nltroblphenyl, occupations! Safety & Health Reporter [See. 1910.1003(b) (10)1 30 r*\ DE 009549 A T^> giF& INTERNAL CORRESPONDENCE_________________________________ BROWN & ROOT, INC. P.O. Box 3370, Brownsville, Texas 78520 To (Name) Company Location All Brown & Root Foremen Brownsville Plant Copy B. Glock / G. Townsend/ 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 the 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, ') IX A. L. Barefoot DE 009550