Document bOYk4d0JByp2EY3vOQ15O4ZN1

June 4, 1973 ll 0f dsie^/cj PLAINTIFF'S EXHIBIT CHV-626 Mr. F, Colon Chemical Reference Laboratory NIOSH Morgantcara, West Virginia 26505 Dear Mr. Colen: In your excellent presentation on the Proficiency Analytical Testing program at the American Industrial Hygiene Conference in Boston you indicated that private laboratories could obtain individual samples for proficiency testing. We would very much like to receive one of your artificial samples, or a set of samples If available, of asbestos. We wish to evaluate the proficiency of the laboratory that is performing our asbestos analyses. Your assistance will be greatly appreciated. If there is a charge for these samples, please let me know. Sincerely yours, Stanley L. Dryden Industrial Hygienist CHEV BB 010481 Sah Francisco, CA May 13, 1973 demolition w>. 2 hattest thermal unit el SKontno Mm3 TO FILE: On May 15, Mr. Buss Tilley, Superintendent, Purchase and Stores in Jfl. Segtrado, called regarding a new SPA regulation concerning Rational Emission Standard* For Hasardou# Air Pollutants. Under these reflation*, a Notice of Intention To Dasaoliah shall be provided to the Administrator at least 20 day* prior to camstcmccmmt of cUnoolitioo if the facility being daaolishad is insulated or fireproofed with friable asbestos Material. The qocatioe which fflL Segtmdo asked was vho had dia responsibility to prepare this Notice of Intention to the SPA. According to the regulation, the notice is the responsibility of the owner or operator of tha demolition operation. Is the case of El Setgundo, the Ho. 2 battery of the thermal unit la being demolished and rmoored. H Ssgundo has arranged for a contractor to perform the work. In effect, the contractor has become the owner of the facility from tha ground up. It was felt, then, by El Saguado, that the contractor had the responsibility to notify the EPA. In addition, there was a question as to whether the OSHA regulations affected the performance of the demolition of this plant. I called Mr. Stan Judd of the Personnel Safety Division to discuss the OSHA inplicatioius. Hr. Judd indicated that to his knowledge the OSHA requirements did not call for notification from an owner or operator prior to demolition. Of course, the OSHA requirements are in force regarding the personnel h surerda which soy be Involved due to asbestoe missions, Mr. Judd further indicated that a copy of ths OSHA requirements sad a copy of the EPA regulations and California standards had been seat to the 21 Segundo Safety Engineer. I then called Mr. Hawkins and asked his opinion regarding the question of whether tivc company or the contractor should notify the EPA. He indicated that in his opinion, because this was a sensitive period dwe to the sxmotmcsd piss to expand the El Segundo Refinery, the refinery should prepare the Hotice of Intention To Demolish to the EPA just to be srore that it was done promptly and correctly. I raised a question regarding the statement that the application should be made by the owner or operator and Mr. Hawkins said he felt it was quite likely in this case that the company was both the owner and operator. I called Mr. Tilley again end passed along the information which I had obtained from Messrs. Judd sod Hawkins. Mr. Tilley gave me the impression that he did mot necessarily agree with our advice. Howeverhe has all the information that lie needs to make the decision and does not expect any further cootact from this office. W5L:mg cc* Hr. F. H. Hawkins Mr. S. H. Judd / W. E. LSOL Cv- V CHEV BB 010482