Document bOykpXOD4bjnZzBRkzq2qvKGZ
59. General
correspondence
regarding
asbestos
replacement program
FROM
J. L. DIEDERICH METALS & CHEMICALS GROUP PITTSBURGH OFFICE - 29
TO
1989 January 09
RE: ASBESTOS
With respect to the captioned, would you please advise me of the following for your plant:
1. Are we in violation of any regulations?
2. Are we proactive enough? 1989 should be a good year, and it will be a nice time to deal with asbestos issues before they become potential . problems.
^-Please send me a brief summary on this subject when convenient.
Yfi/M
Jjj L. DIEDERICH
JLD/vds
Distribution: T. W. Baugh, Jr. - Badin Works H. W. Cooper - Pt. Comfort Operations W. J. Drake - Rockdale Works M. E. Goza - Wenatchee Works R. G. Kuerner - Arkansas Operations H. McLaughlin - Warrick Operations D. F. Simonic - Tennessee Operations G. F. Stephens - Northwest Alloys, Inc. L. E. Tate - Massena Operations
cc: R. C. Rawe - 29 R. F. Slagle - 29 R. A. Schultz - Arkansas Operations R. R. Taylor - 28
ALCOA
HAROLDS. EVANS
PrrrSBURGH OFFICE
M "--------
MR. B. R. BARSTOW MR. ALAIN BELDA MR. B. H.J.BEMELMANS MR. K. L. MILUCAN MR. W. A. SNADECKI MR. N.F. STEPHEN
January 17, 1989
RE: ASBESTOS Attached is a letter from Fred Fetterolf advising us of the need to deal more aggressively with asbestos. I would appreciate your comments on the following:
1. Are we in violation of any local regulations concerning asbestos? 2. Are we dealing with asbestos issues before they become
potential problems? When convenient, please send me a brief summary on your situation.
HAROLDS. EVANS
mb Attachment cc: R. M. James
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30
TO MESSRS. R. R. HOFFMAN - 29 J. L. DIEDERICH - 29 V. R. SCORSONE - 29 C. K. LIGON - 30 H. S. EVANS ~ 30
1989 January 04
RE: ASBESTOS* 1 2 3 4
In a meeting this morning on a variety of environmental issues, the subject of asbestos was discussed.
We didn't have the knowledge in the meeting, but there were strong feelings that we need to deal more aggressively with eliminating asbestos.
Will you please insure yourself that:
1. The plants are aware of their asbestos situation. 2. We are not in violation of any regulation. 3. We are doing the right thing. 1989 is a good year to
put problems behind us. 4. You are satisfied with our position.
I would like your feedback.
C. F. FETTEROLF CFF/sam
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ALCOA
Pittsburgh. Pennsylvania 15219
FR0M R. H. BARTON AFL - NASHVILLE
T0 C. K. LIGON
ALCOA PITTSBURGH OFFICE - 30
RE: ASBESTOS
1989-02-03
Regarding Fred's letter of January 04, all locations have
reported there is no known asbestos. AFL is satisfied it knows its situation, and we have no problem.
Robert H. Barton RHB:ss\201
Alcoa Fujikura Ltd.
H
ALCOA
Ann L. Brooks
We can't wait tor tomorrow1
656 A.B., would like s of all the responses
to the letters regarding
ab 2/3/89
EJ ALCOA
1501 Alcoa Building Pittsburgh. Pennsylvania 1S219
FROM
HAROLDS. EVANS
PTTTS8URGH OFFICE
MR. B. R. BARSTOW MR. ALAIN BELDA MR.B.H.J. BEMELMANS MR. K. L MILUCAN MR. W. A. SNADECKI MR. N. F. STEPHEN
January 17, 1989
RE: ASBESTOS
Attached is a letter from Fred Fetterolf advising us of the need to deal more aggressively with asbestos.
I would appreciate your comments on the following:
1. Are you aware of any specific local regulations concerning asbestos? (Please advise Charlie DiMascio's office of any local requirements.) Are we in violation of any of these regulations?
2. Are we dealing with asbestos issues before they become potential problems?
When convenient, please send me a brief summary on your situation.
HAROLDS. EVANS
mb Attachment cc: C. F. DiMascio
A. C. Roemhild
Q ALCOA
SF-4563 tREV 85-7)
FROM c. F. FETTEROLF
-Sr '* PITTSBURGH OFFICE - 30
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TO MESSRS. R. R. HOFFMAN - 29 J. L. DIEDERICH - 29 V. R. SCORSONE - 29
C. K. LIGON - 30 H. S. EVANS - 30
1989 January 04
RE: ASBESTOS
In a meeting this morning on a variety of environmental issues, the subject of asbestos was discussed.
We didn't have the knowledge in the meeting, but there were strong feelings that we need to deal more aggressively with eliminating asbestos.
Will you please insure yourself that:
1. The plants are aware of their asbestos situation. 2. We are not in violation of any regulation. 3. We are doing the right thing. 1989 is a good year to
put problems behind us. 4. You are satisfied with our position.
I would like your feedback.
C. F. FETTEROLF CFF/sam
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FROM RONALD R. HOFFMAN PITTSBURGH OFFICE - 29
FILE COPY
TO MR. F. A. APPEL - LEBANON MR. G. E. BERGERON - RICHMOND MR. D. M. FALLS - PGH. 28 MR. R. A. GLAH - PGH. 27 MR. T. J. TAYLOR - PGH. 28
1989 JANUARY 11
RE: ASBESTOS
There's a growing concern inside our environmental group here that we need to deal more aggressively with eliminating asbestos. Will you please advise me promptly of the following:
(1) I need to know if your plants are completely aware of their asbestos situation.
(2) Are we in violation of any regulation anywhere?
(3) Are we doing the right thing? The year 1989 is a good one to get problems behind us, and we should not be dealing with the asbestos situation on an "ability to fund" long-term program.
(4) Please indicate, based on the three previous questions, whether or not you are satisfied with your position.
Please give me your feedback promptly. Thanks.
RONALD R. HOFFMAN RRH/ab
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ALCOA
(rcv
FROM RONALD R. HOFFMAN,
PITTSBURGH OFFICE - 29 X*
TO MR. F. A. APPEL - LEBANON MR. G. E. BERGERON - RICHMOND MR. D. M. FALLS - PGH. 28 MR. R. A. GLAH - PGH. 27 MR. T. J. TAYLOR - PGH. 28
1989 JANUARY 11
RE: ASBESTOS
There's a growing concern inside our environmental group here that we need to deal more aggressively with eliminating asbestos. Will you please advise me promptly of the following:
(1) I need to know if your plants are completely aware of their asbestos situation.
(2) Are we in violation of any regulation anywhere?
(3) Are we doing the right thing? The year 1989 is a good one to get problems behind us, and we should not be dealing with the asbestos situation on an "ability to fund" long-term program.
(4) Please indicate, based on the three previous questions, whether or not you are satisfied with your position.
FROM T. J. LEVEQUE CLOSURE SYSTEMS INTERNATIONAL RICHMOND, INDIANA
T0 MR. R. R. HOFFMAN PITTSBURGH OFFICE
1989 January 27
RE: ASBESTOS - CSI INTERNATIONAL LOCATIONS
In response to your questions:
1. Plant Asbestos Situations:
a- Alcoa Deutschland - have eliminated all asbestos except possibly brake systems on presses and lining machines and seals on an extruder oven.
b. Capsulas Metalicas - have been eliminating asbestos but may have very small amounts in oven joints or on compressed air pipes.
c. Shibazaki - only asbestos is reported in oven wall and door insulation and "low content" asbestos in slate roof and sidewall - also ceilings.
2. All three managements report they are not in violation of any regulations. The Japanese do not have any asbestos regulations
3. The Spanish plan to replace their few uses of asbestos. The Germans are formulating plans now for complete elimination also. The Japanese are investigating substitutions for the oven insulation. The Japanese do not believe the "low content" applications pose health risks.
4. Both the Germans and Spanish seem to have satisfactory positions. I feel the Japanese situation should be investigated further to develop more information on the building situation. I will discuss this with George upon his return.
T. J. LEVEQUE TJL/ljh
cc: G. E. Bergeron
B ALCOA
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FROM RONALD A. GLAH PITTSBURGH OFFICE - 27
TOMR. R. R. HOFFMAN PITTSBURGH OFFICE - 29
1989 January 25
RE- AS8EST0S Ref: Your 1989 January 11 Letter;
In reviewing our facilities, we have found that we have two potential problem areas:
1. Ragsdale - Ceiling tile 2. Randolph - Pipe insulation
We have obtained test samples which have been forwarded for analysis to confirm whether or not the material is actually asbestos. If the results are positive, we must proceed immediately to remove the existing ceiling tile and pipe insulation by qualified contractors and replace with substitute materials.
RONALD A. GLAH
/eds
0 ALCOA
fr^-Y-ad
T. J. LEVEQUE
TO MR. R. R. HOFFMAN
CLOSURE SYSTEMS INTERNATIONAL
RICHMOND, INDIANA
PITTSBURGH OFFICE
1989-01-26
RE:ASBESTOS
This is in reply to your letter of January 11. I will respond to your questions with reference to C.S.I.'s domestic facilities. George will advise on the international locations when he returns from his trip overseas.
1. Plant asbestos situations:
a. Lancaster - All asbestos was discovered and removed or encapsulated during the process of shutdown. A consultant was used for identification of asbestos and certification of treatment.
b. H-C Industries - Olive Branch - Due to the age of the facility we do not believe any asbestos was used in its construction. No survey has been made, however.
c. H-C Industries - East Plant (New) Crawfordsville Due to the age of the facility we do not believe any asbestos was used in its construction. An internal survey has been made.
d. H-C Industries - West Plant (Old) Crawfordsville Asbestos pipe lagging was discovered and removed dur ing demolition of the old warehouse. We believe asbestos may be present in the roof.
e. Richmond Works - An audit was conducted by Corporate Environmental in 1986. Based on that data asbestos has been removed by an approved contractor whenever asbestos was disturbed or involved in maintenance work or equipment removal. Asbestos remains in the boiler house, in ducts in roof fanhouses, and in roof flashing, in pipe insulation on most overhead steam and water lines, and in oven insulation. None of this poses a health hazard according to the appli cable standards.
2. We are not, to our best knowledge, in violation of any regulations. We are complying with OSHA regulations for identification placards and labels for our drawings and in buildings where asbestos exists.
3. Based on regulatory and Corporate standards, we are doing the appropriate things.
T. J. LEVEQUE TO MR. R. R. HOFFMAN PAGE 2 - RE: ASBESTOS 1989-01-26
4. Am I satisfied? Ed Smith has directed his engineering department to develop costs for the complete removal or treatment of all remaining asbestos at Richmond.I've asked H-C Industries to contract with an outside consultant for identification/confirmation of their asbestos situation. The information gained from these projects will allow us to accel erate our asbestos activities if we wish to do so.
TIMOTHY J. LEVEQUE
TJL:dkb
cc: G. E. Bergeron - C.S.I., Richmond, Ind. E. F. Smith - Closure Division, Richmond, Ind. J. L. Eicher - Closure Division, Richmond, Ind. C. B. Schiele - H-C Industries, Crawfordsville, Ind. K. M. Walker - H-C Industries, Crawfordsville, Ind.
FROM: M.S. NELSON SHEET & PLATE DIVISION
TO:
V.R. SCORSONE ALCOA AEROSPACE & INDUSTRIAL PRODUCTS PITTSBURGH OFFICE
cc: L.P. HASSEY G.O. PRATT, JR
January 20, 1989
RE: ASBESTOS
I have attached a synopsis of our asbestos activity at Davenport broken down along the lines of the original 4 questions in Fred's letter of January 4. While this may be a little more of an answer than you want to give Fred, I feel it is important you understand we have a lot of asbestos at Davenport and we are stepping up our removal efforts. It will be no small task and will impact our profitability.
In regard to the P.S., there are spots where asbestos has come loose on pipes and these represent our "extreme" hazard areas and are the areas we work on first. We do not feel employees are exposed to airborne asbestos above the action level.
MSN: Attachment
M. S. NELSON
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ALCOA
m . Ttir
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89 ei/ii ns43
2 3193443821
fil.COfi SH 8 PL
82
FRO%, B. SCORSONE
ALCOA AEROSPACE & INDUSTRIAL PRODUCTS ^PITTSBURGH OFFICE
T0Mr. c. R. GILLESPIE ---CLEVELAND
MR. R. A. KOCERHA - LAFAYETTE MR. T. S. MOCK - MASSENA MR. M. S. NELSON - DAVENPORT S&P MR. D. W. RAY - PITTSBURGH - 18
1989 January 10
RE: ASBESTOS_____________________________________ Please respond to the four questions Fred poses in the attached letter. Sandy, I also need your response to the PS allegation. The due date for replies is January 25.
V. R. SCORSONE VRSrrsb Attachment
r
'89 61/16 11:44
2 3193443021
fiLCOft SH i PL
PC c. F. FETTEROLF PITTSBURGH OFFICE - 30
MESSRS. R. R. HOFFMAN - 29 J. L. DIEDERICH - 29 V. R. SCORSONE - 29 C. K. LIGON - 30 H. S. EVANS
:
1989 January 04
RE: ASBESTOS
In a meeting this morning on a variety of environmental issues, the subject of asbestos was discussed.
We didn't have the knowledge in the meeting, but there were strong feelings that we need to deal more aggressively with eliminating asbestos.
Will you please insure yourself that:
1 . The plants are aware of their asbestos situation. 2. We are not in violation of any regulation. 3. We are doing the right tiling. 1989 is a good year to
put problems behind us. 4. You are satisfied with our position.
I would like your feedback.
C. F. FETTEROLF CFF/sam
PS - VRS - The statement was made that Davenport had loose asbestos hanging from pipes/ceiling. A real danger.
C8
SITUATION:
ASBESTOS PROGRAM STATUS REPORT January 20, 1989
Davenport Works is aware of the presence of asbestos in the facility.
Approximate extent:
37 miles of asbestos insulated pipe 12 pressure vessels or tanks
4 HVAC systems 49 heat treating furnaces
Facility survey began 1988 June, approximately 50 percent complete. Description in attachment A.
Survey results indicate a significant amount of asbestos abatement is required at Davenport Works.
Preliminary cost estimate to abate the asbestos hazards at Davenport Works, including removal and reinsulation and/or repair, are approximately*:
Piping: Pressure vessels and tanks: HVAC systems: Heat treat furnaces:
$6,232,000
500.000 400.000 _____526,000
Total
$7,658,000
`(These figures do not include lost production resulting from outages, additional equipment maintenance which may occur concurrent with asbestos abatement, or expenses for administering abatement program.)
Additional information on pending lawsuits, employee awareness and medical claims is listed on Attachment B.
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REGULATORY COMPLIANCE;
Potential violations of 29 CFR 1910 or 1926:
- 1926.58{k)(2) Labels, (i) ...Where feasible, installed asbestos... products shall contain a visible label.
Heat treat furnaces have been posted with signs warning of the presence and hazard of asbestos in thermal insulation installed thereupon. No labelling program has been initiated for asbestos containing materials on piping, HVAC or pressure vessel equipment.
- No Davenport Works employees are currently involved in asbestos removal, repair or renovation which would result in an exposure to airborne asbestos above the action level. This work has been contracted to experts in the field since 1988 July.
- Davenport Works employees are exposed to low levels of airborne asbestos below the action level emitted from damaged and deteriorating insulation present in the workplace. This is not currently a violation of any regulation but is a potential liability.
RECENT. CURRENT AND PLANNED ACTIVITIES
In 1988 the following asbestos abatement projects were undertaken:
1. Removal and reinsulation of No. 3 batch furnace 2. Removal and reinsulation of pipe insulation in Bldg.
815 3. Removal and reinsulation of stack and breaching of
No. 29 batch furnace 4. Removal from heat exchanger in Bldg. 855 prior to
installation of new unit 5. Removal and reinsulation of collector ducts of No.
11 horizontal heat treat 6. Removal and reinsulation of doors on No. 14 batch
and No. 5 reheat furnaces 7. Removal and reinsulation of collector ducts and
stack of No. 4 foil anneal furnace 8. Emergency clean up and repair of insulation on tank
in Bldg. 855 9. Emergency clean up and repair of insulation on pipes
in Bldg. 814 N (two occasions). Bldg. 816 (three occasions), and Bldg. 810 (one occasion) 10. Removal of insulation and piping in Bldg. 814 above 100 inch mill 11. Removal of insulation and piping in Bldg. 816B 12. Removal and reinsulation of piping in Bldg. 808 tunnel
The following asbestos abatement projects have been completed in 1989 or are currently in progress:
1. Removal and reinsulation of stack, breaching and collector ducts of No. 26 batch furnace
2. Cleanup of debris and repair of insulation on stack, breaching and collector ducts of No. 25 batch furnace
3. Removal and reinsulation of collector ducts and stack of No. 5 foil anneal furnace
4. Removal and reinsulation of collector ducts of No. 8 foil laminator
The majority of projects undertaken to date have been initiated by the need to accomplish other goals, because of employee complaints, or under emergency spill and clean up conditions.
PROGRAM NEEDS
- A timetable or priority for asbestos abatement has not been established. The following activities have been identified for the implementation of an asbestos abatement management program:
1989 ASBESTOS PLANS
- Finish the survey
- Formalize and communicate our abatement plans
- Establish a contractor on site, full time, to remove the extreme and severe conditions
- Assign needed resources to coordinate efforts of the contractor
- Evaluate capability to handle multiple crew/multiple contractor teams
- Estimated cost $500,000
FUTURE YEARS
- Handle multiple crews/multiple contractors to shorten abatement time to 10 years
Attachment A
ASBESTOS SURVEY DESCRIPTION
Intent: to document the location and condition of asbestos containing material (ACM) in the plant to prioritize asbestos abatement activities.
Method: visual inspection of suspected ACM.
Material
appearing to be asbestos was assumed to be asbestos unless
proven otherwise. Many bulk samples of asbestos containing
materials from the plant have been analyzed over the past ten
years by the industrial hygienists and results demonstrate
that most (85%) thermal insulation contains asbestos.
Ranking. the following attributes are ranked based on severity: deterioration, physical damage, potential for continuing damage, delamination, presence of debris and water damage. The degree of severity is ranked as extreme, severe, moderate or slight.
Completion: approximately 50 percent of the plant has been inspected by the industrial hygienist. The inspection was halted in the fourth quarter of 1988 due to the commencement of an OSHA general inspection lasting nine weeks over a three month period.
Results: the 50 percent of the plant inspected is
representative of the plant as a whole. Based on this
information the following table summarizes the condition of the asbestos in the plant (based primarily on deteriorat physical damage , and presence of debris):
Piping
Extreme 15%
Severe 25%
Moderate 30%
Slight 30%
Vessels, tanks and HVAC
33%
25%
42%
0%
Heat treat equipment
6% 35% 28%
31%
LAWSUIT
Attachment B
OTHER ASBESTOS ACTIVITY
A class action lawsuit has been filed by 23 people (4 Alcoans) against the 29 named asbestos supply companies.
A restraining order was issued against Alcoa by the law firm representing these plaintiffs, to have us stop removing asbestos. We are actively debating this issue in front of a judge.
Alcoa legal and Lane & Waterman are representing Alcoa.
EMPLOYEE AWARENESS
Law firm or technical expert talked to ABGWIU last spring (88) and convinced several to go to Des Moines for medical evaluation. Law firm is trying to get more clients.
-Unrest among employees. Complaints seem to be coming from those that bought into the law firm's story.
EMPLOYEE ASBESTOS CLAIMS
.
Brick mason has confirmed asbestosis. Worked here 30 years, all as a Brick mason. Asbestos products were used in past years in the Ingot Plant furnaces.
General Mechanic claimed asbestosis; pre-employment X-ray 5 years ago showed same thing. We don't know if he was exposed here.
Facilities Service Department person claims asbestosis. We are actively testing for verification.
Ingot Plant employee claimed exposure; no asbestosis found.
Inter-Office Communication B. James January 31, 1989
To.
C. F. Fetterolf
7)fJ ^
Asbestos
... ....
Please be advised that ALCOA/TRE has assessed the asbestos situation throughout its four divisions. The Composite Structures division in Monrovia is the only location where asbestos exists. It is located in floor tiles, which pose no health hazard. Some asbestos also exists within the ceiling of the plant area. We will be conducting tests within two weeks to determine the extent of this situation and the health hazard it may pose to our employees. If the tests reveal exposure above permissible levels, the asbestos will be removed.
The California Health and Safety Code was recently modified (effective January 1st), requiring building owners to notify employees and contractors of the presence of asbestos in buildings. The Alcoa legal staff is preparing,,a standard notification letter, which we will distribute.
Otherwise, we are not in violation of any regulations and appropriate members of management have been apprised of the situation.
Bruce James
/lit
cc: C. K. Ligon E. Ecton J. Rauls J. Carter W. Gartner R. Shepard
R. Walker M. Scott P. Pruitt A. Piecka
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ALCOA TRG
F.. FETTEROLF % '
ITTSBURGH OFFICE - 30 ` '%-
<.i.s
Received
TO MESSRS. R, R. HOFFMAtT- 29
JAN 1 3 Bog
L. DIEpfiRICH - 29
V. R. SpdRSONE - 29~
C. K-/LIGON - 30 H. JS, EVANS
1989 January 04
ASBESTOS
i.In a meeting this morning on a variety of environmental issues, `^the subject of asbestos was discussed.
,We didn't have the knowledge in the meeting, but there were strong
feelings that we need to deal more aggressively with eliminating asbestos.
Will you please insure yourself that:
1.
; `I 2.
r:
i.-.*r*>-
3.
4.
|?X would
i
The plants are awaxe of their asbestos situation. We are not in violation of any regulation.
put problems behind us.
l`c. f. f;
ALCOA
IMHI (*
ALCOA S.A.
AVENUE D'OUCHY 61 1000 LAUSANNE 6. SWITZERLAND
from R.G. Franzoni
to C.F. DiMascio
re: Asbestos
Bill Snadecki has asked me to respond to Harold's letter on
the subject dated January 17.
.
1) Switzerland has very stringent regulations on asbestos. The sale and importation of products containing asbestos is prohibited in Switzerland as of March 1, 1989. Since 1975 already it was recommended to not utilize asbestos any more.
2) In our Lausanne building we have torn out the last asbestos insulation some years ago and we progressively discard fire-proof filing cabinets which still contain asbestos.
In response to Harold's earlier letters on compliance with safety rules and policies I can at this point offer the following response:
Since the Lausanne building houses exclusively administrative functions, safety concerns centre around fire and emergency evacuation. In a forthcoming general meeting with our employees we are planning to discuss this matter, reconfirm the existence of the in-house "intervention team" and "crisis response unit" and announce that there will be a fire and evacuation drill soon after the meeting. With the help of the Swiss Bureau of Accident Prevention we have also organized access to demonstrations for safety belt utilization and general accident prevention.
We'll continue to increase our employees' awareness about safety, health and accident matters and ensure compliance with rules and policies. Not necessarily through spectacular events but by regular and repetitive information.
cc: H.S. Evans, A.C. Roemhild, W.A. Snadecki
AISA 201