Document dYL307zVoerm3nRqM91p8BjQq

W- o 2-07 /yy ASBESTOS INSULATION REMOVAL PROJECT OBJECTIVE OF THE PROJECT The objective of this project is to minimize hazards of airborne asbestos in the South Charleston Plant. JUSTIFICATION The justification for this project is Occupational Health. The present OSHA Asbestos Standards, 1910.1001, specifies 0.2 fibers/cc as the maximum allowable exposure over an 8-hour period. ALTERNATIVES TO REMOVAL Continue operations with the present asbestos insulation. Personnel may be exposed to airborne particulate asbestos. TECHNICAL RISK There is no technical risk associated with this project. OCCUPATIONAL HEALTH CONSIDERATIONS This project will correct an occupational health concern by removing asbestos insulation from equipment, lines and facilities. When the insulation is being 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 clothing. ENVIRONMENTAL PROTECTION CONSIDERATIONS ' This project will be in compliance with all applicable OSHA and EPA Regulations. The U. S. Environmental Protection Agency will be notified that the removal of asbestos insula tion could occur at the South Charleston Plant. UCC 006626 PROJECT PLAN Initial implementation of this project authorized the removal of asbestos insulation from idle equipment and lines only, as specified in approved "838 Work Order Requests". These areas included: Specialty Chemicals Middle Island Polyols Upper Island Specialty Catalyst Solvent Vinyl Resins Subsequent "838 and 930 WOR's" have also been approved for removal and replacement of asbestos and temporary insulation at the Oxide Adducts Unit. The work associated with this project will be performed by outside contractors. Powerhouse Equipment Company is currently on-site performing this activity. Work priorities and schedules will be developed based on the criteria contained in the attached "Asbestos Project Criteria". A preliminary "Schedule for Asbestos Removal" is also attached which reflects individual job status. Through 1987, approximately $147,000 has been spent on this project. Projected costs to be incurred as a result of this project scope are anticipated to run about $5 million over the next 3 years. In order to assist in the effective management of this project, a single individual has been assigned as the "Insulation Contract Coordinator" (Herb Price x2953). To ensure that this project is performed in accordance with the applicable laws and regulations, the Insulation Contract Coordinator recently attended the "Asbestos Competent Person Training" conducted by the National Asbestos Training Center. The attached job description reflects the initial attempt to define the activ ities associated with this position. During the next few weeks. Herb will meet with each department head (or designated unit contact) to review individual department requirements in order to develop a composite list of the plant's critical few. UCC 006627 ASBESTOS PROJECT CRITERIA 1. Analytical tests are used to identify the composition of insulation materials. 2. Work priorities and schedules are developed based upon:. o verification of the insulation as asbestos o degree of deterioration of the insulation o interior locations with greater exposure potential are given priority over exterior locations with low exposure potential o scheduled or pending shutdowns are considered o potential for interference with other work activities, i.e. paint program o efficient utilization of the contractor resources (minimize skipping around) 3. All insulation material identified or applied under this program is clearly labeled for future reference. 4. Records are maintained documenting removal and repair activities, quantities of asbestos insulation removed, and associated costs. 5. All applicable Federal and State regulations are followed. 6. A schedule is developed projecting 30-day work activity and is updated every two weeks. RGH:mb 3/23/87 0179a UCC 006628 JOB DESCRIPTION CONTRACT COORDINATOR - INSULATOR The following list of job activities represents the initial attempt at defining a new position in the Maintenance Department Contract Coordinator Group. This job description will be reviewed and updated as necessary no later than July 1, 1987. 1. Receives all work requests for insulation work to be done by contractors. Generally, the incumbent should receive these requests from the Area Maintenance Superintendent. This will ensure the Area Superintendent concurs with the decision to sub-contract the work and that he knows what work is being done in the area. 2. Establishes priorities for contractor usage. A schedule will be developed listing the contractor insulation work that is planned. The schedule will cover a 30-day period and will be updated every two weeks. 3 Enforces safe work practices with the contractors. Monitors contractor work for compliance with all Federal, State, and Plant Safety/Health regulations. 4. Ensures that all required testing and analysis is performed to clearly establish insulation material as being either asbestos or non-asbestos. 5. Ensures that all required personnel monitoring and area sampling is conducted. , 6. Recommends/decides removal vs. repair and encapsulation. 7. Assists in developing a recommendation to enable clear identification of insulation material as to its asbestos or non-asbestos composition. This identification will apply to newly installed insulation as well as insulation which is tested and repaired. Once a method to identify is agreed upon, the incumbent ensures that identification is applied. 8. Prepares estimates as needed to aid in notification by EP personnel to Federal and State regulatory agencies. 9. Decides when special work hours are appropriate for the contractors. 10. Verifies all contractor time and material changes. 11. Ensures that valid account charges are used. Monitors and reports costs as appropriate to ensure meeting objectives. 12. Monitors contractor productivity. Takes or recommends action as appropriate. 13. Prepares and distributes periodic reports documenting progress of the Asbestos Insulation Program. RGH:mb 3/23/87 0180a UCC 006629 UCC 006630 on~t3 46 b lF !? 1! ic 7T 5. 0VA \ |! X ^. 1 Q QO$cJ: 9 3 \*0 l *\ n ~sfs-------- 1 *0 TV^ >\5 it A. `3? *) If* ^tG^t -UrV*S5)' -7 4 5^.r k8CX^\^ <iU <5 <u ~Q 3 ti *!"4r4 Co \^ > > 5X =a ^* a*" 7^) VL4 ^. E^ ; f<NtK.\ ` V) fc -O ft 1 - tj ^O1i ^xOis ` tt* OCi A 0 "" .Ovx' . -% . uJu>: vro* .nZsa W '\x ' .. . ____ __1i 1j| *.?: 2'f -141*tH *i^mX^5"<ch'*-> $ *^V \ Vi >sS Ci L j stj1 i[ t\i 1 1i-i0** & 4 Q *1 > AV \U \-- <Qn\ C3 rCt>i UCC 006631 'X -K^ ^=7tr *> v CcO: =c --* . V\\QiC\ I?- <f* MS0 Ir cXr^ .<^0n - N ^^ I \ '0v OQ. A X $bl*J UCC 006632 UCC 006633 V--.rv v)'T3- . I r- M) T- lh> s| \5 (O 'CW . fi 1 -<v^ <3i 'fi \i iN m Q ^t $ 1?>> Qj Qc $ V St ^145Q . <* ^c i 4) l ^<9 `O : i <s_^J n^ ^ CL ~i? -Q <u -5: <4 ^ ? \ ~3r si -O i ft! rk* CN *& P \ _f^ V. . Ni <A ^ 4 f* Mv 'Q (^)- ^ Cc i. >Oj -*o 5 '0 ^ ti . y* -a *E 3-J iK 'S* 4 Os <0 O' o si a o tK 1b a " UCC 006634 '-~3 t7 & O- O'-