Document e1Qgj2qdRnaXdDyrjxGXgYb4q

P.R. ATKINS ENVIRONMENTAL CONTROL C.F. DIMASCIO PGH. HEALTH & SAFETY DISTRIBUTION 1990 March 27 RE: ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY - PLANT COMMENT The attached Alcoa Asbestos Managemant Policy has been developed as a subset of Alcoa's Environmental Policy. Review and input has already received from a number of people representing Environmental, Industrial Hygiene and Safety, Procurement, Real Estate and Legal. Our basic philosophy is that when Alcoa controls a facility, the asbestos can be managed via remediation and monitoring, but if a facility is sold, the asbestos must be removed to minimize Alcoa's long term liability. Before its release, your input is requested. Of particular interest are your thoughts on the implementation schedule. There are at least two types of implementation options: A fixed time schedule might have one effective date for completion of asbestos surveys and a later effective date for location Asbestos Management Programs. For example, surveys could be completed within two years and Management Plans could be completed within four years of the date the Policy is communicated. A negotiated implementation schedule could be a implementation schedule proposed by the plant location and approved by the appropriate Management Committee Member. This concept is modeled after the written plans for corrective action described in the Environmental Policy. Before the Asbestos Policy is put into place we would like your final input. Please Send your comments via Fax to Laura Rippey at 8/553-3835 by 16 April. C. F. DiMascio P. R. Atkins 369054 0510 1990 March 27 ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY SCOPE: Proposed policy will apply to all Alcoa owned or controlled facilities including industrial as well as office buildings. Relevant aspects of the policy should also extend to properties leased by Alcoa where Asbestos Management Programs should be required of building owners. Some variations may occur where local regulations or special circumstances dictate. POLICY OBJECTIVES: 1. Uniform and consistent practices are hereby established for the purchase of facilities, equipment and new products and for the divestiture of equipment and facilities including real estate. A. Sponsoring managers shall require that environmental surveys conducted prior to purchase of new facilities, involve asbestos surveys and risk assessments. Full compliance with all Alcoa asbestos management policies will apply if properties with asbestos are purchased. B. Prourement agents shall insure that only non-asbestos products are be purchased. Every effort will be made to find non-asbestos substitutes for the remaining asbestos containing products used in Alcoa facilities. Deviations from this policy will require written approval of the Location Manager. The Procurement Manager must maintain written records of asbestos products purchased in exception to this policy. C. Purchasing agents shall insure that equipment sold by Alcoa must be free of friable asbestos prior to sale unless an exception is made by Pittsburgh Environmental Control. Where an exception is granted, written disclosure of the presence of asbestos must be provided to the purchaser. D. Sponsoring managers shall insure that before any sale of real property, an asbestos survey will be conducted. All friable asbestos materials must be removed and disposed of properly. In some cases, non-friable asbestos materials should also be removed if it is suspected that the future use of the property will subject them to damage, thereby releasing asbestos fibers. Exceptions to the removal policy can only be made by Pittsburgh Environmental Control. Buyers must be informed in writing of the presence of any asbestos in buildings which are sold. 2. Operations Managers shall require surveys for all Alcoa facilities to determine the presence of Asbestos Containing Materials, "ACM" (greater than 0.1 % of any fibrous asbestos mineral forms). Surveys must follow the general format recommended in the Alcoa Engineering Standard on Asbestos Surveys and must include the condition of ACM in addition to the location accessibility and an estimate of ACM quantity. I\asbestl6.LLR 369054 0511 ASBESTOS POLICY 1990 March 27 Page 3 3. Plant managers operating facilities having any ACM shall develop written Asbestos Management Programs which must be approved by a member of Alcoa's management committee. The Location Asbestos Managemant Program is to include: A. Identification of ACM via direct labels or any alternatives to direct labeling which would clearly comminicate the presence of ACM to affected employees. Such alternatives could include placards, inventories, diagrams, or marked blueprints. To effectively communicate the presence and location of ACM, some of the alternatives should be associated with training and be made accessible to employees. B. Communication of the presence of asbestos to facility employees and contractors who work in areas where asbestos is present C. A plan for reinspection of ACM on a periodic basis (minimally, every 3 years) with written inspection reports D. Remediation, through removal, repair, enclosure or encapsulation of ACM in a deteriorated condition (Attachment 1) E. Assurance that all asbestos work including removal and disposal is carried out in compliance with all relevant Federal, State and local regulations (ref. Alcoa Engineering Standard 18.18 "Asbestos Removal Standard") F. Directions to ensure that Operation and Maintenance procedures will be defined to prevent employee exposure to asbestos during normal day- to-day operation of facilities where ACM is present. G. Acknowledgement that all asbestos contracts will be written in Pittsburgh in close cooperation with the various field Procurement Departments and will be retained for the 30 year retention period in accordance with the 1989 Pittsburgh Procurement policy. H. A plan to address any potential emergencies where asbestos may be released in the facility. The SPCC (Spill Prevention Control and Countermeasures Plans) could be revised to include this contingency where appropriate. I. A long range strategic plan that recognizes that at the end of a facilities life, prior to its sale or demolition, all friable asbestos must be removed 4. Alcoa locations will comply with applicable asbestos laws and regulations and will employ more restrictive internal standards where necessary to conform with the above policy. I\asbestl6.LLR 369054 0512 Attachment 1 MANAGEMENT OF ASBESTOS CONTAINING MATERIALS IN ALCOA FACILITIES ACM - Asbestos Containing Materials both friable and non-friable materials containing > 0.1% fibrous asbestos mineral forms. Friable - EPA definition - asbestos containing materials which can be crushed with hand pressure. Examples of friable asbestos include sprayed on fireproofing, most asbestos insulation and any other ACM which is deteriorated to the point that it can be crushed with hand pressure. Non-friable - Examples asbestos include transite (asbestos cement products) and vinyl asbestos tile. I\asbestl6.LLR 389054 0513 Ap^- / ^ ASBESTOS MANAGEMENT POLICY 1990 March 27 Page 2 I | bj O'S - Action Copies; T.S. Mock, Massena R.M. Overby, Massena S.M. Anderson, Massena J.L. Eicher, Richmond B.L. Humphreys, Richmond K.R. McElheny, Richmond P.D. Judd, Portland Australia Gerard Kennedy, Portland Australia Barry Chesson, Boorangoon Australia Alain Belda, Sao Paulo Office Ik \) 'Vko. A ^ o^nK 3> ^ 'n, w. toncuio, sdu rauiu Informational Copies; C.F. DiMascio, Pgh. 6 J.L. Fungaroli, Pgh 12 L.F. Schneider, Pgh 14 W.L. Wells, Pgh. 26 yU^s- `O . v^\aa\jlJc a\a-o k^JO^f 11 z^u_ /Vw^_ tu^rp^vu^ UMjbk) ^. J RPRRECEI3VE1D990 JLF. 1XASBEST19. Hr /^ ' r A 5" ^ 360054 0500