Document e5Bw432B9DBg8ebYzNOmyqNEp

FROM: C. A. CARTER TO: L. D. RUSSELL 1989 JANUARY 19 RE: ASBESTOS In response to Mr. Diederich's January 09 letter on the captioned subject, 1 have the following comments. 1. Are we in violation of any regulations? Ail asbestos waste is going to a special section of the County landfill in full compliance with the regulations. We have been utilizing certified asbestos removal contractors for large-scale asbestos removal jobs for last five years. We are in full compliance with the regulations on these jobs. the We are probably not in compliance with personal protective requirements of our maintenance people working on smallscale, short-duration operations. This would include such jobs as repairing or replacing a valve in a steam line. We have been trying for some time to conduct air monitoring on this work to determine the level of asbestos exposure and hence, the appropriate level of protection for our employees. However, since this work is usually done on an emergency basis and almost always on the weekends or off-shift, we have not been successful. However, we have decided to proceed with a comprehensive six (6) hour training program in April and to cover a I 1 of the protection options. This will put us in full compliance with the regulations on these jobs. 2. Are we proactive enough? I believe that we are very proactive on the elimination of asbestos from our plant. Over the last ten years, we have successfully eliminated virtually all asbestos from our operating supplies and spare parts. Vie are currently working on a plan and cost estimate to remove all remaining accessible asbestos from the plant during 1989 and 1990. Since this will be a major expenditure on the order of *500,000, it is imperative that our corporate management be supportive of our plan. 1 sense from Mr. Diederich's letter that the support is in place at this time. Conrad Carter cc: T. W. Baugh FILE: IH\A]R\ASBEST0S\D1EDER1CH BDN 033327 rAVnA4CAl