Document ev02pq4EMGJoK5KVebnX8L6zm

PLAINTIFF'S EXHIBIT SOUTH CHARLESTON PLANT ASBESTOS INSULATION UPGRADING PROGRAM SUMMARY A program 1$ proposed to upgrade asbestos Insulation In the South Charleston Plant to comply with OSHA standards. The program Is estimated to cost 14.2MMover a three year period. The plan Is to remove asbestos from Idle equipment, replace damaged Insulation with an approved type, and seal with metal cover all remaining asbestos Insulation. Outside contractors will be required to meet the schedule. The work will be divided Into three (3) phases: No. 2 steam plant, operating units within battery limits, and support facilities. JUSTIFICATION The Justification of this project Is occupational health. The present OSHA Asbestos Standard, 1910.1001, specified two flbers/cc as the maximum allowable exposure over an eight hour period. The figure refers to fibers greater than five micrometers In length and would amount to about 16 million fibers In that time period. Because there Is no evidence In occupational studies to show that there Is a threshold level below which there are no adverse effects. OSHA Is pressing for a lowering of the level to 0.5 or 0.2 flbers/cc. Much of the Insulation In the Plant Is asbestos and Is In poor condition. Uncovered, unprotected asbestos Insulation In the plant constitutes a threat to employees, and even the community. It represents a pool of fibers which slough off as weather and wind dictate, and enters the air In which our employees work. Although there Is a legal exposure limit which our measurements suggest we are complying with. It Is believed that any exposure may be harmful In the long run. UCC 006474 PROGRAM DESCRIPTION Phase 7 Units No. 2 Steam Plant ; Portion Hater Treating Unit Schedule Complete 1985 Cost Capital $ 900,000 Expense 251.000 Total $1,151,000 The attached work order request details this phase of the program. Phase 2 Units Mixing Upper Island Mainland PVA Resins Solvent Vinyls Polyols Specialty Catalyst Specialty Chemicals Middle Island Oxide Adducts Schedule Complete 1986 Cost $2,480,000 Phase 3 Units Complete Hater Treating Unit Utility Distribution Distribution Bulk Terminal Maintenance Schedule Complete 1987 Cost $540,000 UCC 006475 COST ESTIMATE -3- The Phase 1 estimate Is based on a detailed scope and budget pricing obtained from a local Insulation contractor. The cost estimates for Phase 2 and 3 are based on an Insulation survey of each operating unit and estimating the associated manhours and materials required to do the work. COST ALLOCATIONS TO TENANTS The program costs for Phases 1 and 3 are allocated to tenants based on 1985 usages of utilities and services (plant period cost allocations); whereas, the Phase 2 costs within the manufacturing battery limits are funded by the responsible tenant. Division H-Dollars Phase 1 CaDltal Expense Phase 2(2) Phase 3(1) Grand Total Silicones & Urethane Intermediates Specialty Chemicals Solvents & Coatings Materials Ethylene Oxide/Glycol Specialty Polymers & Composites Totals 392 no 565 316 88 1,354 90 25 77 21 293 164 25 7 900 251 104 2.4B0 183 1,250 no 1,868 177 585 62 324 8 144 540 4,171 Notes: 1. Funded as Host support project 2. Funded as tenant direct manufacturing projects Hay 14, 1985 UCC 006476