Document gDmpmyLVm8mVd8X4e6w2NVNOG

...ION CARBIDE CORPORATION ENGINEERING, HANOFACTORING AND TECHNOLOGY SERVICES DEPARTMEN' HEALTH, SAFETY AND ENVIRONMENTAL TECHNOLOGY South Charleston, West Virginia BUSINESS CONFIDENTIAL MEMORANDUM March 23, 1987 TO: C. C. Neely w(jUyAnUb. 4i* 4.1 COPY: FROM: L. E. Calvert S. W. Clark G. B. Elder R. W. Engle P. R. Kavasmaneck S. S. Murphree J. E. Neff T. E. Hanning RECEIVED MAR 2 4 1987 CCN SUBJECT: Asbestos Implementation Task Group March 17 Meeting Minutes Clyde, The following information is being forwarded for issue as part of the subject minutes and represents those items tagged for responsibility by the Industrial Hygiene contact on the Asbestos Implementation Task Group. Also please find attached SH-256, Removal and Handling Asbestos-Containing Materials, which is a Standard Practice of the C&P Safety/Health Technology Manual. Section 2.6 of this standard deals with the EPA regulations for removal and handling of asbestos materials and has not been updated with respect to recent EPA asbestos proposals. The sections dealing with OSHA regulations have been updated. SH-256 has been volatile and will be revised when needed as part of my responsibility as a member of the Safety/Health Standards Team. Identification of Asbestos-Containing Materials A goal of the asbestos task group is to establish a program so that asbestos will not be purchased after January 1, 1989. A C&P criteria ( guideline document ) for the identification of asbestos-containing materials is needed as part of the overall program. A consensus of C&P Industrial Hygiene Departments will be sought as a basis for the criteria. The criteria will provide recommended techniques and when to use them, pricings timing and accuracy of results, and other*Subjective information. Polarized light or scanning electron microscopy are two identification techniques that can provide fast and accurate confirmation for the presence of asbestos. This assignment will have the following estimated schedule and cost. Schedule: 4Q 1987. Cost: None, cost will be part of normal Safety/Health Standards Team Work. UCC 015769 Removal. Modification, and/or Disposal of Asbestos-Containing Materials The need for a protocol to sample asbestos at the new 0.2 fibers per cubic centimeter of air exposure level was discussed. The protocol would be used to establish asbestos exposure data from the storage ( binders may deteriorate and release asbestos }, cutting and changing out of asbestos gaskets and packing. After discussion with Industrial Hygiene representatives, the need to develop a generic test protocol for asbestos exposure is not warranted since the OSHA Asbestos Standard clearly defines the sample taking method that must be used. The Plant Industrial Hygienist is familiar with this method and can quickly outline a technician's job duties in taking air samples during storage, cutting and changing out of asbestos gaskets and packing. Additionally, the Plant Industrial Hygienist will be able to supply other recent asbektos exposure data from the plant monitoring strategy program, if available and applicable. This action will have the following estimated schedule and cost. Schedule: Sample taking can proceed immediately with the support of the location Industrial Hygiene area. Cost: Hone, resources are outside this task group. Sincerely, Terry H. Hanning 2000/3828 Unicom 8-721-5903 UCC 015770 o \ l t. I TANDARD PRACTlCfc MUTER MVI8ION SH-2S6 PAGE 1 OF 7 DECEMBER 1986 REMOVAL AMO HANDLING ASBESTOS-CONTAINING INSULATION MATERIAL 1 GENERAL , 1.1 This Practice provide* a procedure for the safe removal and handling of ashettoa-contalalng Insulation Material and csnpllance with USHA regulation 29 CFR 1910.1001 and 1926.68 and CPA regulation 40 CFR hi Subpart H. The purpose of the Practice Is to ensure the safety and health of taplayees directly Inwived with perforating the wort and of others, either In the laraeolate area or downwind, who nay be exposed to residual dust/fibers. Insulation Material containing asbestos Is no longer Installed by uct; therefore, the concern of this Practice Is to control renovation and demolition operations Involving the reaoval of old. asbestos-containing Insulation; In these activities OSHA Standard 29 CFR 1926.SB Is applicable. For additional details, review the OSH* Standards. All Insulation materials approved through the use of UCC Insulation Standards have been specified asbestos-free since 1976. 2 STAWARDS 2.1 feralssible exposure Units 2.1.1 Eaployee 8-hour time-weighted average exposure to airborne concentrations of asbestos fibers shall not exceed 0.2 fibers, longer than S micrometers, per cubic centimeter ef air. 2.1.2 An action level of 0.1 fibers, longer than 6 micrometers, per cubic centimeter of.air has been eat which triggers the Monitoring, Medical, and eaployee Information and training requirements. 2.2 Wort Practices 2.2.1 Insofar as practicable, demolition, removal or handling of asbestos-containing Insulation shall be performed while the material la In a sufficiently wet state to prevent (mission of airborne fibers exceeding exposure limits prescribed In 2.1.1 and 2.1.2. See Section 2.7.9 for the specific EPA regulations that control wort practices. Wherever feasible, the employ*r shall establish negative-pressure enclosures before coamenctng removal, demolition, and rennovetlon operations. 2.2.2 Caution signs shall be posted at all approaches to areis which may contain excessive concentrations of airborne asbestos fibers so that an employee may read the signs and take necessary protective steps before entering the area. Tim signs shall state: DANGER-ASBESTOS; CANCER AND UHC DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS AND PROTECTIVE CLOTHING ARE REWIRED IN IMIS AREA In addition to these signs, legible signs warning of the health hatards of ssbestoa shall be provided and displayed et each location where airborne concentrations of asbestos fibers may exceed the exposure limits listed In Section 2.1.1. See Section 2.0.4.a for additional requirements for posting signs. Whenever feasible, a negative pressure enclosure must be established before cowenclng removal, demolition or rennovetlon operation. Air exhausted from the enclosure must pats through a ICP filter (See 29 CFR 1926.S8). 2.2.2.1 An appropriate barricade, using caution or barrier tape for cxaaple, shall be erected around the perimeter of outdoor areas as a supplementary, protective measure to discourage unauthorized entry. L. ' C 22.6.1.2 UCC 015771 STANDARD PRACTICE SH-250 PAEE'i OF 7 DECEMbER 1586 INTER DIVISION 2.2.3 Insofar > pnctlubli, rwM Insulation thill k netted end pieced directly lute libeled pintle Hgi (or other suitable contilnert) for disposal it n approved landfill. Otherwise, piece pintle eheetlng heoeith the job site, olit spray the rawoved Insulation with witer, {ended water,) or netting igent end then piece In pintle fat. When net aethods of rewovil/Cleanup ere Inpractlcel. e.g., nhen topentmti ere helon freezing, vecowing or snecplng Mjr ierve n ineffective iltemeu cleenup nethod. Snecplng ccapouna thill he epplled to the nort irei to prevent dust generetlon nhen snecplng. See Sections 2.7.J.7 iM 2.7.4 for specific nort practice requlments. 2.2.4 libel Speciflcitlow lontelner ceutlon libels shell he printed In letters'of sufficient size end contrast es to be readily visible end legible. Where feeslble. Instilled esbestos-contelnlng products shell ilso conteln e visible libel. The libel shill stete: DANGER - CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST; CANCER AND LUNG DISEASE HAZARD Where feeslble. Instilled isbestos cootilnlng predicts tlould be libeled In eccordince with 2.2.4. 2.2.5 Reoulited Areis - Enployers oust Identify is regulited ireis try locitlons In their workpieces rdiere there mty be occupittons) exposures to llrborne concentrations of isbestos ibove the PEL. Only tuthorized persons, with proper respiratory protection, way enter regulited ims which oust be cleirly posted. Eating, drinking, end saoklng ire prohibited In regulited trees. 2.2.b Housekeeping - All external surfices In ny pltce of toplqywent shill be mlntalned free of occiaulitlon of isbestos fibers. Speclil ittentlon should he given to cletnlng sciffolds used In dewollttoo nort. Clen-up of isbestos dust Is prohibited with ccaprested ilr, dry-sweeping or my dry clein-up process. 2.2.7 Niste Dispose! - Asbestos waste, scrap, debris, bigs, containers, equipment, Md asbestos-corrteolrated disposable clothing, that Is consigned for disposal im which nay produce airborne concentrations of isbestos fiber* In excess of perwlstlble exposure Halts, thill he collected and disposed of In sealed leak-tight containers to an approved landfill. See Section 2.6.4 for specific disposal requlresents. ' 2.3 Persons! Protective Eoulpaent 2.5.1 Respiratory Protection - Eaoloyees engaged In the spraying [wettlng-downj of ashestos, the moral; In the dcwolltlon of pipes, structures, or equlpaent covered or Insulated with isbestos: and in the reaoval or deaolltlon of isbestos Insulation or coverings shall he provided with respiratory eqilpacnt based on the air concentration In Table I and selected froa aaong those approved by tbe Mine Safety and Health Adalntstratlon, Departaent of the Interior, or the National Institute of Occupational Safety and health, Departaent 'of health and Karan-Services described -to JO CFR Part II. Coop11(net with exposure Halts prescribed In 2.1a fernlsslble Exposure Halts, shill not be achieved by the use of respirators, except:. 1. During the Interval necessary to Install or laplewent feasible engineering tnd wort practice controls, 2. In wort operations such as ailntenance and repair activities or other activities which the eaplcyer establishes that engineering and work praettee control procedures are not feeslble, 3. In wore situations where feasible englneeriag and wort practice controls are not yet sufficient to reduce exposure to or below the Kl, 4. In eaergencles. Where respirators are peraltteo the employer shall provide a powered, air purifying respirator In lieu of any negative pressure respirator specified In Table 1 whenever: 22.5.1.2 a. An eaplcgyee chooses to use this type of respirator; and b. This respirator will provide adequate protection to the twplqyee. UCC 015772 STANDARD PRACTICE 'O INTER DIVISION SH-2S6 PACE 3 OF 7 CECEHBER 1986 ......... > ..... TABLE 1 RESPIRATOR! PROTECTION FOR ASBESTOS. TREM0L1TE. ANTHCPKTLUTE. AN) ACT IROUTE FIBERS Airborne Concentration of Subject Materials or Ccnblnation of These Kauri ill Requl red Reap I rotor 1. Hot In ancan of ic f/cc (10 a PEL| 2. Not In excess of 10 f/cc (SO x PEL| 3. Not In axcesi of 20 f/cc (100 X PEL) 1. Half-aask alr-puri'fying respirator equipped with hlgh-efflclency filters. 1. Full facepiece air purifying respirator hlgh-efflclency filters. 1. Any powered air-purifying respirator equipped with high efficiency filters. 2. Any supplled-elr respirator operated In continuous flow node. 4. Not In excess of 200 f/cc (1000 x PEL) 1. Full facepiece supplied air respirator operated In pressure demand node. S. Creater than 200 f/cc (greater than 1,000 x PEL) or unknown concentration) 1. Full facepiece supplied air respirator operated In pressure demand node equipped with an auxiliary positive pressure self-contained breathing apparatus. 2.3.2 Special ClotMna - The t^lpyer shall provide end require use of specie! clothing, such as coveralls or slatlar whole body clothing, head coverings, gloves, and foot coverings for any rmplnjir exposed, tontwilnated clothing oust be stored In closed containers such at sealed lockers. It should he changed dally. 2.3.3 Hygiene Facilities and Practices - At any fixed place of e^rlqyment exposed to concentrations of asbestos fibers In excess of peratsslble exposure Units, the eaployer shall provide change roons for eaployces working tegulerly et the piece. Two separate lockers or containers shell be provided each employee, so separated or Isolated es to prevent content nation of the enployee's street clothes fron his work clothes. Enployees exposed to asbestos during their work shift oust shower before leaving the plant and wust not leave wearing contaminated work clothing. E^rlqyees working In asbestos areas nust have ready access to filtered air lunchnxms and dust-wash their face end hands priwr to-eating or sacking. . Protective clothing nust not be worn In the tunchroon. 2.3.4 Laundering - Laundering of asbestos-contenlneted clothing shall be done so et to prevent the release of airborne asbestos fibers In excess of prescribed exposure Units. Those perfornlng laundering of esbestos-contanlnoted clothing nust be informed of ell requlrtnents listed In Section 2.3, Personal Protective Equlpnent. Contanlneted clothing shall he transported In sealed Inpernetble containers tad labeled In accordance with Section 2.2.6, Label Specifications. If disposable coveralls ere used, they should be placed Into containers wlta asbestos for disposal. L i L 22.6.1.2 UCC 015773 S*-e MSE 4 Of 7 OCLEMER l8t iliiuu; - BITER DIVISION 2.4 li4wtrt>l Hyiltne Responsibility 2.4.1 Wont tort na - Employee exposure monitoring shall be conducted to dctenelne compliance (totut with regard to penrtaslble expotore Italts and respiratory protactloo raqulraatrrts. Emrlromental/Area non1 taring tball ha conducted along the periphery of the restricted area to aiwre that fugitive Missions exceeding paralsslble exposure Halts do not extend past the demarcated area. Samples shell be collected using 25 as dlaaeter nixed cellulose filters end a SO aa extension coal. Seaples shall be of such frequency end pattern as to represent with reasonable accuracy the levels of exposure of the eaploytes. Monitoring It required at least every 6 aonths for euployecs whose exposures to asbestos Is at or above the action level. Ware construction standard I926.be Is applicable, dolly aonltortng is required unless employees esc supplied air respirators in e positive pressure node. Samples aist be analyzed using e phase contrast alcroscope calibrated using a phase shift test slide and equipped with a Walton-Beckett graticule, the filter sables aust be prepared using ecetone-triacetln clearing aolirtlon and he counted In accordance with the *A* rules contained In the M105M 7400 nethod. 1 2.5 Training 2.5.1 All anplcyees oho ere exposed to airborne asbestos concentrations In excess of the exposure Unit listed In Section 2.1.2 with or without the nse of respirators shall participate In a training prograa at the tine of or prior to Initial assignment end at least annually afterwards that Includes these Information topics: 1. Health effects associated with asbestos exposure. 2. Relationship between exposure to asbestos end noklng In producing lung cancer. 3. Mature of operations which could result In exposure to osbestos ond necessary protective steps to alolalxe exposure Including, es applicable, engineering controls, wort practices, respirttors, housekeeping end protective clothing. 4. Purpose, proper use, fitting Instructions, and llaltetlons of the respirators used to protect against asbestos fibers. 6. Review of ell provisions contained In 29 CFR 19I0.1U01, Asbestos. 6. Purpose for and description of the asbestos aedlcal surveillance progran. 7. Instructions for handling spills as well as emergency and clean-up procedures. 2.5.2 Training records shell'be maintained by the location and shall be readily available to all affected eaplcyees and to OSHA personnel upoa their request. 2.6 Medical Surveillance 2.6.1 Medical surveillance shit be provided to all oaployees where exposure, without regard to the use of respirator Is st or above the action level for 30 or aore days per year. 2.7 Federal EPA Regulation, 40 CFR 61, Hazardous Air Pollutants: Subpart H - National Ealsston Standard for Asbestos 2.7.1 Applicability - Those requirements apply to the demolition of structures or renovation of equipment and piping that Involves removal of Insulation that contains friable asbestos materials. Friable asbestos material means any maurlal containing more than 1 percent asbestos by weight that hand pressure can cnmfcle, pulverize, or reduce to powder when dry. Demolition means the wreck1 ng or taking out of any load-supporting structural member of a facility together with any related handling operations; on the other band, renovation meant to alter one or more facility components la any way without taking out load-supporting structural members. Denned renovitlon operations Include scheduled end unscheduled operations la which the 22.6.1.2 UCC 015774 STANDARD PRACTICE INTER DIVISION SK-2S6 FAME b OF 7 DECEMBER J9M6 aaount of friable asbestos material that Mill be nwl or stripped within a given tine period can be estimated or predicted based on operating experience. Adequately wetted nrant sufficiently nixed or coated with water or an aqueous solution to prevent dust Missions. 2.7.2 Key Motl Motion Requirenents 1. Tialnq - The EPA oust be notified with a written notice of intention to deoollsh or renovate according to these tlalng requirements: a. As early as possible before renovation begins If planned, but not necessarily scheduled, renovation operations are predicted to involve the stripping or PMOving of at least 260 linear feet on piping or 160 square feet on other facility components of friable asbestos naterials within a year. b. At least lu'days before a demolition operation that Involves at least 260 linear feet on piping or 160 square feet on ether facility components of friable asbestos Mterials. c. At least 20.days before a demolition operation that Involves less than 260 linear feet on piping or 160 square feet on other facility components of friable asbestos naterials UFA requires further advance notice for these demolitions that are shorter la duration). d. As early as possible before a structurally unsound facility in danger of iMinent collapse is demolished under an order of a state or local government agency. 2. Text of notification Letter - A suggested notification letter for the demolition and/or renovation of facilities containing friable asbestos Mterial per requirements of 40 CFR 61, Subpart M, Section 146 (c), is: Form of notification U0T1CE OF IMTEHT TO DEMOLISH OR RENOVATE STRUCTURtS, EQUIBiEMT OR piping involving friable asbestos insulation 1. Name of Owner Union Carbide Corporation 2. Address of Owner (location Street Address of facility being demolished or renovated). 3. Description of Facility Various buildings, equipment and piping used in manufacture and distribution of chemicals and plastics and also age, sire and prior use of these facilities. a. Estimate of Quality of Asbestos Approximate amount of friable asbestos material present in the facility end explanation of techniques of estimation if estimate for demolition operation is lets than 160 square feet or 260 linear feet. 6. Scheduled Start and Completion Oates 6. Hethodfs) of Demolltion/Renovation 7. Comp1lance Procedures Now EPA regulations will be followed_______________________________ . Disposal Site name and location of site where asbestos wette material will be deposited_______________________________________________________________ Only parts 1 through 4 are necessary for oeanlitlon operations involving lest than 26U linear feet or 160 square feet of friable asbestos material. The name, title, and authority of the State or local government representative who oraert the demolition should be added to the notification for demolition of structurally unsound facilities. Some states, including Georgia, Mew Tort, Morth Carolina, and California, also require notification of demolition and/or renovation operations involving friable asbestos materials. UCC 015775 22.6.1.2 SH-2b. PAGE 6 OF 7 TANOARO PRACTICE 4c INTER IHVItlON 2.7.3 key Xtwoval kequlrements - For a planned demolition optration or for the total of scheduled renovation optrations In which at Iwit 2M linear feet or ICO aquare feet of asbestos notarial la raowl: . 1. Friable aabeatoa aaterlala shall be rumored before a denolltlon or renovation operation If tbe operation would likely break up or precluda accent to the aabeatoa naterlalt for aubaaquent raaoval unleaa the aabeatoa natariala are on a facility coaponent encated In a material auch aa concrete or are adequately wetted whenever exposed. Z. if a facility coaponent It covered or coated with aabeatoa natariala and It removed in aoctlona or unite. It ahall be carefully lowered, not dropped or thrown, to the ground level and ahall have ary exposed aabeatoa notarial a adequately wetted while cutting or dlaconnectlng. 3. Wetting la not required during renovations If the EPA la requested to confirm that netting would unavoidably damage equipment. If the EPA confirms this, then a local exhaust ventilation and collection system must be used to collect aabeatoa particulates. The exhaust syaten oust exhibit no visible amissions to the outside air or be designed and operated according to 40 CFR *1.154. 4. After sections or units of piping or equipment with asbestos materials have been taken out of the facility, the aabeatoa materials during stripping shall be adequately wetted or shall be collected by a ventilation and collection system at specified In Z.7.3.3. b. Dust-tight chutes or containers shall be used to lower asbestos material removed or stripped more than SO feet above ground level and not removed In units or sections. *. All friable aabeatoa material a that have been removed or stripped shall remain adequately wet until collected for disposal. .... 7. and 2.7.3.6. possible. If the aadilent temperature Is below 0*1. then the only wetting requlevents-are those specified in 2.7.3.4 Equipment or piping coated or covered with asbestos materials shall be removed to the maxim* extent i. For denolltlon of a structurally unsound facility under the order of a State or local government agency, tht portion of the facility that contains friable asbestos materials shall be adequately wetted during the wrecking operation. The wetting requirements specified In 2.7.3.4, 2.7.3.5, 2.7.3.b, and 2.7.3.7 shall also apply to aqy emergency demolitions. 2.7.4 key Disposal Requirements 1. Visible emissions shall not occur during the collacting,-transporting, or disposal of any asbestos-containing waste material unless the alr-cleantng methods specified In-40 CFR Pert (1.1&4 are used to collect asbestos fibers before they escape to the outside air. 2. The disposal method for collecting and transporting asbestos-containing waste materials shall be approved prior to use by the EPA, unless either of these two CPA-approved methods ere used:. a. Form all asbestos-containing waste material Into nonfriabla pallets or other shapes, or b. Adequately wet end teal while wet In leak-tight containers all asbestos-containing watte materiel. The watte containers shall be labeled according to Section 2.2.4. i l 22.4.1.2 UCC 015776 STANDARD PRACTICE INTER OIVISION SH-iSt PALE 7 OF 7 DECEMBER *1906 3. The disposal site for asbestos-containing Mitt aatertal shell hive no visible eatsstons, or the disposed uterial shill be covered within M hours with it lent sis Inches of nonesbestos-contalnlng baterial or with in effective resinous or petroleva-besed dust suppression agent (waste crankcase oil Is not acceptable.) Alternative aethods for controlling asbestos emissions aust have EPA approval before being Itpleaented. 4. Either a natural barrier or a fence shall adequately deter (as deteruined by the EPA upon request and supply of appropriate Infonaatlon) public access to the waste disposal site. If fenced, then warning signs (20* x !<*) shall be posted at all entrances and at Intervals no greater than 330 feet along the perl he ter of the sections of the site where asbestos-containing material Is deposited. The signs shall state: ASBESTOS WASTE DISPOSAL SITE DO NOT CREATE OUST BREATHING ASBESTOS IS HAZARDOUS TO TOUR HEALTH B.b AUDITS 2.6.1 Each location shall periodically audit this procedure to ensure understanding and coopllance. UCC 015777 22.S.1.2