Document gNG12RrwoYZaZ4KaGR66yjn3

UNION CARBIDE CORPORATION TECHNICAL CENTER SOUTH CHARLESTON, WEST VIRGINIA' MEMORANDUM. November 21, 1983 PLAINTIFF'S EXHIBIT TO: Holders of Safety/Health Technology Manual COPY TO: F. C. Graves FROM: 0. T. Watters ' SUBJECT: Issue of Revised Standard Practice SH-256 "Removal and Handling Asbestos - Containing Insulation Material" Attached Is a copy of SH-256, "Removal and Handling Asbestos Containing Insulation Material", Section 5 - Practices. Please remove and destroy your copy of SH-256. This practice has been revised to be consistent with the Emergency Temporary Standard (ETS) for Asbestos that was Issued by OSHA on November 4, 1983 (Federal Register Vol. 48, No. 215, pp. 51086 51138). The revisions are: (1) Permissible Exposure Limits The eight-hour, time-weighted-average employee exposure to airborne concentrations of asbestos fibers Is now 0.5 fibers, longer, than 5 micrometers, per cubic centimeter of a 1r,rather-tfian 2.0 ffbers/ee.- (2) Work Practices A sentence was added to paragraph 2.2.2 to specify the new requirement for posting signs that warn of the health hazards of asbestos at each location where airborne concentrations of asbestos fibers may exceed the revised 0.5 flbers/cc exposure limit. OSHA did not mandate In this ETS how to specify the health hazard on these signs, so the wording of the signs will be that chosen by the Individual location. (4) 2.5 Training Paragraph 2.5.2 was completely rewritten to specify the training program that Is mandated by the Asbestos ETS for all employees exposed to asbestos concentrations exceeding 0.5 flbers/cc (with or without the use of respirators). This program must Include these topics: 1. Health effects of asbestos 2. Relationship between smoking and asbestos exposure in producing 1ung cancer 3. Nature of operations which could result in asbestos exposure and the necessary protective steps to minimize exposure UCC 003233 Holders of Safety/Health Technology Manual Page 2 November 17, 1983 4. Purpose, proper use, fitting Instructions, and limitations of the respirators used to protect against asbestos fibers. 5. Review of the entire OSHA standard on asbestos. All of these revisions were effective as of November 4, 1983, except the training program specifications. The training program as specified by the ETS must be instituted by December 4, 1983. This ETS Is in effect uhtil May 4, 1984; however, OSHA anticipates final revisions to its asbestos standard to be Issued by that date which will probably Incorporate these measures Included in the ETS. Revised practice SH-256 was not issued for normal review by Division representatives because the revisions are ETS related and UCC time of response was critical. If there are Division comments, please contact Greg Twait, Unicom 8-721-3701. DTW/GDT:abg 1258D D. T. Watters UCC 003234 STANDARD PRACTICE r INTER OIVI8ION SH-256 PAGE 1 OF 5 NOVEMBER 1983 REMOVAL AND HANOI!MS ASBESTOS-CONTAINING INSULATION MATERIAL 1 GENERAL T.l This Practice provides a procedure for the safe removal and handling of asbestos-containing Insulation material and compliance with OSHA 29 CFR 1910.1001. The purpose of the Practice Is to ensure the safety and health of employees directly Involved with performing the wort and others, either In the (mediate area or downwind, who maybe exposed to residual dust/fibers. Insulation material containing asbestos Is no longer Installed by UCC; the concern of this Practice (s to control the demolition of old, asbestos-containing insulation. All Insulation materials approved through the use of UCC Insulation Standards have been specified asbestos-free since '1976. 2 STANDARDS 2.1 Permissible Exposure Limits 2.1.1 Employee 8 hour time-weighted average exposure to airborne concentrations of asbestos fibers shall not exeed O.S fibers, longer then 5 micrometers, per cubic centimeter of air. 2.1.2 No maployee shall be exposed at any time to airborne concentrations of asbestos fibers In exess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air. 2.2 Nor* Practices 2.2.t Insofar as practicable, demolition, removal or handling of asbestos-containing Insulation shall be performed while the material Is In a sufficiently wet state to prevent emission of airborne fibers exceeding exposure limits prescribed In 2.1.1 and 2.1.2. 2.2.2 Caution signs shall be posted at all approaches to areas 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 erea. The signs shall conform to 20" x 14* vertical format and state: AS8EST0S DUST HAZARD Breathing Asbestos Dust May Be Hazardous To Your Health Avoid Breathing Dust Near Assigned Protective Equljknt Do Not Remain In Area Unless Your Nor* Requires It Sign design specification details are found In 29 CFR 1910.145 Id) (4). In addition to these signs, legible signs warning of the health hazards of asbestos shall be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the exposure limits listed In Section 2.1.1. 2.2.2.1 An appropriate barricade, using colored tape for example, shall be erected around the perimeter of outdoor areas as a supplementary, protective measure to discourage unauthorized entry. 2.2.3 Insofar as practicable, removed Insulation shall be wetted and placed directly Into labeled plastic bags (or other suitable containers) for disposal at an approved landfill. Otherwise, place plastic sheeting beneath the Job site, mist UCC 003235 STANDARD PRACTICE SH-256 PACE 2 OF 5 NOVEMBER 1983 INTER DIVISION spray the removed Insulation with water, and then place In plastic bags. When wet Methods of removal/cleanup are Impractical, a.g., when temperatures are below freezing, vacuuwlng or sweeping aiay serve as an effective alternate cleanup aiethod. Sweeping compound shall be applied to the wort area to prevent dust generation when sweeping. 2.2.4 Label Specifications - Container caution labels shall be printed In letters of sufficient size and contrast as to be readily visible and legible. The label shall state; CAUTION Contains Asbestos Fibers Avoid Creating Oust Breathing Asbestos Dust May Cause Serious Bodily Harm 2.2.S Housekeeping - All external surfaces In any place of employment shall be Maintained free of accumulation of asbestos fibers, if, with their dispersion, there would be an excessive concentration. Special attention should be given to cleaning scaffolds used In dentition work. 2.2.6 Waste Disposal - Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos-contnlnated disposable clothing, consigned for disposal, which way produce airborne concentrations of asbestos fibers in excess of prescribed exposure Itwlts shall be collected and disposed of In sealed iMpenaeable bags, or other closed lapermeable containers to an approved landfill. 2.3 'Personal Protective Equlintent 2.3.1 Respiratory Protection - Employees engaged In the spraying [wetting-down] of asbestos, the removal; In the demolition of pipes, structures, or equipment covered or Insulated with asbestos; and in the rewoval or demolition of asbestos Insulatlon or coverlngs shall be provided with respiratory equipment selected from among those approved by the Bureeu of Mines, Department of the Interior, or the National Institute of Occupational Safety and Health, Department of Health and Huaan Services. Compliance with exposure limits prescribed In 2.1, Permissible Exposure Limits, shall not be achieved by the use of respirators, except: 1. During the time period necessary to Install the engineering controls and to Institute the work practices to prevent exposures from exceeding permissible limits. 2. In work situations In which either engineering controls or wet method work practices are not feasible to an extent to reduce the airborne concentrations of asbestos dust below Units prescribed. 3. In emergencies. Where respirators are permltted: 1. A reusable or single use, air purifying respirator may be used to reduce exposure below permissible limits, when the celling or the 8-hour time-weighted average airborne concentrations of asbestos fibers are reasonable expected to exceed no more than 10 times the PEL limits. If not monitored and verified, a type *C" continuous verified flow or pressure demand, suppllad-air respirator must be used. UCC 003236 STANDARD PRACTICE INTER DIVISION SH-256 PACE 3 OF $ N0VEM8ER 1963 2. A full-facepiece powered air purifying respirator may be used to reduce exposure below permissible 1lofts when the celling or the 8-hour tine-weighted average efrborne concentrations of asbestos fibers have been monitored and verified to exceed 10 times but not 100 times the PEL limits. If not monitored and verified, a type *C* continuous flow or pressure demand, supplled-atr respirator must be used. 3. A type "C* continuous flow or pressure-demand, supplfed-air respirator shall be used to reduce exposure below permissible limits when the ceiling or the 8-hour time-weighted average airborne concentrations are reasonably expected to exceed 100 times those limits. 2.3.2 Special Clothing - The employer shall provide and require use of special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed. Contaminated clothing should not be stored In lxkers. It should be changed dally. 2.3.3 Change Rooms - At any fixed place of employment exposed to concentrations of asbestos fibers In excess of permissible exposure limits, the employer shall provide change rooms for employees working regularly at the place. Two separate lockers or containers shall be provided each employee, so separated or Isolated as to prevent contamination of the employee's street clothes froai his work clothes. 2.3.4 Laundering - Laundering of asbestos-contaminated clothing shall be done so as to prevent the release of airborne asbestos fibers in excess of prescribed exposure limits. Those performing' foundering of asbestos-contaminated clothing oust be informed of all requirements listed In Section 2.3, Personal Protective Equipment. Contaminated clothing shall be transported In sealed Impermeable containers and labeled In accordance with Section 2.2.S, Label Specifications. If disposable coveralls arm used, they should be placed into containers with asbestos for disposal. 2.4 Industrial Hygiene Resposslblllty 2.4.1 Monitoring - Employee exposure monitoring shall be conducted to determine compliance status with regard to permissible exposure limits and respiratory protection requirements. Environmental/Area monitoring shall be conducted along the periphery of the restricted area to assure that fugitive emissions exceeding permissible exposure limits do not extend past the demarcated area. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted In an open-face filter holder. Samples shall be of such frequency and pattern as to represent with reasonable accuracy the tevels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed prescribed exposure limits. All determinations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at 400 - 450 x (magnification) with phase contrast Illumination as specified In Voliaae 38 Method 38C - 29 x 4 - RLa of UCC Industrial Hygiene methods. 2.5 Training 2.5.1 All employees who are exposed to airborne asbestos cone entrains in excess of the exposure limit listed in Section 2.1.1 with or without the us* of respirators must participate In a training program that Includes these information topics: 1. Health affects associated with asbestos exposure. 2. Relationship between exposure to asbestos and smoking In producing lung cancer. 3. Nature of operations which could result in exposure to asbestos and necessary protective steps to minimize exposure Including, as applicable, engineering controls, work practices, resplritors, housekeeping and protective clothing. UCC 003237 SH-2S6 PACE 4 OF 5 NOVEMBER 1983 STANDARD PRACTICE INTER DIVISION 4. Purpose, proper use, fitting Instructions, and llultetlons of the respirators used to protect against asbestos fibers. 2.S.2 5. Review of all provisions contained In 29 CFR 1910.1001, Asbestos. Training records shall be Maintained by the location. 2.6 Federal EPA Regulation, 40 CFR 61, Hazardous Air Pollutants 2.6.1 Applicability - To the dsnotltlon of structures or renovation of equipment and piping that Involves removal of more than 160 square feet or 260 lineal feet of Insulation containing more than one percent asbestos by weight, either In a single project or a predictable series of projects over the course of one year that are additive to this mount. 2.6.2 Overall Requirements of Regulation Practices - Comply with defined removal and disposal practices. Notification - Provide timely notification of EPA 2.6.3 Kay Requirements - Removal Practices ' 1. Insulation shall be removed.prior to demolition where the demolition would likely damage and expose Insulation. 2. Insulation must be wetted prior to removal and kept wet until disposal Is accomplished. 3. Insulation on pipe or equipment which is to be removed In sections must have exposed surfaces wetted and kept wet during dismantling. 4. Stripped insulation must not be dropped or thrown to the ground. Dust tight containers or chutes must be used for lowering removed insulation that Is more than 50 feet above ground level. 2.6.4 Kay Requirements - Disposal Practices 1. No risible emissions of Insulation are altowed 'in transport to the disposal stta. 2. No visible emissions may result from disposal operations. mS:3. For disposal areas one of the following requirements must be a. A six-inch earth cover Is provided over disposed Insulation within 24 hours. b. An effective resinous or petroleun-based dust suppression agent Is applied at the and of each operating day. c. A natural barrier adequately deters public access to the site. d. The area is fenced and (20 x 14 Inch) warning signs are posted at least every 330 feet. UCC 003238 STANDARD PRACTICE INTER DIVISION SH-256 PAGE 5 OF S NOVEMBER 1983 2.6.5 Requirements - EPA Notification Tfelng * EPA end applicable States are to be notified either: a. Annually, or b. 10 dtyt prior to planned denolltton or renovation, or c. As soon at possible after beginning an unplanned (emergency) removal project. The above notification requirement applies whenever the total amount exceeds 160 square feet of equipment or 260 lineal feet of pipe Insulation. Office to be Notified federal: State: Director, Enforcement Division Enviromental Protection Agency (Regional Office City Address) (Applicable only in the following UCC States) California (Sacramento County) (Bay Area) Georgia New York North Carolina . ' Suggested Text of Notification letter - The attached notification relative to the demolition and/or renovation of facilities containing friable asbestos Insulation Is provided per requirements of 40 CFR 61, Subpart B, Section 61.22 (d). Please contact the writer If there ere questions concerning Information contained in the notification. Form of Notification NOTICE OF INTENT TO DEMOLISH OR RENOVATE STRUCTURES, EQUIPMENT OR PIPING INVOLVING FRIABLE ASBESTOS INSULATION .1 Name of Owner Union Carbide Corporation .2 Address of (hmer (Location Street Address) 3. Description of Facility Various buildings, equipment and piping used In manufacture and distribution of chemicals and plastics. 2.7 AUDITS 2.7.1 Each location shall periodically audit this procedure to ensure understanding and compliance. UCC 003239