Document jywLd3Rwb7qXO23LMDn5Lw3j2

E. I. ou Pont de Nemours & Company Wilmington. Delaware 1989b ' ENGINEERING DEPARTMENT CCx X. X. Helnera 2C 13 - AXStf March 8# 1976 X. C. OTT. ISDOSTXXAI, CHEMICALS UXPAXTHHBT WZIiCBCTOS J. G. TKXSILK FIBERS DEFASSMEST MZLKI5GTGS DU POST XB7UT TO SATXGKAL SMI SSICM STAHDAXBS FOX HAZARDOUS AXX POU2JSASTS (OCTOBER. 14, 1975* FZSE2AX* XSGXSTSE) Attached la the SPA gaaponaa to our comments submitted on tha than proposed subject regulation In tha October 25, 1974 Federal Xegistar. Oor cnroenta baaad oo your input appeared to reduce the potential operation problem inherent in the original proposed standard. Hopefully Most unscheduled 'renovation" can b categorized as "routine renovation" and reported once per year. Thought you might be interested -- thanks for your comments. . JUFxgl atch DUP 0904130 SC-DP-04985 . Section Comment >er Commentator tn *- Comment ^Vi \ ' Response________________ _____________ the OSHA standard to Protect employees' health can be achieved bv the use of resolratorv ecuipment, even in those situations where wettino is not imolemented and emissions may produce concentrations in excess of the OSI1A exposure limit. The extent to which emissions to the outside air are reduced cannot be determined. The Agency intends that OSHA regulated industries report renovation operations to the Administrator. Without the reporting requirements, the Agency's enforcement of the renovation standard will be relatively ineffective; therefore, the standard has not been revised. 100 The frequency and lead time for written The Agency has reevaluated the reportinq requirements notice of Intention to do repetitive of the amendments and a discussion of the revised renovation work on certain processes is excessive. reporting requirements for renovation operations is presented in the response to comment number 101. The notice of intention to do renovating work must be postmarked or otherwise delivered to the Administrator as soon as possible, prior to commencing renovation. The Agency believes that the frequency and lead time reporting requirements are reasonable and will not cause untenable hardships for any renovation operation. DUP 0 9 0 4 1 3 1 The proposed reputations should be modified to include definitions of "emergency and routine maintenance renovating," and to stipulate that written notice of intention toperform these operations must be filed once every year for each plant site. The Agency agrees that routine and emergency renovation operations should be distinguished and reported to the Administrator by separate reporting procedures. There fore, the standard has been revised by adding a definition for planned renovation" and "enx'rc^ncy renovation." ' DUP 0904132 ;ction - Trent Commentator cn <J- ontd Comment 'S' Resoonse The primary characteristic that distinguishes these types of renovation operations is the degree of pre dictability of their occurrence. Planned renovation operations are defined as those renovation operations in which the amount of friable asbestos material that will be removed within a given period of time can be predicted. Included In this category of renovation are Individually non-scheduled renovations, provided a number of such operations can be predicted to occur during a given period of time based on operating experience. Emergency renovation operations are defined as those renovation operations that are not planned and result from a sudden, unexpected event for which Immediate renovation-Is required. Renovation operations due to significant malfunctions and failure of equip ment are Included In this category. The standard has been revised to specify more clearly how the amounts of friable asbestos material removed during renovation will be quantified in planned renovation and emergency renovation operations. The quantity of friable asbestos material that must be removed In a renovation operation for the standard to apply Is 80 meters of pipe Insulated with friable asbestos material or IS square meters of friable asbestos material used to insulate or fireproof any boiler, duct, tank, reactor, turbine, furnace, or structural member. For a planned renovation'opera tion, the amount of friable asbestos material that is subject to the standard is the summation of the friable asbestos material removed during the planned renovation period. l. Section I Comment iber Conmentator CJ1 c- Comment Resoonse 1 (Contd) Emergency renovation operations that Involve the remov al of more than the stated quantity of friable asbes tos material are covered by the standard and must report for each individual emergency situation. DUP 0904133 2 3 3.4 op It would be practical to state that if proper work practices are observed to minimize asbestos emissions to the environment (no visible emissions) during renovation, the notice of intent to renovate is unnecessary. The alternatives to wetting asbestos during demolition allowed under sub freezing temperature should be allowed in all cases. The Agency does not believe that reporting for a definite period of time, such as the suggested oneyear period, is appropriate in all planned renovation operations because of the many variations that occur between renovation operations at different plants. The period of time for which the removal or stripping of friable asbestos material will be predicted for planned renovation operations shall be not less than 30 days nor more than one year. This range of periods provides the flexibility to deal with variations from facility'to facility. Periods of less than 30 days will cause much Agency enforcement manpower to be spent in reviewing such reports, while periods in excess of one year generally provide Inaccurate esti mates. The Agency believes the notice of intent to renovate is necessary. The notice of Intent is required to inform Agency personnel of the renovating operation so that inspections can be made during the operation. These inspections are necessary to verify compliance with the standard and to ensure that proper work practices are being observed. It had been brought to the attention of the Agency by a demolition contractor association prior to proposing these amendments that worker safety may be Jeopardized during wetting of asbestos prior to stripping and removal under freezing conditions. The Agency considered the following two alternatives in an attemnt to correct this situation: f Asbestos Blamed for Disorders SAN FRANCISCO (AP) -- Thousands of persons who worked in San Francisco Bay area shipyards since World War II may have developed lung abnormalities from expo sure to asbestos, a physician says. Dr. Phillip L. Polakoff of Berkeley joined union leaders at a news' confeerence yester day to describe what- he called a potential "mammoth epidemic" of lung disease in shipyard workers. He disclosed results of a preliminary study of workers at Mare Island naval shipyard exposed to asbestos for the first time at least 10 years ago. Of 359 employes X-rayed, 59 per cent showed lung abnormalities. "The long lapsed period between onset of asbestos exposure and clinical appearance of disease ... now brings the World War II shipyard work people to a period of risk," a report released, by Polakoff said. The study was made by the Federal Employes Metal Trades Council 'kt Mare Island because the Navy failed to inform some X-rayed workers they had lung problems, said John Robinson,presi dent of the union. x 478 DUP 0904134