Document mm3eopzyaGOJ21p9ROjN74mpd

FILE NAME: Montello (MNT) DATE: 1979 July 16 DOC#: MNT009 DOCUMENT DESCRIPTION: Letter from Montello to Mr. John Myers RE Pending Regulations on the Transportation of Asbestos 61 OS EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-239$ July 16, 1979 Mr. John Myers Union Carbide Corporation 4625 Royal Avenue Niagara Falls, Hew York 14302 Dear John: He understand that you are meeting with the Department of Transportation in ?" Jiy " ** n e r e M l I - H u s s i o n of thi p S ,, 9 S , tions covering the transportation of asbestos. This letter is in answer to re1^es^ fr a review of asbestos applications in the drilling industrv with emphasis on material handling and tiansportatio. 9 1ndustry* i n U r i 11 inaUf1h IHe6 *2 establ?h that asbestos performs a valuable function n i 11 ! ! f `u1ds- . fiy Providing desired levels of mechanical viscosity cut tings can be more adequately removed from the bore hole, with attendant im- negative^lncentlve^of " *"'* " s e X T v a 1 ebeaa ^ E ^ ,dC."l, b=.'-ctad, however. If it 1s not cona??. at the right time, in the right place, and in the riaht quantity. This is especially true in the drilling Industry With H n iim now costing in the tens of thousands of dollars per day the logistics of S c ^ i a tia0bfii;de-V1>tUalli: 311 other considerations.^Th^problem f f ?ig lSLtioil arl L i l L ef Cerb?d by the fact that* with rare exceptions, portation!nS * from 311 rout1ne warehousing facilities and trans- 5 "?? n L drillin9 f1uids differs substantially from its uses carToad shipnents frequently involve in smaller source m i n to the end user's plant. (Even arrival^at in n J ' J 1vfry of less than a Pallet load would be rare.) On aTmnndiipr-riefd-ic?table,,^?low of c^amwamtateerriia!l? t^h^roubgeh^ theS mpaanrutfacftu3ritnagi>flayciclinttvinuous consumption in S k i S f f i l S h S ^ d i f ^ ^ expectatl'on of their mipUte In the drilling industry the delivery rig) is much more complex. A carload of material to the "plant" (drilling originating at the source mill will Mr. John Myers July 16, 1979. Page 2: frequently be split to two or more major field warehoues. From these, even smaller lots are normally re-shipped to area field warehouses. From these, quantities as small as five to ten bags (50 lbs. each) will be shipped to rig locations. Use of the material is dependent upon generally unpredictable events encountered during drilling. At the end of every well there will re main highly variable quantities of unused material, including asbestos. Unlike the fixed location manufacturing plant, these coverages can t be sim ply held for "tomorrow's production". All such overages are returned to the supplier for credit, where the materials are later shipped to another rig for possible use. Implicit in all material orders for drilling .rigs is the concept of "don't run out". This makes the return of overages inevitable. This process of making materials available at the rig involves variable split loads down to only a few bags; inter and intra state handling; camion, con tract and private carriers; highly irregular routes and destinations, (in- . eluding land rigs, inland barges, offshore facilities, etc -); a"d the return of variable quantities of unused products. A requirement that all this acti vity be carried on in minimum one ton unitized pallet load lots would vir- taully eliminate the practical use of the products. We understand that Union Carbide will be furnishing us asbestos in dust and sift proof bags by August 20th. Each 50 pound bag will be double shrink filmed to assure cleanliness. It seems to us that such a Pac^aS if ford all the protection that could be reasonably expected, and that n t t i e i T any additional protection would result from also requiring palletizing, le therefore urge clarification of the proposed regulations to accomodate for the distribution factors peculiar to our industry.- Allowing shipment of in dividual, sift proof bags of asbestos will enable the industry to continue realizing the economic advantage of the material. - Please let us know if further information is needed. Sincerely,a MONTELLO [NC. KNC/jd