Document nZBD3MZygR90LZmvMVgwvjna

uoO-Offtf SPECIALTY CHEMICALS DIVISION SOUTH CHARLESTON PLANT ENGINEERING November 7, 1986 TO: D. A. Gosselin R. G. Link S. Rossi wmamBbagtsK E. D. Southard J. L. Worstell CC: Vi - D. Bradbury J. R. Dement SLBXCT: South Charleston Plant Insulation Upgrade Outline of Project Gentlemen: The Insulation Upgrade Outline of Project (0/P) is attached for your review. This plantwide Insulation Asbestos Upgrade Project is a high-priority Safety/Health Program. The total cost is $3.3MM Capital and $1.4MM 838 Expense. Please note that the required Health, Safety, and Environmental review by the Engineering, Manufacturing, and Technology Services Department has been completed and is incorporated into the 0/P. Please return any comments directly to me by November 13, The finalized 0/P will then be transmitted by the Director of Engineering to the functional Vice-Presidents for approval. Please call if you have any questions. ^V I do 0 t/\ WoCjG ,.o dr \ l\ ^ ^ J^CNT W\ V V\X- CLg yvV UCC 020072 UC-4004 SOUTH CHARLESTON PLANT ENGINEERING SPECIALTY CHEMICALS DIVISION OUTLINE OF PROJECT SOUTH CHARLESTON PLANT INSULATION UPGRADE SOUTH CHARLESTON, WV November 7, 1986 UCC 020073 OUTLINE OF PROJECT SOUTH CHARLESTON PLANT INSULATION UPGRADE TABLE OF CONTENTS PAGE I. INTRODUCTION II. SUMMARY III. SPONSOR'S OBJECTIVES IV. FACILITIES V. ENVIRONMENTAL PROTECTION/OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS VI. SUPPORTING FACILITIES VII. PROJECT PLAN VIII. 5CHEDULE IX. COST ESTIMATE A. Summary B. Basis for Estimate C. Cash Flow X. COST ALLOCATIONS TO DIVISIONS XI. APPENDIX o Health, Safety, and Environmental Review by Engineering, Manufacturing, and Technology Services Department o Division/Profit Center Cost Allocations Summary 1 1 1 2 3 3 A A A 5 6 UCC 020074 I. INTRODUCTION Much of the insulation in the South Charleston Plant is asbestos and is in poor condition. Exposed asbestos presents a safety and health hazard associated with airborne particulate asbestos. II. SUMMARY The asbestos insulation throughout the South Charleston must be upgraded to comply with the Occupational Safety and Health Administration (OSHA) standards. The project is estimated to cost $4,7MM over a three-year period: $3.3MM capital and $1.4MM removals 836 expense. The plan is to remove asbestos from idle equipment, replace damaged insulation with an approved type, and seal all remaining asbestos insulation. This project will be implemented over a three-year period with completion in 1989. The justification of this project is Occupational Health. The present OSHA Asbestos Standard, 1910.1001, now specifies 0.2 fibers/cc as the maximum allowable exposure over an eight-hour period. The figure refers to fibers greater than five micrometers in length. 111. SPONSOR'S OBJECTIVE The basic objective of this project is to upgrade the asbestos insulation throughout the South Charleston Plant to comply with OSHA Standards. Completion All insulation upgrade to be complete by December 1989. Project is high priority and must be executed on a continuous basis over the three-year period with only curtailment during the bitter cold winter months. Safety/Health All Division Safety/Health Guidelines must be following during asbestos removal/disposal, repair, and covering. UCC 020075 2- - Government Regulations Plant will be in compliance with all applicable OSHA and U.S. Environmental Protection Agency (EPA) Regulations at project completion. IV. FACILITIES The asbestos insulation upgrade encompasses the following units and the work schedule on a priority basis follows: Phase 1 No. 2 Steam Plant Portion Water Treating Unit Phase 2 (Manufacturing Units) Chemical Mixing Upper Island Mainland PVA Resins Solvent Vinyls Polyols Specialty Catalyst Specialty Chemicals Middle Island Oxide Adducts Phase 3 Complete Water Treating Unit Utility Distribution Distribution Bulk Terminal Maintenance Some of the work has already been authorized for removing asbestos insulation from idle equipment and lines; the work is not part of this major capital project. These projects are listed below: Project Approval Cost Status No. 2 Powerhouse Solvent Vinyl Resins Specialty Chemicals Division Units Upper Island Chemical Complex Oxide Adducts 10/85 1/86 1/86 Total $111,000 17,000 182,000 Complete Complete On-going 26,000 WOR To Dan IQ/9/86 100,000 WOR to Dan by 11/13/86 $436,000 UCC 020076 -3- V. ENVIRONMENTAL PROTECTION/OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS This project will correct an Occupational Health concern by replacing or sealing exposed asbestos insulation throughout the Plant. When the insulation is being replaced or removed, Safety and Health Guidelines will be followed which includes: installing rope barricades and clearing the area of plant personnel, posting of warning signs, proper bagging and disposal of insulation, and monitoring of surrounding work areas. In addition, assuring that contractor personnel adhere to guidelines such as: wet clean-up, wearing of appropriate respirators, wearing and disposal of proper protective clothing, etc. This project will be in compliance with all applicable OSHA and ERA Regulations. The EPA will be notified that the removal of asbestos insulation could occur at the South Charleston Plant. The required Health, Safety, and Environmental review of the project was completed on October 30, 1986, by the Engineering, Manufacturing, and Technology Services Department; the project is endorsed contingent upon the following: 1. Maintenance Procedure XVIII Provisions for Asbestos Material Removal and Disposal Safety will be revised to be in compliance with the latest OSHA Standard 29 CFR 1910.10D1. 2. Procedure XVIII will be revised in accordance with the environmental concerns listed in the review. A copy of the complete review is attached in the Appendix section. VI. SUPPORTING FACILITIES A. Distribution The project will have no effect on Distribution facilities. 8. Energy Systems The project will have no effect on Energy Systems requirements, however, Energy Conservation will be improved with this insulation upgrade. C. Safety and Environmental Considerations See Section V above. UCC 020077 -4- VII. PROJECT PLAN The project survey, or scope, was prepared by the Maintenance Department over the last year. The priority of work is shown in the Facilities Section on page 3. Insulation specification consultation will be supplied by Engineering. Field construction by an outside contractor or the Central Engineering Construction Group, will be supervised by the Maintenance Department. Project Management, including cost control and reporting, will be provided by Plant Engineering. The project organization follows: Steering Committee Assistant Plant Manager Maintenance Superintendent General Project Manager Project Team Maintenance Coordinator/Supervisor Project Manager S. Rossi J. R. Dement 3. F. Dodd L. B. Hewitt J. R. Maier VI11. SCHEDULE Key dates are: Outline of Project Approval C8P Approval Mechanical Completion December 1986 February 1987 December 1989 IX. COST ESTIMATE A. Summary o Labor o Materials o Engineering/Maintenance* o Contingency Total Capital $1,950,000 860.000 160.000 330.000 $3,300,000 838 Expense $1,140,000 50,000 70,000 140,000 $1,400,000 * Insulation specification consultation, project management and field coordinator of contractor. UCC 020078 -5- B. Basis for Estimate The estimate for the Phase I work is based on a detailed scope and budget pricing obtained from a local insulation contractor. The remaining work is based on an insulation survey of each operating unit and estimating the associated man-hours and materials required. The total man-hour estimate is 101,000 hours of work. C. Cash Plow Capital 838 Expense 1987 1988 1989 $1,100,000 1,100,000 1,100,000 $ 466,000 466.000 468.000 Total $3,300,000 $1,400,000 X. COST ALLOCATIONS TO DIVISIONS The project costs are allocated to tenant divisions based on the 1987 plant period cost allocations furnished by the Plant Controller. For example, costs for insulation work on steam lines in the Energy Systems area would be allocated plantwide to those profit centers on a steam usage basis. The overall project allocations to divisions follows: Division Percent Costs Capital Expense Specialty Chemicals Solvents & Coatings Industrial Chemicals 75.12 21.80 3.08 $2,479,000 720.000 101.000 $1,052,000 305,000 43,000 Total 100.00 $3,300,000 $1,400,000 These costs are spread equally over three years (1987, 1988, and 1989). The individual profit center cost breakdown for each division is shown in the Appendix section. JFD 11/07/86 2301G UCC 020079 6- XI. APPENDIX UCC 020080 UNION CARBIDE CORPORATION BUSINESS CONFIDENTIAL ENGINEERING MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH. SAFETY AND ENVIRONMENTAL TECHNOLOGY SOUTH CHARLESTON. WEST VIRGINIA MEMORANDUM October 30, 1986 TO: COPY: Mr. J. R. Dement Mr. J. F. Dodd Hr. D. A. Gosselln Mr. R. L. Foster Mr. E. 0. Southard Mr. W. 0. Bradbury Dr. P. R. Kavasmaneck Dr. 0. Llebesklnd Mr. R. R. Rankin Hr. S. Rossi Hr. A. 0. Williamson FROM: H. W. Wegert G. H. Whipple SUBJECT: Health, Safety, and Environmental Review Insulation Uporade Project. South Charleston This Health, Safety, and Environmental review was based on the draft Outline of Project and the South Charleston Plant Maintenance Procedure XVIII Provisions for Asbestos Material Removal and Disposal Safety. Attached are the applicable Summary Checklists; the Project Safety Summary Checklist was not Included as no product Is produced as a result of this project. The review was conducted by qualified engineers from CEO's Health, Safety and Environmental Technology Section. Endorsement of the project Is recommended contingent upon the Items listed at the end of this memo. Written response to the contingency Items by project personnel Is requested prior to start of work In the field. This project will upgrade asbestos Insulation In the South Charleston Plant over the next three years. Much of the asbestos Insulation In the plant Is In poor condition and presents a potential exposure problem for plant personnel. The plan Is to remove asbestos Insulation from Idle equipment, replace damaged asbestos Insulation with an approved type, and seal all remaining asbestos Insulation. This project will be executed In accordance with all applicable OSHA and EPA Regulations and the South Charleston Plant procedure for handling asbestos material. The EPA will be notified that the removal of asbestos Insulation could occur at the South Charleston Plant. UCC 020081 -2- BUSINESS CONFIDENTIAL The plant procedures for asbestos material removal and disposal safety was reviewed by CEO Health Technologist Terry Hanning. The procedure should be revised In accordance with Terry's comments (see attached memo) for conformance with OSHA 29 CFR 1910.1001. are: Additional comments on this procedure from an environmental viewpoint o The procedure does not refer to review of State Air Pollution Regulation No. 15 which deals with notification of the West Virginia Air Pollution Commission. o The procedure does not refer to state requirement to notify the West Virginia Department of National Resources before land filling. o The procedure does not refer to NESHAPS 40 CFR 61.152 (Disposal Container labels) or 40 CFR $1,156 (Warning Signs at Landfill). However, the procedure does refer to OSHA warning label requirements and these are probably equivalent to the NESHAPS requirements. The procedure shoulb clarify this Issue, particularly the signs required at the landfill. Based on review of the draft Outline of Project and Maintenance Procedure XVIII, endorsement of the project Is recommended contingent upon the following: 1. Maintenance Procedure XVIII Provisions for Asbestos Material Removal and Disposal Safety be revised to be In compliance with the latest OSHA Standard 29 CFR 1910.1001 per Terry Hanning's memo. 2. Procedure XVIII be revised In accordance with the environmental concerns listed above. 14 kW" irt HWW:BMW:mw 6536D UCC 020082 -3- BUS1NESS CONFIDENTIAL HS&E REVIEW SUMMARY Reviewers EP - L. K. (Linda) Scholl, Senior Chemist In CEO's Land Disposal Technology Group HS - H. W. (Harvey) Wegert, Group Leader of CED's Safety & Fire Protection Technology Group Protect Data a. Material Balance - Not applicable b. Environmental Releases - Asbestos removal wastes will be landfilled. c. Governmental Requirements - HSGE regulations that apply to this project Include OSHA 29 CFR 1910.1001, H. Va. State Air Pollution Regulation No. IS, and NESHAPS 40 CFR 61.152 & 156. d. Corporate HS&E Policy Requirements - No variances are required. e. Project Reviews o Process Safety/Health Review - Not applicable o Safety/Health Review Board - Not applicable o Pre-startup Safety/Health Review - Not applicable Concerns There are no HS&E concerns that had not been adequately discussed In the checklists or the endorsement review memo. J'* HWW:GMW:mw 6001D UCC 020083 UNION CARBIDE CORPORATION ENGINEERING. MANUFACTURING AND TECHNOLOGY SERVICES DEPARTMENT HEALTH. SAFETY ANO ENVIRONMENTAL TECHNOLOGY SOUTH CHARLESTON. WEST VIRGINIA MEMORANDUM October 28, 1986 TO: r. M. Negert: COPY: Mr. S. W. Clark Mr. J. F. Dodd Mr. 0. A. Gosselln Dr. P. R. Kavasmaneck Mr. J. E. Meff FROM: T. E. Hanning SUBJECT: Review of South Charleston Plant Procedures Removal and Olsposal of Asbestos Materials The following updates/changes apply to the 514 Maintenance Department's procedure for handling and disposal of asbestos Insulation: Definitions 1. The OSHA allowable limit for personnel exposure to asbestos was revised In July 1986. 2. The 8-hour time-weighted average for asbestos shall not exceed 0.2 fibers, longer than five micrometers, per cubic centimeter of air. 3. There Is no celling concentration In the revised standard. .4 The revised standard calls for an action level of 0.1 fibers, no longer than five micrometers, per cubic centimeter of air. This level triggers monitoring, medical, and employee Information and training requirements. UCC 020084 2- - Overvlew of Procedure 1. The warning signs mentioned In Item 4 should state: DANGER - ASBESTOS: CANCER AND LUNG DISEASE HAZARD-AUTHORIZED PERSONNEL ONLY: RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA 2. Item 7 should he expanded to read: Remove asbestos to special containers for handllng/dlsposal. These containers should be properly labeled as follows: DANGER - CONTAINS ASBESTOS FIBERS: AVOID CREATING OUST; CANCER AND LUNG DISEASE HAZARO. Disposal containers should be leak-tight and discarded In an approved landfill. 3. Item 6 should be expanded to state: Where feasible, the employer shall establish negative-pressure enclosures before commencing removal, demolition, and renovation operations. Respirators Disposable (throw away) respirators are not permitted under the Duly 1986 asbestos revision. Respirators are to be selected by the following scheme. Airborne Concentration Required Respirator 1. Not In excess of 2.0 f/cc (10 X PEL) 1. Half-mask alr-purlfytng respirator equipped with hlgh-effIclency filters. 2. Not In excess of 10.0 f/cc (50 X PEL) l. Full-facepiece air purifying respirator equipped with hlghefflclency filters. 3. Not In excess of 20 f/cc (100 X PEL) 1. Any powered air-purifying respirator equipped with high efficiency filters. 2. Any supplled-alr respirator operated In continuous flow mode. 4. Not In excess of 200 f/cc (1000 X PEL) 1. Full facepiece supplled-alr respirator operated In pressure demand mode. UCC 020085 -3- 5. Greater than 200 f/cc (greater than 1000 X PEL or unknown concentration) 1. Full facepiece supplled-alr respirator operated In pressure demand mode equipped with auxiliary positive pressure self-contained breathing apparatus. OSHA has also required that employers provide powered air-purifying respirators for employees who request them for concentrations of asbestos-fibers less than 100 times the PEI. This recognizes that the proper use of respirators may depend on the worker's comfort and preference for various types of respirators. Work Area Precautions Warning signs should contain the same message as stated In Number 1 under Overview of Procedure In this letter. Wet Cleanup Any asbestos Insulation left In place will contain a visible label, where feasible. The label will contain the same Information as stated In Number 2 under Overview of Procedure In this letter. Clothing Storage Two separate lockers or containers shall be provided each employee, so separated or Isolated as to prevent contamination of the employee's street clothes from his work clothes. Employees exposed to asbestos during their work shift must shower before leaving the plant and must not leave wearing contaminated work clothing. Employees working In asbestos areas must have ready access to filtered air lunchrooms and must wash their face and hands prior to eating or smoking. Protective clothing must not be worn in the lunchroom unless cleaned beforehand. We question the use of vacuums to clean asbestos - contaminated clothing unless hlgh-efflclency filters are attached to the vacuum exhaust. This action could also prevent an employee from properly disposing his clothing after a designated work period. Laundering Caution labels will contain the same Information as stated In Number 2 under Overview of Procedure In this letter. Disposal by Trucking tinder RCRA truck drivers do not need a properly fllled-out manifest for asbestos disposal. UCC 020086 -4References The 1972 standard Is redesignated as 29 CFR 1910.1101 to distinguish It from the revised standard for general Industry which Is designated as 29 CFR 1910.1001. Asbestos Information for construction activities Is under 29 CFR 1926.58. i. *7Terry Et Hanning TEH:mw 62840 UCC 020087 A7 /k le J itloa la n t a ffllM b la , \ Si > j- k Jz ;] "> '-S - V 1 '3 *' \ $ > -j <2 - d <3 sa y) "e %A 'PI 1' i 3. -iji 05 i 333 3 * I I: 3 3 B *9 : M ii II ifro a 3 'S 3 XI _ N 3N I a 3 13 3 UCC 020088 3 "g 3 'a 3 3 3 3 3^ N i > I3 3 'g 3 Ol t 33 I N I "3 1 ji !* 1 Is ii in si i ii] i ?il i li l I ! ia f? n ii* 4 li Hi i] If?* !,sj i 51 !i ill sa UCC 020089 ! Ii t i ii lb Ii1]- I 3l it!!! ii ii! 8 3 3 3! 'a n a - I IN 3N I II] N 3 'S 'S 3 3 3 I I 3 3N 33N N 3 3,, 3a N UCC 020090 I i 33 8' N N 8 33 3 3^^ 33 3 3 11 3 ^ N 33 N3 nr/:rv UCC 020091 n * 3n N N i iN > 8^3 3 3 3 3 3 3 UCC 020092 a * SI 1 N vl 3 3 N I 3 H M a *) 3 3 N 3 v3 I 3 >9 3 UCC 020093 mi wBt a'tO'ti D 8 ?s ij t * i -I lI * II1-! | I | || ? ii | If mi 1i i h 9 ? 5? r <o r tt UCC 020094 & <0 5- 4- > rA V/> > <50 N~! v 1 ^l-C) 1 "|N| NISI wM WM W WV ~l 1 ~|N| 1 || | I I si -| 1 1 1 UCC 020095 -q \~| ww I~vl | \'| WW 11 v^ gl UCC 020096 o COST ALLOCATIONS TO TENANT DIVISIONS (Continued) PROFIT CENTER PROJECT ALLOCATION PERCENT INDUSTRIAL CHEMICALS DIVISION 108 156 160 161 170 174 SUB TOTAL TOTAL PROJECT 0.03 0.26 0.04 0.15 1.74 0.86 3 .08 100.0 COST ALLOCATION. Mf CAPITAL EXPENSE 1 .0 8.4 1 .3 5.0 57.0 28.3 101 .0 3300.0 0.4 3.6 0.5 2.1 24.3 12.1 43.0 1400.0 11/07/86 2903G UCC 020097 INSULATION UPGRADE PROJECT SOUTH CHARLESTON PLANT COST ALLOCATIONS TO TENANT DIVISIONS PROFIT CENTER PROJECT ALLOCATION PERCENT SPECIALTY CHEMICALS DIVISION 139 143 147 162 165 175 1 B4 337 351 353 384 399 423 53? 5.86 3.27 5.59 15.00 3.30 6.20 4.68 0.03 5.66 20.55 4.67 0.13 0.15 0.03 SUB TOTAL 75.12 COST ALLOCATION, M$ CAPITAL EXPENSE 193.4 107.9 184.5 495 ,0 108.9 204.6 154.4 1 .0 186.8 678.1 154.1 4.3 5.0 1 .0 2479.0 82.0 45.8 78.3 210.2 46.2 86.8 65.5 0.4 79.2 287 .9 65.4 1.8 2.1 0.4 1052.0 SOLVENTS AND COATINGS DIVISION 106 122 163 181 188 270 271 279 304 307 309 31 1 313 314 315 316 324 326 33? 332 333 381 485 486 639 0.03 0.32 1.32 0.49 0.22 0.45 0.39 0.01 0.38 0.36 0.03 0.15 0.33 1.26 0.30 0.12 0.74 0.63 0.26 0.47 0.17 12.25 1 .06 0.03 0.03 SUB TOTAL 21 .80 1 .0 10.6 43.6 16.2 7.3 14.9 12 .9 0.3 12.5 11.9 1 .0 5.0 ?0.9 41.6 10.0 4 .0 24 .4 20.8 8.6 15 .5 5.6 404.4 35.0 1 .0 1 .0 720.0 0.4 4.5 18.5 6.9 3.1 6.3 5.5 0.1 5.3 5.0 0.4 2.0 4.6 17.6 4.2 1.7 10.4 8.8 3.6 6.6 2.4 171.5 14.8 0.4 0.4 305.0 UCC 020098