Document nkvM8npgNnVbO4J9xbzXVgLvR

cc: Mr. S. A. D'Armond^ Mr. H. O. Bourcue ETHYL CORPORATION INTER-OFFICE a ** .j To Mr. R. E. Conrad Address Baton Rouge Plant From W. D. Skipper Subject Asbestos Standard Address Baton Rouge Plant Date April 15, 1976 At the request of Mr. S. A. D'Armond, Maintenance Engineering has carefully reviewed the EPA standard on asbestos titled "National Emission Standards for Hazardous Air Pollutants - Asbestos and Mercury" as listed in the Federal Register on October 14, 1975. The following information is an accurate synopsis of the EPA standard concerning asbestos; the standard for mercury is not applicable to our plant. Definitions, Section 61.21, page 48299. The following definitions have been established for the purposes of this standard. Demolition - The wrecking or taking out of any load-supporting structural member and any related removing or stripping of friable asbestos material. Section 6l.21(j), page 48299. Friable Asbestos Material - Any material that contains more than 1 percent asbestos by weight and that can be crumbled, pulverized, or reduced to powder, when dry, by hand pressure. Section 6l.21(k), page 48299. Renovation - The removing or stripping of friable asbestos material used to insulate or fireproof any pipe, duct, boiler, tank, reactor, turbine, furnace, or structural member. Section 6l.21(m), page 48299. Planned Renovation - A renovation operation, or a number of such operations, in which the amount of friable asbestos material that will be removed or stripped within a given period of time can be predicted. Operations that are individually non-scheduled are included, provided a number of such operations can be predicted to occur during a given period of time. Section 6l.21(n), page 48299. ETC 14709 F-00585 Mr. R. E. Conrad Asbestos Standard April 15, 1976 Page 2 Emergency Renovation - A renovation operation that results from a sudden, unexpected event, and is not a planned renovation. Section 6l.21(o), page 48299. Demolition Under the definition of ''demolition'1 as set up for the standard, we do not expect to be performing any work of this nature at the Baton Rouge Plant. However, should the situation arise the same basic procedure as that for renovation is to be followed. Written notice is required 10 days prior to commencement of demolition. Renovation The following requirements shall apply to any owner or operator of a renovation operation who intends to renovate any institutional, commercial, or industrial building, structure, facility, installation, or portion thereof where more than 260 feet of pipe insulated or fireproofed with friable asbestos material are stripped or removed, or more than 160 square feet of friable asbestos material used to insulate or fireproof any duct, boiler, tank, reactor, turbine, furnace, or structural member are stripped or removed. Section 61.22(d), page 48299. 1. Written notice of intention to renovate shall be provided to the Administrator by the owner or operator of the renovation operation. Such notice shall be postmarked or delivered as early as possible prior to commencement of renovation. Section 61.22(d)(2), page 48299, 48300. 2. Written notification of intention to renovate shall include all information outlined in Attachment I. Section 61.22(d)(2), page 48300. 3. For planned renovating operations involving individually non-scheduled operations, the additive amount of friable asbestos material that can be predicted will be removed or stripped at a source over a maximum period ofitime for which a prediction can be made. The period shall not be less than 30 days and not longer than 1 year. Section 61.22(d)(3)(i)(A), page 48300. ETC 14710 p-00S8fe Mr. R. E. Conrad Asbestos Standard April 15, 1976 Page 3 As noted above these requirements shall apply to any renovation where more than 260 feet of pipe is stripped or more than 160 square feet of area covered with friable asbestos material is stripped. The requirement for 260 feet of pipe and above is not considered to be a probable occurance since most jobs would involve less than this amount. However, the 160 square feet of area would apply in a number of cases. Examples include: 1. TEL or TML- Stills 2. Alloy Manufacturing Pots 3. Alloy Distribution Pots 4. Furnace Lead Pots Handling Asbestos Waste The following procedures shall be followed when handling friable asbestos waste material: 1. Friable asbestos materials used to insulate or fireproof pipes, ducts, boilers, tanks, reactors, turbines, furnaces or structural members shall be adequately wetted during stripping. Section 61. 22(d)(4)(ii), page 48300. 2. Such materials that have been stripped or removed more than 50 feet above ground level shall be transported to the ground via dust-tight chutes or containers. Section 61.22(d)(4)(v), page 48300. 3. Local exhaust ventilation and collection systems may be used instead of the wetting procedure. Section 6l. 22(d)(4)(vii), page 48300. 4. After wetting, all asbestos-containing waste material shall be sealed into leak-tight containers while wet and such containers shall be deposited at waste disposal sites which are operated in accordance with the standard for waste disposal. Section 61.22(j)(3)(i)(B), page 48301. > 5. Containers with waste friable asbestos materials shall be labeled with a warning label that states: E-00587 ETC 14711 Mr. R. E. Conrad Asbestos Standard April 15, 1976 Page 4 CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous To Your Health Section 61.22(j)(3)(i)(C), page 48301 Our present method of handling asbestos waste complies with the requirements with the exception of the labeling procedure. Asbestos material is wetted when removed, placed in plastic bags and sealed, and deposited for disposal. The only change needed would be to label the bags which could be accomplished through the use of printed tags. Waste Disposal Site We are presently investigating all possible sources of an existing waste disposal site which meets the requirements for asbestos disposal. If none are found a site shall be developed on property belonging to Ethyl Corporation which will meet the standard as detailed in Section 61.25, page 48302. Worker Safety All employees working with asbestos material shall be provided with respiratory protection. The wetting procedure shall be strickly adhered to in order to control any asbestos dust hazards. Page 48295. Insulating Molded insulating materials which are friable and wet-applied insulating n terials which are friable after drying, installed after the effective date of these regulations, shall contain no commercial asbestos. Section 6l.22(i), page 48301. 'I We are in compliance with this ruling at the Baton Rouge Plant. No molded asbestos containing insulations are stocked; substitute insulation are in use. E-00588 ETC 14712 Mr. R. E. Conrad Asbestos Standard April 15, 1976 Page 5 Recommendations The following changes in our present procedure should be made in order to assure compliance with the EPA standard: 1. Submit a notice of intention to renovate 10 days prior to renovation. 2. Utilize a form such as shown on Attachment 1 to assure all needed information is included. 3. Label all containers of waste asbestos materials. 4. Proper disposal at approved waste disposal sites. 5. Develop our own disposal site if necessary. 6. Make a specific written procedure covering the Baton Rouge Plant suitable for use by field supervision and the appropriate wage roll employees. 7. Make a list of vessels, towers, etc. which are insulated with asbestos and have more than 160 square feet of surface area. Attachment E-00589 ETC 14713 ATTACHMENT I Section 61.22(d)(2), Page 48299, 48300 NOTICE OF INTENTION TO RENOVATE DATE: Name of Firm: Address of Firm: Description of Facility to be Renovated: Age of Facility: Size of Facility: Use of Facility: Approximate Amount of Asbestos to be Removed: Location of Facility: Scheduled Starting and Completion Dates: Nature of Renovation and Methods: Procedure for Handling Asbestos Waste Material: Name and Address of Disposal Site: 1 -00590 ETC 14714