Document oeRZbVKj78EkxR4nM4vNZn01E

BUSINESS CONFIDENTIAL MATERIALS ENGINEERING CENT <AL FILE UNION CARBIDE CORPORATION ENGINEERING AND HYDROCARBONS DIVISION CENTRAL ENGINEERING SOUTH CHARLESTON, WEST VIRGINIA MEMORANDUM April 7, 1987 18583 TO: CC: FROM: SUBJECT: J. R. Allen, 3001 R. G. Eager, Jr., 312 E. A. Knockaert, Weston Canal J. B. Rader, 514 G. B. Elder, 511 M0C H. T. Pritt ASBESTOS-CONTAINING GASKETS Attached is the final draft of the Recommended CAP Program to Phase out Use of Asbestos-Containing Materials In The Work Place. Since this program makes the statement "no asbestos-containing materials will be purchased after January 1, 1989", I felt you would want to be aware of the possible implica tions affecting your use of asbestos sealing materials. Although the program does not forbid the use of asbestos sealing materials, EPA rules for handling asbestos are such that the usage of asbestos will rapidly decline which will help them (EPA) implement their purposed ban of asbestos in ten years. Effective July 1, 1986, EPA lowered the acceptable exposure to asbestos from 2.0 to 0.20 fibers per cubic centimeter on an 8 hour time-weighted average. The 0.2 fibers/CC has been exceeded in some air samples when handling asbestos gaskets. The present recommendation for replacement of asbestos compressed gasketing is Grafoil and spiral wound gaskets with Teflon or.Grafoil filler. Reinforced Teflon may also be used. The organic fiber (ARAMID) compressed gaskets are not recommended for use in the plants because they do not pass the API 607 fire test. Preliminary data from a current test program being conducted by the Materials Technology Institute show that after 24 hours at 750"F the organic fiber gasket is disintegrated and at 550F retains zero breaking load strength compared to 50 PSI breaking load for compressed asbestos. The chemical resistance of Teflon is outstanding, as is well known. Grafoil also had excellent chemical resistance, particularly in organic chemicals. We will be doing some specific chemical compatibility testing with Grafoil. 0101J UCC 015695 PLAINTIFF'S EXHIBIT UC-2411 -2 Grafoil is a relatively expensive material and I have attached a cost study comparing Grafoil and asbestos gasketing with the additional cost of handling asbestos according to EPA requirements being considered. The technical service people at the Carbon Products Division are available to discuss Grafoil for specific application needs. There is also enclosed the UCC Specification SH-256 from the Health, Safety and Environmental Technology Group that details the handling of asbestos-containing insulation material. While the specification addresses insulation the handling requirements apply to asbestos in general. If there sire further questions, please contact me. HTP:es ATTACHMENT 18583 INDEX: B. 23, 42, 50, 112 113, 180, 343 H. T. Pritt 0101J UCC 015696 DRAFT RECOMMENDED C&P PROGRAM CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) 9/29/86 GOAL: PHASEOUT USE OF ASBESTOS-CONTAINING MATERIALS*1>IN THE WORK PLACE PURPOSE/BACKGROUND The Corporate Charter (1.1) contains the following commitment to em ployees: "To provide working conditions, programs of training and education, and persistent review and appropriate modifi cation of facilities and practices to protect the health and safety of employees." It also contains a social commitment to conduct business "In accordance with all the applicable national and local laws and regulations." As a result of available evidence that airborne asbestos In the occupa tional environment had proven to be carcinogenic in man, all C&P Insulation Standards were revised In 1976 to specify only asbestos-free Insulating materials; and new or replacement Installations of these materials have sub sequently been selected accordingly. Additionally, a Safety/Health Standard designated SH-256 was prepared covering the safe removal and handling (in cludes disposal) of asbestos-containing Insulating material during renova tion and demolition. The requirements of this Standard equal or exceed those of current applicable government standards. OSHA's rule-making efforts relative to asbestos usage In the work place are mired In controversy. Hearings on the latest EPA proposal which In cludes the phaseout of all asbestos over a ten-year period are now In prog ress. The proposal states: "EPA Is considering banning the manufacture. Importation, and processing of asbestos construction products and asbestos clothing soon after the rule's promulgation with the category of asbestos friction products banned about five years later, and other asbestos products banned at a later time." Gaskets and packing that contain asbestos are In the category of "other asbestos products" that would apparently be banned after ten years. No peer company that we are aware of has a target date for removal of existing asbestos-containing Insulation, gaskets, or packing; however, one major chemical company has recently discontinued the purchase of asbestos-containing gaskets and packing. A cost analysis of pipe-size gaskets shows that GRAFOIL*, probably the most expensive of the acceptable gasket substitute materials, is. In fact, cost effective when the cost of mandatory work practices associated with the use of asbestos (e.g., wetting for removal or airborne fiber <l)"Asbestos-conta1n1ng materials" Include but are not limited to Insulation, gaskets, packing, welding blankets, and construction products. UCC 015697 DRAFT 2- - 9/29/86 exposure monitoring during removal, placing In labeled plastic bags after removal, landfill disposal, and record keeping) Is considered. The same conclusion Is drawn relative to valve packing when the additional considera tions of Improved service life and seal ability are Included. Consistent with the aforementioned commitments and the economic use of materials, C&P has concluded that positive actions relative to asbestos-con taining materials^1* should be taken. RECOMMENDED C&P PROGRAM Except as otherwise provided by applicable law. Chemicals and Plastics Business Group will: Continue to phase out the use of asbestos-containing materials: Asbestos-containing insulation shall be replaced with asbestos-free materials as required to maintain structural and functional Integ rity. No asbestos-containing materials shall be purchased after January 1, 1989. C&P Standard Practices shall be employed for the identification, removal, modification, and/or disposal of asbestos-containing mate rials; and for use of asbestos-substitute materials. Evaluation of asbestos-substitute materials shall Include considera tion of health effects as well as suitability for intended service and cost. A variance approval procedure shall be employed to cover considera tion of uncommon circumstances. Approval must always Include en- ,, dorsement of C&P HS&EA management. SCOPE This Recommended Program applies to all C&P operated/hosted facili ties. Other components of the Corporation will be apprised of Its content. DELEGATION The assignment of duties and authority to carry out the Recommended C&P Program defined herein Is delegated as follows: To Central Engineering Department Develop and maintain C&P Standard Practices covering: - Identification of asbestos-containing materials; UCC 015698 D RAFT 9/29/86 -3- - Removal, modification and/or disposal of asbestos-containing mate rials; and - Use of asbestos-substitute materials. To Line Operations Management Implement C&P Standard Practices for the Identification, removal, modification, and disposal of asbestos-containing materials. Implement C&P Standard Practices covering asbestos substitute mate rial applications, and communicate the service experience with these materials. To Manufacturing Services Monitor use of asbestos-substitute materials and communicate the service experience with these materials. To C&P HS&EA Audit compliance with governmental regulations and C&P Standard Practices relating to asbestos-containing materials and, where applicable, their substitutes. UCC 015699 C. C. Neely 47071 RECOMMENOEO PRACTICE CENTRAL ENGINEERING SH-26 PAGE 1 OF SEPTEMBER 198 REHOYAL AMO HANDLING ASBESTUS-tONTAINING lhSULATIDN MATERIAL 1 GENERAL 1.1 lials Practice provices a procedure for the sir e removal and handing of asbestos-containing insulation materia) and compliance with OSHA regulation Zb CFR lblO.lOul'and EPA regulation 40 CFH 61 Subpart h. The purpose of the Practice is to ensure tne safety and health of employees directly Involved with performing the work and of others, either in the Imediate area or downwind, who may be exposed to residual dust/fibers. Insulation material containing asbestos is no longer Installed by UCC; therefore, the concern of tnis Practice is to control renovation ano demolition operations Involving the removal 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-nour time-weighted average exposure to airborne concentrations of asbestos fibers shall not exceed 0.2 fibers, longer than S micrometers, per cubic centimeter of air. 2.1.2 An action level of 0.1 fibers, longer than b micrometers, per cubic centimeter of air has been set which triggers the monitoring, medical, ano employee Information and training requirements. 2.2 Work Practices 2.2.1 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.) anu 2.1.2. bee Section 2.0.3 for the specific EPA regulations that control Mrk practices. 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 area. The signs shall state: DANGER-ASBESTOS; CANCER AND LUNG DISEASE HA2ARD - AUTHORIZED PERSONNEL ONLY; RESPIRATORS ANO PROTECTIVE CLU1H1NG ARE REQUIRED IN THIS AREA 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 exceeo the exposure limits listed In Section 2.1.1. See Section 2.6.4.4 for additional requirements for posting signs. 2.2.2.1 An appropriate barricade, using caution or barrier 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 sprgy the removed Insulation with water, and then place In plastic bags. When wet methods of reuoval/cleanup are impractical, e.g., when temperatures are below freezing, vacuuming or sweeping nay serve as an effective alternate cleanup method. Sweeping compound shall be applied to the work area to prevent dust generation when sweeping. See Sections 2.6.3.7 and 2.6.4 for specific work practice requirements. UCC 015702 rrr.*'-'i RECOMMENDED PRACTICE SH-2bb PAGE 2 OF 0 SEPTEMBER IVBb CENTRAL ENGINEERING 2.2.4 label Specifications - Container caution labels shall be printed In letters of sufficient site and contrast as to be readily visible ano legible. The label shall state: DANGER - CONTAINS ASBESTOS FIBERS; AVOID CREATING DUST; CANCER AND LUNG DISEASE HAZARD 2.2.5 Regulated Areas - Employers must Identify as regulated areas any locations In their workplaces where there nay be occupational exposures to airborne concentrations of asbestos above the PEL. Only authorized persons nay enter regulated areas which nust be clearly posted. Eating, drinking, and saoking are prohibited in regulated areas. 2.2.0 Housekeeping - All external surfaces In any place of employment shall be maintained free of accumulation of asbestos fibers. Special attention should be given to cleaning scaffolds used in demolition work. Clean-up of asbestos oust Is prohibited with compressed air, dry-sweeping or ary dry clean-up process. 2.2.7 Waste Disposal - Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos-contaminated disposable clothing, that is consigned for disposal and which may produce airborne concentrations of asbestos fibers In excess of permissible exposure limits, shall be collected and disposed of in sealed leak-tight containers to an approved landfill. See Section 2.6.4 for specific disposal requirements. 2.3 Personal Protective Equipment 2.3.1 Respiratory Protection - Employees engaged in the spraying (wettlng-downi of asbestos, the removal; in the demolition of pipes, structures, or equipment covereo or Insulated with asbestos; and in the removal or demolition of asbestos insulation or coverings shall be provided witn respiratory equipment having high efficiency filters selected from among those approved by the Nine Safety and Health AAinl strati on, Department of the Interior, or the National Institute of Occupational Safety and Health, Department of Health and Human Services described in 30 CFR Part II. Compliance with exposure limits prescribed In 2.1, Permissible Exposure Limits, shall not be achieved by the use of respirators, except: 1. During the Interval necessary to Install or implement feasible engineering and work practice controls. 2. In work operations such as maintenance and repair activities or other activities which the emplqyer establishes that engineering and work practice control procedures are not feasible, 3. In work situations where feasible engineering and work practice controls are not yet sufficient to reduce exposure to or below the PEL, 4. In emergencies. Where respirators are permittee the employer shall provide a powered, air purifying respirator In lieu of any negative pressure respirator specified In Table 1 whenever: a. An employee chooses to use this type of respirator; and b. This respirator will provide adequate protection to the employee. 22.5.1.2 UC'C 015703 3k\- RECOMMENDED PRACTICE CENTRAL ENGINEERING TABLE 1 RESPIRATOKT PROTECTION FOR ASBESTOS. TREMOL1TE, AHTHOPHTLUTE, AMD ACTINOLITE FIBERS Airborne Concentration of Subject Materials or Cooblnation of These Materials Requireo kespirator SH-2b6 PAGE 3 OF 6 SEPTEMBER 1<<86 1. Mot In excess of 2 f/cc 110 x PEL) 1. Half-mask air-purifying respirator equipped with high-efficiency filters. 2. Hot In excess of 10 f/cc (SO x PEL) 1. Full facepiece air purifying respirator hlgh-etflclency filters. 3. Hot 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 node. 4. Not In excess of 20U f/cc (100U x PEL) 1. Full facepiece supplied air respirator operated In pressure demand mode. 5. Greater than 200 f/cc (greater than 1,000 x PEL) or unknown concentration) 1. Full facepiece supplleo air respirator operated In pressure demand mode equipped with an auxiliary positive pressure self-contained breathing apparatus. 2.3.2 Special Clothing - The employer shall provide and require use of special clothing, such as coveralls or slnllar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed. Contaminated clothing must be stored In closed containers such as sealed lockers. It should be changed dally. 2.3.3 Hygiene Facilities and Practices - 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 from his wort 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 aust 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 lunchroca unless cleaned before hand. 2.3.4 Launderlnq - 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 laundering of asbestos-contaminated clothing must 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 are used, they should be placed Into containers with asbestos for disi sal. 2.4 Industrial Hygiene Responsibility 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 tlx periphery of tire restricted area to assure that fugitive emissions exceeding permissible exposure limits do not extend past the . v--Vjr* i*i UCC 015704 . .1:12.5.1.; RECOMMENDED PRACTICE SH-25b PAGE 4 OF 6 SEPTEMBER 1586 CENTRAL ENGINEERING demarcated ire*. Samples shall be collected using 25 sn diameter mixed cellulose filters and a 50 mm extension cowl. Samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. Monitoring Is required at least every b months for employees whose exposures to asbestos is at or above the action level. Samples must be analyzed using a phase contrast microscope calibrated using a phase shift test slide and equipped with a Walton-Beckett graticule. The filter samples must be prepared using acetone-trlacetln cleaning solution and be counted In accordance with the "A* rules contained in the HIOSH 7400 method. ' 2.5 Training 2.5.1 All employees who are exposed to airborne asbestos concentrations in excess of the exposure limit listed in Section 2.1.1 with or without the use of respirators shall participate In a training program at the tine of or prior to Initial assignment and at least annually afterwards 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. Mature of operations which could result In exposure to asbestos and necessary protective steps to minimize exposure Including, as applicable, engineering controls, work practices, respirators, housekeeping and protective clothing. 4. Purpose, proper use, fitting Instructions, and limitations of the respirators used to protect against asbestos fibers. 5. Review of all provisions contained In 29 CFR 1910.1001, Asbestos. 6. Purpose for and description of the asbestos medical surveillance program. 7. Instructions for handling spills as well as emergency and clean-up procedures. .,2.5.2 Training records shall be maintained by the location and shall be readily available to all affected employees and to OSHA personnel upon their request. 2.6 Federal EPA Regulation, 40 CFR 61, Hazardous Air Pollutants; Subpart H - National Emission Standard for Asbestos 2.6.1 Applicability - These requirements apply to the demolition of structures or renovation of equipment and piping that Involves removal of Insulation that contains friable asbestos materials. Friable asbestos material means any material containing more than I percent asbestos by weight that hand pressure can cruable, pulverize, or reduce to powder when dry. Demolition means the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations; on the other hand, renovation means to alter one or more facility components In any way without taking out load-supporting structural members. Planned renovation operations Include scheduled and unscheduled operations In which the amount of friable asbestos material that will be removed or stripped within a given time period can be estimated or predicted based on operating experience. Adequately wetted means sufficiently mixed or coated with water or an aqueous solution to prevent dust emissions. 2.6.2 Key Notification Requirements 1. Timing - The EPA must be notified with a written notice of Intention to demolish or renovate according to these timing requirements: a. As early as possible before renovation begins if planned, but not necessarily scheduled, renovation operations are predicted to Involve the stripping or removing of at least 260 linear feet on piping or 16U square feet on other facility components of friable asbestos materials within a year. . 22.5.1.2 UCC 015705