Document p38eogbDL540qXVQGnXq11zk

V% /' ( *< ^ To C. J. Lowe ETHYL CORPORATION INTER-OFFICE Address Pasadena From Subject Donald' E. Johnson Address brt Asbestos Removal, Central Shops Ceiling Date Feb. 2, 1979 R.P . Love has asked for comments on the written, protocol for. asbestos coating removal from the .central shops ceiling. (See attached). The recommendations look excellent to me. It is a highly commendable effort to meet the regulations and still get a dif ficult job done. Your people obviously, have put a lot of ef- . fort into preparing to' handle the job correctly. The. industrial hygiene group, will provide the requiredsupport. Please, give.us as much.advance, notice as feasible ' so we can arrange prompt analysis,of monitoring samples. DEJ:sbb cc: W. Arrastrong/A.O. Wikman J.G. Burdick/G.B. Meyers R'. Herzog C.B. Hunt . R.P. Love G.L. Ter Haar -J.'T ^'Rucker/P :J r-Sanders**1 File:Oper.Houston (Monitoring) ETH 002367 /\ ) fcfL ASHFMTM.1; I . (.HW siipps j:!:rr.PF: nia-KCT r < lysfibv-rc -- 3 Q i*S?Q! GENERAL DESCRIPTION The project Involves the safe removal of .1 ee i I i ng coating sprayed ". to portions of the underside of the Houston- Plant OuLral Shops Building. : t The material has been determined to contain 457 friable clirysotil.e (nsbe*?- ' tos) , sprayed onto concrete, blocks and thus removal Tails under jurisdic- ' tion 06 numerous-governmental authorities. GOVERNMENTAL REGULATIONS All regulations governing asbestos handling which have been issued bv proper governmental nuttiortties, shall be strictly adhonred to. The singl ing out of particular rules should not be construed to mean that our concur- rance would be given for disregarding other applicable rules and regulations The following are re.gul.nl ions of particular importance. OSHA Standards and Interpretations 1010.1001 (herein referred to ns OSTIA 1910.1001) and th.e Enviromental.Protection Agene Regulations on National Emission-Standards- ; for`hazardous air pollutants part 61 sub-parts A&R (herin referred to as-EPA 61 AfB). . * PROJECT SCOPE- ' -: The locations where reiMovai will ho reqo i is ,-j 160' x 160-- (approxi mately 25,000 sq. Tl.) area with ceilings approximately 15* in height. The area is roughly covered by the aluminum nozzel rebuilding shop to the SW, - the blacksmith to (In- SK. the El h-It i cal foreman1nTTice t<-> the NE, and the Electrical Shop to the NU. The asbestos mater inL varies in thickness, but * ,, * y' , on the'average Is 1/4" thick. The total volume of asbestos (Before crushLng or wetting should not exceed 60 cubic yards. GENERAL JOB REGULATIONS Due to lln* n.-ilun- of (In- project and I be crit i ni 1 need to try to main tain normal operations in the shops area, working hours for this project ETH 002368 CF.HKRAf, JOB RECldATiON:: - rout i nurd. would run between : 3(1 p.m. and (> a.m. , except for the weekend when It may run from *i: 30 p.m. Friday to fj: 110 a.m. Monday with the: first dav of >' actual asbestos removal to commence on Friday afternoon. Et is expected . I that the job will be stopped soon enouth.to previd** adequate time for . ! through clean-up oC all waste, from work areas. y It may be necessary to stop the cleaning operation at any time so work can be accomplished in 'the Simps by Ethyl personnel. Access to the' jobsite will be .tarofully restricted.' Compliance .is expected for OSIIA 191.0.1001 (d) O-m),, however Ethyl Corporation will not allow access.or use of company ''Lothes, sanitary facilities, eating facilities, or change- lockers. Space will he provided : as required for portable buildings to provide these services. In general, personnel not involved i.n retnval will not be permitted in! tle Shops area, ami personnel involved in. ibisproject will borest ricted ; to the jobsite .and the portab Ic'buildings supplied for their use. Anyone ^ entering the- building during removal will wear disposable overalls, and res pirators and clothes changes will be required before and after each work ; ' period. ATR OriAIITV AND CONTROT. Every effort shall be made to limit the amount of air space where air-* borne concentration of asbestos exceed the permi.ssa.b1e level as stated in 0SHA 1910.1001 fh). Where these levels may hr- exceeded supplied air res pirators will be provided in -accordance with 0S1IA .1910.1001 (d) (1-21-. Air for this system will be supplied by Ethyl Corporation, except where portable equipment is required. This will be provided by the contractor. - Tt is understood that until monitoring should show otherwise, personnel in iho Immediate vicinity or directly below the removal area will wear : ETH 002369 1- - A1K...QWAJJTY AND CONTROi. - nm! inuo-l suppl iid nir respirators. Necous.nry stnndbvs. i 1 I tin' safety ni (pcr.'iMiim* 1 . provided to insure Ventilation system:! which limit air eon cent rat ions wf.ll be used when-ever possible. Particular attention should he given to OSHA 1910.1001 (c) (ii) (a) and EPA 61.23 Co assure that ventilation exhaust are properly fil tered. All ventilation and ftiter- systems, will be. supplied by the contract tor, but must be approved by Ethyl Corporation. The location .of thuse'sys-r terns on plant property will he restricted to these areas approved bv Ethyl" Corporation. The contractor is expected to comply with OSHA 1910.1001 (f). (moni-- toring) for protection of it's own employees. * . REMOVAL . '***, ' Consideration-should hi* given to the .method ol removal and the method ' qE surrounding area protection, with procedures made known to and-approved * by Ethyl. The contractor shall sec that all tools directly used- for the removal of asbestos from- the. ceil Lug-shall be^vent 1 In led In. .compliance w.i th OSHA. 1910.1001 (c) (i) (ML). Per OSHA 1910.1001 (.-) (2) and EPA 61.22 (0) .(4) - (ili) (D) (4) (vi) ruinovaL shall be in a wot state er accomplished by wetting o-r ventilating (vacuum system). STGflS The contractor is further re.spons ible. for the proper procurement, place/ , \ ment, removal, and storage of the proper signs and caution labels as speci fied by 0SIIA 1910.1001 (g) . and directed by Ethyl. . II musl" In: h i pji ly ( mpli.r: i/.i-<l I lia l .ill emit a I lie re. (drum.-:, hags, cans, truck tanks, and enclosure.:;) where scraps are held and all areas where" ex-- enssive concentrations mav he located (inside the building at doors,, around ETH 002370 REMOVAL - continued ventilation exhausts) are to lie so designated.'per the above section. [(Jj-c.-v.tt- 'f-i r.t- L"/'v/fc c/K-ct ./'%y ctr*, DISPOSAL AND NOTICE V.A- . Of.* i jt /' t i -/ A-.}> t c, , rj f. j j y . The. particular method of disposal'of waste asbestos shall be made' ' * known to Ethyl Corporation, from renp/al, to containment, to disposal. '. The disposal site shall meet the regulations- as governed by EPA 61.25..J ( This information shall be made known to Ethyl 30 days prior to beginning. f . < the job for forwarding to the EPA. The asbestos is. to remain in tho wet ^ ` .- state during all| handling steps thru- disposal. ; Trip tickets to the disposal site will be provided by the' contractor toEthyl. BID INFORMATION _ . ,1 (M'l Your bid for th Ls.^should address the foil owing: A. Time per unit area B. Price per unit area and/or per man-hours. . C. Equipment costs. D. Manpower and job time projections. F. All- pertinent work methods. G. A written statement to the effect that you are aware of all aforementioned government regulations. A. A. Navarre' November 28, 1978 ETH 002371