Document ped0OMKr5OdNyXjbOjkQKvB3a

MAY-13-2003 11:39 WILLIAMS BAILEY LAW FIRM 7136436226 P.02/04 \SBEaTOS USAGE - tii-Aiii uir' nAJ.NU-cuuH'-^ ui^riu^iruini iu 'i-iuMtui , " " Briefly," we feel that the highest exposure rates are experienced by "'c Insulator Group which handles the material on a day-in and day-out .sis, both maintenance and construction. The next highest group would be the Brickmasons who apply the loose asbestos fill used in the mag pot program. Next in the exposure-time-weighted factor would be the persons who occasionally fabricate asbestos-bearing materials such as transits, haveg, and the like. The last on the exposure list would be those persons who occasionally perform demolition of asbestos-bearing insulation within the plants such as removal to facilitate repairs, etc., and handling loose material torn off existing lines prior tp sending to the dump grounds. Presently, we have discontinued all purchasing of asbestos-bearing insulating pipe covering with exception of certain selected sizes of ICaylo 20* a high temperature pipe covering material, used for temperatures from I2Q0F to 220QF* Only use we are aware of for this material is certain STOO02.8 I 8 , Lght hydrocarbon plant furnaces tube-turn bends. ) ' * . We have made a concerted effort to eliminate the small stocks of asbestos pipe covering which are scattered throughout the division. I believe we have accomplished this goal to the tune of about 95% complete We have also returned all asbestos pipe covering from our supplier (Gulf Supply) back to the manufacturer* Presently, we believe^ that only about 2% of the insulatorsf work within the division is made up of asbestos pipe covering. ($4,Q00 to $5,000 to eliminate all existing stocks.) u Insulating materials we are using to replace asbestos are: 1*. Fiberglass - both in "snap-on11 and loose blankets, ' ambient to 350F. ' -: * 2. Foamglass - 450 to 800F - also used where temperature^ cycle excessively and for Dowtherm service. 157# more expensive than asbestos, f EXHIBIT 1 ' MAY-13-2003 11=40 WILLIAMS BAILEY LAW FIRM 7136436226 P.03/04 ^ '* { 3, Carey temp 1500 - ambient to 1500F - expanded pearlite - fiberglass reinforced. Some problems associated with application but best available at present. Same cost as asbestos. ' Several other areas we are working on: 1. Have problems with loose fill insulation, used when setting mag pots* This generates a terrific amount of dust when asbestos shorts are used. We have found that "Super 48" by "48 Insulations, Inc,11 mineral wool makes less dust than asbestos shorts and contains only about 10% asbestos. The texture is slightly damp or moist feeling, thus Cutting down on the dust problem. When our brickmasons are using ' this material, they have been wearing respirators, . We . have been assured by the manufacturers of "Super 48" that ,by October 16 they will be producing an asbestos-free T ST000281 9 insulation "in bags marked as such. The composition of . this material is a mineral wool made from copper slag. 2. Fabricating of asbestos-reinforced plastics such as transite, haveg, micarta, where dusts become a problem in . operations such as. sawing and grinding. We have no problem with insulators wearing respirators when this work.is going on. Saws have been developed with vacuum systems to reduce . * . .amount of dust, but we still wear respirators as we still get quite a bit of residual dust. ' 3, Our foremen have been notified that respirators are to be . worn by the employees when- significant amounts of ^ng^irrtinn are to be removed when demolition occurs. We have not yet made it a firm rule to wear respirators in any'situation where dusts of ashes top occur, but I believe this will be only a short time before we do. Due to gathering evidence MAY-13-2003 11=40 WILLIAMS BAILEY LAW FIRM V- o existing hazards. 7136436226 P 04/04 ' , '' The last principal area I wane to cover is that of new construction. : ' We are currently in the process of changing the -Texas Division standards which will require the elimination of Kaylo (asbestos-type pipe covering) from the list of approved material. The Construction Department is continuing with all new construction in asbestos in which the material is on the job site, but any other new work will have Che Careytemp 1500 or expanded pearlite installed in lieu of asbestos. This change,took place about the 5th of October. " ~' '_ . This is a* brief sunsnsiy o where we stand in the Maintenance program of elimination of asbestos exposure hazards. . ST0002820 F, E. Crouch lbs October 13, 1970 TOTAL P.04