Document rBm8G1BY7xomJBb1qvRYEYZB7

Building 3502W November 4,1994 CERTIFIED MAIL RETURN RECEIPT REQUESTED State of Louisiana Department of Environmental Quality Air Quality Division Nathan Levy Asbestos Program Coordinator Dow U.S.A. The Dow Chemical Comoany P,0. Box 150 Plaauemine. Louisiana 70765-0150 PRODUCED FOR THE ASBESTOS DATABASE DATE:______ ________________________________ MASTER No. _ at&mj SUBJECT: Asbestos Complaint Dear Mr. Levy, As requested, Dow is responding to the complaint the Department of Environmental received from Dr. Glenn M. Gomes, which described an alleged asbestos exposure incident at the Power I Plant in Plaquemine. After thoroughly investigating this alleged incident, Dow strongly feels that no improper renovation activities occurred, and that none of the Furnace and Tube Service (FATS) employees were exposed to friable asbestos-containing material in the course of performing maintenance on Boiler #2 during the referred to time period. The following discussion should help clarify any misunderstanding. ORIGINAL SCOPE OF WORK The original scope of the work performed on Boiler #2 included replacement of insulation, both asbestos-containing and non-asbestos type materials, refractory brick and steel associated with the roof and south wall of the boiler. Petrin and Furnace and Tube Service (FATS) were two contracting firms employed to complete the work. Petrin supplied asbestos abatement personnel to address the part of the job dealing with asbestos. Furnace and Tube was contracted to deal with the non-asbestos containing insulation, refractory brick and steel aspects of the work. A written job scope was prepared and given to FATS prior to their starting the job. Before beginning the work, an on site discussion was conducted with job associated personnel from FATS, Petrin, and Dow. The topics covered included scope of the work, emphasis on the fact that asbestos was present in some locations of the boiler, and because of that, certified asbestos abatement trained Petrin personnel would be present to handle that portion of the job. FATS would only be allowed to work on material that was asbestos free. Petrin began some preparatory work in late February. Bulk samples were taken of material in various spots inside the boiler, and analysis completed prior to FATS coming on site. SAFE WORK PRACTICE There has been an overwhelming effort on the part of Dow to protect individuals from asbestos exposure. Some of the primary safe work practices followed during this job included: DO 075604 CONFIDENTIAL (1) Petrin would complete their asbestos related work activities (e.g. sampling, removal, cleanup, encapsulation) prior to any FATS workmen entering the area to do their work. (2) If any questions arose regarding the nature of a material (i.e. asbestos containing or not), or if there were any scope changes to a job that would involve an unchecked material, a sample would be taken and the material identified, then work would proceed utilizing the proper contractor (Petrin if asbestos-containing material is involved, and FATS if it is non-asbestos). (3) Material requiring asbestos analysis would be sent to a laboratory in Baton Rouge. (4) Asbestos abatement work practices would include: a. Setting up regulated areas to limit access and minimize the potential for exposure; b. Erecting enclosures or partial enclosures if feasible; c. Using glove bags and wet removal techniques to prevent airborne fibers; d. Cleaning, vacuuming with a HEPA vacuum and encapsulation would be employed following completion of asbestos removal activities; e. Having an asbestos competent person on site at all times to supervise asbestos removal activities, answer any questions, and address any concerns. ENLARGEMENT QfLSCOPE OF WORK During the performance of refractory and steel work involved in the original job scope, some additional boiler related maintenance repair needs were uncovered, and the original job content was enlarged. This additional repair work involved the east, west and north walls of Boiler #2. Samples of material from these areas were taken and sent to Baton Rouge for analysis. Analytical results for the initial samples analyzed were mixed (i.e. some samples were asbestos positive and others asbestos negative), therefore a decision was made to employ Petrin asbestos abatement personnel in the removal of all insulative and gasket material in those locations regardless of whether it was asbestos-containing or not Petrin followed abatement work practices appropriate for the type of material involved, and upon completion, FATS personnel moved into the area to perform their pan of the required repairs. CONCLUSION Dow has a specific plant indoctrination for each plant The plant indoctrination which every FATS employee was required to receive stated that there was asbestos located in the Power I Plant block, and then explained the hazards associated with asbestos. In addition, concern for the safety and health aspects of this job are evident by the fact that a Petrin asbestos competent person was kept on site during the entire job, even when asbestoscontaining material was not being worked on, in order to be present to answer questions and address any concerns. Also, Dow supervision was there to ensure compliance with safe work practices and procedures associated with the job, enforce Dow standard practices, and ensure compliance with appropriate governmental regulations. Thank you for this opportunity to respond. If you have any further questions concerning this matter, please call Bruce Heinze at (504)-353-1817. Sincerely, Industrial Hygiene DO 075605 OONFTDFNTTAL State of Louisiana Department of Environmental Quality A Edwin W. Edwards Governor Bruce Heinze DOW Chemical Post Office Box 150 Plaquemine, LA 70765-150 October 25, 1994 William A. Kucharski Secretary RECEIVED OCT 2 8 1994 INU. jtr l RE: Asbestos Complaint Dear Mr. Heinze: The Department received the enclosed letter from Dr. Glenn M. Gomes, which describes an asbestos exposure incident at the DOW Chemical Plant in Plaquemine. According to a patient of Dr, Gomes, improper renovation activities took place in the plant's Power One Block from February to March. Workers of a subcontractor company called Furnace and Tube were exposed to friable asbestos. The workers were unaware that they were being exposed to asbestos until the project was close to completion. According to the complainant, when the project was near completion, a licensed asbestos contractor was brought in to remove the remaining asbestos. Our records indicate that two asbestos disposal verification forms (ADVF) were issued for the Power One Block for dates which correspond to those noted in Dr. Gomes's letter. Enclosed you will find copies of the notification forms (AAC-2 forms) which DOW submitted. The Department requests that you reply to this complaint within 10 days of receipt of this letter. If you have any questions concerning this matter, I can be reached at (504) 765-0899. Sincerely. Nathan Levy Asbestos Program Coordinator Air Quality Division NL//RMM/rmm Enclosures fl:wpwin\icttcfi\DOWGOM5 recycled pacer OFFICE OF AIR QUALITY P.O.BOX 82135 BATON ROUGE. LOUISIANA 70854-2135 AN EQUAL OPPORTUNITY EMPLOYER HO 075606 CONFTDFNTTAl.. OCHSNER CLINIC OF BATON ROUGE 16777 MEDICAL CENTER DRIVE BATON ROUGE, LOUISIANA 70816 October 13, 1994 Telephone 755-5200 Area Code 504 RECEIVED Mr. Nathan Levy P. O. Box 82135 Baton Rouge, LA 70884-2135 Dear Mr. Levy: OCT 2 8 1994 -- *----- - *- It has come to my attention through one of my patients that there is a significant problem with asbestos exposure at industrial work sites in this area. Specifically my patient worked for a company called Furnace and Tube in Gonzales, Louisiana, and was a subcontractor at the Dow Plant in Plaquemine. He relates to me that they worked on an electrical generation boiler at Power One Block at the Dow plant in Plaquemine from a period of around February through May of 1994. During this time they were exposed to asbestos without any respiratory protection in a poorly ventilated area inside of a boiler. The employees found out that the boiler was insulated with asbestos products when they had nearly completed the job. Individuals wearing respiratory protection and asbestos abatement equipment came in and finished the work. My discussions with my patient have led me to believe that this is somewhat of a common practice, especially among small subcontractors who are working at larger facilities such as the Dow Plant in Plaquemine.I I would appreciate it if you would look into this unregulated and unprotected exposure to asbestos. Respectfully yours. Glenn M. Gomes. M.D. < GMG/drm/14 OO 075607 CONFTDFNTTAl. PLANNED SHUTDOWN ASBESTOS QUESTIONNAIRE Plant: OXYGEN SUPPLY Shutdown Schedule: Start Completion: i hr ShutdownDescription: AIR LIOUIED WILL TAKE DOWN THE LOCAL Q2 DISTRIBUTION SYSTEM FOR 30 HOURS FOR TIE-INS. 1. Is any Regulated Asbestos-Containing Material (RACM) being removed or disturbed (RACM includes asbestos gaskets)? Yes ^ No IF THE ANSWER TO #1 IS NO, PLEASE SIGN BELOW AND RETURN TO I.H. 2. If Yes, is the RACM friable or will it become friable in the course of doing the work? YesNo y IF ITIS REASONABLE TO EXPECT THE RACM WILL BECOME FRIABLE, AN ADVF SHOULD BE OBTAINED TO AVOID POSSIBLE JOB INTERRUPTING CIRCUMSTANCES. 3. If Yes, (Question #2), contact LH. at extension 1817. 4. Is there any demolition activity associated with the shutdown? Demolition is defined as the wrecking or taking out of any beam or load-supporting structural member ofa facility? In the context of this regulation, a facility is considered a building and not process related equipment (e,g., reactors, distillation columns, tanks, exchangers, piping, pipeways and associated equipment). YesNo X IF THE ANSWER IS YES, AN ADVF MUST BE OBTAINED FROM THE DEQ AT LEAST 10 WORKING DAYS PRIOR TO STARTING THE DEMOLITION. Form CompletedBv: ** Mo<t/ns,,j_______ Date: X / 3 / 9 </ Rev. 3/92 RETURN TO: Bruce Heinze Industrial Hygiene Department Building 3S02W FODUCED FOR THE ASBESTOS DATABASE :ATE; "l*121 iVM No. 00 075608 OONFTDFNTTA