Document re2LV6JNDwdMgQvQN5JpEagLG

Union Carbide Corporation Linde Division Old Ridgebury Road Danbury, CT 06817 To: Linde Health Coordinators Cryogenic Equipment & Coatings Service Health Coordinators December 19, 1983 Re: Asbestos OSHA - Emergency Temporary Standard On Friday, November 4th, OSHA issued an Emergency Temporary Standard redu cing the permissible exposure limit for asbestos from 2 fibers per cubic centimeter to 0.5 fibers per cubic centimeter for an 8 hour time-weightedaverage (TWAq). This new lower exposure standard requires a training pro gram for all employees exposed to airborne concentrations of asbestos in excess of 0.5 fiber/cc (TWAg) without regard to the use of respirators to include: 1. The health effects associated with asbestos exposure. 2. The relationship between asbestos and smoking in produ cing lung cancer. 3. The nature of operations which could result in exposure to asbestos and necessary protective steps to minimize exposure. 4. The proper use, fitting and limitations of respirators. Posting of warning sicpis is required if airborne concentrations of asbestos fibers may exceed 0.5 fibers/cc. If you have questions, please give me a call. EKJ/mbb Eleanor K. Jensen File Copy Only; N. A. DiFranco and T. V. Kelly received instructions on this regulation under separate cover. 052b UCC 009965 PLAINTIFF'S EXHIBIT UC-4I95 S \983 Mr. G. J. Hoeing UCC - Linde Division Danbury, CT R3692 Mr. R. H. Argo Mr. T. E. DeBrlae Mr. R. P. Guess Mr. F. J. Gould Ms. E. K. Jensen # Mr. G. J. Keehn Mr. T. E. Kehler Mr. J. S. Pirretti Mr. V. A. Smith December 1, 1983 '' Asbestos Exposure Dear Mr. Hoeing: On Friday, November 4th, OSHA issued an Emergency Temporary Standard re ducing the permissable exposure limit asbestos from 2 fibers per cubic centimeter to 0.5 fibers per cubic centimeter for an 8 hour time weighted average. The major source of asbestos exposure in Package Gas Plants is in the maintenance of acetylene cylinders when valves are removed to check the well depth. The asbestos is present in the filler at a concentration of 1% by volume. It is not expected that maintenance of acetylene cylinders in this manner will result in adverse employee exposure to asbestos. However, there is no employee exposure data on file to support this assumption. I have received some questions from the field in this regard and in order to properly respond, it will be necessary to conduct employee monitoring at selected locations. Alan Duva suggested that the Whiting plant be monitored due to the large volume of acetylene cylinders being repaired. I will arrange for this sometime in December or early January. There may be other instances of asbestos exposure not related to acetylene cylinder maintenance. Many older Package Gas Plants may have asbestos insulation around steam pipes, in boiler rooms or other areas of the plant. I have copied the Region Package Operation Managers to make them aware of OSHA's new Emergency Temporary Standard and to ask them to poll their plants to determine if there are any potential areas of asbestos exposure, in addition to the acetylene cylinder maintenance area described above. A 10526 UCC 009966 Mr. G. J. Hoeing December 1, 1983 In addition to the new lower exposure standard, the Emergency Temporary Standard requires a training program for all employees exposed to air borne concentrations of asbestos in excess of 0.5 f/cc without regard to the use of respirators to include: 1. The health affects associated with asbestos exposure. 2. The relationship between asbestos and smoking in producing lung cancer. 3. The nature of operations which could result in exposure to asbestos and necessary protective steps to minimize exposure. 4. The purpose proper use fitting instructions and limitations of respirators. The ETS also requires the posting of legible warning signs at each location where airborne concentrations of asbestos fibers may exceed 0.5 f/cc. The Region Package Operations Managers should let me know as soon as possible the results of their poll. Very truly yours NAD:Id N. A. DiFranco UCC 009967 UCC 009968 ft 10528 INTERNAL CORRESPONDENCE f[C'UAWR&OIDNEJl BUSINESS CONFIDENTIAL UNION CARBIDE CORPORATION SPEEDWAY FACTORY ENG'NEERING PRODUCTS DIVISION ABOI WEST 16TH STREET. P.O. BOX SA501. SPEEDWAY. INDIANAPOLIS. IN AS22A To Dvn Copy co Mr. F. E. Camic Mr. R. W. Cromer Mr. W. G. Curtis Mr. C. H. Mason Mr. D. P. Maurer Ms. D. J. Praed Dr. L. W. Winter Mr. R. P. Wooldridge Date November 8, 1983 oriQinotinQOept Employee Relations Asbestos Exposure The article here appeared in the Wall Street Journal on November 3, 1983. I verified it with Bob Ondoscln of Industrial Hygiene, Union Carbide Corporation, Danbury. It means that effective November 4, 1983, the limit for asbestos exposure is changed from 2 fibers per cc air to 0.5 fibers per cc air averaged over an 8 hour period. Only fibers exceeding 5 micrometers in length are considered. I've attached a summary of our readings since late 1976. The limit was reduced from 5 fibers to 2 fibers in July, 1976 and has remained at that limit until this time. As the samples Indicate, we can meet the new standard as long as housekeeping and equipment are maintained. These areas are critical for continued compliance. Our requirements of respirator use continues to exceed the requirement of OSHA. We must continue to enforce this policy as extra insurance in reducing exposure to the employee. The only area I see requiring a change is that of maintenance work inside the shredder mechanism. After discussion with Bo Bunting, I believe the use of Jr the paper coverall and hat should be required anytime the inner enclosure is opened for internal maintenance work where there is the potential to stir up asbestos dust. The choice to wear this clothing has been somewhat optional in the past. Bo will also check on paper foot coverings that are available. Corporate Industrial Hygiene will send me additional information when it is available. Contact me if you have any questions. T. V. KelTr^ Safety Director pk attachments u)cn C, v --oye op" Coof J G CJQyJSMisS <OpJ be, OSA. c; * Ch t .i.> Ofexuriofis . Covld X l`^e coffcs, -/*?7 --,^Jcs k i 052 9 UCC 009969 New Rule Limiting Asbestos Exposure Is Issued by OSHA J lUW By Joann S. UfauN Staff Hrponer / The W/Wj. Srnrr /ovkmai. WASHINGTON--In a step rarely taken, the Labor Department placed Immediate tougher limits on occupational exposure to asbestos, which has been linked to fatal dis eases. The department's Occupational Safety and Health Administration issued an emer gency temporary standard that sets maxi mum workplace exposure for asbestos at 500.000 fibers per cubic meter of air. The current level, set in 1972, 1$ two million fi bers per cubic meter. The temporary rule, sought by It unions, takes effect Friday and remains in effect for six months while the job-safety agency decides whether to make the tougher standard permanent. This marks the first time OSHA has is sued an emergency temporary standard since 1978. The asbestos industry is expected to challenge the ruling in federal court. Al though unions won the desired emergency ruling, they remain unhappy with OSHA be cause they wanted even more stringent new limits and fear the agency won't step up Its enforcement efforts. The emergency rule reflects new scien tific evidence Unking low-level exposure of asbestos to asbestosis, a lung disease, and mesothelioma, a cancer of the lining of the lungs. An OSHA analysis found 50,000 work ers in the U.S. are exposed to between 500,000 and two million fibers per cubic meter of air, averaged over an eight-hour day. "That really is the basis" for the emer gency-rule, said Patrick Tyson. OSKA's dep uty chief. "We had to demonstrate that - there are a number of workers at risk." The agency believes the new exposure limit may prevent 200 of those employees from dying from cancer. Mr. Tyson added. OSHA bas agonised for months about whether to issue the emergency ruling, be cause of its, poor track record with such steps in the past. Industry groups have sued the job-safety agency over five of the eight emergency standards issued since the agency's inception in 1971. Only one of those five rulings has been fully upheld by the courts, a standard limiting exposure to acry lonitrile. a chemical widely used to make . synthetic rubber, plastics and other prodI ucts that has been linked to cancer. UCC 009970 A 10530 All. ^LOtS '^> osha Lf*A\~T pa*. cc~ A'**~ of RofliD^4 ? 2--0 QA itJSpCCJToiZ. 1/-76 ' 0.1 2/77- <0.1 G/6L- 0,03 '/&* - 0.0$ 2-/b$ * 0, OZ 6/# 3 -0 0.07 V*3 - 0'OZ -&/ /?SS&n6/<XL *&/7 b ~ 0 O. I 9/74 - O./ ?/7 - 0. / v5y-7^ - o. 07 6/7f - 0, 0/ 6 - 0 O.o/ v_7 /Tn7t>c.t/}V0 S/fcZL <t/-7d - 0.5 /z/v6 - ^OJ 3 / 77 - ^O./ jr/7? - 0.0/ <&/7? - 0,0/ 7-/71 0.0/ S*f Vfit'Tf s/71-0.0/ 79-0.02 6/7/0.0/ d/79-0.0/ 320 /rw4n.-oi>r <2/76 <2.0. f &/7b 0. z <*-/7b 0 0.1 3/77 <2 O. f 0&O GMd<? <0/77 <CO. 1 tv/?>^> O , 26 u/4u, <ro. 1 f(^CuArROyiDfTn^Jl BUSINESS CONFIDENTIAL ^5// f.CL&S. - OVZL7Z5Z5&A e/n? - ^,e> y7 ^ 3 /2/7^ - 3/77 * ?.^5 6/77 - 0.2- &/79 - 0. 04- s/ 7? _ 9/tt 9/0/ - /o/ai - "/$/ '/ // /2/e?/ - O. o<j O - O/ 2*7,' 7"1700 Axf &***& S'n&f 'fW^d if- OAJ A jfuti <J 0.0 7 "Tt'v- jCoCM . O./O 0. <7 <?. 7/ t/e>efr/dv C-34 0. /9 A 1 0531 7/<bZ. 00.0/ d/9,3 '4. 7/<a> &/ <2. 22 OJZ UCC 009971 > \ * \ Y^j^CS, vr<r**\ v v^> SA^-t- Wj; Kr? ^ ^V -Vi ----r-- a^ Y^V^Vjsc-a^. Aju, ^y^\\) o 2>^ S\ v. ^i) .9\ & n,v- Jfl2^ll<3 rcpt< cx C.90 < & UCC 009972 f ^ f *TV \^.<i Ac>o^ ^ 23HIT33M YT33A2 H3M3*<n :WAM3A03 ~?L\^V SL\^ :M0IT332 E&__ y -> uTL :3TA0 .. -^OT ? x%a\\ . A. v>>xaA xur^T , AW<& & = (538MUH) 33HA0H3TTA HI J3MH02A3<? YJAUOH ________________________________ A~___________________ ____________ * 2TM3MM03 3-ryA^- \^vS>\ ^aV. tvj^^>.wr^N Vaj^va VrtvS^ fovVV.__ s2L sJTY-V Qa^j>y. s Jir-A. -Vrc*-*^- >>!EJuMl\ . aa^!K 15 *kAX3S> i\x\v1^vO\J>aK UbL Vsy\^V.K bi^W .y^ M^lV V^/v>wy^K _____________________________ ____________________ : 030H3MM033J1 H0IT3A 3VIT33flfl03 geao r a UCC 009973 8 UCC 009974 UCC 009975 Stap-By-Stap li * UMOM CAABfDC INTERNAL CORRESPONDENCE RECEIVED APR 10 1S87 P.0 BOX 44, IONAMANDA, NEW YORK 1 TELEX 754632 M. D. Brower - Danbury P-2623 r D. Crowell - Danbury E-3246 Da,e N. A. DiFranco - Somerset \Ea.K. Jensen - Danbury R-46&f`9'natin9 ^ R. S. Kramer - Danbury R-4655 opyto vf. M. Therrien - Danbury R-2676 Subject D. E. White - Tonawanda April 7, 1987 Gas Products Production Vermiculite W. R. Grace's letter of October 11, 1986 alerted us to a potential problem in that vermiculite produced by their Libby Montana mine may contain asbestos fibers. Grace's solution was to wet down the packaged vermiculite to reduce airborne asbestos to levels in compliance with OSHA standards. The solution is not acceptable to Linde in that we cannot tolerate wetted vermiculite as a cold box insulation. A group met in Danbury in January 1987 to discuss the problem and it was agreed that further information was required in order to develop a plan of action. The following summarizes the information that has been developed since that meeting. We have had 39 batch samples taken and tested by National Loss Control Service Corporation (NATLSCO). No asbestos content has been detected by NATLSCO in any of the samples. The vermiculite source at two locations; Wilmington and Pittsburg, California, has been positively identified by W. R. Grace as coming from the Libby mine. It is very likely that some of the other samples cams from here also. With Randy Kramer's assistance, all purchase orders to W. R. Grace for vermiculite dating back to 1983 were collected and transmitted to W. R. Grace with a request to identify the vermiculite source for each one. They reponded within a week and were able to identify some and not others. A copy of Grace's March 19, 1987 letter to Randy is attached. W. R. Grace also forwarded air sampling data collected while handling wetted vermiculite from the Libby mine. This data indicated that they were in conformance with OSHA's July 1986 regulations in all cases. The data really is not significant to Linde as we cannot tolerate wet vermiculite. Grace's March 19 letter also indicates that their South Carolina source is in conformance without wetting. We have also had discussions with other suppliers of vermiculite. Strong-Lite Inc. is a midwest supplier of vermiculite with whom we have done very little business. They have submitted a study of air sampling conducted in 1986 covering their mining, processing and packaging operations,all of which were in compliance with OSHA regulations. Their mine source is also in South Carolina. Two companies supplying vermiculite to the Central region have also responded with test data. J. P. Austin Associates Inc. submitted information on a South African source and Therm-O-Rock Company submitted test data on a Virginia source. None of this information included any asbestos content to be alarmed about. 1180N-48 UCC 009976 A 10563 Vermiculite Page 2. April 7, 1987 Discussions have also been held with testing laboratories and bulk handlers to determine what on-site action would be required if we found an intolerable amount of asbestos in the vermiculite at any location. This now becomes a new ballgame. Most bulk handlers are not equipped to handle asbestos contaminated products. Those that are, such as Specialty Vacuum Inc. of St. Louis, Missouri, have limited capabilities and would handle and bag the insulation with equipment similar to that shown in the attachment. On-site air sampling would be required throughout the operation by a qualified lab such as NATLSCO and their quotation is also attached. It can be seen that this becomes a very expensive and time consuming operation. Nothing that we have uncovered so far indicates the need for any of these special precautions in handling vermiculite. After developing the above information, it is recommended that we proceed as follows: (a) Revise MPS-201, the Material Purchase Specification for vermiculite to include a requirement that every batch be certified free of asbestos. Once revised, this specification should be enforced and the certification kept in a retrievable file if needed for future verification. Material safety Data Sheets (MSDS) should also be requested with each order and kept on file. (b) Instruct all purchasing locations to avoid purchasing vermiculite from W. R. Grace's Libby, Montana source. If W. R. Grace is the chosen vendor, then supply must come from the South Carolina source and be certified to be "asbestos free." This could involve transportation penalties west of the Mississippi which must be evaluated. (c) We should continue to handle vermiculite taking the normal precautions for insulation handling as outlined in the Gas Products production Safety Manual, Section 25. (d) We presently have venaiculite in 93 cold boxes at 35 locations around the country. The vermiculite has come from several sources and in many cases the source cannot be identified. As mentioned previously, we have tested 39 of these boxes without finding evidence of asbestos. This has cost us approximately $2500. The remaining 54 boxes could be tested at an additional cost of $3500. This is not recommended as the data we already have appears to be a good representative sampling and indicative that a field problem does not exist. (e) 1180N-49 We could also hire NATLSCO or a similar laboratory to conduct air sample testing during a typical vermiculite transfer operation. This would cost several thousand dollars, and unless we are aware of asbestos content through prior batch testing, would probably reaffirm that a problem does not exist. This action is not recommended either. , . ^_ A 10564 UCC 009977 <t Veriniculite Page 3. April 7, 1987 (f) In summaryr if we implement and enforce recommendations (a-), (b) and (c) above, this should be sufficient to ensure that we don't purchase any asbestos-contaminated vermiculite and that the vermiculite is handled safely. From information developed to date, the existing cold box insulation does not appear to present a problem of asbestos content, and no further action is recorrmended to confirm this. We would appreciate comments from the recipients of this letter on the recommended course of action. If another meeting of interested parties is required, please advise. J. J. Neitz/jps 1180N-50 UCC 009978 A 1056b n Nausea March 30, 1987 Mr. J.J. Neltz Union Carbide Corporation Linde Division P.O. Box 44 Tonawanda, New York 14151 - 0044 Dear Mr. Neitz: Thank you for your interest in NATLSCO Industrial Hygiene services. It is our pleasure to offer this proposal. If selected for this project, we will have one of our experienced Associate Industrial Hygienists visit your facility to collect air samples while vermiculite is being handled. The study will be conducted by using small, battery operated pumps, appropriate filter media, and other equipment to collect air samples as needed. Subsequent to the visit, the samples will be returned to our Environmental Sciences Laboratory for analysis. The lab is accredited by the American Industrial Hygiene Association. Under normal conditions, NATLSCO's final report would be mailed within 40 days of the last study date. The report would be structured as follows: Introduction Summary of Results R ecommendations Equipment and Study Procedures Discussion Data Tables NATLSCO has a formal Quality Assurance Program. Every report prepared by a NATLSCO field Industrial hygienist Is reviewed prior to mailing by a Manager of Industrial Hygiene, ABIH certified in the comprehensive practice of industrial hygiene. National Loss Control Service Corporation Long Grove. Illinois 60049-0075 (312) 540-2400 TWX (910) 651-3571 Toll Free 800-323-9585 UCC 009979 Mr. J.J. Neltz Union Carbide Corporation Linde Division Page -2- The estimated on-site cost per day for this project is as follows: Visit and Travel Time - 9 hours at $45 per hour Report Time - 2 hours at $45 per hour Laboratory Pees - 10 samples @ $25 per sample $405.00 90.00 250.00 DAILY TOTAL $745.00 The above contains an estimate of the amount of report writing time which is generated by each day in the field. The actual time spent preparing the report would be charged for each project. Likewise, the laboratory fees are based on an estimate of ten samples per day for fiber count using phase contrast microscopy (PCM) as specified in the OSHA standards. If more or fewer samples are collected, the charges will be adjusted accordingly. If "as soon as possible" (ASAP) service is requested, a 50% surcharge will be added to the laboratory fees, bringing the cost per sample to $37.50. In addition, travel expenses will be billed at cost and will depend on the location of the work site. This proposal is valid for 90 days. Work can commence upon receipt of a purchase order or letter of Intent. If you have any questions regarding this proposal, please do not hesitate to contact me. I look forward to hearing from you in the near future. Assistant Manager of Industrial Hygiene Certified/Comprehensive Practice Direct Dial Number: (312) 540-4159 RMM/Jjt 8032H UCC 009980 A 10567 Gary Storr (314)544-2800 4 7 CLS r d, Y I 9403 GRAVOIS AVENUE ST. LOUIS, MISSOURI 63'S3 UCC 009981 t o i.-Oc.ii/tU Ah; i j^j/ J. J. NEITZ March 26, 1987 Mr. Jack Neitz Union Carbide Linde Division P.0. Box 44 Tonawanda, NY 14151--0044 Dear Mr. Neitz: As per your request, I am writing to introduce you to our company. We have been commercial and industrial vacuum contractors for the past eight years. Some of our equipment is equipped with the necessary air filtration for us to vacuum asbestos containing material. I understand that some of your plants may contain a granular pipe insulation which contains some asbestos. In the event that you need to remove this ma terial, we would be happy to offer you a proposal to perform this work. Enclosed please find a copy of our brochure, which explains our equipment and the services that we perform. When you have further questions regarding how we can aid you, please call me. We look forward to serving you. Sincerely, encl. [anager 9403 Gravois Rd. St Louis, MO 63123 (314) 544-2800 UCC 009982 M ~~[e; %c-Y~y^^z- GRACE Construction Products Division W.R. Groce & Co. 62 Whittemore Avenue Cambridge, Moss. 02M0 (617) 876-1400 March 19, 1987 APR - f pj,j/ J. J. NEITZ Mr. R. S. Kramer National Materials Manager Union Carbide Corporation Linde Division 39 Old Ridgebury Road Danbury, CT 06817-0001 Dear Mr. Kramer: This is a response to your memo to me dated March 12, 1987. As you requested, we have reviewed the purchase orders you sent to identify whether the products were made from Enoree, South Carolina or Libby, Montana ore concentrate. Hand-written notations were made on sixteen of the twentyeight orders where the mine source could be identified; the balance (twelve) are labelled "unknown". A response to your request for air sampling data is also enclosed. This information demonstrates the conformance of dampened Grace (Libby) expanded industrial vermiculite to OSHA regulations which became effective in July 1986. Our dry expanded vermiculite is produced from Enoree, South Carolina concentrate and meets OSHA regulations without dampening. Please call if I can help with any other items. PMK:mg Paul M. Keeffe Marketing & Sales Manager UCC 009983 c