Document re4amvvqeExa2zzJBzLRookZa

SM 3? (P.-v V i/J SHELL OIL C 10[irttnu I oztifi ' ENVIRONMENTAL date NOVEMBER 21, 1978 SEE DISTRIBUTIONS SI_ it,TV 2 . /?!/ IMtti 7 RETURN TO EVC FILE COPY IN EVC FILE FOR EVC INFO ONLY fROM MANAGER - MANUFACTURING ENVIRONMENTAL CONSERVATION HEAD OFFICE subject EpA REGUlaTI0NS - ASBESTOS (H) HANDLING As a result of the recent Environmental Review program, it was learned that there are differences in interpretation of the EPA's Hazardous Emission Standard for Asbestos as it relates to demolition and renovation (40 CFR Part 61). This regulation has been revised a number of times since its original promulgation in 1973, generally, to increase the scope of covered operations. In reviewing this regulation, we have concluded that only the very small renovation and demolition operations were intended to be excluded from the requirements. With this in mind, and to have a uniform procedure, we suggest that the following definitions and procedures be used when it is necessary to handle asbestos insulation removal. A "Planned Renovation" should include all those items of routine maintenance which require removal of asbestos. This would include those operations which can be predicted to occur in a given period of time (normally one year). It is suggested that an estimate, based on experience, be made of the amount of insulation to be removed during routine maintenance for a period of one-year. If this amount meets the quantity criteria of part 61.22d, then the notification requirements of the regulations will apply. An "Emergency Renovation" should be any operation which requires the removal of asbestos insulation as a result of sudden unexpected event such as fire, explosion or major equipment failure. If an event of this type results in the need to remove more than the minimum quantities (61.22d) of asbestos, the reporting requirements would apply - separate from those reported under the "Planned Renovation." A "Demo!ition" operation is one that requires the removal of load bearing structures and generally occurs only when units are being significantly altered or physically removed. If the quantity of asbestos to be removed exceeds the minimum quantity (61.22d) the reporting requirements would again apply - separate from those reported under "Planned Renovation" or "Emergency Renovation." Although it appears that the removal and disposal procedures prescribed by 61.22d(4) and 61.22(j), respectively, would not be applicable to those operations which do not meet the minimum quantity requirements we believe that company policy dictates they should be followed in all cases. LAM 016921 DPMC-10664 2 The prescribed removal procedures are likely to be no more than must be done to comply with OSHA requirements. The disposal requirements should be met to insure that the public is not exposed to asbestos fibers. You will note that, for those locations which do not have access to an approved landfill, the Clean Air Act regulations do permit operation of your own such facility provided it meets State requirements for solid waste handling. If you have any questions regarding specific requirements of the regulation, please contact J. A. Mullins. A. G. Smith LAM 016922 DPMC-10665 DISTRIBUTION LIST ENVIRONMENTAL CONSERVATION SUPERINTENDENT, DEER PARK MANUFACTURING COMPLEX ^"^Tcopy for (-<&& NORCO MANUFACTURING COMPLEX ' 1------------- ~~ MANAGER ENVIRONMENTAL CONSERVATION MARTINEZ MANUFACTURING COMPLEX WILMINGTON MANUFACTURING COMPLEX ANACORTES REFINERY SUPERINTENDENT OPERATIONS CINIZA REFINERY MANAGER OPERATIONS ODESSA REFINERY MANAGER QUALITY CONTROL WOOD RIVER REFINERY TECHNICAL MANAGER DENVER CHEMICAL PLANT PRINCETON CHEMICAL PLANT WOODBURY CHEMICAL PLANT MANAGER - HEALTH, SAFETY & ENVIRONMENT GEISMAR CHEMICAL PLANT MARIETTA CHEMICAL PLANT MOBILE CHEMICAL PLANT CHEMICAL PLANT MANAGERS EL PASO CHEMICAL PLANT TAFT CHEMICAL PLANT lam 016923 DPMC-10666