Document rpGZwDmeEmpeZnZjVZgw7rEpG

UNION CARBIDE CORPORATION Specialty Chemical Division Wi/'O y ~r "r 'ff't Pc i Sistersville, WV Orvu MEMORANDUM TO: F. E. Dai1ey J. E. Bo ley E. L. Doerflein J. K. Kyle K. B. Purinton A. J. Vandenberg COPY TO: D. G. Beddow K. F,, Carroll L. W. Phair w. V. Summers DATE: May 7 , 1987 SUBJECT: Future Asbestos Disposal Site(s) ^ to l U ^ d) Our present asbestos disposal landfill is approaching the end of it's life unless we apply some possible options or, move elsewhere. We are O.K. for the immediate future, but it is time to prepare a new game plan. For this purpose please plan to meet in the Maintenance Conference Room, Building 33 (Area III Shop) on May 26, 1987 at 1 PM. It is important that we develope a plan.1 If there is a problem with this date, please let me know. GWW/bah yfj iO. a. ) t~~ G. W. Wulfert /' ^ UCC 007057 o* /- ' ' .-d, <6X_ * it *1c * ** t UNION * *. CARBIDE * it it ** INTERNAL CORRESPONDENCE n SPECIALTY CHEMICALS DIVISION Bldg. 82-902 South Charleston, WV 25303 TO: FROM: CC: Attached Distribution List C. R. Rotthoff Attached Dlstrlbuton List DATE: ORIG. DEPT: SUBJECT: March 3, 1987 HS&EA Personnel Safety & Occupational Health Asbestos Management HS&EA's guidance on Asbestos Management for the Specialty Chemicals Division Is: 1) Complete encapsulation of servlcable asbestos Insulation Is a / long term, viable and legitimate option (See Attachment A). 2) Damaged asbestos Insulation should be replaced with non-asbestos containing materials. 3) Should complete removal of asbestos materials prove to be a viable economic approach. It should be undertaken In a planned program in strict accordance with existing regulations which have recently been revised and which, In-part, Include these significant requirements. o Use of negative pressure enclosures during asbestos removal (See Attachment B). o Disposal of asbestos containing materials In a suitable waste landfill. ' o Labeling of asbestos waste containers (boxes, drums, bags, etc.) o Proper personnel protective equipment and the asbestos removal notification requirements must be fulfilled as before. This correspondence provides the direction on two key asbestos Issues - encapsulation and negative pressure enclosures. Attachments A, B & C are Included with tuts cnrresjmnrloepp hor-Hn-p they pPm/iHe the haAKflfQUnd InfOTmatlon which irTmportant to the nnderctanrilnq of the guidance provided for AsbeTtOS Management: Your~full understanding and arrepjbanrg of tbF~~ guidance is necessary. Please contact me as needed (304) 747-2397 or 8* ----------------------------------------------------------- ----------------------------------------------------------------------------- ------------------------------------- ------------ Sincerely, CRR/rhw 2968K (3/04/87) Attachments UCC 007057A UNION CARBIDE CORPORATION CHEMICALS & PLASTICS GROUP HEALTH, SAFETY & ENVIRONMENTAL AFFAIRS P-2 MS ATTACHMf ENT "A" 39 OLD RID6EBURY ROAD DANBURY, CT 06817-0001 TO: D. Llebesklnd DATE: March 3, 1987 COPY: Dave, R. E. Bollinger D. R. Crowell C. R. Rotthoff B. L. White SUBJECT: Encapsulation of Asbestos This Is In response to your request for guidance on the likelihood that an Agency would sometime In the future mandate the removal of asbestos or asbestos-containing products from the workplace. You noted the Importance of this issue In view of the resources that you plan to expend to encapsulate asbestos Insulation In your facility. The response below reflects C&P HS!tEA*s view, with the concurrence of Don Crowell and Betty Lynn White. Recently I had the opportunity to meet Mr. Charles Adkins, Director of Health Standards Programs for OSHA, and was able to discuss this Issue with him. While Mr. Adkins gave the expected caveat of "not being able to give total assurances as to what the Agency will or won't do years from now....," he firmly stated that he could not contemplate OSHA's ever requiring removal of In-place asbestos Insulation. He noted that that activity would In fact create a greater hazard than merely leaving the Insulation In-place. He further stated that OSHA's role in asbestos removal would be limited to setting standards when asbestos was to be removed based on other considerations. You are, of course, aware that EPA also gets Into the "asbestos business". The Asbestos Hazard Emergency Response Act of 1986 gives EPA authority to regulate containment and removal of asbestos In school buildings, and some Interests are pushing for expansion to commercial buildings. EPA Is also considering banning the use of asbestos In certain commercial products. While these possible actions do not apply to the (chemical) workplace, these are some circumstances in which EPA could. In the absence of an OSHA response to a hazardous situation In the workplace, take action. This, however, would appear to be highly unlikely here. Accordingly, there would appear to be no reason not to proceed with your encapsulation program. Sincerely, REP/pjm 0576Y 2957K, Wang received 3/3/87 R. E. Plevan UCC 007057B f UNION CARBIDE CORPORATION Ol O RiDGfBURY RO*D DANBURY CONN 06SI 1 LAW DEPARTMENT ATTACHMENT "B January 27, 1987 To: From: C. R. Rotthoff D. R. Crowell II Re: Use of Negative Pressure Enclosures for Asbestos Operations After our telephone conversation yesterday, 1 spoke with Bob Ondocsin about the two issues you has raised, i.e., whether a negative pressure enclosure must always be used for reapplication of mastic to asbestos covered containers and whether a negative pressure enclosure is required where the use of wetting techniques reduces airborne concentrations below the action level of 0.1 fiber per cubic meter. The clear intent expressed by OSHA has been that if asbestos is involved, there is a heavy burden on the employer to demonstrate the standard's inapplicability. With respect to the second issue, Bob agreed that his understanding of OSHA's position was that reductions below the action level by the use of wetting techniques or other procedures does not exempt such situations from the coverage of the asbestos standard. Similarly, the first issue raises a presumption of the applicability of the standard's provisions for engineering controls. It is my understanding that the specific operation you had in mind was the application of mastic over existing mastic that encapsulates asbestos insulation on process vessels and pipelines. While the specific operation involved may have far less probability of resulting in impermissible airborne concentrations of asbestos than would other types of repair work, very detailed monitoring data will be required to demonstrate that the application of new mastic to repair cracks in the old mastic does not result in the action level being exceeded. Unless monitoring demonstrates that the action level will not be acceded, engineering and administrative controls will be required for such operations, i.e., negative pressure enclosures and the associated decontamination areas, or for small jobs, glove bags. UCC 007057C OSHA has reiterated in public forums the breadth of coverage stated in the Preamble to the standard, i.e., all "occupational exposures." Bob's memorandum and attachments of January 15, 1987 (copy attached) reflect OSHA's intention to broadly interpret the standard's coverage and strictly apply its protective provisions. These facts, coupled with the well-documented and well-recognized hazards associated with asbestos dictate that any determination that the standard is inapplicable be carefully scrutinized and scrupulously documented. DRC/ce Enclosure N. E. Bolton S. E. Hine M. G. Manetti R. D. Ondocsin B. L. White 2- - UCC 007057D *** * ** UNION *,, * CARBIDE INTERNAL AMAUIMtNI "L" FILE . OlHA AfrUrTel CORRESPONDENCE CHEMICALS AND PLASTICS GROUP HEALTH, SAFETY & ENVIRONMENTAL AFFAIRS P-2 39 Old Ridgebury Road Danbury, CT 06817-0001 TO: SEE ATTACHED DISTRIBUTION LIST DATE: January IS, 1987 COPY: SEE ATTACHED DISTRIBUTION LIST SUBJECT: ASBESTOS STANDARD Below are clarifications of OSHA's Construction Asbestos Standard which were made by officials from OSHA's Office of Health Compliance Assistance at ORC's Asbestos Task Force Meeting on January 14, 1987. In addition to this communication, I am sending out immediately via Express Mail two letters of interpretation signed by John Miles, Director of Field Operations. Unfortunately, the Field Compliance Instruction is still not available from OSHA but it was said to be in typing now and will distributed to OSHA field offices very soon (within two weeks) for last minute comments. As soon as it becomes available, I will forward it to you. Three OSHA officials, Dave Smith, Joe Hopkins (primary spokesman) and Ray Gibbs provided the clarifications below: 1. Scope - The General Industry Standard covers primary and secondary producers of asbestos products, shipbuilding and automotive clutch and brake repair. All other activities are covered by the construction standard. 2. Negative Pressure Enclosures - Such enclosures are to be used on all removal, demolition or renovation operations where it is physically possible to establish them and which do not qualify as short duration, small scale operations. Inability or impracticality of enclosing structures within a single enclosure does not by itself mean that enclosures are infeasible. In such a case, the feasibility of several smaller enclosures must be considered. If it is physically possible to establish the smaller enclosures, then they are to be constructed and the removal is to be done section by section. Hazards created by the presence of negative pressure enclosures can be taken into consideration in determining feasibility. 089 4E JAN 15 1987 ft ft Cffowai UCC 007057E 2 3. Short Duration Task - Definition of such tasks by length of time or amount of material were totally avoided by OSHA. Rather, maintenance activities (as opposed to removal operations) which can be controlled by employee isolation (such as glove bags) or wet methods are called short duration tasks. Note: if the short duration, small scale exemption from negative pressure enclosures is claimed, the requirements of Appendix G must be followed. 4. Hygiene Facilities - Decontamination areas are to be located adjacent to regulated areas where feasible. As with negative pressure enclosures, feasibility is interpreted to mean physical feasibility. The use of commercially available movable trailers which provide the decontamination area should be considered as an option. Each employee must follow the decontamination area exit prorp^Mrac--?a/-h Mme he leaves the regulated a&&a-^jreqardless of the time he spent in the area. This includes lunches and breaks. 5. Labels - The labelling requirements are primarily intended to apply to new products. Use of the prescribed label wording will not be required by OSHA on previously installed asbestos. Some sort of identification system such as color coded tags or signs, which identifies the material as asbestos, will meet the intent of the standard by alerting employees to the presence of asbestos. Employees need to be trained to recognize and understand such an identification system. 6. Medical Surveillance - Annual requirement may be discontinued for one-time exposures under certain conditions. OSHA letter of interpretation will explain more fully. 7. Competent Person - A specific number of days of training is not required but training content should be equivalent to the referenced EPA course. A Competent Person may delegate responsibilites but he must be the lead contact and retains ultimate responsibility. I am hopeful that this telex together with the letters being sent via Express Mail which you should receive Friday morning will provide the additional clarification that you will need. Nevertheless, there will still probably be further detailed questions that you may have after you read this information. I will be in the office all day Friday, January 16 and through noon on Monday, Januray 19. Please call me on extension 5265 with further questions or to discuss any of the above information.. RDO:jmc Attachments 08 94E Robert D. Ondocsin UCC 007057F MATERIAL SAFETY DATA SHEET ( IDENTITY (As Used on Label and List) Asbestos and:Rubber#binder 'sheet and roll ^ NOTE: Blank, spaces are not permittmv Ijf any item is not applicable ot^'fio information is available, the space must be marked to indicate that. SECTION I Distributed By Mar-ur a c turer^s Name Cincinnati Gasket Address (Number, Street, and ZIP Code) 40 Illinois Avenue City, State* Cincinnati (Reading), Ohio 45215 Emergency Telephone Number 761-3458 Telephone Number for Information 761-3458 Date Prepared April 23, 1986 Signature of Preparar (optional) 6SECTION II - Hazardous Ingredients/Identity Information Hazardous Components (Specific Chemical Identity, Common Name(s)) Other Limits ____________________________ OSHA PEL_________ ACGIH TLV__________ Recommended %(optional) Asbestos (Chrysotile) ,2 fibres/cc_____ .2 fibres/cc_______. 1 fibre/cc (each fibre to be 5 micrometers or longer) SECTION III - Physical/Chemical Characteristics Boiling Point Vapor Pressure (mm Hg.) Vapor Density (AIR * i) j N/A j N/A N/A Specific Gravity (^0 = I) Melting Point Evaporation Rate (Butyl Acetate =1) N/A N/A N/A Solubility in Water insoluble Appearance and Odor _______ '~ light or dark colored depending upon binder -- no odor SECTION IV - Fire and Explosion Hazard Data Flash Point (Method Used) Flammable Limits LEL UEL N/A non-flammable N/A N/A Extinguishing Media use media suitable for type of surrounding fire Special Fire Fighting Procedures Unusual Fire and Explosion Hazards none UCC 007057G SECTION V - Reactivity Data c Stability [ Unstable Stable Incompatibility (Materials to Avoid) Hazardous Decomposition or Byproducts Hazardous May Occur Will not Occur X SECTION VI - Health Hazard Data Route(s) of Entry: Inhalation? Health Hazards (Acute and Chronic) Conditions to Avoid none none Conditions to Avoid none Skin? Ingestion? ... Acu-^-----skin irritation, respiratory irritation ^ nf *she*rnc generally h,,t Chronic: respiratory cancer, asbestosis] not in this form Carcinogenicity:NIP? ygs IAE.C Monographs? yesOS HA Regulated? y Applies to asbestos not to this product Signs and Symptoms of Exposure Medical Conditions Generally Aggravated by Exposurerespiratory diseases if airborne concentra- ( Emergency and First Aid Procedures tions are high N/A to this product SECTION VII - Precautions for Safe Handling and Use Steps to Be Taken in Case Material is Released or Spilled no special requirements Waste Disposal Method normal land fill Precautions to Be Taken in Handling and Storing N/A to this product Other Precautions no special requirements SECTION III - Control Measures Respiratory Protection (Specify Type) no special requirements Ventilation Local Exnaustno Specia^ requirements Special Mechanical (Ggge^kai requirements Other ___ Protective Gloves Eye Protection Other Protective Clothing or Equipment no special requirements ( ""k/Hygienlc Practices ,,,, speclal requlrMW>t. NOTE: The information provided herein is accurate to the best of our knowledge, but no warranty, express or implied(is made. UCC 007057H s U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration MATERIAL SAFETY DATA SHEET Form Approved OMB No. 44-ft 13fl7 Required under USOL Safety and Health Regulations for Ship Repairing. Shipbuilding, and Shipbreaking (29 CFR 1915, 1916, 1917) manufacturer's NAME SECTION 1 (Distributed by) EMERGENCY TELEPHONE NO. Various (Cincinnati Gasket Pkg. & Mfg., Inc.) (513) 761-3458 AOORESS (Number, Street. City, Srate, and ZIP Code) 40 Illinois Ave. Cincinnati, OR 45215 CHEMICAL name and synonyms j TRADE NAME AND SYNONYMS [asbestos & rubber binder sheet & r CHEMICAL FAMILY FORMULA --* SECTION II HAZARDOUS INGREDIENTS PAINTS. PRESERVATIVES, & SOLVENTS % TLV (Units! ALLOYS AND METALLIC COATINGS PIGMENTS N/A BASE METAL CATALYST N/A ALLOYS . VEHICLE SOLVENTS ADDITIVES OTHERS N/A N/A N/A N/A METALLIC COATINGS FILLER METAL PLUS COATING OR CORE FLUX OTHERS HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS, OR GASES Various amounts of asbestos fibers are encapsulated bv rubber binders. .These materials do not come under the definition of a hazardous material, having none of the seven characteristics which define a hazardous material. TLV % (Units) N/A N/A N/A N/A N/A TLV % (Units) .... SOILING POINT (F.) VAPOR PRESSURE (mm Hg.) VAPOR DENSITY (Alfl=l) SOLUBILITY IN WATER APPEARANCE ANO ODOR SECTION HI - PHYSICAL DATA N/A N/A N/A SPECIFIC GRAVITY (H.jO=l) PERCENT, VOLATILE BY VOLUME EVAPORATION RATE ( N/A N/A N/A N/A SECTION IV - FIRE AND EXPLOSION HAZARD DATA FLASH POINT (Method used) N/A FLAMMABLE LIMITS , N/A Lei EXTINGUISHING MEDIA water, foam, carbon dioxide, dry chemical SPECIAL FIRE FIGHTING PROCEDURES when fire involves large qunatities of product Uel self contained breathing apparatus would be desirable UNUSUAL FIRE AND EXPLOSION HAZARDS thick smoke produced PAGE (1) (Continued on reverse side) UCC 007057I Form OSHA-20 Rev. M? *** THRESHOLD LIMIT VALUE EFFECTS OF OVEREXPOSURE SECTION V HEALTH HAZARD DATA N/A N/A EMERGENCY1 AND FIRST AID PROCEDURES N/A STABILITY UNSTABLE SECTION VI - REACTIVITY DATA CONDITIONS TO AVOID STABLE INCOMPATABILITY (Materials to avoid) HAZARDOUS DECOMPOSITION products N/A JN/A HAZARDOUS POLYMERIZATION MAY OCCUR WILL NOT OCCUR - X CONDITIONS TO AVOID SECTION VII - SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED N/A WASTE OISPOSAL METHOD standard land fill ____ . SECTION VIII - SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (Specify type) VENTILATION LOCAL EXHAUST mechanical (General) PROTECTIVE GLOVES OTHER PROTECTIVE EQUIPMENT N/A N/A N/A N/A special N/A OTHER EYE PROTECTION N/A N/A N/A SECTION IX - SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN IN HANDLING AND 5TORING N/A OTHER PRECAUTIONS N/A FIRST AIO TREATMENT! SKIN CONTACT EYE CONTACT SECTION V - SUPPLEMENT INHALATION ANTIDOTE AND TREATMENT FOR SWALLOWING UCC 007057J