Document wgZnE9RaLNDBOQMB0BvgKQ1e6

UNION CARBIDE CORPORATION Specialty Chemicals Division Sistersvilie, WV February 6, 1987 MEMO TO: D. G. Beddow K. F. Carroll L. W. Phair COPY TO: E. L. Doerflein R. A. Hazelwood D. Liebeskind C. Rotthoff A. Walker G W. Wulfert SUBJECT: Asbestos Removal Strategy Please find attached a brief on the strategy and resources to meet the newly required OSHA asbestos handling guidelines. Particularly noteworthy are: * Additional resources approaching $350,000/year. * Major insulation craft productivity loss. * Use of encapsulation techniques without negative air systems. Please be prepared to review at our next managers' meeting. WVS/jec Attachment 2382A UCC 007044 SISTERSVILLE PLANT ASBESTOS STRATEGY 1. Plant will meet the OSHA intent for additional personnel protection. 2. Industrial hygiene will monitor asbestos procedures and methods to ensure exposure levels are below 0.1 F/CC or that work procedures are commensurate for levels in excess of 0.1 F/CC. 3. Asbestos monitoring will be done within the Sistersville plant laboratory to facilitiate maintenance productivity. 4. A decision process by maintenance management will be used in selecting the proper procedure to remove asbestos. A. Emergency jobs (spill, leak, fire hazard or other imminent safety and/or environmental threat). * Wetting is appropriate for emergency removal in conjunction with required breathing/filter devices. B. Routine, short duration jobs. * Utilize glovebag technique which includes vacuum and wetting techniques. * It is appropriate to move bag along the pipe. C. Encapsulation of asbestos. * Use of lag-seal or other encapsulant is appropriate without negative air system. * I/H samples should be taken to confirm past exposure profile and history of less than 0.1 F/CC. D. Major asbestos removal (indoor or outdoor) * The negative air technique is to be employed. All other means of the new OSHA guidelines will be adhered to (decontamination facilities, shower, clean room, etc.). 5. Resources required to meet OSHA guidelines. Materials: * Stock glove bags * G. B. vacuum unit * Stock lag seal encapsulant * Purchase decontamination trailer * Laboratory analytical equipment * Negative air vacuum/HEVA filtration units * 2000/1000 CFM unit * 600 CFM unit * New respirators * Scaffolding/misc supplies $ 3,000 $ 2,500 $ 2,000 $ 25,000 $ 10,000 6,000 $ 1,000 10,000 S 61,500 UCC 007045 Sistersville Plant Asbestos strategy. Continued Personnel * One additional lab technician * Four insulators to offset productivity loss * Contractor for tent building/scaffolding $ 50,000 $160,000 $100,000 $310,000 Above requirements are unbudgeted items and will require budget overrun exceptions. 6. Other Considerations * Consider use of contractor for all major asbestos removal jobs. Utilize maintenance for application of insulation and small removal jobs. * Address/compare other locations strategy at next maintenance managers meeting. * Modify scope of asbestos insulation project ($2.1MM) to: * Contract encapsulation of all exposed asbestos within the plant. * Identify by marking all asbestos insulation. f * Upgrade/removal asbestos as necessary. * Project should receive priority approval. '^ * Company needs to take position on whether to: 1. Upgrade/encapsulate/remove asbestos insulation, or 2. Totally remove from plant. I believe that in the next 5-7 years the government will legislate removal from the workplace. All future upgrade projects should be aimed at Total Removal. * Implement plant wide asbestos removal training program. wvs 2 3 8 2A UCC 007046 DRAFT ASBESTOS C0WTA1HIN6 MATERIAL ~ REMOVAL AND DISPOSAL Purpose: Establish requirements for the removal, cleanup and disposal of meterielscontaining asbestos. Introduction: This procedure is written to ensure compliance with all applicable OSHA and Union Carbide Corporation's Requirements and Regulations. Compliance with this procedure will ensure proper handling and preparation of asbestos containing materials for removal and disposal in such manner as to prevent unnecessary exposures of employees to asbestos fibers. Definition: For the purpose of this procedure, asbestos shall be defined os any material that contains chrysotile, omosite, crocidolite, tremolite, anthophyllite, and octinolite asbestos. Competent person, means on employee who has a responsibility to oversee the project involving the asbestos abatement to ensure the work is carried out in compliance with the requirements of the OSHA standard. This individual shall have training in all aspects of asbestos abatement. Such training shall be obtained in a comprehensive course such os conducted by on EPA Asbestos Training Center. Regulated area means an area where airborne concentrations of asbestos can reasonably expected to exceed the permissible exposure limit. Exposure limits: Permissible Exposure Limit (Based on on eight-hour time-weighted average (TWAg)) 0.2 fiber/cc of air Action Level Exposure Limit (TWA8) 0.1 fiber/cc of air 1- UCC 007047 General Requirements: 1. Street cloths shall not be worn by employees involved in the asbestos abatement projects. 2. Two sets of coveralls shall be worn by all employees involved in the asbestos abatement project. 3. The outer set of coveralls shall be disposable type and the inner set of coveralls shall be either disposable or reusable type. 4. The inner set of coveralls shall be made of such suitable material that keeps the employee warm in the winter end relatively cool in the hot work environments. 5. If inner set of coveralls are reusable type they shall be washed at the end of the work day. 6. Disposable head covering shall be worn at ell times while in the regulated area. Disposable coveralls equipped with hood are acceptable with provision for elastic in the arm sleeves and pant legs. 7. Disposable overshoes or rubber boots shall be used at all time in the regulated area. Disposable overshoes shell be removed when going outside of the regulated area. If rubber boots are used they shall be washed and cleaned before going outside of the regulated area. 8. Rubber gloves shall be used while conducting asbestos abatement project. Gloves will be disposed off at the end of the work day. 9. Respiratory protective equipment shall be worn by all employees in the regulated area. 10. Full face supplied air respirator in a positive pressure mutis Shan be used in all asbestos abatement projects, except, high efficiency particulate air (HEPA) filter negative pressure respirator shall be used when employees ore being monitored for exposure to asbestos by the Industrial Hygiene Department or when using glove bag technique for exposure control. 2- - UCC 007048 11. All mojor asbestos abatement projects will require a detailed project review by the Technical Center Industrial Hygienist. 12. Regulated area shell be demarcated in ell asbestos abatement projects. The following types of regulated areas shall be considered for each job. Negative Pressure Enclosure: As the name suggest this system maintains negative pressure within the enclosed work area compered with that of the outside environment. The negotive pressure inside the enclosure shell be achieved by means of HEPA-filtered power exhaust unit. The enclosure shell be fabricated with 6-mil polyethylene plastic end lumber or other material for support where the existing walls ore not avoilable. All openings inside the negotive pressure enclosure shall be sealed with 6-mil polyethylene plastic and tope to prevent airborne asbestos from escaping into areas outside of the work area. Openings that require sealing are typically found around electric conduits, telephone wires, water supply and drain pipes, air supply and exhaust ducts. Blove Bag Enclosure: Small scale jobs shall be conducted using the glove beg technique. Glove bogs are fitted with arms through which the work can be performed. It allows workers isolation from the asbestos containing material being removed inside the glove bog. The bogs shall be made of transparent 7-mil thick polyethylene plastic fitted with arms equipped with rubber gloves. The glove bags shall have a tool pouch and a port for introducing spray nozzel and vacuum hose. These bogs shall be considered as single use control device and disposed of at the end of eoch job. 3- UCC 007049 The glove bag shall be installed in such a manner that they completely cover pipe or the other structure where asbestos removal work is to be done. All openings in the beg must be sealed using the duct tape. A minimum protective equipment required while using the glove bag for asbestos abatement is single disposable body coverall, head cover, HEPA filter negative pressure respirator, and disposable shoe covers or rubber boots. Sufficient warning signs shall be posted around the regulated area to warn all employees of the asbestos hazard. The sign and the regulated area shall remain in place until the job is completed. The warning sign shall read: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA Employees shall not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in the restricted area. Access to regulated areas shall be limited to authorized fully protected persons. High-speed abrasive disc saws that are not equipped with appropriate engineering contols shall not be used for work related to asbestos. Compressed air shell not be used to remove asbestos unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air. Wetting the asbestos material shall be achieved by using amended water or formulated wetting agents to reduce the number of fibers from becoming airborne. - A- UCC 007050 19. Any residue that remains on the surface of the object from which asbestos is being removed shall be cleaned by wet method or by HEPA equipped vacuum cleaner. 20. Asbestos material shall be removed and placed directly into a prelabeled bag for proper disposal in accordance with the location Environmental Protection disposal procedures. The label shall contain the following information: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUN6 DISEASE HAZARD 21. Disposable coveralls, polyethylene plastic enclosure material, filters used on negative pressure exhauster shall be disposed of in the same manner as the asbestos material. Respirator shall be worn at all times during the cleaning and disposal procedure. 22. Before leaving the regulated area for luch, breaks, or at the end of the work day employees shall clean the outer coverall with HEPA equipped vacuum cleaner and wet clean the rubber shoes. The outer coveralls including head cover and shoe covers, if used, shall be placed in the asbestos disposal bag. 23. Employees shall wash their hands and face in a clean facility before lunch or coffee breaks. 24. Employees shall take shover before putting on their street cloths and leaving the plant premises. Responsibility of Craft supervisor or suprintendent: a. consult with the owner of the piping or equipment from which the insulation is to be removed to determine if the insulation contains asbestos. 5 UCC 007051 if it can not be determined that the insulation material contains asbestos, the responsible craft supervisor or suprintendent shall provide a sample of the material for analysis to the Technical Center Industrial Hygiene Department. any job involving the demolition of any structural member containing friable asbestos material or any job involving the removol of at least 160 sqare feet or atleast 260 linear feet of insulation shall notify the location Environmental Protection Department for approval prior to the start of the job. notify the Technical Center Industrial Hygienist at extension 3750, the intention of removal of the asbestos containing insulation. if needed, set up an inspection and planning review with the Industrial Hygienist for determining procedure to be used for removal of asbestos insulation. fill out a supervisors report (attachment I) for asbestos insulation removal and disposal, send the report to Industrial Hygienist for each day the work is performed for asbestos removol. insure a competent person shall be available to oversee the project through completion. insure that all employees including laborers, involved in the asbestos abatement work, have been provided: i. asbestos training by the Technical Center Industrial Hygiene Department within lost twelve months, ii. training in the use of respiratory protective equipment which includes fit test, proper use, care, and limitations of the equipment. If employees are required to use High Efficiency Particulate Air (HEPA) filter negative pressure respirator, the training must have been done within the last six months, iii. medical examination within lost twelve months. 6- - UCC 007052 i. notify Industrial Hygiene, Medical and Safety Departments when an employee is added or deleted from use in the asbestos abatement project. j. provide a list of employees, used in the asbestos abatement projects, to Industrial Hygiene department for verifying compliance with the OSHA requirements. The list shall contain the dates of Industrial Hygiene training, respiratory protection training, end medical surveillance. k. when industrial hygiene exposure monitoring is conducted, the results shall be communicated to affected employees and written documentation shall be obtained by having employees to sign the report. The signed report shall be returned to Technical Center Industrial Hygienist Building 701, room 330. l. plan end provide necessary personal protective equipment end other supplies specified in the general requirement section of this procedure to ensure satisfactory completion of the work. RESPONSIBILITY OF COMPETENT PERSON: a. ensure the integrity of the enclosure b. control entry to and exit from the enclosure c. supervise employees being monitored by Industrial Hygiene Department d. ensure the use of protective clothing and equipment e. ensure that employees ore trained in the use of engineering controls, work practices, and personal protective equipment f. ensure the use of hygiene facilities and the observance of proper decontamination procedures g. ensure that engineering controls are functioning properly h. ensure that unauthorized personnel do not enter the restricted area 7- UCC 007053 i. ensure that the asbestos waste is properly disposed j. ensure that the supervisor's report is sent to Technical Center Industrial Hygienist. RESPONSIBILITY OF INDUSTRIAL HYGIENE DEPARTMENT: Help management stay in compliance with the regulatory requirements by providing: a. technical assistance b. employee's training c. recommendations for personal protective equipment d. recommendoti ons for procedures e. recommendations for equipment used for asbestos abatement f. exposure monitoring of employees g. repository of records for documentation of compliance h. liaison to other location Industrial Hygiene personnel RESPONSIBILITY OF SAFETY DEPARTMENT: a. provide respiratory protection training b. provide personal protective equipment c. maintain training records 8 UCC 007054 RESPONSIBILITY OF MEDICAL DEPARTMENT: A. provide medical clearance for respiratory fit test for employees involved in the asbestos abatement project. B. provide medical surveillance to employees in accordance with the requirements of the OSHA standard 29 CFR 1926.58 which shall include: a. initial employee's questionnaire end medical examination b. annual employee's questionnaire and medical examination 9- UCC 007055 ASBESTOS INSOLATION REMOVAL AND DISPOSAL CONSTRUCTION/SERVICES DEPARTMENT SUPERVISOR'S REPORT (LOCATION OF JOB:} PLANT: AREA:________ ZONE:________ BLOG:________ UNIT: JOB SUPERVISOR_______ ________________DATE JOB PERFORMED: _ DESCRIPTION OF JOB: -...................................................................................................................................... LOCATION ASBESTOS INSULATION DISPOSED: .................... ........................................................................... ESTIMATED FEET REMOVED: LINEAL FEET SQUARE FEET EMPLOYEES INVOLVED IN ACTUAL JOB(S): .................................... _________ Plant 511 Hygienist notified (M. A. Patel - ext. 3750) Negative pressure enclosure feasible? Negative pressure enclosure installed? Use of Glove 8ag feasible? Glove Bag used? Barrier tape used Warning signs used Protective clothing used - boots, head cover, gloves, coveralls Outer coverall vacuumed before removing Outer coverall removed before leaving barricaded area Plastic used on floor and over equipment Area vacuumed Employee showered before reapplying street clothes Proper clean-up (area housekeeping) Barricades down (after clean-up only) Employee(s) monitored by Industrial Hygiene Type of respirator used: Half-face AO R57-A (HEPA) Half-face Willson R-12 (HEPA) Supplied Air-Full Face - Positive Pressure Employee trained for respirator in last 6 months (If not using Supplied Air - Positive Pressure) Employee trained for OSHA Asbestos Standard in last 12 months COMMENTS: YES _____ _ __ ____ ____ ___ ___ ___ ___ ___ __ ___ ___ ___ ___ NO ___ __ __ _____ ___ ____ ___ __ ____ __ ____ ___ __ ___ N/A .' ~ ' __ __ ___ ____ ___ ___ __ _ ___ ___ ___ _____ ___ ___ ___ ___ ___ ___________ (Form Filed By:) Return filled out form (original) after completion of the job to: M. A. Patel - Bldg. 701/330 Telephone :____________________________ 1791P UCC 007056