Document wqGdpoNODao9nEDrbgRvZDyOB

From L. L. RIPPEY PITTSBURGH OFFICE - 6 To J. L. DIEDERICH PITTSBURGH OFFICE -29 1989 APRIL 18 RE: PLANT ASBESTOS PROGRAMS - METALS & CHEMICALS With the recent interest in Alcoa location's compliance with existing asbestos rules as well as the interest in positioning ourselves for the future, a table has been set up show the status of their Asbestos control programs (Attached). The portion of this table for the Metals and Chemicals Division, shows that for those locations-which have made preliminary estimates of their outstanding asbestos liability, the total is $11.2 million. As can also be seen, there are a number of plants for which no asbestos removal costs are available. It is expected that if plant asbestos containing materials; (ACM) inventories were all finished and a complete cost study could be done, the total cost to the Metals and Chemicals Division would be much higher. Because of the general way in which the asbestos regulatory compliance question was asked, the answers were varied. Specific comments have been made on each plant response from this Division. Minimally, to be in compliance with existing asbestos regulations and Alcoa policy the following areas should be addressed: - Identify asbestos containing materials, ACM in each facility. - Communicate the presence of asbestos with employees where there is a potential for exposure. - Label intact asbestos insulation per 29 CFR 1926.58. Alternatives to direct labeling are permitted if they are accompanied by appropriate training and communication and effectively provide employees with information concerning location of ACM. alternatives include: - inventories of ACM - plant drawings where ACM is marked - area placards - JSAs or work procedures which define certain tasks as having potential to disturb ACM - Abatement (either removal or repair) is required for deteriorated ACM - Alcoa IH policy since 1979 has stressed the purchase of non-asbestos alternatives for applications where asbestos products had been used. With the exception of brake linings and some pump packings, no new asbestos containing products should be purchased. TSCA Sec. 6 is expected to be used this year to ban some existing uses of asbestos in new products. 511877 0076 193^ April 13 Asbestos Page 2 - All asbestos removal jobs should be done according to the guidelines in Alcoa Engineering Standard 18.18, 1988. This encompasses notification, worker training and licensing, sampling, medical surveillance, special work practices to control asbestos, manifesting and " proper disposal of asbestos waste. - Alcoa policy established Jan. 1989 requires all asbestos removal contracts to be written by Pittsburgh Procurement. Evaluating the plant's responses against these regulatory requirements, it becomes clear that although all of these locations have established special work practices to insure that jobs involving known asbestos are done correctly and asbestos exposures are controlled, very few have inventories of ACM or any form of labeling. Inventories and communication of the presence of asbestos to the plant employees are critical in preventing unknowingly disturbing asbestos and possibly being exposed to airborne asbestos fibers. AHERA, the EPA regulations which cover asbestos in schools, are expected eventually to be expanded to apply to commercial and industrial buildings. It has also become clear with recent sale of property and equipment that asbestos needs to be removed or remediated in some way prior to transfer. A proactive program might mean a Corporate Asbestos Management Policy and Asbestos Management Plans for each location. Asbestos Management plans would include strategic plans for dealing, with each location's remaining ACM, asbestos emergency contingency plans for dealing with unexpected events such as rupture of asbestos lagged pipes as well as ACM inventories, inspections and employee communications. Pittsburgh Health and Safety will be working with other affected groups in formulating a draft Corporate Management Policy. LAURA L. RIPPEY ASBES10.LLR cc: R.M. James, Pgh. 6 L.F. Schneider, Pgh. 13 R.L. Holtz, Pgh. 13 P.R. Atkins, Pgh. 19 R.E. Yester/J.V. Holder, W.L. Wells, Pgh. 9 C.F. Di Mascio, Pgh. 6 Pgh. 20 511877 0077 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 METALS AND CHEMICALS LOCATION ADDY ANDERSON CO. BADIN BAUXITE FT. MEADE FRANKLIN PARADISE PT. PT.COMFORT ROCKDALE WENATCHEE ALC.KASEI LTD MORALCO JAMAICA LUDWIGSHAFEN MOENGO PARAMARIBO PARANAM PORT OF SPAIN ROTTERDAM FORGES DE BOLOGNE ASBESTOS ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM SPECIFIC AREA ABATEMENT EST. COST complete list blue prints transite pipe cooling towers Bldg. 101 furnace vinyl/asbestos floor tiles yes complete direct labeling $500,000 40000 ft3 (9 - 10 MIL.) $10,000,000 $250 /f no in progress none complete none vulnerable ACM removed 13000 ft steam/wat. line 1500 ft flamaStic coati 3 steam boilers 2 ingot furnaces Sandow mines homo furnaces boiler room general piping $416,000 $318,000 $32 /f $212 /f . - TOTAL $11,234,000 511877 0078 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 AEROSPACE & INDUSTRIAL LOCATION ALCOA BLDG. PROD. CLEVELAND CLE PERM MOLD CORONA DAVENPORT H. C. PRODUCTS LAFAYETTE MASSENA STOLLE TEPCO TIFTON, GA TIFTON, DELHI VANEXCO VERNON PIMALCO ACM ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM SPECIFIC AREA ABATEMENT EST. COST no no yes no almost none some labels list 50% heat treat furnace only yes complete complete not much built 81 built '66 built 82 list none $1,200,000 195360 ft piping 12 ea press, vessels 4 ea HVAC systems 49 ea furnaces $6,232,000 $500,000 $400,000 $526,000 steam pipes furnaces other ' 4800 ft cable mill $637,000 ACPC $35,000,000 (20-50 mil.) 0 remelt area non-ACM built '73 steam lines billet heaters press runout relocated equip. TOTAL $44,495,000 $32 /f $133 /f' 511877 0079 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 MATERIAL SCIENCES LOCATION ASBESTOS ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM AFL PEP VIDALIA 'ADS AFL SPARTANBURG LANCY S. C. T. AFL PEP ACU I. W. T. AICX TRE ASTECH TRE CSD no ACM in progress TRE FTBERTECH AFL PEP MATTAWAN AFL PEP N. ROYALTON PERMATECH NC no ACM SPECIFIC AREA ABATEMENT EST. COST floortiles ceiling TOTAL 511877 0080 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 OTHER LOCATION ALCOA LABS ALCOA BLDG. ASBESTOS ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM under way under way some labels inventory undecided SPECIFIC AREA ABATEMENT ESI. COST TOTAL $0 CORPORATE TOTAL $59,283,000 AVERAGE COST $167 511877 0081 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 PACKAGING SYSTEMS LOCATION LANCASTER LEBANON RICHMOND TENNESSEE WARRICK HCI HCI, MS SHIBAZAKI SWANSEA VIERNHEIM WORMS TELI.TG CAPSULAS MET GENESIS PKG. RAGSDALE PKG. RANDOLPH PKG. MIDDLEPORT ALCOA RECYCLING ASBESTOS ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM SPECIFIC AREA ABATEMENT EST. COST yes no complete complete some direct labels partial none yes complete list label piping complete occupied areas no ACM no ACM encapsulated complete roofing piping misc. jobs boiler house fan housings 2000 ft3 South Plant 7000 ft_3 North Plant 7000 ft3 West Plant $47,000 $7,000 $500,000 $1,500,000 $1,500,000 0 East plant West pit. roof West pit. piping ovens bldg, structure $0 machine brakes machine brakes machine brakes piping oven joints ceiling tile piping $250 /fl $214 /fl $214 /fl TOTAL $3,55t,000 511877 0082 BUSINESS UNIT - ASBESTOS CONTROL PROGRAMS - 1989 INTERNATIONAL LOCATION KWINANA PINJARRA PI. HENRY U. A. MINING HAGERUP PORTLAND ALUSUD ENG PINDA POCOS ALUMIN POCOS CABLE RECIFE SAO LUIS SOROCABA OOTIA TUBARAO IFEMA GUARULHOS NORDESTE GRUPO ALCOKEX DKUNEN ASBESTOS ACM POLICY INVENTORY ACM LABELING METHOD INSPECTION REMAINING FREQUENCY ACM SPECIFIC AREA ABATEMENT EST. COST TOTAL 511877 0083