Document x1B9wkaObV0wKB8Qx0Rb35740

0<^ " ij/'Vl j7 -01/ Shell Oil Company Shell Chemical Company A Oivmon of Stwll Oil Company Deer Park Manufacturing Complex P.O. Box 100 Deer Park, TX 77536 August 14, 1990 CERTIFIED MAIL - RETURN RECEIPT REQUESTED Texas Air Control Board Compliance Section 6330 Highway 290 East Austin, Texas 78723 Gentlemen: SUBJECT: ASBESTOS INSULATION REMOVAL AT SHELL'S DEER PARK MANUFACTURING COMPLEX This letter is to give notice (in accordance with 40 CFR Part 61.146) of our intent to remove asbestos materials over the next one-year period. This estimate covers small jobs as well as planned maintenance projects and unit demolition projects that may involve asbestos materials. I~ any other major jobs of demolition or renovation arise that are covered by Part 61.146, or we begin to exceed our predicted total as stated below, we will notify you in a letter with appropriate details. Shell has hired Brown & Root Construction to remove asbestos insulation. We expect that the work in this notification will be done by Brown & Root. The following information is for your consideration: 1. Name and Address of Owner Shell Oil Company, Deer Park Manufacturing Complex P. 0. Box 100, Deer Park, Texas 77536 2. Name of Operator (Asbestos Remover) Brown & Root Construction Company LAM 025413 3. Description of Facility Involving Asbestos The Deer Park Manufacturing Complex will remove about 460,000 square feet of asbestos insulation during both renovation and demolition projects. The amount of asbestos removed for demolition projects will be approxi mately 430,000 square feet. Some major projects which wij^_jjivolve asbestos removal include: demolition of WOB Annex buildings, removal of Main Shop air handlers, and demolition of PXU and NPRU units. The amount BCBR9022604 ABS-031988 of asbestos to be removed due to renovation is about 30,000 square feet. Some projects involving asbestos removal include: G300 Control Room Floor replacement, Epon 2 Unit Siding upgrade, insulation replacement on C3 storage vessels in IPA Reactor unit. 4. Asbestos Removal Reporting Time Period August 17, 1990 through August 16, 1991 5. Procedures to the Followed a. Shell, or their contractors, will remove insulated piping as units or in sections in accordance with paragraph 61.147 of the regulations. Asbestos materials exposed during cutting or disjointing or exposed to permit lowering of equipment to grade shall be wetted. Units, sections, or other parts will be lowered carefully to ground level to avoid air dispersion of asbestos fibers. b. Shell shall strip the asbestos insulation materials from removed piping by removing the weatherproof cover, immediately wetting the exposed asbestos material, and promptly removing the wetted asbestos material into heavyweight plastic bags. Filled bags shall be tied tightly at the top, proper "Asbestos" warning labels affixed in accordance with regulations, and transported to an approval disposal site in a covered roll-off bin. **' c. When sufficient asbestos-filled bags are accumulated, they will be transported by truck either to our own onsite facility, to Western Waste Industries of Texas, Incorporated in Conroe, Texas, or to Chemical Waste Management in Carlyss, Louisiana for offsite disposal. d. Shell will wet down transite sheets and cover with heavy-duty plastic for transport to disposal. If you have any questions, please contact Kim Glauner at (713) 246-7515. Very truly yours. J. M. Sowle, Manager Environmental Compliance cc: Mr. Herbert W. Williams, Director Texas Air Control Board, Region 7 5555 West Loop, Suite 300 Bellaire, Texas 77401 LAM 025414 BCBR9022604 ABS-031989 G. C. Anderson W. B. Austin M. J. Boyle M. L. Corron K. C. Glauner A. F. Schmit tmymnrms N. A. Gilbert EC8 Satellite ECB Chron OSP RECEIVED HS&E ADMINISTRATIVE SERVICES AUG 161290 9CBR9022604 LAM 025415 abS-031990 LAM 025412 p/JKxC u J A S -rg ' ou - bPtn - uud c y 7wo ABS 031987.]