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CORRESPONDENCE RACOMPANY 1.68 'M H. DeLa Garza ~ tae dtgn t . vi & ECT R. F. Nelson W. M. Singleterry J. B. Barbee T. King T. Dunn Sid Haynes Maintenance General Foremen Operations Area Superintendents July 17 1987 INSULATION INSPECTION + sees 8 ~~ On Haynes asbestos July 15 Sid and I conducted an insulation inspection in Facilities 26 30 and 33. Deterioration of weather coating and insulation through the on many lines and vessels has occurred repair or removal is evident the years and need for It is also evident that our personnel are not aware of the hazards involved handling asbestos insulation During the inspection we found line insulation 12 line containing asbestos on top of No. 3 settler that had been stripped In Facility 42 insulation had also been stripped off a line Again the insulation contained asbestos Scalers are shooting holes in the that insulation to get to cases pipe is to be scaled This was evident in many These types of practice have to be stopped All insulation will be inspected before it is removed for any job Proper procedures have to be followed when working around asbestos insulation insulation for asbestos When in doubt we can have our lab check Facility 26 overall needs to be worked the most Asbestos falling from tanks and lines and is laying on catwalks through busy access areas that pose a problem Area superintendents will be called upon to write work orders on many insulation jobs in an attempt to correct the situation at can ~~ es Insulation Inspection HesteDreLa Garza 003731 20 be ENVIRONMENTAL CONTROL PROCEDURE 002 INSULATION REMOVAL July 1987 Revision l (( 9JULY 87 Technological 9JULY TechnologicalSuperintendent M Satel Operations Superintendent St M Safety Director D. Laboratory Director Mila Assistant Plant Manager hi Plant Manager lade H. DeLa Garza ECP 002 Asbestos 003852 26 - ws ' ' o6ne wane aww . e ity, evar pt . - iment own Mz, . 7 . - Pod Saat we . + 5. pint gg 8 e Pose oom : - eer Sof o ^' . we *% ~ A ow) oe a . . ~ . . I. SCOPE II WORK ORDER . III RESPONSIBILITY . . # vod . : oy . . - . e cman ae . ateee Oe > ~ 1 ee . - . hd eee . , wetee + FT me . te suse Et te T oF 7 ros Term Tee 2s . me . . 7 a mew meee ne mee Oe 8 . : + 6 ne te cerns oe we = om - ON . . ~~ ow * . we . st nem ee anaes . :: a . . . ry . . +* . - . . . oo . . oe ge . . ene " . we ew ; e . nny . a . . * . Aan e, -_ a * . . . oe a Noste gormter ag . ~* ae . ., new, oe. ne et - wee - . . - . oo. . we pee eo . Me . i . . . . . e ry - . . .e . 7 _ . . . . . *. o . La . . = eee - was - a om ie + ne ee nw :ene . . . . - - . . . . . . , . . : : . . mano . . e ' . 2 we * ne oe . . . . * , . , . . . . . . . * * . . . 003853 . ad ENVIRONMENTAL CONTROL PROCEDURE 002 . INSULATION REMOVAL . . Revision 1 I. SCOPE II Much of the insulation in the plant contains asbestos Friable asbestos is a hazardous material and requires special handling Disposal of any type asbestos is allowed only to facilities licensed to accept it No insulation of any type will be disposed of on plant property nor will it be handled by anyone other than the building trades crew trained and outfitted for removal of containing insulation environmental and insulation The following procedures must be followed when removing insulation if the insulation is deemed to contain asbestos . SAMPLESI VISUAL INSPECTION WORK ORDER TO DETEAN THE OF CONTAINS CONTAINS ASBASSES IS NOT POSSIBLE SN ucatiev NEED TO BE ARVINGO : SENT TO AN SRESTOS SRESTOS LAS FOR SAMIFICATION SAMIFICATION A. The owner of the equipment involved must initiate a work order for insulation removal He will indicate on the work order an estimate of the surface area involved This procedure must be followed on jobs where insulation removal is incidental other work as well as where insulation is the primary objective Work orders will also indicate whether insulation is needed B. The work order will be sent to the Environmental section of the Technological Department Rector DeLa Garza Tony Dunn for proper identification The Environmental Quality section will then send the Maintenance work order to proper number personnel to be assigned work order - C. The Environmental Group with the help of Maintenance building trades Cave supervisor Sid Haynes or foreman Howard the following action upon request will take . Check the records to determine if the insulation involved contains asbestos Primary source will be the survey provided by the RMC Industrial Hygiene Group from Richmond in 1984. If not covered in this survey the material involved will be tested by the Sherwin Lab and outside laboratories 2. If asbestos is involved the Environmental Group will make a - friability determination for record only They will verify the quantity involved and notify the appropriate environmental agency as required At this point the determination will be made whether to use the plant staging area to place the insulation directly into the transportet's containers 3. Notification for removal of insulation containing asbestos will have to be done ten 10 days in advance of removal This applies to quantities greater than that covering 160 square feet of insulation or 260 linear feet of pipe Notification for small quantities will be done five 5 days in advance of removal 003854 68 . .INSULATION REMOVAL . 5 mee 2 re - - : ECP 002 . Revision I . 4 When notification is completed the work order will be returned to the normal system with a listing of any special requirements over and above normal asbestos handling procedures III 5 copy of the work order and any associated correspondence will be sent to the Safety Department at this time for review and comment if desired ~ D. Upon receipt of the work order from the work Environmental can be assigned and can begin Group a number - RESPONSIBILITY A. Plant Forces , insulation The General Foreman having control of the crew removing the is responsible for the following 1. Providing protective clothing include mask disposable coveralls head and foot coverings and gloves 2. Posting warning signs around the work area - 3. Placing insulation in the proper bags and removing to the staging area 4. Keeping daily count of bags removed to the staging area and coordinating with the Environmental Group to insure that the is mtaimteerial removed in a timely manner 90 days maximum holding . B. Insulation Removal and Renovation Contractors . The contractor is responsible for the proper handling of the containing insulation by his crew This includes Items t through 4 in A above C. Project Engineer Plant Insulation Projects The project engineer is responsible for overseeing the contractor and assuring that the proper procedures are followed The project engineer will conduct a contractor asbestos removal audit as the job progresses July 1987 003855 Page 2 29