BASF Corporation Title: ASBESTOS HANDLING, REMOVAL AND DEMOLITION

Transcription

1 Procedure No.: IH-6 Page: 1 of 16 Preparer: Owner: Approver: RECORD OF REVISIONS Date Details of Change 11/02/01 Added a Record of Revisions table. 08/14/08 Review of entire procedure. Deleted and /08/11 General review 08/04/14 Periodic review 05/13/15 Updated the required language for regulated areas and container labels. 06/04/18 Periodic review. Updated title of EHS Hub Director in header.

2 Procedure No.: IH-6 Page: 2 of PURPOSE This standard is established to ensure compliance with OSHA Standard CFR , EPA Standard 40CFR61 Subpart M, and the State of Louisiana regulations concerning: the proper handling of asbestos containing material (ACM) and presumed asbestos containing material (PACM) to prevent emissions to the environment the protective measures taken by BASF and Contractor personnel handling ACM/PACM to prevent personal exposure proper disposal of ACM/PACM. 2. DEFINITIONS 2.1 Accredited Inspector: An individual who has completed an accredited 3-day Asbestos Inspectors course and is licensed by the state of Louisiana to conduct inspections. 2.2 Adequately Wet: Sufficiently mixed or penetrated with liquid to prevent the release of particles. EPA guidelines recommend sufficiently wetted such that droplets of liquid are apparent. 2.3 Asbestos: Chrysotile, amosite, chrocidolite, tremolite, anthophyllite or actinolite asbestos and any of these materials that have been chemically treated and/or altered. For the purposes of this standard, presumed asbestos containing material (PACM) as defined is also included. 2.4 Asbestos Containing Material (ACM): material is considered as asbestos if it contains 1% or greater asbestos. 2.5 Class I Asbestos Work: Activities involving the removal of thermal system insulation and surfacing material which contain or are presumed to contain asbestos. 2.6 Class II Asbestos Work: Removal of ACM and PACM which is not insulation or surfacing material. This includes, but is not limited to removal of wallboard, transite, floor tile and sheeting, roofing and siding shingles, and construction mastic not used in roofing materials. Removal of asbestos containing gaskets is considered Class II work.

3 Procedure No.: IH-6 Page: 3 of Class III Asbestos Work: Repair and maintenance operations where ACM and PACM, including insulation and surfacing materials are likely to be disturbed. Examples include removal of insulation to gain access to valves, instrumentation or other process equipment. 2.8 Class IV Asbestos Work: Maintenance and custodial activities where employees contact, but do not disturb asbestos containing material as well as cleaning up dust, waste and debris resulting from Class I, II and III work. 2.9 Competent Person: Person who is capable of identifying existing asbestos hazards in the workplace, who select the appropriate control strategy, and who has the authority to take prompt measures to eliminate them as specified in 29CFR (f). In addition, for Class I, II and III work, this person must have successfully completed the Louisiana State Certification Program for asbestos abatement supervision and be familiar with the duties of a Competent Person as outlined in 29CFR (b) Demolition: The wrecking or taking out of any load-supporting structural member of a facility Emergency Renovation/Demolition: A demolition or renovation that results from a sudden, unexpected event that presents a safety or public health hazard, is necessary to protect equipment from damage, or is necessary to avoid imposing an unreasonable financial burden. This includes operations necessitated by nonroutine failures of equipment Permissible Exposure Limit: The eight hour time weighted average personnel exposure shall not exceed 0.1 fibers per cubic centimeter or the 30 minute excursion limit of 1.0 fibers per cubic centimeter Presumed Asbestos Containing Material: All thermal system insulation, surfacing material, floor tile, and other suspect materials (such as ceiling tile, mastic, wallboard, transite, etc.) installed prior to 1981 must be presumed to contain asbestos, unless documentation exists to refute the material as asbestoscontaining. If PACM is analyzed and the results are negative, then the requirements of this standard do not apply Project Coordinator: BASF Engineer or Coordinator responsible for the completion of the project or work.

4 Procedure No.: IH-6 Page: 4 of Regulated Area: Posted work area, with restricted access, established for handling asbestos containing materials. All Class I, II and III asbestos work must be conducted within regulated areas. The purpose of which is to minimize the number of persons who could be exposed Renovation: Altering a facility or one or more facility components, including the stripping or removal of ACM or PACM Vacuum: Use of an industrial vacuum cleaner with high efficiency particle filter (HEPA) attachment capable of trapping and retaining at least 99.97% of particles of 0.3 micrometers in diameter. 3. SCOPE This standard applies to all BASF Geismar units and departments, including service groups, who handle ACM or that have control of asbestos or presumed asbestos containing materials. This includes, but is not limited to, gaskets, building materials, transite, and ceiling and floor tiles. 4. PROCEDURE 4.1 IDENTIFICATION At least 30 days prior to any demolition or renovation activity a complete inspection must be conducted by an accredited inspector, as defined in this standard, to determine the presence of ACM All unknown insulation, surfacing material, floor tile, and other suspect material must be considered to contain asbestos unless documentation is available which shows it is not asbestos or until an inspection is conducted by an accredited inspector Identification of possible asbestos containing materials will be completed by a NVLAP laboratory accredited in bulk asbestos analyses.

5 Procedure No.: IH-6 Page: 5 of All known asbestos containing materials (ACM) must be clearly labeled to identify the presence of asbestos and appropriate hazard warnings The presence of any other ACM shall be communicated to all potentially affected employees in a manner to ensure that they are aware of potential hazards should the material be disturbed. 4.2 ENVIRONMENTAL NOTIFICATION The Ecology Department must be notified prior to any renovation involving ACM/PACM and prior to all demolitions, regardless of whether or not ACM is involved Any scheduled removal work involving < 1 cubic yard of ACM/PACM must be reported to the Ecology Dept. at least 15 days prior to beginning the work Jobs involving > 1 cubic yard of ACM/PACM must be reported to the Ecology Dept. at least 30 days prior to beginning work Emergency renovations are to be reported as soon as possible after the job scope has been defined The information to be provided for all jobs must include: Location Job Scope Amount of ACM/PACM to be removed (linear feet of pipe or square feet for building or tanks, etc.) Planned start and completion date Contractor to be used In addition, the Ecology Dept. must be notified immediately if the amount of ACM/PACM to be removed changes by at least 20% or if the project start date is changed The Ecology Dept. is required to report removal activity to the Louisiana Department of Environmental Quality (LDEQ) ten (10) days prior to the beginning of work. For a large job, notification is required at termination of the project. The Ecology Dept. will provide notification and waste disposal documentation.

6 Procedure No.: IH-6 Page: 6 of TRAINING REQUIREMENTS Only trained and approved personnel may perform any asbestos work. Asbestos workers must be trained to the required competence depending upon class of asbestos work This training must be current - initially and then annually thereafter Class I workers must have a Louisiana Asbestos Workers Certification (40 hours) Class II workers must have completed an approved EPA course or equivalent course which meets the requirements for the EPA course curriculum and includes hands on training. Where Class II work involves removal of building materials such as siding, tile, or transite panels, the training class must be at least 8 hours & include specific work practices and engineering controls for the material. Where Class II work involves removal of other types of asbestos including, but not limited to, gaskets the training must include specific work practices, engineering controls, and removal methods related to the material. If the Class II work must include the use of critical barriers and/or negative pressure enclosures, the training must be at least 40 hours Persons performing Class III asbestos work must have received either the EPA Asbestos Abatement Worker Certification or training equivalent to the EPA 16 hour Operations and Maintenance course. The training must be at least 16 hours in length and include hands on training in the use of respiratory protection and work practices.

7 Procedure No.: IH-6 Page: 7 of CLASS I & II ASBESTOS WORK REQUIREMENTS The asbestos contractor will provide the following: 1) On-site Competent Person for supervision of all Class I & II asbestos jobs; 2) Employees who have met the training requirements specified in section 4.3; 3) Current physical for each employee, as required in 29CFR ; 4) Current respiratory protection training and fit testing for all types of respirators to be used; 5) Written compliance plan and documentation of all required training maintained by the contractor on the Geismar site; and 6) Any additional requirements of 29CFR applicable to the class of work All required documentation of training and physicals must be made available to BASF personnel upon request Appropriate controls, as specified by 29CFR paragraph (g), will be used for all Class I and II jobs Monitoring Requirements The contractor will conduct daily personnel monitoring on jobs where asbestos materials are being removed or disturbed unless employees are equipped with positive pressure supplied air respiratory protection or a negative exposure assessment has previously been performed within the last 12 months Area monitoring will be performed as necessary to demonstrate that engineering controls and work practices are adequate to prevent migration and emissions of ACM/PACM to adjacent areas.

8 Procedure No.: IH-6 Page: 8 of Monitoring results will be reported to the IH Dept Minimum Personal Protective Equipment (PPE) to be Worn Disposable coveralls, over street clothing, which is taped at wrists and boots Rubber type steel toe boots, gloves, safety glasses and hard-hats Respiratory Protection. The following types are approved for asbestos work: a) Half face air purifying respirator equipped with high efficiency filters (HEPA) is the minimum to be worn b) Full face air purifying respirator equipped with high efficiency (HEPA) c) Supplied air or powered air purifying respirators (PAPR) will be used when necessary or as requested by workers Additional PPE, which may be needed to work on equipment that previously contained hazardous chemicals, will be determined by the Owning Department who is issuing the Safe Work Permit and/or as based upon the asbestos contractor s own program Asbestos Removal Procedure Obtain a Safe Work Permit from the Owning Department Establish a Regulated Area as required by 29CFR (e): a) Barricade work area at least 15 feet from work on all sides, following BASF Safety Standard 22 (GSS#22). b) Post warning signs at all approaches to the regulated area, or at distances no more than 10 feet apart, in order to provide notification of the hazards to personnel working in adjacent areas. The signs are required by 29CFR (k)(l)(i) and must read: DANGER ASBESTOS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS

9 Procedure No.: IH-6 Page: 9 of 16 AUTHORIZED PERSONNEL ONLY WEAR RESPIRATORY PROTECTION AND PROTECTIVE CLOTHING IN THIS AREA Restrict entrance to the regulated area to trained personnel who are wearing the required PPE and utilizing decontamination procedures Establish the appropriate enclosure (i.e. glove bag or negative air enclosure) to prevent release of asbestos fibers Locate the decontamination area or unit as close to the work area as possible Inspect all personal protective equipment prior to beginning work Remove any weather barriers and adequately wet the ACM/PACM behind it Keep material adequately wet at all times to prevent fiber release. Remove material in sections, spraying water continuously while handling. Re-wet as needed to prevent fiber release Place contaminated material in properly labeled plastic bag and secure for disposal Rinse the outside of the bag and place into a second plastic bag. Goose-neck seal the opening of the bag Rinse the outside of the bag before transporting outside of regulated area Material must not be dropped or thrown to the ground. Bag and lower to ground level Contain all wash water where feasible or as required by site Ecology Decontamination Procedures A decontamination area must be established adjacent and connected to the regulated area when performing Class I work

10 Procedure No.: IH-6 Page: 10 of 16 involving over 25 linear feet or 10 square feet of ACM or PACM. The decontamination area shall consist of an equipment room, shower area and clean room in series If a shower and clean room cannot be feasibly located adjacent to the regulated area, then personnel leaving the regulated area for any reason must: a) Establish a decontamination area (i.e. drop cloth) adjacent to the work area; b) Vacuum protective clothing, hose off boots, remove respirator, and then wash face and hands; c) Leave regulated area; and d) Proceed immediately to shower/clean room facility If reusable coveralls are used, then they must be properly bagged, labeled, and laundered before reuse. 4.5 CLASS III ASBESTOS WORK All Class III work must be done under the supervision of a Competent Person Work must be performed using approved control methods as specified by 29CFR paragraph (g) ACM/PACM must be kept adequately wet at all times If feasible, HEPA ventilation will be used A plastic mini-enclosure or glove bag system must be used where work involves drilling, cutting, abrading, sanding, chipping, breaking or sawing of insulation or surfacing material Where a negative exposure assessment has not been completed, or if a negative exposure assessment has been completed but monitoring results indicate that a PEL is exceeded, employees must wear at least a half-face air purifying respiratory with HEPA filter A Regulated Area must be established as required by 29CFR (e):

11 Procedure No.: IH-6 Page: 11 of Barricade work area at least 15 feet from work on all sides, following BASF Safety Standard Post warning signs at all approaches to the regulated area, or at distances no more than 10 feet apart, in order to provide notification of the hazards to personnel working in adjacent areas. The signs are required by 29CFR (k)(l)(i) and must read: DANGER ASBESTOS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY WEAR RESPIRATORY PROTECTION AND PROTECTIVE CLOTHING IN THIS AREA Entrance to a regulated area must be restricted to personnel wearing the required PPE and utilizing decontamination procedures If a decontamination unit is required, it should be located as close to the work area as possible Inspect all personal protective equipment prior to beginning work. 4.6 CLASS IV ASBESTOS WORK Custodial work performed on site is exempt from the requirements of this standard within the following guidelines: Stripping of finishes is conducted using low abrasion pads at less than 300 rpm When buffing floors, sufficient finish is left so that asbestos containing material is not contacted Where custodial work is covered by the standard, training must be the same as for Class III work and work practices must include appropriate wet methods using HEPA vacuum systems. All other requirements to Class III work may apply.

12 Procedure No.: IH-6 Page: 12 of WASTE DISPOSAL PROCEDURES 5. RESPONSIBILITIES Asbestos containing material shall be adequately wetted, collected and disposed of in closed impermeable containers. Containers must be closed at all times, except when adding material The Ecology Dept. will make arrangements for transportation to an approved off-site landfill Questions regarding disposal should be forwarded to the Ecology Group Warning labels shall be affixed to all containers with asbestos The warning label required shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: DANGER CONTAINS ASBESTOS FIBERS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS DO NOT BREATHE DUST AVOID CREATING DUST 5.1 It is the responsibility of the BASF project coordinator to assure compliance with this standard. Attachment A includes optional audit forms for different types of jobs (i.e. Glove bag, negative pressure enclosure, mini-enclosure, other). 5.2 It is the responsibility of the designated Competent Person to ensure that all individuals involved in the project comply with the requirements of 29CFR and LDEQ Chapter 51 of Title 33, Part III, and follow all requirements as outlined in this standard. 5.3 Procurement is responsible for maintaining a list of Louisiana State certified asbestos abatement contractors. 5.4 Site IH is responsible for ensuring that ACM is properly identified, for assisting with exposure assessment as needed, and for maintenance of exposure records.

13 Procedure No.: IH-6 Page: 13 of BASF Ecology is responsible for reporting asbestos removal jobs to the appropriate regulatory agencies and acquiring the disposal authorizations (ADVF s). 6. RELATED DOCUMENTS 6.1 LDEQ Chapter 51: Emission Standard for Asbestos 6.2 OSHA 29 CFR

14 ATTACHMENT A ASBESTOS AUDIT CHECKLIST - GLOVEBAG JOBS Location/Job: Date: Contractor Performing Work: Start Date: Completion Date: Auditor's Signature: 1. Type of Work Class Type and quantity of ACM Indoors Outdoors Other workers adjacent to regulated area NEA available YES NO N/A 2. Work site barriers (polyethylene sheeting) All openings to regulated area sealed with sheeting. HVAC systems sealed with 2 layers of 6 mil plastic. Impermeable drop cloths placed beneath removal activities. 3. Glove Bag Systems At least 6 mil seamless bag used. Bag completely covers ACM to be removed. Bag is smoke tested to ensure good seal. Bag used only once. Bag not moved once sealed to pipe. HEPA vacuum used to collapse bag before removal from pipe. 4. Signs/barrier Entrance(s) to work area posted with warning signs. Demarcated areas roped off or otherwise restricted. 5. Work practices Wet methods used. HEPA vacuum used. Wastes promptly placed in clear, labeled bags. Waste double bagged and gooseneck sealed. Droplets of water visible in the disposal bag. Ends of newly exposed asbestos covered or contained. Smoking prohibited in regulated area. Eating/drinking prohibited in regulated area. 6. Personal Protective Equipment NIOSH-approved respirators being used. Protective suit/foot coverings and gloves worn. 7. Decontamination Showers available/functioning. HEPA vacuum used to clean protective clothing/equip. Dirty suits removed and clean suits worn to decon trailer. 8. Unit personnel and other contractors in area notified of activities. 9. Contractor and employees certified to do asbestos work. 10. Exposure monitoring conducted. 11. Daily meetings conducted with IAS to review status of activities. 12. Daily log kept by IAS. Comments:

15 ATTACHMENT A ASBESTOS AUDIT CHECKLIST - MINI ENCLOSURES Location/Job: Date: Contractor Performing Work: Start Date: Completion Date: Auditor's Signature: 1. Type of Work Class Type and quantity of ACM Indoors Outdoors Other workers adjacent to regulated area NEA available YES NO N/A 2. Work site barriers (polyethylene sheeting) All openings to regulated area sealed with sheeting. HVAC systems sealed with 2 layers of 6 mil plastic. Impermeable drop cloths placed beneath removal activities. 3. Mini Enclosure (2 people or less) Constructed of 6 mil sheeting. Negative pressure throughout enclosure. Enclosure smoke tested to ensure good seal. Electrical power locked out; GFCI used. All holes and penetrations sealed. All equipment covered with sheeting. Entry curtains at entrance into enclosure. 4. Signs/barrier Entrance(s) to work area posted with warning signs. Demarcated areas roped off or otherwise restricted. 5. Work practices Wet methods used. HEPA vacuum used. Wastes promptly placed in clear, labeled bags. Waste double bagged and gooseneck sealed. Droplets of water visible in the disposal bag. Ends of newly exposed asbestos covered or contained. Smoking prohibited in regulated area. Eating/drinking prohibited in regulated area. 6. Personal Protective Equipment NIOSH-approved respirators being used. Protective suit/foot coverings and gloves worn. 7. Decontamination Showers available/functioning. HEPA vacuum used to clean protective clothing/equip. Dirty suits removed and clean suits worn to decon trailer. 8. Unit personnel and other contractors in area notified of activities. 9. Contractor and employees certified to do asbestos work. 10. Exposure monitoring conducted. 11. Daily meetings conducted with IAS to review status of activities. 12. Daily log kept by IAS. Comments:

16 ATTACHMENT A AUDIT CHECKLIST - NEGATIVE PRESSURE ENCLOSURES Location/Job: Date: Contractor Performing Work: Start Date: Completion Date: Auditor's Signature: 1. Type of Work Class Type and quantity of ACM Indoors Outdoors Other workers adjacent to regulated area NEA available YES NO N/A 2. Work site barriers (polyethylene sheeting) All openings to regulated area sealed with sheeting. HVAC systems sealed with 2 layers of 6 mil plastic. Impermeable drop cloths placed beneath removal activities. 2. Negative Pressure Enclosure At least 4 air changes per hour. Negative pressure though-out enclosure; water at gauge Enclosure smoke tested to ensure good seal. Electrical power locked out; GFCI used. 2 layers of 4 mil sheeting on wall. 2 layers of 6 mil sheeting on floors. All equipment covered with sheeting. Entry curtains at entrance into enclosure. 3. Signs/barrier Entrance(s) to work area posted with warning signs. Demarcated areas roped off or otherwise restricted. 4. Work practices Wet methods used. HEPA vacuum used. Wastes promptly placed in clear, labeled bags. Waste double bagged and gooseneck sealed. Droplets of water visible in the disposal bag. Ends of newly exposed asbestos covered or contained. Smoking prohibited in regulated area. Eating/drinking prohibited in regulated area. 6. Personal Protective Equipment NIOSH-approved respirators being used. Protective suit/foot coverings and gloves worn. 7. Decontamination Showers available/functioning. HEPA vacuum used to clean protective clothing/equip. Dirty suits removed and clean suits worn to decon trailer. 8. Unit personnel and other contractors in area notified of activities. 9. Contractor and employees certified to do asbestos work. 10. Exposure monitoring conducted. Comments: