Document 6w6vvqL9wNmaYLDbYgXJxRek4

HMBB-0032M0 From m: Obk ; Subject Ind./Mfg. Engxg. - 3S20 299-4827 October 13, 1982 EPA Asbestos Reporting Requirements To Headquarters Industrial Hygiene R&D Center 401 3X9 Mr. Wayne Bickerstaff tzi Attached i6 our Negative Declaration signed by our Plant Manager, Mr. J. Micka. Also attached is correspondence that is supportive of our decision that LRA is exempt from reporting* JF0:IMC Attachments J. F. Onofrey IE/ME Department Manager OiscafdOare: 03114350 MMBB-0032M1 * 'w'C-' a NEGATIVE DECLARATION In accordance with Che EPA Toxic Substances Control Act Section 8 (a) "Asbestos Reporting Requirement," we have reviewed our purchases and processes for the year 1981. According to our records and to the best of our knowledge, asbestos was not used at this facility in such a manner as defined as a primary processor, secondary processor or importer. V'y-j .< - Signed by: Q Plapt/General Manager Plant: l-.fi A- fit-rfOT"_________ Title -pLA^T- A/f4A)ACr./l Date: CX~r >%| I S L- Send to: Headquarters Industrial Hygiene R&D Center 401 3X9 1310 Beulah Road Pittsburgh, PA 15235 03114351 HWBB-0032M2 from wh &te Socter Ind./Mfg. Engrg. - 3S20 299-4827 October 12, 1982 EPA Asbestos Reporting Requirements "JJA -3 ,,_1 E. Pgh. , 2N32 Mr. J. C-. Micka cc: E. Pgh. , 4013 - Mr. M. A. Roy cc: E. Pgh., 5-C - Mr. J. G. Leppla cc: E. Fgh., 5-C - Mr. A. B. Dvorsky cc: E. Fgh., 2NS - Mr. M. D. Farr cc: E. Pgh., 4S2 - Mr. H. J. Finney cc: E. Pgh., 4S6 - Mr. J. S. Zgurich LRA use cf asbestos products in 1981 has been investigated, and ve have concluded that our usage during this time period us such that we are exempted from report ing as a Primary or Secondary Processor. Purchasing has reviewed our records for 1981 and concluded that although we pur chased asbestos-containing materials for use in our end products, ve did not codify the products in our plant (reference attached M. Farr's letter of September 27, 1982). This status was also verified by Messrs. L. Petrieh and J. Cavicchio (see attached letters). Purchasing also verified that LRA did not purchase any of the P.D. Spec, material listed on the "Asbestos Tradenames" attachment of Mr. Frank S. Beal's letter (reference attached M. Farr's letter of October 11, 1982) . Plant Services is considered an "aid user" of asbestos products since none of the material they purchase is further distributed in our end products. LRA. Operations and Plant Services are therefore both exenpted from reporting per page 2 of Mr. Prank S. Beal's letter on the subject (attached). Ve therefore recommend that the attached "Kegative Declaration" be signed by you and forwarded to Headquarters Industrial Hygiene. We have already verified that this is the correct procedure with Mr. Wayne Bicker6taff, Manager of Industrial Hygiene. ; I. V'*// /. F. Onofrej IE/ME Department Manager JPOtlKC C sea- c Date 03114352 HWBB-0032M3 5=3 JBi fiom East Pittiburrh, 2NS - ** 299-4145 Septembe. 27, 1982 ScC;i EPA ASBESTOS REPORTING REQUIREMENTS T A. B. Dvorsky - 5G cc: C. B. Yaskanlch - 2N4C F. G. Praysner - 2NS R. P. Carozza - 2NS l ` { { .J r c. we have reviewed our purchasing records and have verified that during 1981 IRA did not purchase any asbestos for Manufacturing's use. Specifically: 1. The-e were no purchases of asbestos stator wedge material as the Kevlar replacement was in use. 2. No asbestos gasket raw material (sheeting) was purchased, although we continue to buy finished asbestos gaskets from Argo Packing. Based upon the above, I agree with your conclusion that IRA should be exempt from reporting. Mark 0. Farr, Manager Component Materials Purchasing H)F/WPC:12039 03114353 HHBB v=3 0 0 > - fr:m WIN Oars Subject D General October 5, 1982 EPA Asbestos Reporting Requirements TO A. B. Dvorsky en S 9 i -.2 <5 We have reviewed our records and verified that during 1981 in D-Annex, no asbestos bearing wedges were used in manufacturing. Any asbestos gaskets were received as a finished part and used without modification. L. P. Area Manager, DX 03114354 w a iD m te f M B8-0032445 !,,.h wm Cate" S^cct {.PA E-f.on ' ) 4A31 . October 4, 1982 PA Asbestos Reporting Requirements To A. B. Ovorsky - 5-G CC* 'A E. Ponit2 - E-5 K. L. Fulton - E-General It is my understanding that during 1981, none of the " M Aisle sections performed any operations involving asbestos. All asbestos processing was discontinued in 1979 fiN ^j}d { {s-*- JT A. Cavicchio Area Manager 03114355 East Pittsburgh, 2NS 299-4145 October 11, 1982 EPA ASBESTOS REPORTING REQUIREMENTS A. B. Dvorsky - 5G : C. B. YasKanich - 2`i-C F. G. Praysr.c^ - 2NS R. P. Carozza - 2NS 0. F. Onofrey - 3S20 -99AH rsj c*> s As a fs-lcfc-jj t: 'y Sc-ptemoer 27, 1932 lett3r, we have reviewed our 1981 pj-cnascs specifically checking for any activity against tne P.D. Specs. 'isted on the `astestos tradenames" attachment. 0j r r ec o r d s indicate that there were no purchases during 1981. Mark 0. Farr, Manager Component Materials Purchasing MDF/WPC:12114 03114356  T O E m lb w i o t HM88- ASBESTOS TRADENAMES Name Accopoe AS-428 Anchor 317 Asbestocite . Aribest C Calidrin RC-100 Calidrin RG-144 Calidrin RG-6Q0 . Cassiar AK Duroid 3700 Ebony Garlock 901 Cerlock 7021 Garlock 7021 Rock Hard K6-30 '. K68 Mannitewp 111 Manniteap 115 Manniteap 127 Metaxite Moaobestos Mysorite Nicolet Ohastone . Plastibest 20 Quincerra 5 Quintex 1 er\ Sealsafe Novatex Tape 2132N Service Sheet 60 Super Tvilstele Joining 200 Sylodex Trensite Valvolite 20 WeldgarJ Commercial 2225 (W) Material Number. 42261AJ 41521DA 46316CJ 42262A8 463I6CA 42241AD 42241A? 42241AG 42251BC 42331CS 42331CC 42331CD 46316CN 46316CK 46316CC 4233IBC 42331AJ 4I521AD 42241AE 41521EM 46316CE 41521DA 42511BR -3 -0* oj m S 03114357 s=3 ' S'' --i s_.n 2- - Exemption from Reporting The EPA has exempted certain classes of potential respondents from the requirements of the rule. The exempt class includes: 1. Companies employing 10 or fever employes. 2. Secondary Processors vho apply, assemble, install, erect or consume asbestos products without modifying or fabricating the asbestos product. Example: an appliance manufacturer vho installs electric motors containing asbestos components would be exempted-*-- 3. Persons vho repair articles, repackage asbestos mixtures without modification or vho engage in construction work. 4. Persons vho are distributors and do not manufacture, process or import bulk asbestos or asbestos products. 5. Persons vho are "end users" of bulk asbestos or asbestos products and do not further distribute such items in commerce. Example: asbestos welding blanket. Plant's Responsibility Each plant must survey its facility and determine vhether the EPA Asbestos Reporting Requirements apply. This initial survey (three (3) year period' from 1979 to 1981 if Primary Processor or just one (1) year, i.e., 1981, if Secondary Processor) should include a review of purchasing invoices for either the three year or one year period, any processes involving bulk asbestos or mixtures and products imported into the United States that contain asbestos. Be avare many asbestos mixtures or products use trade names such as Transite, Monobestos, etc. Review the attached cable on Asbestos Tradenames. If the EPA Asbestos Reporting Requirements apply to your plant, then a decision must be made as to which form (i.e.. Primary or Secondary Processor) applies. Then complete either EPA Form 7710-36 or 7710-37 and send the completed, signed form to Headquarters Industrial Hygiene, R&D Center 401 3X9, 1310 Beulah Road, Pittsburgh, PA 15235, by October 11, 1982. Do not send any form directly to the EPA. EPA Form 7710-36 asks for detailed data on products, importation of bulk asbestos, worker exposures, waste and disposal and pollution control equipment. Therefore, allow sufficient time to gather this data and complete the form. If the EPA Asbestos Reporting Requirement does not apply to your plant, then sign the attached Negative Declaration and return to Headquarters Industrial Hygiene, R&D Center 401 3X9, 1310 Beulah Road, Pittsburgh, PA 15235. t * 03114358 * r HW BB-0032M8