Document 6wYvk96B5Voeqap1a8VJv1Ne6

1 PLAINTIFF'S EXHIBIT L\TKIL\AI. CllKSI`M)i;.\CK UC-1703 UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS To (Namel Company Location Messrs.: B. F. Brown R. C. Glock K. G. Townsend/^ Staff (12) P. 0. BOX 3370, BROWNSVILLE, TEXAS 78520 Date March 30, 1977 Originating Dept. Answering letter date Copy to Subject EPA Asbestos Standard and Proposed Amendment Gentlemen: r On April 6, 1973, the EPA Administrator promulgated the national emission standard for asbestos. One of the provisions of the standard limits asbestos emissions from the"demolition or renovation of any institutional, commercial, or industrial building, structure, facility, installation, or portion thereof which contains any pipe, duct, boiler, tank, reactor, turbine, furnace or structural member that is covered or coated with asbestos material". Such an operation would be necessarily preceded by written notification to the Administrator at least 20 days prior to commencement of demolition. The notice would include, among other things, the name and address of the owr'r, description and location of the facility and the scheduled starting and completion dates of demolition. The standard requires that asbestos material should be removed from any facility prior to wrecking. Such materials should be adequately wetted to ensure that they remain wet during all stages of demolition. After wetting, all asbestos-containing material should be sealed into leaktight properly labeled containers while wet, and such containers should be deposited at waste disposal sites which are operated in accordance with established requirements. Rather than comply with the wetting requirement, a local exhaust ventilation and collection system may be used to prevent emissions to the outside air. Also, rather than meet the no-visible-emission requirements as specified above an owner or operator may elect to clean emissions containing particulate asbestos material before such emissions escape to or are vented to the outside air. Fabric filters or wet collectors may be used for this purpose. The methods used to comply with the standard or alternative procedures to be used must be reported in the forms provided by the EPA. t BRG 0138 EPA Asbestos Standard and Proposed Amendment 2- - March 30, 1977 In brief, this is the status of the asbestos standard after having been amended on May 3, 1974, and again on October 14, 1975. The Administrator is again proposing to amend this standard. One of the provisions of the standard limits asbestos emissions from the spraying of materials to insulate or fire-proof buildings. EPA did not know of uses other than fire-proofing and insulation for asbestos containing spray-on materials that were major sources of asbestos emissions during application or later removal. Recently it has come to the EPA's attention that certain types of decorative spray-on materials containing from 29 to 64 per cent asbestos by weight have been sprayed on ceilings in residential buildings. These materials would be a major source of asbestos emissions during renovation and demolition operations. For this reason EPA is proposing to prohibit spray-on application of paints, decorative sprays, and weatherproofing which contain asbestos in excess of one per cent by weight. The proposal, in short, would broaden the applicability of the terms, provisions, and spraying regulation to cover all asbestos material. In addition, the EPA has issued a final rule making action which consists of adding a definition for the term "structural member". The above standard is an EPA standard and should not be confused with the one promulgated by OSHA. Any questions or comments concerning the asbestos standard should be conveyed to the writer. Very truly yours, JLG: mfw J. L. Garcia