Document 91GY6G7dj5m06NaG779w9K9O7

FILE NAME: Allied Signal Bendix (ASB) DATE: 1990 May 2 DOC#: ASB095 DOCUMENT DESCRIPTION: Memo RE OSHA Proposed Standard with Handwritten Notes Memorandum BencSix Bandix Friction Materials Division Green Island, New York Date: To: From: Subject: May 2,1990 T.P.Rancour (FAX) C.R.Larson OSHA Proposed 0.1 //s'J&rff' \f<K * i } ^ u L ' / til /hvjAdf3, DELIVER UPON RECEIPT /URGENT f/cc Asbestos Standard Med V Signal & 1^ 7 . The foliowing information is provided regarding the . potential impact upon the plants if the standard were to be passed "today"- ' (1) If the 0.1 f/cc standard were passed "today", how. many employees would be recuired to wear respirators? - Cleveland-seven (7 5 employees - Troy-ninety (90) employees (2) How many regulaued areas do you have as of today? o How many employees? Cleveland-cne (1! werk station. tree (3) employees Troy-twenty C 20 ; worp- soarions increase in work stations .5 due to' restructuring of the work 3 L l - U i i CtllU :he inc jase in employees shifts^ *** Both don't include maintenance employees *** (3) How many work stations would exceed the. 0.1 f/cc - - standard that are presently below the 0.2 f/cc standard? Cleveland-seven (7) work stations Troy-twenty (20) work stations . (A) What is your opinion on the feasibility of adding engineering corn :ols to reduce employee exposures to below the 0.1 f/cc PEL? Cleveland- Preventative maintenance will be the key to insure maximum efficiency of current ventilation. / TroyJ It is, believed that additional controls Qiould be added)to reduce the exposures to below tne 0.1 PEL, however, the likelihood of obtaining permit is extremely remote. The timing of this regulation could drive Troy out of the market-place if the regulation were passed in 1991. The permitting timeframe would expend well into 1992 and with the EPA asbestos ban of August 93, there wouldn'r be time WCK007950 r , - s:v v ** 1 for installation of additional ventilation equipment before . s the EPA ban went into effect. Logic would dictate not to J spend any capital for additional ventilation in light of the ^ business being curtailed in the immediate future. '"M - I > . > There is also concern in Tennessee regarding the states I response to increased emissions of asbestos. The State has * already indicated that increasing asbestos emissions either " from increase in production or ventilation is not J acceptable. Dispersion mode ling/impact analysis/risk ] assessments were discussed by the State for any increase in ; emissions. If the Cleveland facility required additional ventilation controls, conceivably, the timing for the ; approval for a permit to construct could be similar to Troy. - * The amount of time required to perform the testing and analysis is extensive and could severely impact upon the plants. This concern has to be hammered home to OSHA that . > the.permitting timetable for increased ventilation controls i could violate the timetable for compliance to reduce the I asbestos PEL to below 0.1 f/cc. This issue is a serious concern for FMD and has to be put into the record relative . : to comments submitted. Please advise if further information is needed: ' CC: J.Bateman J . Fountain -J.Herman K. Macon K.Miller ' -H.Scott WCK007951