Document G5voLEE66JNVy7qDeM93NZyYY

FILE NAME: Rogers Corporation (ROG) DATE: 1973 Aug 17 DOC#: ROG045 DOCUMENT DESCRIPTION: Letter to CT Dept of Environmental Protection RE Proposed Air Quality Regulation for Asbestos Mr. tekardt C. Back Director Air Compliance Vatt State of Connecticut Department of Environmental Protection State Office Building Hartford, Connecticut >06115 Deer Mr. Back* la regard to the proposed Air Quality Regulation for asbestos, we have submitfed our letter of July 13 1973 supplemented by our testimony during the hearing held on July 25 1973. Since the record la open until September 10 1973 m would like to submit the following date and additional ccassettes VO feel that the testimony presented during the hearing clearly indicates that further information is necessary in regard to the efficiency obtainable from the SPA specified bag collector. Shis it evidenced by the fact that Mr* Brockman stated that a bag collector of 99.91 efficiency would meet the proposed standard of 25 micrograms per cubic meter. Mr. Clapp testified that a beg collector of 99.0% efficiency would meet the proposed standard of 2S mlcrograms per cubic meter. S representing Sogers Corporation submitted calculation showing that at 99*991 efficiency mad with only 1 grain per cubic foot lending the discharge would be 229 mictograoa per cubic meter which is well above the proposed standard. Me believe that the State, with its subpoena power is most likely to he successful in obtaining from the manufacturers of bag dust collectors a figure that they can guarantee in regard to the efficiency of the unit. To further complicate matters particle else will also have to be considered. St would amtathat the efficiency of the bag collector would vary with the particle else. MT-KAZAN-FIBER-043897 Sir, S'C.8ek Uepartment: of Environmental frotaction Angus 17, 1973 Bugs 2 The m o t problem which rises is testing* lie hove spent a considerable amount of tins searching the literature and have cos to the conclusion that at this tine there is no noil accepted method which can reliably test for the amount of sebostos in a Maple* The testing also appears to be extremely expensive so that it would at boat servo as a last resort referee* As stated at the hearing we also foot that the hermetically sealed method of disposal is restrictive* He feel that any method that disposes of the Asbestos without allowing it to escape should be permitted after approval by the Commissioner. While the goal being sought is commendable ami fully supported by ue m feel that lack of sufficient data at this time will prevent its achievement. A program to obtain the necessary data would permit putting a proposed regulatory system on firm ground and assure it of success* lie would be glad to work with your organisation to achieve a firmly based regulation supported by firm data. Very truly yours, CAB/pvo otfcanrhtd Charles A. gergjbeimer Director of Corporate Engineering MT -KA2AN-FIBER-043898 MTA Proposed OSP Standard 99.991 Efficient Bag Collector a) 10 grains per cubic foot loading b) 1 grain per cubic foot loading 99.9X Efficient Bag Collector a) 10 grains per cubic foot loading b) 1 grain per coble foot loading Micrograms per cubic meter 25 2,290 229 22,900 2,290 Conversion Figures t Igm 15.43 grains leu.meter 35.31eu.t. Proposed OSP Standards 25 micrograms per coble meter or 20 grams per day 25 x 10"" gms per cubic meter. 99.991 Efficient ) Loading 10 gratae per cu. ft. 10 grains x l am. x 35.31 cu. ft. cuft, 15.43 grains 1 cu. aeter . 22.9 a. eu. meter ' 22.9 gas per, cu. meter at .0001 * .00229 gma/cu. meter 2290 x 10" aas per cubic water b) Loading l grain per cu. ft, 1 gr&in x cu. ft, 15.43 grains lg.,, x 35.31cu. ft. bJ3LJBgL&... 1 cu. meter cu. aeter 2.29 grains per cubic meter x .0001 * .000229 gms/cu. meter or 229 x 10* rams per cubic aeter 99.91 efficient a) Loading 10 grains per cu. ft. per b-1- 22.9 gme per cubic meter 22.9 gms per cubic meter k .001 - .0229 gma/cu. meter 22.900 x 10*6 gna per cubic iMiter b) Loading 1 grata per cu. ft. 2.290 x t0~6 gms per cubic meter MT-KAZAN-FIBER-043899