Document J3o2eZaX5yD0JMk4Vro98yr1a

AIA-18 'VJJC.V:;:..; - ;j. e * REPORT OH MEETING OP A.I.A. SUBCOMMITTEE ON E.P.A. PROPOSED REGULATIONS ON EMISSION OF ASBESTOS y.**.*.... .w ' >. .y i1"-*'* .: * - -rw.-HT*Za-' :r** " -'?r- CLEVELAND, OHIO 5*" C .i DECEMBER 22,. 197VWJ;- _ . V *** r*. v-T ;*v * .* .* : ** fciE^ ^ -*-** . . ..-v - -***>; x*' *' * " - * ;,,: * i * ' -r - . Wl* " - -a .. ** i:___T*- ^ . *"*"V ' #1 ** *_ **.**J >v.j.'1p ' * -"~* Ml*- \*">r.3s*\*i TO: P.S. Bettoll - S.B.B. C.F. Bien - Linden A.<I*S. Clement - New York .A. Darrell - New York L.J. Faneuf - New York R.P. Fraser - New York J.G. Hall - New York H. J. Holloway - Linden W.R. Holt ~ Erie I. E. Matthews - Vermont R. Van Buren - New York P. Weiner - New York R. J. Wilcox - New York FROM: W.H. Page - Joliet 0i--0217998 I ( *0 . * PERSONNEL ATTENDING; AIA-18 . - - .. Edmund Fenner Isaac Weaver Ivan Sahourin S.A. Saverland Fred PUndsack George Wright, M.D.. - Frank Zimmerman . J. V ' , -- 'mf^ _ T.H. Davison, M.D. H.M. Jackson - - . .. .. . - * I. ' . .. - . W. Robert Bolt - * Wayne H. pigs - < Director Environmental Control Johns-Manvllle Denver Director Environmental Control Raybestos-Manhattan Mannheim, Pennsylvania Legal Adviser Johns-Manville St. Johns, Quebec Manager, Pollution Control Panscon Corporation Cincinnati, Ohio Vice President -- - . ^ Research & Development Johns-Manville . - Manvllle, New Jersey '' - . ; _* Head, Medical Research Div. ; St. Luke's Hospital'. "; -Ohio*- 'ea-4 w - Director ot Safetyc1--' - '* % . National* Gypsum- Company .s~-*^- Buffalo', New York . Corporate Medical Director. *' Johns-Manville Waukegan, Illinois Director, Employee Relations Johns-Manville New York, New York Plant Manager GAF Corporation Erie, Pennsylvania ` Regional Manufacturing Manager * GAF Corporation - Box # 798 ** Joliet, Illinois . * ._ _ ^ 01-0217999 AIA-18 CRITICAL DATES: December 291 1971 Meeting A.I.A. to decide action on proposed regulation. -- January 3, 1972 January 17, 1972 X February 1, 1972 Submit names of witnesses to testily at hearings. (15 days before hearing) : .--January 8, 1972 oJanuary 22, 1972 'XFebruary 6, 1972 Must submit live copies of testimony to be given at hearings.' January 18, 1972 February 1, 1972 Hearing in Hew York ' . Hearing in Kansas City . . -p . . )C February 15, 1972 Hearing in Los Angeles : January 4, 1972- -. '- a-- Johns-Uanville Group to - > . */ * . " * - \ " '" review their., testimony. . ^ ni. *-, - March. 5, 1972 \ ~ r *- `.-'L-:-- ..** * *i.r'-^"V *r` *E.P.A. accept written comment*-1" ^ until .this. date. '- s iTy ** '* - '. * _ m . * - *' *. * . ' jjr J . *'.. / . - * 4 . ' 1 ***--**-- ;* ---.'l * *. , . -* - ,, ' \ r. ^ * -f W ".......... ~ ....... ;sr ": -T : . - - ' 01-0218000 AIA-18 The meeting was held to review proposed emission standards and to determine if any objections should be made. It was the consensus of the group that It was best to take the position that sons controls were needed; that the group was willing to cooperate in this important ares, where the proposed standards were practical and feasible and that the economic conditions permitted compliance; that on the points where we differ a statement as to why and to propose a constructive alternative with reasons why the alternate is better. Suggested changes were: 61.09- That the 30-day period be changed to 90 days to provide time for administration. 61.20 61.22, (a), (3) 61.22, (f) 61:21, (h) GAP requested that the reference to surfacing of roads be deleted. This applies only to GAT. The committee said that Dr. Sellkoff ' had made specific statements -. that this was very detrimental and doubted if 2.P.A. would delete - it. It is felt that this item ' -- . can be corrected, but only at -.*.*:.** considerable cost toGAFr' Thim'^' ' point should be covered , by GAP* *. Be changed to read essentially.. ~'-~- Particulate matter means, any.: . __-* asbestos containing material other v. than uncombined water .....................-- ' *-?-- ---T T -r Visible emission means................for this subpart any asbestos fiber emission................... . 61.22, (c), (1) Be changed as follows. - In direct forced gas stream containing particulate matter resulting from manufacturing or fabricating operations, . these shall not be any visible emissions, ..* Mr. Bettoli has suggested that we propose a constructive- - ' alternative and X feel that this is an excellent suggestion. ____1 would suggest that some wording such as mine roads surfaced with asbestos tailings shall be treated with- "'7* water and/or chemical agents'to control visible emissions ^ ^'-for* vehicle traffic. - - -........ - --...........- - ........ 01-02i9001 * AIA-18 Discusaion of other areas Included: 61.13 The secrecy aspect of process data. It was stated that this was common terminology and that it was felt that if data was classified confidential, past experience Indicated it would not be disclosed. 61.22,. (b). CD It was felt that Jlf and GAP should indicate that technology for eliminating visible emissions from tailing dumps had not been developed and that there is not -' any indication that this problem .. _ can be readily resolved. A maximum . ' - . waiver would have to be requested. ~ - The committee questioned if this ... reference would be eliminated by E.P.A. GAP would also have to X devise technology to eliminate -. wind blown dust from discharge of conveyors onto pile. `T.v ' : - , -- ifcX/X'^urd.'like .to-'-jpoint^duT.'tfiat.'^.r - Canadian emission standards..contittuTv.nA`l-- Jto be less restrictive, -it^places^ GAP and .other u.SV firms in as - unfair competitive situation. - - . ." Tt .was the' consensus :df.; the group that they would not oppose the ba- ^ . V'Oh spraying of asbestos on. buildings . ." ; ' or* structures as fireproofing. It , was felt that the use of sprayed ...asbestos on boilers, etc., was . _ permitted under 61.22, (e), (2), (3). ].<'/ ' ' .. GAP is also affected in another area by this same paragraph, which is the wet rock storage pile and for which --feasible technology is not presently available. This matter should be further discussed to review the . > possible solutions, :- ..... a 9 Qi-oziBOO-z** \ AIA-18 * * *. V' Discussion of Testimony: It was the consensus of the group and Hr. fenner is to recommend to A.I.A. that this organization monitor all the hearings and that A.I.A. testify at the Los Angeles hearing as a sort of rebuttal for any testimony prejudicial to our case which vas presented in Nee York or Kansas City. Johns-tfanvllle plans to testify at the New York hearing and a rough outline of their -testimony is attached. It was suggested thvjf rrther tmirimlri inulil .limply m I a I >' 11 if* v sews Tiliu mii il with tbs' Jobnh^Manville ppsiiLom9^p=te*-^tSs^cHna-Hanville' fitness y they *reeprreesenntte^d* a*ty mapiny requesting . It was_auggest@3^that Johns-Hanville could present /the economic testimony and that Dr. Wright and Dr. MacDonald wonld-preaont the health aspects. I feel^tfiat GAF should testify especially on Cfie tailihgs pile problem,^ibe-Toadway problem, and the effect of competing with Canadian mines who are not under such stringent standards. ) It may be wise tos^oordinate any economic presentation to avoid duplication, but-the ef feet-Jrt^naa on GAF., is. vital to our operations.--r ,, ` The proposed emission standards will- affect the' Vermont Vine, the Floor Tile plants at Vails Gate, . Joliet, Houston,.and Long Beach, Erie 16th Street, / v Whitehall, the Mineral Fiber Plants at Bound Brook," - Mobile, and St. Louis. The Building Products Plants" producing paints and plastics, Joliet,. Erie, Kansas City, Millis, Baltimore, Mobile, Minneapolis, : So. Bound Brook, and plants processing asbestos felt, Joliet, Erie, Mobile, and proposed installations at Kansas City and Millis, will be affected. In general, any operation which produces a visible emission of asbestos containing particulates must be ducted to a bag filter, with certain filter media. - - ; J*. - rv mV'-'-* . *.i * 1-0216003 AIA-18 .V- . lv. v '* * -- i>.' / -iv. * * ' v* -.i-i . - i* " '.iV* i--i "y.W* >' ' --* ~ v . `-i ' As specified, unless there is a change in the regulation, it will also mean that any forced gas stress would also have to be filtered or proof offered that the emission was less than it would be if it were filtered. Several other areas of concern would be the fact that we have a fairly tight timetable: December 7, 1971 Preliminary regulation published. June 7, 1972 Final regulation to be published. September 7, 1972 gust be in compliance or have requested a two-year waiver." - September 7, 1974 Final date of compliance. This means that a major engineering effort must be expended to determine the best technological means - of resolving the emission problems confronting the ' various plants. The cost of compliance for the corporation will be quite high. Mr. Matthews has ." estimated the cost of complying at $250,000 without ' the tailing dump and roadways. I feel that this is , very conservative and for us to bring the interior of the plants into compliance with current O.S.H.A. Standards of five fibers7 per mllillter. - -- I would estimate that the total coat at the othert * plantq might be in the area of $500,000. It is very important'"that we obtain some test data" as soon as possible using the same memhane filter as used by 8.P.A. and 0.S1H.A. Johns-Manvllie made a statement that the air from a bag filter properly maintained Was 0.5 filter per millliter. ' ;r**r. f -;'ry-'-r' rr.i><' * l r.I<r~v^ --- --01-0218004 fI ,' - , .. e ... AIA-18 December 22, 1971 OUTLINE JM TESTIMONY Prepare testimony along lines given in Chicago. J.B. Jobe gives this testimony 1. Recognize need lor controls; 2. Discuss economics of industry in 9.S.A.; a. Value ol goods used - mining industry . - mlg. industry - b. Value of goods produced - mining Industry - mfg, industry- c. Number of people employed directly and payroll; . d. Number of people employed indirectly and estimated payroll; 3. Discuss estimated cost of controls as required - : - by proposed regulations; . -4 , Dr. George Wright gives r? T'tbis; testimony *r " .. Place issue of health in perspective; a. Review background of health questions; b. Review epidemilogical studies; .. I* Knox-Poll studies; . .... 2.. Newhouse studies; "' - 3.-811ikoff studies; 4. MacDonald studies; -- ' ' ' 5.-Others - ' *-*"' c. Place isolated cases cited in medical literature in perspective; ' di Review 'animal studies; L. W. Smith, 2.U. Stanton, NIH 3. Gross .4. Others ,rir, "V", _. Ed Fenner gives this - testimony ..5. Address remaining testimony to specific points of v . proposed control regulations. On those points. which we differ, state why and propose a . constructive alternative with reasons alternative is better. .. i *; ... . . Corbett MacDonald could be Invited as an independent i.' . . witness . . _021806 oi AIA-18 Recommendations: 1. That GAP testify at the New York hearing and that the.name of person to testify, probably Mr. Fraser, be submitted by December 29th. 2. That the testimony be prepared as well as suggested wordings for 61.20, 61.22 (a), (3), 61.22 Of), 61.22 (b), (1), 61.22 (c), (1). 3. That our testimony be coordinated with JohnsManrille to avoid repetition. 4. That test data using membrane filter be obtained at once in all our plants. 5. That engineering be started at once to design filter Installations for our plants. 01-0218005 1 AIA-18 6. or. Pundsack testify on following items: . a. Build-up of fiber concentration in air; b. Fiber dynamics in air; e. Consumption of fiber and changes in recent years; d. Explain that fiber is not indestructible; e. Asbestos gets in air from earth's surface. Serpintine is widely distributed. j * 4( i* .x , <v4'` '4* *5t . . .. \..TrT-z';s ** ri "trr >f.v **' V- * '' ,% * T . f. :*: -v, - ^* r. - *--*'.** v y Xi- *. , - *..*. r ' - _ >*' 01-0218007 until the ro.Vn, iind re* eoeAsi on the p.t^nW fitnn *ith oopythereof placed la the locuaiouve i "h, - ,, 4- it points where the crew of one curler tate> over control end ocerstion of t run-ihrou-h or mui twa from the cm of msothrr comer, be inspected to detertnme motive cab contains the - fora, brake pipe lenu' 5 pounds per muaitc. a sppiy cad rt'^aoe on t' 20-pound semee brak pres.-1 dagton. If the loco;* contain the traps most be areort the present mnuimr.ertt* ,,<o>-fh> aec^Aoited i lit] social^ o^^njftiean tauon nii'jny __hearing. al i samlt.]0b.WRA wui con10 An. on 9332^asslf lnrton. DC.^ Street SW. Hasordowt Maitriols Regulations Board I 49 CFR Bart 173 1 . lOocktt Xo. KJt-M. Naur* so. Tl-mi TRANSPORTATION OP HAZARDOUS MATERIALS don PropeUonf Explosive* in Fiber Drums; Notice ef Extension of Tima ta File Comments On November #. 1371, the tlsrardnus Materials Resnhitinn* Board pu&Ushed Docket No. HM-93: Notice No. 71-2* (3C FJL 213C0*, Clan B Propellant Explo sives la Fiber Drums. In response to a petition filed in accordance with 49 CFIt f 170.25. the Board has extended the pe lted lor comments on tins notice of pro posed rule making from January A 1973 to February 23. 1973. Till* extension is made under the au thority ef sections 131-935 of title IE United States Code, end section 9 of the Department of Transportation Act <49 U.S.C.I937). Issned in Washington, D.C. on I or eoiwAwut* to. fcwfcresa.-.r-- m.iy enierf- jin mortality or as increase in serious irrereruoie. ot inecpadtaun* rcvciiiDlc. mrwn; ntus. n so. (3) what standards should be adoptee to reyuinte enussiona ef such pollutants The Administrator is required, under sec tion HE to establish standards at ths level which In his Judgment provides an ample margin of safety to protect th public healtii from any hazardous au pollutant, unless, on the basis of infor mation prorated at the hearings. bt finds that such pollutant dearly la not a hazardous air --wm*hs Accotdtnclr. partlcipftntii tn the hearam aro re? cn-.'.:tcd_to..itlmttiiy sneetfiemiy tno nor- Ltheir mxsentrtiotw. if_nny^ rfctrtito tlie it.ue of whether the ^""LgLgisa^His qejit. '^Ai'r.prtiaa gghctaqt.jas fioiincd in seetum 112(*> 11) oftirejtct. -- - William H. Mcuuunell hereby is designated Presiding Officer for the bear ings. Ho will have the mponslbUttr for maintaining order, excluding internal or repetitious matmtal: scheduling pree- antattoos: and. to the extent ptuUbie. notifying porttrtpoats of the time at The an Informal' andwtUbwcf uddeted in accordance 49 CFIt 3UJ \ ly a representative dcsil acted by Administmtor. The liear tag will be a aonsdvemry proceeding ar 13, 1971. Abur Z. SottnSi i Secretary, notorious Material* Regulations BoroL | Doe.n-l3S7 mm ta-15-7l;:7 oa| and. themore, there win be no cre*s- exxminaiios of persons prssentintr state ments. The representatives ef the mlnlsirator will make an opening stated mens outlinine the scope ef the r.eonng. Oral statements should highlight and topics dheussed and written mmn PROTECTS MESY eommrau Bled pursuant to Wte natlre published ha the October 20, 1071, issue ( 40 CFR Part 611 of the FDnut Rimma, and rhould NATIONAL EMISSION STANDARDS which they may appear. The hearings wiB be conducted informally. Technical rules of evidence will not apply. Persons wishing to make a at a bearing are requested to file a notice of neb intention not later thanjsmva PTlor to the appropriate beazteg and; not later than in dam prior to the appro priate hearing. If practicable, to submit flvo conies of the prowl statement to the Administrator of the Eavtronmartal Protection- Agency. ARentten: Presiding Officer. Hazardous fintaka et--si-w Hearings, Bo. 17-79,5909 Fishers Lana Rockville, Jdd. 20952. . . foesa upon the contents ef that notice. FOR HAZARDOUS AIR POLLUTANTS After alt tntiial statements have been, completed. those pencils who wish to . Notice of Public Heariags Dated: Drrrmher LS^IFIL, ^ make brief rebuttal Statements will bo given: the opportunity to do so in the same order In which they made their initial statements. Additional procedures. If necessary, for the conduct of t!u> liccjJnr will be announced at Use hearing; - . ' Section 112<7 <l> (BT of tlie Cam Air Act,-M amended be Public Xaw 95-999; directs the Administrator of the finironsmital Protection Agency to pni-Iirh propo.'-d reductions ot;.bashing cmlsrtoss rtundcunls for hcsirdotB air pottnt- Interest*! pcicsna axe invited to at .sms tasether, with a noUco t* petiUe ' [f39BSil-ll4afBdl|4H>AlliBU. FECERAL Cfl*j?uOTTniis ; :i r [ tend the bearin' and to present oral hrarinq. Sueh resulatlonv lor asbestos, stattvnrnts on* the matters lnrrlved. in beryllium- end mercury were proponed In this prccecotnc. TTicre statement* will the Oscrmlxy 7. 1071. isuc of the Fso- 147 CFR Forts 2.' 21, T. 97, 99, 91. 9SI . .. be stfida a pars of the public docket of csss llKontn* et iurc't'4223. (DocketM. 199UZ * the notice. ... - AU communlcaUoii: coneernlne the bearin'. and nr-n should be endm^ed Notice Is hfii>y givi-n of public I^urfcrs etmcrnmff tlie pruro-MT ha.snlons emlssiuit staiuiardv to l.' held at the fol DIGITAL MODULATION TECHNIQUES IN MICROWAVE RADIO to the D>'ttt Clerk. OiSco of Heart? and rrcectdia;-. Federal Knil.-nr d ministration. Aitmina: Docket FB-5.409 Seventh Sum SW. 'Wa.diln.i too, DC 30339. lowin'-; dales, time* m<d plitcsn: JsatEWy tt. 1072.1einr!i"* < lilim. m. OA Cniueu Court Iiut'it.ue. C-njiu\-a mf;Uu.!,liwm tOt.l t'.iklJ liwa. Tits Notice of Inquiry; Extension of Time for Filing Common)* In ti.- matter of inquiry Into the use of digital modulation tcclmtquea to micro This notice in iwi under tt-a? aulh'" ity of section 9. title 45, Uni*i rit-.iij Code, and section 21131 of flic rc-oii tblotrnasttcoaf (h9ecJmejs:imlJi lR>a.ilroad Atluuif HCdtfainXJunjtdn, Jjg, ui DvC ter 10.1071. .' - -. Joo* W. Ixessit * . Administrator. , m OMTUiasn rw t*-i-n;c;4< Mil ivnraiirv l. 1072. b-*-!;nfii- *t 10 .m_ *w.,, : SiWUim r.ittli;:::-. i,m o; l. ITT? list- liW .1'OiH. Kmua-. C"y. MIX t<`~nt^rr is. Ui.*. it) t nt- pa.;, VS C,xml<eu r. uncut ion. 112 Km) Fpetiut S'l--t. Luo Ar.rvi*-;. C.V. Tliera h-nrtnm ue intended to provide epDoeturuly Ir tntervxted prrsens to slate ifiuir views or amtimew* or to pro vide lufonnation as to: 11) Whctbet os- bestow beryllium, or mercury, when wave radio, the dodmblltty of tmpnsing rr.'i rirtiens on the use of such tesimlquca, and tlie possibln amendment of Parts X 21, 01. 97. 93.91, and 01 of the Commhsinn's rules and lecutattena relative thereto. Order. 1. on September IE 1971, the CommisEtun released a notiro of inquiry in this r---'ding tree 71-9)0) dedg- niUt., *ovember IS and December IE t 197L, at dates for filing comments and cx-i fictrst uciitu, you -ntuwosr. Knvui it, ivn / ..i 1-0218008