Document JrB12zXEdXVB9p7B1Mw7zGOo6

Combustion Turbine Systems Div. November 27, 1979 - Comments on Proposed Federal Rulemaking Restricting Use of Asbestos Mr. John F. Gormley, Director Product Safety and Integrity R&D Center, #601 - <----- iVED NOV 301979 PRODUCT SAFETY ' t.?.TG!3TY n--n lii The Combustion Turbine Systems Division has utilized asbestos materials in four areas of our product line; i.e. 1. Turbine engine insulation . 2. Hot piping insulation 3. Expansion joint fabric component 4. Gaskets for joints in hot pipe assemblies Some years ago, we successfully implemented a subsitution program and have completely eliminated asbestos from Areas 1 & 2 above. Area 3, the expansion joint fabric is ' shortly expected to be successfully replaced with a workable substitute material. The remaining item, gaskets, will be the most difficult for which to find a substitute. We use this item installed as a finished product, slipped into a steel flange assembly which, when bolted together, is enclosed, thereby eliminating human exposure. The essential ingredient for our success has been the commercial availability of usable substitutes. Cost has not been a factor for us. In reviewing the issues high lighted in your letter of November 9, 1979, it is clear that we must address "Essential use" of asbestos; the problem being how to define what is essential. p--n A-good example is our presently unsolved category 4, gaskets for high temperature piping. We use a product called the "flexitallic" gasket which is a combination of metal and asbestos. It is a standard product in industry for this application. We have no immediate substitute avail able and cannot operate our equipment without the product. We, therefore, consider this an "essential" item. 03112612 040752 2 \ We endorse the government motives aimed at improving the health and well-being of the population but we are very concerned about the potential here for getting involved in laborious justifications and unnecessary paper work simply due to unworkable or unclear definitions of essential use of asbestos. Thank you for the opportunity to comment. -" r--n ESI /* tt. c* `' v J. Citino, Mgr Systems Engrg. CTSD ESI 9 C=2> <s> 0311261