Document N2XJjDJJX5vg3kXxMDZ4Z7VMR

rv Mr. a. P. Truer NY Mr. W. DarreU NY --CEIVED FEB. 25 1972 ' 1G AC 'J I EPA HEARING IN LOS ANGELES February 23, 1972 Messrs. Bettoli - Deal - Hall - Welpe* &A nt On February 19th and 19th. Mr. Bettoli and I attended the EPA meetings in Lea Angeles. The major part of the first day vu spent on mereary testimony vith Karl Linden, termer head ai Johnn-Manville in testifying la behalf of the Qnebee Asbestos Manateetarers Association. e I bellere all of die points in urtdch GAF hu an interest were covered by the testimony of the A.LA., Mr. Bettoli, Mr. Fraser, which m entered Into the record, sad my testimony. There is still time te submit some testimony to EPA for inclusion in tbs record. 1 basically confined my testimony and Phil Bettoli also confined hie to the material wfaieh m prepared and given to us by Mr. tfeiasr. I prepared some additional remarks concerning the wet rock storage and the roads bat, due to the tenor of the meeting, decided not to give thin u It wu to some degree an amplification of the termer remarks and also because 1 felt we might wish to send this in as separate testimony. The Hearing Officer, Mr. William MegonelL handled the testimony very well in my judgment. He really did not badger anyone, although he wu a little rough on the gentleman from Pacific Aabeston who started hie presentation by comfnrlng the actions of EPA to those of Pontius Pilate when be washed his hands. It wu obvious though that EPA felt they have been charged with the responsibility of eliminating the addition of the 3 materials, asbestos, mercury and beryllium from the atmosphere. It is siso obvious that they did not and do not have enough time to really get all of the facts and make s sound scientific judgment, and 1 so old say all of the facts that are required are not available. They not only have to concern themselves with what is happening today but in the case of those substitutions which do not break down into some harmless materials, have to consider what the addition year by year will do in the future. 10. 20 and 50 years from now. Therefore, I feel if they are going to have to make judgments, they are going to make them on the aide of preventing any of these materials going into the atmosphere. They appear and 1 think, as a result at the trip Mr. Bettoli and 1 took, to be very sympathetic with the tailings pile problem and admitted that many of the items brought up by Mr. Bettoli had not been intended to be restrictive by EPA and that they would search for wording which would permit the use of asbestos roofing felt. However, Mr. Megonell did ask questions as to what would 51-jO --;v 1 - a - lap^M to this roofing when It vu tors off a bUlB| which to to bo demolished. nroofM* tie* There were many other non-industry people there end X hare suggested to Mr. Weiner that he get a copy of their testimony. It is obvious there are a number of citizen groups and many responsible professional people eho feel sincerely that asbestos fibre ia the atmosphere is a very definite hazard and any lavs vhich permit more of tfao asbestos fibra to go into ths atmosphere vould be wrong. X think we can expect these people end groups to keep up the pressure on the government. My own feeling is that whatever regulations are finally adopted, and X believe they will give us some breathing room on the tailing pUe. will be tightened from time to time. While I do ant have the Ml details on this. Max Swetoaic. Secretary of AIA. stated that late Monday afternoon the Department of Labor decided they would adopt the 2 fibre standard. This has very serious implications for tbs Vermont operation. While 1 do not have the technical expertise, it is ay Judgment end 1 believe the J-M people fed the same way. that the attainment of the 2 fibre standard is not possible in asbestos mining and milling. Presently, the Vermont mine is under the jurisdiction of the Bureau of Mines, not OSHA. and unless the Bureau of Mines adopts the OSHA standards, we feel we can with expenditure adhere to the present Bureau of M ines standards and probably with expenditure, if we get a favorable legislation on the tailings pile, comply with EPA regulations. However, if we feel that the OSHA standards are going to be adopted for the mting operation, we will have to make some Judgments aa to what our future is going to be and what, if any. expenditures we will make at the mine to comply with EPA . the Bureau erf Mines and the State of Vermont regulations. My feeling is that the OSHA standards will be adopted aft some point in time and that we may have to decide to phase out the Vermont opt ration. I feel we need to have within our own management a thorough discussion of the situation so we can decide what actions ought or ought not be taken at Vermont having to do with expenditures for pollution control, internal and external, and any other capital expenditures at the WD :mm W. Darrell SI ,, 0 "PC* Pv p