Document N6xLMYypwg968qL7vXRyOeQ8
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Jul 29 2003 12:20
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INTERNAL CORRESPONDENCE
Plaintiffs Exhibit S-UC-382
JNION CARBIDE CORPORATION po. BOX :i.'
'.Ir'TALS DIVISION
! ' '.V i-L! JUNCTION, CSLCMACJlJ iii * jyjJS* 0035 gA`s 3700
- Mr. R. F. Wolff -Metals * Section HI371 5 Danbury, CT
November 12, 1982 E/R-Occupational Health
Amt
R. F. x, Fusaro, w/o attachment
J. L. Myers
"
E. A. Piersall
M
. R. W. Rebholz
"
) H. C. Thurber
*'
Sy&tW.
<cr
Reporting "Health and Safety"
studies to EPA under TSCA Section 8(d)
(4.3,12.2.2)
As you are aware, the Corporation Is required to submit certain unpublished "health and safety studies'1 to the EPA by December 4, 1982. In order to do
this, the Corporation has set up an ad hoc task group to coordinate the activity and do the final reporting. The attached letter of October 21, 1982, from D. L, Haywood describes their activities and time schedule.
Specifically, the domestic Divisions are requested to do the following:
a. Identify a single Division contact for the effort. (November 4, 1982)
b. Identify chemicals on the first list (see Attachment T, pp. 38791-38798) which the Division manufactured or processed
since October 1972 and for which, therefore, submission of any applicable health and safety studies is required.
(November 17, 1982)
e. Itemize any known studies in Division files for which reporting
may be required.
.
(November 26, 1982}
d. Develop a Division management review system by which the Division may approve, request confidentiality treatment for, etc*, any studies whieh the Corporation must submit on chemicals which the Division manufactures or processes.
(November 26, 1982)
'
e. Convnunicate the conclusions of the Division review of the
proposed submission to HS&EA. (December 2, 1982)
PLAINTIFFS EXHIBIT
A4129.00
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The following actions have been taken or are recommended to comply with this request;
a* D. L. Haywood has been notified that H. B. Rhodes is the Metals Division contact
b, The only Item on the reportable list that clearly applies to our Division Is asbestos. The list of reportable materials has been circulated to the locations and to others to check that none of
the otter materials have been 's&riuf&cturea1 or 'processed' oy the Division in the last ten years.
c. The only known asbestos studies that may need to be reported are two1 made by the Mellon Institute in 1966 and 1971. These, however, appear to be older than the ten-year cutoff and may not be reportable (attached letter of October 26, 1982 from J. L. Myers).
There Is an additional Igrey area that should be noted. Over the past years we have developed a number of aggregations of industrial hygiene data that show the kind of exposure levels that have been found to occur for various uses of asbestos. Depending on how the regulation Is interpreted, these may or may not be reportable. Based on the
latest Corporate interpretation (letter of November 5, 1982 from
R. G* Hanlon) all of these can be classified as "simple aggregation and statistical analysis of routine monitoring results" and as such are not reportable. Unless the*guidelines change, we plan not to
report these studies.
d, Unless some other reportable material turns up In our survey, which Is considered to be quite unlikely, we have only two asbestos docu ments that are possible candidates for submission. On this basis, it seems most useful to have the Division review group consist of
the appropriate vice president, or person(s) designated by him. Mr, Fusaro, and the Occupational Health Manager.
e. I will handle this directly with the Corporation when the appropriate
approvals have been received.
Please let me know if this Is acceptable.
Very truly yours,
HBR/SW
H. B. Rhodes
*