Document Rp9XqXy26VbkbYmwLr4a1qXZn

r ZONOLI TE division w. . n*ce 4 CO. LlSOV. MONTANA T*C.WONt HI 4111 F, W, Kupp R. A. lich January 25* 066 iior.fi Jfflca Libby Maryland Casualty Company Dear Frenki We received no report on the October Inspection made by William . Walker of Maryland Casualty Company's Seattle office. His verbal report before leaving was that ne had no recoenendattons to make and that everything appeared to be very good. As far as reports from them are concerned, If Chicago doesn't get them. Libby most certainly wl11 not. Mr. Walker and Mr. Schmidt did taka three dust samples whan they were here In March 1965. Personal opinion Is that they were very Ill-equipped to do any sailing. Their equipment was Inadequate, even If It had beon conplete, which It was not, and they were apparently unfemlller with Its operation. Tha samples were act ually taken with our gear and personnel under their sveervfslon. They had a laboratory In Spokane analyxe the sample. The lab oratory fouled up the analysis and the results meant nothing. I am enclosing e letter from Mr. Parks to Don Carkaner regarding that visit. Wa purloined ar rather conned Mr. Walker out of a copy on a later visit or we would never have known any results. The samples and analysts are worthless. In Mr. Parka latter to you he mentions Threshold Limit Values (TLV) and Maximal Acceptable Concentrations edited by the AC4IN `(American Conference of Governmental Industrial Hygienists) and parts od his explanations art quoted from tha Threshold Unit Value - 1941. On page J of his letter to you In Item 5, Mr. Parks wrote "The 1963 Threshold Umtt Value for Mineral Busts containing lets than IX Crystalllae Silica and asbestos Is 5*000,000 particles par cubic foot of air* This Is the evaluation upon which Mr. Walker has made his reconnendattons." To our knowledge, Mr. Walker has net made such a recommendation. Most certainly he has not made It to Libby either verbally or otherwise. We ere unaware of such a recommendation by anyone except In Mr. Park's letter to you. I am eoclosing a copy of tha 1943 TLV to which Mr. Parks refers. Also some Information from Data sheet 531 published by the Nat ional Safety Council titled Dust, Fuses, and Mists In Industry. Paragraph 6o gives the origin of the Smopcf suggested for asbestos 003981 j ZONOLITE DIVISION W. (t. OffACC A CO. LIBBV. MONTANA 0601648^ F. W. ftupp -2 January 25, 1966 dust. Net* that this Is for tha esbestos textile Industry where all tha dust is asbestos and not just part tremollte as In our casa. We have less than IX Crystalline Silica* Wo have two distinct differences from what Hr. Parka has Indic ated* Our dust contains treaollte, not tha asbestos type referred to In tha TI.V and our dust Is not all tremollte. In Hr. Ian Waka'i report of May 23,1963, Montana State loard of Health, tha Maxlmue Allowable Concentration for us Is 20 ail I Ion particles par cubic foot of air total dust and S at 11 Ion particles par cubic foot of air for asbestos* Ha explains that tha asbestos concentration Is calculated on tha basis of our air-borne dust being 40X asbestos* In April 1963, Hr. Wake had 6 samples analyzed by tha U. S. Public Health Service which Identified the mineral as Treanllte - Act Inoilta in concentration varying from 6.2X to 22.SX. Mote tha use of Traraollte instead of Asbestos and the high of 22.5X Instead of 40%. However, this did not change tha maxima allowable concent ration of 29 mppcf and 9 nppef. Tha 20 oppef total multiplied by 40% gives 8 appef Instead of tha allowable 5<bppcf for Tremollte* Hr, Wake explained that the 20 nppcf total was acceptable because the 5 tnppcf for Tremollte was not an exact dividing line between a safe and unsafe condition but a range at which control should be set. (Report dated May II, 1964). These limits ware referred to in Mr. bike's report of October 2, >964 and ta our knowI edge era still valid at far as tha Montana State Board of Health Ts concerned. We have not been Inspected since that time. For our own purposes, we have vol untarily set our standards at 10 mppcf total dust. I am enclosing our record of monthly dust counts. I can see no reason for further limitations on us. Hr. Parks reconveendatIons are unreasonable and loposstble and unnecessary* I hope thatthe explanations, enclosures, etc., will answer some of your questions. Sincerely RABtelch/rlv c.c. 0. F. Stewart R. J. Kujewa . 0. Lovtck enc *4 PLAINTIFF'S EXHIBIT