Document Y62poGwopONmDV9ykZa4o70y

FILE NAME Allied Signal Bendix ASB DATE 1989 Aug 31 DOC ASB133 DOCUMENT DESCRIPTION Letter from Bendix to NY State Dept of Environmental Conservation RE Renewal & Modification of Asbestos Emission Points Bendu Friction Matanais Dension PO Box 238 Troy NY 12181 August 31 1989 d 8/31/89 8/31/89 certified certified mail recieved on 915189 915189 ae Lit Mr. William J. Clarke Regional Permit Administrator Region IV . New York State Department of Environmental Conservation 2176 Guilderland Avenue Schenectady NY 12306 Dear Mr. Clark This letter is in response to your letter dated 1989 regarding the renewal and August 1 modification of 41 asbestos GermeiesnsioInslpaonidnts at the Bendix Friction Materials facility in prohibits As we have discussed the EPA asbestos ban manufacturing of asbestos materials for original containing friction and for 40CFR 765.165 equipment after August 25 1993 the aftermarket aftermarket on August 1996 40CFR 763.165 We have also indicated the department on occasions to the facility is numerous occasions that the Green Island predominantly an original equipment manufacturer with some aftermarket production As a point out that the Term and Conditions ofresPeurlmtitwe wish to one out does time not take frame of in consideration the EPA August 26 1996. EPA paragraph aftermarket phase - the highway safety concern for the has long recognized aftermarket which is reflected in conversion of the 1996 timetable to allow the aftermarket due to vehicle the natural addition we are turnover In alternatives for the actively researching asbestos time frame specified aftermarket and still may need the by EPA to accomplish this task As result we respectfully request that a Term and Conditions be amended to reflepcatratghreaphEPAonteimoeftabtlhee for the aftermarket follows Paragraph one is suggested to read as . Bendix shall reduce total maximum emissions from the entire permitted asbestos TPY July 1989 to facility from an estimated 5.73 approximately This reduction will be 1.2 TPY August 25 1993 of asbestos accomplished through the elimination containing equipment in 1994 friction materials for original or later model year motor vehicles 0831 PLAINTIFF'S EXHIBIT 757 ; . 7 an - * August 31 1989 Page Two Bendix shall reduce total maximum permitted asbestos emissions from the entire facility from 1.2 TPY August 25 1993 to 0.0 TPY August 26 1996 This final reduction applies to aftermarket replacement parts in brake systems designed for use with asbestos containing friction products A schedule covering the amount of asbestos emissions _ reductions on a year to year basis covering 1989-1996 shall New York be submitted to the Regional Permit Administrator State Department of Environmental Conservation Region IV DEC for review and approval within 60 days of permit issuance This schedule may be modified by DEC based upon the outcome of further analyses of air emissions and health effects as well as progress in meeting the 1996 deadline Bendix shall of each year submit to the DEC an annual report due July that indicates the amount of asbestos which 1st has been emitted over the preceding year and planned reductions . for the coming year This report shall be accompanies by ~ applications to modify those asbestos emission points which will be changed in order to effect the reductions on such emissions for the coming year In closing I wish to reiterate that out strategy is to beat the EPA timeframe with considerable margin and will keep the Department informed of our progress per our agreement If there are any questions please contact myself or Tom Ragosta 270-0322 Very truly yours Roron R. Larson Manager Health & Environmental Affairs 0831 a NAPA NAPA RaYLOC NAPA fi DIVISION OF GENUINE PARTS COMPANY 600 RAYLOC DAIVE S.W. PO BOX 43146 ATLANTA GEORGIA 30378 PHONE 404 / 891-3780 June 24 1991 Ms. Sheri Muncey Bendix Friction Material Allied Signal PO PO Box 2610 Div Cleveland TN 37320-2610 Dear Ms. Muncey As the pressure and awareness of the problems with asbestos must be initiated to continue to grow more controls comply with the requirements of the environmental agencies your Your company has been advised in the past about our Some improvements have been made but it concerns with the dust in packages is imperative that we eliminate this potential hazard ' inspect Our policy for all future shipments will be to dirt is prevalent we will reject the shipment and your product and package for dust If All purchase ord^rswill return it freight collect for your rework reflect the requirement for dust free parts and cartons Your immediate attention to this problem and a written action is anticipated and appreciated If response outlining your corrective we can provide additional information please advise Sincerely RAYLOC JH jw CC Joe White Tom Daniel Henry Dunn John George Cherry Barker Jack Hughes Purchasing Inventory Control Manager 800-631-6989 80 -631-6989 PLAINTIFF'S 80 -631-6989 80-631-6989 EXHIBIT 800-631-6989 80 -631-6989 PENGAD 831 PENGAD PENGAD