Document bBywBO7q9EyJG3oM6DzykbYwZ

FILE NAME: Kaiser Gypsum (KG) DATE: 1972 Mar 1 DOC#: KG012 DOCUMENT DESCRIPTION: Letter from KG to EPA K A iS cR G YPSU M CO M PAN Y, r./.i:ss CENTCR-3G0 L-i:lil5 L ? iv i OAKLANO, CALIFORNIA 9460 IN C. March 1, 1972 Environmental Protection Agency O ffice of Air Programs Division of Compliance Research Triangle Parle, North Carolina 27711 Gentlemen: As users of csbesios in some of our products, we had our representative attend your public hec.-ing in Los Angeles on February 15-16, 1972. We were interested to hear that the proposed prohibition of the spraying of any asbestos-containing product on any portion of a building or structure included in its broad terms sproy applications which the EPA was unaware of but did not necessarily mean to ban , We refer to those operations where the asbestoscontaining product is slurried before spraying and adhesives coat and enclose the asbestos fibers in a bonding m atrix. We market products which are used as decorative ceiling and wall textures over gypsum wallboard. They reduce housing construction costs by eliminating certain costly finishing steps and through labor-saving spray application. We also market products which are used as surfacing compounds to conceal and protect the heating cables in electric radiant heat ceiling systems insfclled on gypsum wallboard. One particular construction design of these systems is rated for one-hour fire resistance by Underwriters' Laboratories. A ll these products are slurried before spraying, are sprayed through small orifices of diameters of one-half inch or less, and coat and enclose the osbestos fibers In a cementitious matrix which hardens as it dries. These products confcin a maximum of 12% of chrysotile asbestos. These products are thus similar to the roofing compounds cited in testimony by M r. F . H . .immerman of the Asbestos Information Association ond to the plaster fireproofing products cited by M r. B . R . Wi I Herns of W . R. Grace and Comoany. They would be expected to show extremely low airborne asbestos fiber emissions similar to or lower than those reported by M r. Williams for a product containing Pcge 2 . We nave not yet found substitute materials which yield the product quality that osbestos gives to these products. It is unlikely that the fire roting of tHe radiant heat ceiling system could be retained without the use of asbestos in (he surfacing compound . Should the Environmental Protection Agency, after its review of the testimony given al the hearings, see fit to modify the proposed prohibition on spray applica tion of asbestos-containing products, v/e request that the modified standards mcl;e provision for the use of the products we hove described. We recommend that the proposed standard be revised as follows: Paragraph 61.22 (e) The spraying of asbestos is limited as follows: (1) The spraying of any product which contains asbestos on any portion of a building or structure is prohibited, with the following exceptions: (1 .a) Wall and ceiling texturing products and rediant heat surfacing compounds containing less than 12% chrysotile asbestos which are mixed to a slurry with water before spraying, are sprcy-opplied through orifices of a maximum diameter of one-half inch, and coat and enclose the asbestos fibers in a cementitious matrix which hardens as it dries, and are applied over a solid substrate such as gypsum w all board. (2) The spreying of cny product which contains asbestos in an area directly open to the atmosphere is prohibited, with the following exceptions: ( 2 .a) Wall and ceiling texturing products and radiant heat surfacing compounds containing less than 12% chrysotile asbestos which are mixed to a slurry with water before spraying, are spray-applied through orifices of a maximum diameter of one-half inch, and coat and enclose the asbestos fibers in a cementitious matrix which herdens as it dries, end are applied over a solid substrate such cs gypsum wall board . , Environmental Protection Agency Match 1, 1972 Page 3 Your favorable consideration of this recommendation is requested. Very truly yours, KAISER GYPSUM COMPANY, IN C . P E . H. Schaper Vice President - Operations EHS/bg bcc: H ,C Dupuis G .BKirk J J S. Sheahan H. Weightman j .* -i-