Document dQJoGd7BzKo3kq7V1KyNzmqEQ

FILE NAME: WR Grace (WRG) DATE: April 13, 1973 DOC#: WRG332 DOCUMENT DESCRIPTION: 1973 Letter to TP Feit from JR Quarles regarding regulations From: david egilman To: Barry Castleman Date: 11/17/99 Tiine: 1:16:38 PM Page 2 o f 4 UNITED `.TATES ENVIRON V.ENTAL P R O T E C T IO N A G E N C Y W A S H IN G T O N , D .C . 204CO 1 3 APR 1373 CN?OBCML..ToAKm'oJ cCCoNrEC.AL Mr. Thenar P. Felt, Manager Cons.truerion Products Division * w. R. Grace s. Co. 62 Whittsmore Aversuw C^r-bridg.. , Massachusetts ^219 0 Dear Mr. Fait: - You have brought to our attention that our regulations limiting emissions of asSes tos, beryllium and mercury, which became effective April 6, 1373, could cause sub stantial disruption, in the building industry depending upon the definition of "existing sources." The regula tions prohibit spraying of insulating and fireproofing _ materials containing more than 1% asbestos on structures, pipeo and conduits. You advised, us that many buildings a:e in the process of being sprayed with. insulating and fireproofing materials containing more than l*. asbestos . z.r.z many -ore are about to be sprayed. You also advised ~s-- that changing from one t_.oe of fireproofing material -r another requires a number* of approvals, e.c., architects and underwriters ^.pprovarr , welch inevitably will take several weeks or more to obtain. Therefore, if spray operations now in process or about to begin are not con sidered existing sources and thus' giver. 90 a?.y; to comply- : with the 1% asbestos materials limitations, many construc tion jobs will have to quit for some weeks until necessary approvals are obtained and 'changeovers of equipment and materials are made. In our opinion, fireproof and insulation sprayir.c opera tions are in the nature of existing sources anc should be treated as such. Therefore, as permitted under 5112 'a) (1) (D) (i; c: the Clean Air Act a; - gfl.es (c> of the regulations, PLAJNTiFFSf GErXUHIOBI:Tf II 11/17/99 14:25 TX/RX NO.4754 P.002 From: david egilman To: Barry Castleman y 4 Date: 11/17/80 Time: 1:16:38 PM Page 3 of 4 2 spraying operations will be permitted 90 days to comply with the 1% asbestos material limitation. We believe that ths 90 day. period will be adequate to. enable all spraying operations to convert to loss than 1% asbestos spray-on materials anc do not anticipate* granting any waivers for spray operations beyond the 90 day period fro/.. the effective date. . If you have any further questions, please contact Dick Denney or Sd Reich of r.y staff. vv. . , L^-'p -- i cV-_-- -Cohn R. Quarles; r. 0 (.Assistant Administrator for Enforcement and General Counsel 11/17/99 14:25 TX/RX NO.4754 P.003