Document dnV7QRqQkk9yyLRyxpN9rV2Yq

lifTO3oalb3ip M B HUBB-0034117 from win Care $..c,ect Pittsburgh-Chatham Center 295-1786 September 3, 1982 EPA Asbestos Reporting Requirements ro Plant/Operating Managers (MML-5A) cc: Engineering Managers (FML-36) (without attachments) Purchasing Managers (FML-28) (without attachments) The U. S. Environmental Protection Agency (EPA) published in the July 30, 1982 Federal Register the final rule on Asbestos Reporting Requirements. This rule applies to asbestos manufacturers, processors and importers. The EPA requires individual plant sites to report quantities of asbestos used in manufacturing a product, processing bulk asbestos and asbestos mixtures and the importation of bulk, mixtures and articles containing asbestos. EPA designated two groups for reporting purposes: Primary Processors and Secondary Processors. Primary Processors are persons engaged in mining, milling and importing bulk asbestos, or who process bulk asbestos to form an asbestos mixture or product such as asbestos paper. Primary Processors must report on EPA Form 7710-36 "Reporting Commercial and Industrial Uses of Asbestos" by November 29, 1982. Secondary Processors are persons who import asbestos mixtures or products containing asbestos or who start with asbestos mixtures and incorporate them into products. An example of a Secondary Processor would be someone who cuts asbestos cement sheets into gaskets for incorporating into a valve or pump. The Secondary Processors must report on EPA Form 7710-37 "Reporting Secondary Processing and Importation of Asbestos Mixtures" by October 29, 1982. The EPA will then select a sample of respondents from the Secondary Processors who will then be required to complete the Primary Form 7710-36. Both EPA Forms 7710-36 and 7710-37 and instructions for completing them are attached. Each respondent is to complete the relevant sections of the form depending on activities of the plant. Some Primary Processors are also Secondary Processors and will have to complete both sections of the Primary Form. Be sure to use the correct codes from the Instruction Section when completing either form. Several Westinghouse products which contain asbestos are listed in the attached table. (Note: this list is not necessarily com plete for all potential products which could contain asbestos.) Oisca/o Dam: o 53 CS 2- - Exemption from Reporting The EPA has exempted certain classes of potential respondents from the requirements of the rule. The exempt class includes: 1. Companies employing 10 or fewer employes. 2. Secondary Processors who apply, assemble, install, erect or consume asbestos products without modifying or fabricating the asbestos product. Example: an appliance manufacturer who installs electric motors containing asbestos components would be exempted. 3. Persons who repair articles, repackage asbestos mixtures without modification or who engage in construction work. 4. Persons who are distributors and do not manufacture, process or import bulk asbestos or asbestos products. 5. Persons who are "end users" of bulk asbestos or asbestos products and do not further distribute such items in commerce. Example: asbestos welding blanket. Plant's Responsibility Each plant must survey its facility and determine whether the EPA Asbestos Reporting Requirements apply. This initial survey (three (3) year period from 1979 to 1981 if Primary Processor or just one (1) year, i.e., 1981, if Secondary Processor) should include a review of purchasing invoices for either the three year or one year period, any processes involving bulk asbestos or mixtures and products imported into the United States that contain asbestos. Be aware many asbestos mixtures or products use trade names such as Transite, Monobestos, etc. Review the attached table on Asbestos Tradenames. If the EPA Asbestos Reporting Requirements apply to your plant, then a decision must be made as to which form (i.e.. Primary or Secondary Processor) applies. Then complete either EPA Form 7710-36 or 7710-37 and send the completed, signed form to Headquarters Industrial Hygiene, R&D Center 401 3X9, 1310 Beulah Road, Pittsburgh, PA 15235, by October 11, 1982. Do not send any form directly to the EPA. EPA Form 7710-36 asks for detailed data on products, importation of bulk asbestos, worker exposures, waste and disposal and pollution control equipment. Therefore, allow sufficient time to gather this data and complete the form. If the EPA Asbestos Reporting Requirement does not apply to your plant, then sign the attached Negative Declaration and return to Headquarters Industrial Hygiene, R&D Center 401 3X9, 1310 Beulah Road, Pittsburgh, PA 15235. HUB8-0034118 HUBB'0034119 Headquarters Industrial Hygiene Responsibility Headquarters Industrial Hygiene will review the individual plant responses for completeness and then will send the responses directly to EPA. The Industrial Hygiene Department will he available for consultation in com pleting these forms. Call either Mark Perriello, Senior Industrial Hygiene Engineer, WIN 236-5849, or Wayne Bickerstaff, Manager, Industrial Hygiene, WIN 236-5847. ' FSB/mj Attachments Frank S. Beal, Director Environmental Affairs