Document eVE9NG204Y3K91bgn7wVJoVq

OAF COMFOmWOM 1361 Alps Road Wayne NJ 07470 ______ 201 628 3000 February 7, 1980 Mrs. Joni T. Repasch, Record Clerk Office of Toxic Substances (TS-793) U.S. Environmental Protection Agency 401 M Street, S.w. Washington, DC 20460 Office of the Secretary Consumer Products Safety Commission Washington, DC 20207 COMOBRTS ON ADVANCE NOTICE OF PROPOSED RULEMAKING ON COMMERCIAL AND INDUSTRIAL USE OF ASBESTOS 1EBS DOCKET NO. QTS-61005 Dear Mrs. Repasch* OAF Corporation is a United States firm which produces a wide variety of industrial and consumer products, including chemicals and building materials. The corporation employs more than 16,000 persons in over 100 locations throughout the world. A copy of the most recent annual report is attached (1). The advance Notice of Proposed Rulemaking (ANPRM) on Commercial and Industrial Use of Asbestos Fibers was published on Oct. 17, 1979 (44 FR 60061) and on December 17, 1979 (44 FR 73127) request ing comments to assist the Agencies in rulemaking. GAF Corporation has. for almost a decade, cooperated with the Environmental Pro tection Agency's Office of Air Pollution and Hazardous Pollutants Branch, Standard Development and Implementation Division in the development of the current regulations. Not only has GAF prepared and submitted written comments and presented oral testimony but this corporation has arranged visits by Agency personnel to GAF locations (including a formerly owned asbestos mine) so that the Agency personnel could become familiar with the manufacturing process and equipment, and could see how fibers were encapsulated (locked-in and bonded) during production of end products. In 1972, the Agency respon^^d with a letter of appreciation to Mr. P. S. Bettoll of GAi Corporation. The following are comments by GAF , first directed generally to the issues raised in the ANPRM and then specifically to the Agency's questions. Continued- An equal opportunity employer GAF 19346 Mi Docket No. OTS-61005 -2- February 7, 1980 These comments are submitted to assist the Agencies in assessing whether current exposure to asbestos presents an unreasonable risk to human health. It is GAF Corporation's position that, where asbestos fibers are used in manufacturing in accordance with current OSHA and EPA rules, there is no unreasonable risk to worker health or to the public and, except by misuse, no increased hazard to the environment. Furthermore, GAF submits that the GAF products con taining asbestos present no unreasonable risk during their life time to the user, including any removal or replacement process if done under commonly accepted industry standards and recossnendations. GAF expects that complete discussions on such industry standards will be submitted by the various trade associations and, therefore, will not burden the Agency with unnecessary duplication of this discussion in these comments. Asbestos is a unique, naturally-occuring reinforcing material with valuable characteristics: including ultra-violet light, water, rot, heat and fire resistance, high tensile strength, chemical and dimensional stability, and insulation value. The regulatory options described in EPA's Advance Notice of Rulemaking will remove these properties from many important products for which substitutes are. in most cases, either inferior, still in early research and develop ment stage, or so expensive as to be commercially impractical. Generally, alternatives to^asbestos ii. existing products demand an acceptance of lower quality standards as well as lower safety stan dards. As an example consider the result of the abrupt change in lifestyle and the unforseen consequences described in the attached article from the February 3 issue of the New York Times. Because of the rise .in fuel cost, many citizens are Installing wood and coal burning stoves. The correct-and safe methods of installation are being neglected. In homes in which asbestos board is used properly, the risk of fire and disaster is reduced. As reported by the New York Times, 53 lives were lost in Maine in 1979 to fires related to wood stoves. In Vermont 42 persons died in such fires in 1979. One must wonder, and investigate, if asbestos board could have helped prevent some of these tragedies and if the risk from the fiber is as great as the risk of fire. New asbestos substitute products are not only more expensive but many under consideration are also petroleum derivatives - the development of which will increase this country's energy dependence. The proposed regulatory options will have a significant adverse effect on industry, create additional unemployment and fuel Inflation by increasing the cost of building construction, as well as automotive and other products. GAF strongly objects to those parts of EPA's ANPRM under the subheadir*'- Il.elth Effects of Substitutes where EPA indicates that glass fibers of certain dimensions will not be considered suitable sub stitutes "unless appropriate testing indicates otherwise." There Continued- GAF 19347 MUShttAtti Docket No. OTS-61005 -3- February 7, 1980 is no apparent legal authority for SPA to regulate glaas fiber pro ducts ubder this proceeding. Again. GAF expects thorough review of these matters by the producers and associations and. therefore, will not duplicate those discussions in these contents. Finally, GAF submits that asbestos fiber use is sufficiently regu lated under the Occupational Safety and Health Act, the Clean Air and Water Acts, and the Consumer Product Safety and Federal Haz ardous Substances Acts. GAF respectfully cautions the Agency to consider all pertinent in formation before conclusions are drawn. Recent experience of other groups Indicate that rushed and perhaps incomplete reviews have disrupted industries and inconvenienced the consumer without accept able gains in safety or protection of either the public or the environment. GAF wishes to reiterate that this corporation will cooperate to the fullest feasible extent with the Agencies to in sure that the best possible data are available for the rulemaking procedure. He stand ready to undertake, in cooperation with the agencies ami manufacturers, a public education program so that the problans by of asbestos products may be further reduced. SEECIFI? CTMKSPTS For convenience, OAF will, as far as possible, follow the numerical order set forth undair the subheading "Questions 6 Information Needs" (44 FR 60066) in the Advance Notice of Proposed Rulemaking. Obviously, GAF is not able to answer each question posed, and no implication should arise from any failure to comment. 1. Definitions: Asbestos is a naturally occurring mineral of the fibrous amphlbole family. Usual commercial forms include chrysotile, amosite and crocidolite. Other forms of little or no commercial significance are actinolite, anthophyllte and tremolite. Encapsulated fibers are completely enveloped in a matrix of another substance so as not to be directly visible. Examples of GAF pro ducts using encapsulated fibers are floor tiles, bituminous roofing cements and coatings, and sound deadening membranes. Locked-fibers are sufficiently bonded to one another by inorganic cements, thermo-set polymers, thermoplastic resins and elastomeric compositions, singly or in combination, and cannot be readily separated or removed from one another or the product, under normal handling or use conditions. Examples of GAF products using lockedfibers are specialty papers, gasket papers, sheet vinyl flooring, asphalt saturated roofing papers, and facing sheet felts on urethene Insulation with high fire resistance. Contlnued- GAF 19348 itfUMi ----- ----------------------------------7, Docket No. OTS--61005 -4- February 7, 1980 Easily-released fibers have a relatively weak bond to one another and are easily separated or released by friction, pressure or abrasion. Friable materials will crush, fragment or break under low order abrasion or pressure. 2. (a) One hundred thirty two workers are employed by GAF in posi tions for which monitoring for asbestos exposure is required by OSSA, at six GAF locations throughout the U.S. In all cases, exposure is well within OSHA regulations and is by the inhalation route. Duration and frequency varies considerably. Good work practices are actively encouraged, including showering after work, washing before meals and proper disposal and washing of work clothes. Respirator use is encouraged although exposure is below permissible levels. Engineering controls are incorporated into GAF opera tions including improved bag-opening aha handling equipment, hood and exhaust systems for dust control and enclosure of specific operations. 2.(d) Fiber "size distribution" could refer to either length or diameter. All fiber, regardless of length, can vary in diameter from a crude spicule to a submicron size. The degree of filamentatlon depends upon how much ."opening" or milling and mechanical attrition the asbestos experiences in the course of mining, milling, opening, mixing, etc. in the various processing stages. Magnifica tion shows that many individual fibers are partially separated into several finer filaments. All product categories listed, therefore, would contain a broad range of asbestos fiber diameters. Fiber length distribution is also a rather meaningless value with respect to the product categories outlined. While fiber is classi fied by a screen test to designate grade, the normal method of length measurement does not truly reflect the actual lengths pre sent. Even the so called long grades contain many very short entrapped fibers in longer feathered filaments. Another reason why fiber length distribution (and content) is not meaningful when related to various products is that wide choices of different grades of asbestos can be employed for equivalency of effectiveness. For example, an asbestos cement formulation employing 10Z of 4T grade fiber (long) could be substituted for a mix containing 20X of 6D grade asbestos (short). In fact, it is very common to employ blends of various grades rather than a single length classification of asbestos in the manufacture of the listed products. Continued- GAF 19349  ' iii Docket No. OTS--61005 -5- .February 7, 1980 la addition, there are significant differences between fibers from the various natural deposits. Some have better physical properties than other sources. Different amounts of an equivalent grade may be required to achieve the same product characteristics. This applies within one type of asbestos and also between types of fiber. The surface area per unit weight for single grades of chrysotile can vary more than severalfold. This has a pronounced effect, for example, on the amount employed in formulating floor tile, bitum inous paints and coatings, friction products, etc. 2.(e) GAT only employs chrysotile fiber in the 4, 5, 6 and 7 grade classifications for manufacturing products. 3.(a) The following categories of GAT products contain asbestos fibers: Roofing felts Sheet vinyl flooring Specialty papers Bituminous roofing Cements and coatings Floor tiles Class X fire resistant gasket papers Automotive t industrial sound deadening membranes 3. (b) Purpose of asbestos in product: -roofing felts - fire, rot, water and ultra violet light degradation resistance. -sheet vinvl - heat, rot, moisture resistance, dimensional stability, tensile strength. -specialty papers - fire, rot, chemical, heat, ultra violet light resistance, strength. -bituminous roofing cements & coatings - consistency for application, fire, ultra violet light, moisture resistance, : reinforcing, non-settling property in storage. -floor tile - heat resistance (processing), moisture, chemical, penetration resistance, reinforcing strength dimensional stability. Permits use of floor tile below grade. -gasket papers - heat, chemical, moisture and fire resistance; compression recovery strength. -sound deadening membranes - fire and water resistance; flow control; reinforcement. Contlnued- GAF 19350 X Docket No. OTS-61005 -6- February 7, 1980 3. (c) During 1979, GAF purchased almost 71,000 tons of asbestos for use In manufacturing. 3. (d) This information is proprietary and cannot be released without assurances of confidentiality. 3.(e), (hi All worker exposure to asbestos fibers during manufac ture is well below OSHA limits. GAF products present no excessive exposures during use or removal under standard recommended practices. Specific Exposure Expected Purina Manufacture and Psei Sheet Vlnvl Flooring The asbestos felt backing employed in the manufacture of sheet vinyl floor covering contains asbestos fibers which are thoroughly bonded by plastic resins which "lock in" or prevent the free re lease of the asbestos filaments during the course of manufacturing the product and its use. In the production of the asbestos backing felt, the fiber is re ceived in pressure-packed, pulpable paper bags that are stacked on pallets. The entire pallet is placed on top of a special conveyor that is meunted over a hydropulper or mixing unit which contains process water. The bags are mechanically pushed from the pallet and completely submersed in- the water without opening. The action of the impeller in the bottom of the tank disintegrates the bag and allows the pressure-packed fiber to wet-out into a slurry so that there is no exposure of dry fiber to the atmosphere. Latex binders and other resins are added to the fiber slurry where deposition of the polymer on the asbestos filaments takes place. This stock is processed in the usual manner as on a paper machine, and the fiber web is formed with a moisture content of about 50k when it leaves the paper producing unit. It proceeds from there to drying drums, which set or cure the resin binders and the sheet is wound into large diameter rolls which then proceed to the floor covering fabrication stage. In the first stage of flooring manufacture, one side of the felt is completely covered with impervious vinyl coatings that isolate the backing material from direct exposure to the environment. In the course of processing, the back of the sheet is not subjected to any abrasive or other forces that would liberate the bonded fibers into the atmosphere. Repeated fiber count measurements at various stages of production lines confirm this. In the course of application, the material is cut with sharp knives or scissors, and. again, no release of fiber is experienced. The sheet flooring is applied with adhesives which further isolate the fibers from the environment. Continued- GAF 19351 Docket No. OTS-61005 -7- February 7. 1980 The top vinyl wear layer has a vinyl foam and size coat underneath, is designed to be extremely resistant to abrasion. After prolonged wear of the top coat, the printed design on top of the foam layer would be worn away and the product would generally be replaced long before the vinyl foam layer or size coat were lost to expose the underlying felt. When this type flooring is removed, the back of the felt generally is covered with adhesive. Zt is possible in some instances to have bonded felt pieces split and remain on the floor. The fiber in these residual pieces, however, is still bonded by the resin matrix, and ambient fiber count measurements show that fibers are not re leased during this stage of removal. In some Instances, the obso lete practice of using an abrasive floor sender to remove the residual pieces of felt from the floor could liberate fibers to the immediate environment. This is avoided, however, by either scraping the material from the surface or wetting down the floor before sanding is employed. riaac Ills Zn the manufacture of floor tile, the asbestos component is added to the resin batch after being weighed in a special, environ mentally controlled station which is designed to control the emis sion of fiber to the atmosphere. The closed mixing operation yields a large dough-like mass in which the asbestos is completely encapsulated. From that point on, the fiber remains encapsulated in the mass. Any fragments that break off in the course of manu facturing the tile are generally a combination of resin and the mineral components. Zn an increasing proportion of the tile mar keted, the surface of the product is coated with a clear, extremely abrasive-resistant urethane finish. This also increases the iso lation of the asbestos from the environment. A large percentage of the tile sold for consumer application is coated on the back with a layer of pressure sensitive adhesive which, by its very nature, prevents any particles from escaping from the back of the tile unit. Zn all Instances, the tile is cemented to the floor with tacky adhesives. Upon removal, a major portion of this adhesive remains on the back of the tile. Vinyl asbestos tile is very resistant to abrasion, and the rate of wear is extremely low. The potential to liberate hazardous amounts of asbestos during the course of the service life is too low to be measured. Asbestos Rooflno Felt Large rolls of asbestos paper which contains a starch and latex Continued- GAF 19352 ii iTMiiiaii m $, fr --^-*^**3. ***.**.**, Docket Mo. OTS-61005 -8-- February 7, 1980 resin binder are unwound and immersed into molten asphalt which im pregnates the felt to further bond and lock in the fiber filaments. The degree of bonding of the fibers is adequate to essentially eliminate any liberation of fiber prior to saturation. In the application of the roofing rolls of saturated asbestos felt, the material is applied onto a layer of molten, coating grade asphalt. A series of layers are built up and finally the top felt is covered with a pour coat of asphalt, into which gravel is usual ly applied. There can be essentially no liberation of individual fibers to the atmosphere during the course of handling or applying the materials in the complete roofing system. Asbestos roofs are quite durable, and a life.expectancy of at least 20 years is normal ly experienced. With a mineral aggregate surface application, the roof will reach a point of failure without any direct exposure of the encapsulated felt. Since the composite membrane remains essentially Intact so far as thf content of asphalt and asbestos, there is no liberation of fiber during removal. On older, smooth-surface specification asbestos roofing, the top coating on the felt may weather to the point where asbestos is exposed. The top ply of asbestos felt will remain for a period of many years so that it is likely that the rate of any fiber libera tion is at extremely low levels at any given time. There is also the real probability that much of it would be eroded and washed away rather than released directly into the air. Urethane Roof Insulation Polyurethane roof insulation boards are customarily faced with asphalt impregnated felts. When the felt is normally of a cellulosic fiber base, these boards do not contain the highest fire resistance rating. Foam surfaces with asphalt-saturated asbestos felt, however, can achieve the Factory Mutual Class I degree of fire resistance. Attempts to do this with other surface skins such as glass mat have, to this date, not been successful. In the manufacture of urethane board, the asbestos felt is already satur ated in large jumbo rolls. There is no liberation of asbestos fiber in the subsequent course of producing the foam panels or in its field application. Zn all cases, the material is covered by a suitable roofing system that includes several layers of felt and asphalt application. In any removal procedure, there is no reasonable expectation for release of the fiber in the felt skins. AafeftKtga <3ft?Ung Paper Asbestos fiber employed in the manufacture of gasketing and a number of specialty papers is received in pressure-packed blocks which are encased in pulpable paper bags. The asbestos slurries Continued- GAF 19353 i^msamaam Docket No. OTS-61005 -9- February 7, 1980 used in the papermaking process are prepared by introducing these bags into -the rater so that the fiber is released under rater and dispersed with the other ingredients of the finish. Resin latex binders are added to the slurry and precipitated into the fiber. There is no reason to have fiber liberated to the environment during the batch preparation stage nor on the rat forming machine itself. The felt web passes over the drum ckiers. During this stage of the process, the latex which is normally of a curing type, binds the fibers together and by the time the sheet is dry the asbestos is locked in and not dislodged by subsequent handling. The gasket ing sheet is shipped in wrapped rolls and should subsequently be treated by a fabricator in a manner that would not liberate par ticles from the bonded mass. In any event, there is no reason why protective steps could not be taken to avoid any particulate matter release in the course of fabricating the variety of paper gasketings produced. The nature of a gasket is to form a seal between two rigid elements and, in service, the faces are completely isolated from the environ ment. They are designed to have good chemical stability and even the exposed edge, which is frequently covered by a metal, will not liberate any measurable quantity of fiber. Gasketings are generally treated so that they will release from the equipment face when it is necessary to remove or replace them. If any portion should stick to the surface, it can be removed by a scraping tool and this action would not liberate fiber because the bonding material is still intact. If abrasive tools are em ployed, the liberation of fiber can be prevented by wetting down the remnants with oil or water. ncnta and CoaUasa Roofing cements and coatings are produced by mixing asbestos in solvent solutions or emulsions of asphalt. The fibers are com pletely encapsulated. These products are very durable and gener ally weather to a hard, brittle state after many years service. Any fiber exposure by erosion would be at a very low rate and only after prolonged periods of time. 3.(f),(g) All rater discharges and waste disposal from GAF plants are in compliance with State and Federal regulations. 4. Thousands of businesses, both retail and manufacturing, of all sizes will be affected by the proposed regulations. The elimina tion of any category of product will necessarily lower competition and assist non-affected companies in controlling the marketplace. Although future substitutes may mitigate unemployment, the regula tion of asbestos will eliminate certain products, at least tempor- Continued- GAF 19354 riuiss Docket No. OTS-61005 -10- February 7, 1980 arily, and result In a net employment loss. It Is beyond the capabilities of a single corporation's staff to prepare a valid economic impact review of a rulemaking which will impact on such a broad spectrum of businesses and consumers. GAP . is hopeful that the agencies will receive the necessary information as a result of the ANPRM. Further. GAF is hopeful that a careful analysis of the data will result in an appropriate and fair rulemaking. Should the data received not be sufficient GAF respect fully requests that the agencies obtain missing information prior to final rulemaking. 5. GAF has been researching for alternatives for about a. decade. Specific details are confidential and proprietary. However, wishing to help the agebeies' guidemaking we have commented. GAF has ongoing, intensive programs designed to develop alterna tives for asbestos where possible. The agencies appreciate that until alternatives have been proven suitable and until such alternatives are in commercial production the specific details are confidential and proprietary. GAF assumes all companies in the industries Involved are in a similar position and suggests develop ment of the necessary confidentiality procedures so that complete data may be submitted. Until such time, GAF. wishing to be of as much assistance as feasible, submits the following discussion. Roofing Felts Glass Mat Roofing Felts - glass, as fiber glass mats, is a relatively new material for roofing felts and earlier eonsnercial offerings have experienced failure. Conversion to glass mats will require both manufacturing experience and applicator training. Plastic Roofing Membranes - These products have had per formance and application problems and require highly specialized and trained crews. They are generally less fire resistant and more sensitive to damage from the elements. Floor Tiles - Higher cost substitutes in limited product lines are now entering the market. Some laminated vinyl sheet forms lack wear resistance and have not demonstrated good durability. Processing refinements are required to improve dimensional stability and other design changes will require both time and high capital expenditure. Sheet Vlnvl - No proven alternatives exist. Organic floor backings have proved unaec *.wole where moisture is present. They are not recommended "on or below grade" service. A relatively long period of research and development will be required before possible substitutes with required properties can be put into con sideration as well as special non-asbestos mineral felts. Costa for potential alternates are considerably higher. Continued- GAF 19355 mmaxk jffr'g i~)MiiTliiVi^''iii~~ ~fn i~ni' *i ifi I'farr-^ '-' - ifuiit Docket No. OTS-61005 -11- February 7, 1980 SpgqlaltY .Eaatr Fggftwta Gasket Paper - no alternatives with the'fire, heat, chemical and physical property requirements of the current asbestos fiber products are known. Substitutes are in research and develop ment but involve an extended period of development and testing in machinery, piping, etc. before production can be contemplated. Paper Products - for cooling towers, metal sheets, ovens, piping and heating stoves* no known substitutes exist with the heat, fire and rot resistance and product fabrication capabil ity of asbestos, or with the strength, insulation value or resis tance to ultra-violet light degradation. An extended period of research and development will be required to provide alternates for the many areas where specialty papers are employed. Urethane Roof Insulation - with asbestos paper/facingss no substitute exists with as high an insulation value per unit thickness and which has high fire resistance on both sides. One competitive foam surfacing is perlite board bonded to urethane foam' which is only fire resistant from one side. The perlite board is sensitive to moisture and has poorer thermal insulating prop erties. Roofino Cement and Sealants - substitutes are in the early research and development stage. None has yet had sufficient exposure to demonstrate the long durability that is essential for this service. Conversion Time Based on GAF's present knowledge and experience the following table has been developed. The times needed for conversion are the minimum conversion periods expected to be necessary, assuming no major technological problems develop, and anticipating that any proposed regulation will allow a further extension of time, for good cause. PRODUCT LINE BEST ESTIMATE POR CONVERSION AS OF FEB.'80 Roofing felts Sheet vinyl Sound deadening material Floor tile Specialty paper products Urethane roof deck insulation Roofing cements S years 10 years 5 years 10 years 10 years 5 years 10 years Continued- GAF 19356 Docket Ho. OTS-61005 -12 February 7, 1980 An estimate whether GAF or any other manufacturer will change to substitutes for asbestos fibers varies from product to product. In the case of roofing felts, GAF has recently spent $15,000,000 to construct a glass mat plant in order to switch from asbestos roofing felts. On the other hand, in 1978, GAF decided to terminate an asbestos cement product line and close plants because the product could not support the cost of conversion. Future decisions must await the results of current research and development efforts. Thus, in production, application, use, removal and disposal the products do not present a hazard. Any hazard which can be considered must be the result of intentional misuse. Zt should be noted that in addition to plant workers a great number of other employees will be involved in mandated changes in product lines. This would include sales persona, as well as staff functions such as Marketing Services, Materials Management, Finance, Research and Development, Corporate Engineering. Commercial Development, etc. The total number for a firm such as GAF approaches 2000 employees. Effect on Innovation The proposed regulation of asbestos will bar the use of a unique, valuable reinforcing material in future products even if no real risk exists. Moreover, considerable technical effort and funds are being expended to maintain a technological status quo, since presently existing products must be replaced. Alternatives to asbestos, which maintain all of its desirable prop erties. may not be possible to develops. The unique combination of desirable properties in one material such as fire, rot, water and ultra violet light degradation resistance, as well as dimensional stability, tensile strength, compression recovery have not been found in any alternative as yet. 6. GAF believes that none of its present products poses a health hazard to users because the asbestos is either encapsulated or locked in. When applied, used, removed and disposed of in an ap proved manner, there is no fiber release. 7. GAF submits that these factors must be considered in a risk/ benefit analysis of the following products: Automotive Gaskets - This specialty paper item is light weight and generally ringed by metal, typically copper or steel. No fiber release 0** Ke expected during use and removal. Substitutes are heavier, and xess heat and fire resistant. A unique property in this application is the compressabillty and recovery characteristics of asbestos containing gasketing composi tions. This important property is most difficult to obtain with Contlnued- GAF 19357 i1 -tfiriTfn ~-~trmi if ir-mr^^-'^rni ii-^p--y --11 nrim nfr***^ -* Docket No. OTS-61005 -13- February 7, 1980 presently known possible alternatives. Zt is obvious that depend able, proven gasketing materials are essential to transportation, farming, mechanical equipment and the defense industries, as well as other motor and machine using applications. Current designs are. based on asbestos gaskets and massive redesigns may prove necessary. This will take time. Sound Deadening Material - Removal of this lightweight product would result in the use of heavier metal and less fireresistant material to minimize vibration and noise. Floor Tile - Limited substitutes presently on the market are significantly higher in cost and will result in higher housing costs, fueling inflation and further depressing the building industry. Sheet Vinyl, Bituminous Roofing Cements and Sealants and Most Specialty Paper Products used for fire or heat resistance presently lack reasonable substitutes* OAF is considering the regulatory options offered in the ANPRM and submits that these proposals may indeed be unnecessary and dupli cate current regulations. As discussed above, it is GAF's opinion and we believe, most of the industries involved will support our opinion, that a minimum of from 5-15 years will be required to find alternatives for the products discussed. GAF wishes to assist the Agency in the development of acceptable and proper rulemaking. Please contact me should you have further inquiries. LB/bsl GAF 19358