Document g2Lxz7B7x8qjgyRr6beprw8Ka

FILE NAME: Kaiser Gypsum (KG) DATE: 1972 Mar 1 DOC#: KG012 DOCUMENT DESCRIPTION: Letter from KG to EPA KAISER GYPSUM COMPANY. K-'- i S i S ' E N T C R - 3G0 l - . : S S l O c ? i v ; OAKLANO, CALIFORNIA 9460C INC. March 1, 1972 Environmental Protection Agency O ffic e of A ir Programs Division or Compliance Research Triangle Parle, North Caro lin a 27711 Gentlemen: As users of csbestos in some of our products, we had our representative attend your public hecring 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 spray 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 ce ilin g 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 ce ilin g systems installed on gypsum wallboard. One particular construction design of these systems is rated for one-hour fire resistance by Underwriters1 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 asbestos fibers in a cementitious matrix which hardens as it dries. These products contain a maximum of 12% of chrysotile asbestos. . These products are thus similar to the roofing compounds cited in testimony by M r. F. H . Zimmerman of the Asbestos Information Association and to the plaster fireproofing products cited by M r. B. R. W illicm s of V/. R. Grace and Company. They would be expected to show extremely low airborne asbestos fiber emissions similar to or lower than those reported by M r. W illiam s for a product containing 12% asbestos. Pc 9 e 2 . . . V/e nave not yet found subit tuts materials which yield the product quality that asbestos gives to these products. If is u n like ly that the fire rating of the radiant heat ce ilin g system could be retained without the use of asbestos in (he surfacing compound . Should the Environmental Protection A gen cy, after its review of the testimony given at the hearings, see fit to modify the proposed prohibition on spray apolication of asbestos-containing products, we request that the modified standards make 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 o f 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) W all and ce ilin g texturing products and rcdiant 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 o n e -h alf in ch , 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 sprcying of cny product which contains asbestos in an area directly open to the atmosphere is prohibited, with the following exceptions: (2 .a) Wall and ceilin g 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 on e-h alf inch, and coat and enclose the asbestos fibers in a cementitious matrix which hcrdens as it dries, cna are applied over a solid substrate such cs gypsum w all board. Environmental Protection Agency Match 1, 1972 Page 3 Your favorable consideration of this recommendation is requested. Very truly yours, ' KAISER GYPSUM CO M PA N Y, IN C d - f m . E. H. Schaper il V ic e President - Operations V. EHS/bg ir- bcc: H .C Dupuis t G . B . Kirk ty t * . . J J S . Sheahan 3 H. Weightman - js i-S *2 sa J * V /C \ A /T*