Document kaBqbJd3jOp5mojve0yD060Rb

FILE NAME Allied Signal Bendix ASB DATE 1990 May 2 DOC ASB095 DOCUMENT DESCRIPTION Memo RE OSHA Proposed Standard with Handwritten Notes ete a. Tee : eer eee - em Lot pene Ae. 2B Sap ee ne mee om ee * Memorandum Bendix Bendix Friction Materials Division Green Island New York vy aoviw cc H. Scott Please review & revise as needed . Allied = Signal Date To From May 2,1990 T.P.Rancour FAX C.R.Larson Nied to have revision revisitonhanks for / Corbporyate DELIVER UPON RECEIPT RECEIPT URGENT Sector Subject OSHA Proposed 0.1 cc Asbestos Standard Craig The following information is provided regarding the potential impact upon the plants if the standard were to be passed today today 1 If the 0.1 ' standard were passed today how many employees would would required to wear respirators seven SES Cleveland seven seven Troyninety ( Me e Doses work station stsatattionion station three three / stations stations stations sixty stations sta ionsstations stationsstationsstations the andandand the the three employees employees ) employees . The restructuringrestructuring restructuring in employees is maintenance maintenance ) How manymany work stations would exceed standard that are presently Cleveland seven 7 work stations twenty 20 work stations What is is your engineering engineering controls below the 0.1 f Cleveland- Cleveland- Preventative will be the key to current Troy believed that could exposures controls bbe e to below the 0.1 of obtaining permit The timing timing of this regulation could drive Troy out of the market place if the regulation were passed in 1991. The permitting timeframe would exetendxtend well into 1992 and with the EPA asbestos ban of August 93 there wouldn't be time PLAINTIFF'S EXHIBIT 771 WCK007950 4 cr for installation of additional ventilation equipment before the EPA ban went into effect Logic would dictate not to spend any capital for additional ventilation in light of the business being curtailed in the immediate future There is also concern in Tennessee regarding the states response to increased emissions of asbestos The State has already indicated that increasing asbestos emissions either from increase in production or ventilation is not acceptable Dispersion modeling analysis assessments were discussed by the State for any increase in emissions If the Cleveland facility required additional ventilation controls conceivably the timing for the approval for a permit to construct could be similar to Troy The amount of time required to perform the testing and analysis is extensive and could severely impact upon the plants This concern has to be hammered home to OSHA that the permitting timetable for increased ventilation controls could violate the timetable for compliance to reduce the asbestos PEL to concern for FMD below 0.1 oc This issue and has to be put into the is a serious record relative to comments submitted Please advise if further information is needed CC Bateman J.Fountain J.Fountain J.Herman J.Herman K.Macon K.Miller H. Scott ite e 3 $ 4 bee ai adiabingt ewe 2408 Pans eae a a on . ey are rt ares | WCK007951