Document mmGBGMK8Xzoojdj0RQ9gov6Mg

PITTSBURGH PROCUREMENT CHEMICALS, PLASTICS & COATINGS PITTSBURGH OFFICE - 19 R. M. JAMES PITTSBURGH OFFICE - 7 1981 JULY 02 t: RECEIVED JUL 6 -1981 one of them, Colonial Refining and Chemical Company's Corro Coat, lists asbestos as one of its components. No question has arisen from the field as yet regarding this material; but in anticipation of some future discusion, we requested the vendor to furnish us with his comments on why we should continue to use his material. Corro Coat is a heavy bitumastic, low cost black protection coating, which you have no doubt seen many times around foundation steel and its corrosion resistance and thick, long life application coating has served us very well in almost all of our plants. On a weight basis, Corro Coat has approximately 11.1% asbestos. Attached is a copy of Colonial Refining's letter and a copy of the article referencing the EPA's ammended emission standard. Would you please give us your comments, as we would like to be prepared to meet questions, if they should come up in the future. This low cost coating has served us well, and we would not like to change unless it became manditory. H. P. JBRUESCHKE HPB/rvg cc: T. I. ALKIRE - PITTSBURGH 21 R. FLANNIGAN - PITTSBURGH 6 Ai EPA Issues Wastewater Pretreetment EPA AMENDS ASBESTOS EMISSION STANDARD Strategy U.&. EPAissued general wastewater pretreatment regu lations. The regulations will affect exist ing as well as new industrial facilities discharging to municipal treatment sys tems, commonly cafled publicly owned treatment works o/POTWs. The regula tions become effective on August 25, 1978. The general Strategy contained in the June 26 regulations outlines EPA's views on pretreatment of industrial wastewater discharges. The\trategy will be reflect ed in the specific'-pretreatment stand ards which EPA wilf\issue for the 21 individual categories. One such catego ry is the paint manufacturing industry which has been furth^rdivided into three subcategories. A /zero pretreatment standard was established for the "oilbased paint, solvent wash" subcategory in 1975. Pretreatment standards for the remaining two/kubcategories, "oil-based paint, caustic wash" and "water-based paints," will be proposed in early 1979 and'finalized 9^12 months later. In the June 19,1978 Federal Register, the US. Environmental Protection Agency (EPA) issued an amendment to its Asbestos Standard which exempts from control all spray-on application of materials in which asbestos fibers are encapsulated with a bituminous or resi nous binder during spraying and which are not friable (easily crumbled) after drying. The Asbestos Standard is part of EPA's National Emission Standard for Hazardous Air Pollutants. This exemption would exclude from control such products as roofing com pounds, waterproofing of insulation exposed to the weather, automobile undercoatings and industrial mainte nance coatings. In their proposed amendments issued on March 2, 1977, EPA considered ban ning the spray-on application of any material containing more than onepercent asbestos. This proposed amendment would have been an expan sion of the control of spray-on applica tion asbestos products which originally related only to the prevention of visible emissions from the application of such coatings. The major purpose of EPA's control of the spray-on application of asbestos-containing materials is to pre vent friable asbestos, that is, asbestos which crumbles easily and is separated into discreet particles, from becoming an air-borne contaminant and a poten tial health hazard. NPGA filed comments on the pro posed amendments with EPA on May 2, 1977 (See Coatings. June 6. 1977) stating that certain classes of coatings, i.e. roof coatings, waterproofing com pounds. and industrial maintenancesystems which may contain asbestos should not be subject to these Stand ards. Such coatings are not a potential source of friable asbestos because even if spray-applied they do not constitute a major source of asbestos emissions. The final amendments to the Asbestos Standard issued on June 19th reflect our industry's positions and provide us with the exclusion necessary for us to con tinue supplying these essential coating systems. Additional information on this subject can he obtained by contacting Ray Connor, Technical Director, at (202) 462-6272. Specifically, tbe~~Jtme 26 strategy requires that any POTW holding a National Pollution Discharge Elimina tion System (NPDES) permit must de If certain conditions are met. industrial dischargers to POTWs may have their velop a pretreatment program consist ent with the June 26 .strategy by 1983. With certain exceptions, POTWs with a daily capacity of less than five million specific categorical pretreatment re- /quirements revised\o reflect consister . poH, ytant re4moval b\> the (_^etreatment regulatio PO`Pt<'fhe Chowev- gallons a1 re ex' emptsi oerr. tthh*aatt esuirochh rrAenmuonuveal by a POTW must not interfere with the operation of the Of immediate impact, the Two 26 POTW or contaminate its sewage regulations prohibit the introduction sludge, or pass through the treatment into POTWs of any discharge which: 1. works into clean receiving waters. would create a fire or explosion hazard, After c^tegoricgt-prStreaTment stand- 2. are corrosive, 3. would obstruct, ards--an issueofor the 21 Industrie sewers, 4. are so solid or concentrated as categories, existing sources must com to interfere with the POTW, or'5. contain ply with their respective categorical excessive heat. The prohibition is effec pretreatment requirements within three tive as of August 25, with the exception years. New sources must comply imme of the prohibition on excessive heat diately. which takes effect three years from that NPCA's Water Qqality-Waste Man date. agement Task Force is presently review ing the pretreatment regulations. As additional information is available re- ling the regulations^rfftj their impact on the categoric^Jg5retreaiment stand ards applicable^ paint manufacturers, it wi(l^bexep6rted to our members. In the meantime, questions concerning the strategy should be directed toeiTTrerBob Nelson or Mike Duff at NPCA. C0AT/lG8"T'rpvblished semi-mj cgprfor one issuexn NoverpbefTby the i 'tional Paint and CoatiUgsAssociation, Inc.7 1500 Rhode Island Avenue, N.W., Washing ton, D.C. 20005. Subscription $9 per year to members (included in dues). Second-class postage paid at Washington, D.C. Vol 30, No 16, August 14, 1978. Editor- Linda C. McCarty Contributing Editors' Bonnie Benhayon, Sue Scheinman. Printed In U.S.A. Page 08--August 14, 1978 DEPENDABLE THEN DEPENDABLE NOW 216-333-1722 REFINING AND CHEMICAL COMPAN> EXECUTIVE OFFICES 20575 CENTER RIDGE ROAD ROCKY RIVER. =OHIO 4411 May 29, 1981 Mr. H.P. Brueschke Senior Staff Buyer Chemicals, Plastics & Coatings Aluminum Co. of America Alcoa Building Pittsburgh, PA 15219 .' Dear Mr. Brueschke: Attached to this letter is a reprint of an article from NPC Coatings, which is the official organization which handles standards being, established by EPA. The article on asbestos is the one I feel that you would want for your records. It does exempt those products using asbestos when those products are mixed in a bituminous binder! ` As pointed out in the article, once the fibers are mixed with the bituminous binder, they are not friable and constitute no hazzard. If any further information is requested, please do not hesitate to contact me. I did enjoy the opportunity of talking to you this morning and I hope that your coming vacation is a very pleasant one in every respect. Cordially yours, James' M McCarthy ficy President leral Sales Manager JMC/cw . ; lK. (X1-*- :- -s. ,/ f 'ty^ y -/ /0, ^ o/> <I I t0 ^cE!VkO JIJN WSl C.H Manufacturers of Specialised Protective Coatings