Document x168d7NeRnBwBx3b4LLEzYRdm

cc: ivir. i i. o. ^`A Mr. E. W. Elmore Mr. J. H. Huguet ETHYL CORPORATION Mr. S. D. Motsinger Mr. W. C. Strader INTEROFFICE Address PLAINTIFFS I EXHIBIT ETCO-283 B. Hunt National Emission Standards for Hazardous Air Pollutants (EPA) Address Date Aug. 22, 1972 We have reviewed Arthur Busch's July 26, 1972, letter to you advising you of the near term promulgation of standards for beryllium, mercury and asbestos. We know of no uses of beryllium on the Baton Rouge plant at all, and hence, we should be exempt from such regulations. We do use some mercury in the sodium area rectifiers, in some plant instru mentation, and in the laboratories, but as I read the regulations, we are completely exempt here also. It appears that our past practice of spraying asbestos insulation bn sodium cells is in violation of the proposed regulations and Hugh Bourque tells me that Maintenance is proceeding to implement a dif ferent insulation procedure. I understand that Houston is not using asbestos insulation, so perhaps we could continue to use the spray technique- but with a non-asbestos material. Dale Motsinger has reviewed the caustic chlorine diaphragm cell rebuilding operation in light of the proposed regulations and believes that there is no problem here. Possibly we might check with the Chlorine Institute to see what the industry consensus is. Overall, I bblieve we will have no trouble in reporting full com pliance with the standards ninety days after their promulgation. Q&jl C. B. Hunt CBH:ar Attachment ETC 15343 E-02300