Document xjwBEawE6BV7ZLjOLbkKRQMxm

Chori** E. SrookM. S*ro, vice P'suce"1 W. R. Groce & Co. Grace Plaza I! 14 Avenue of (he Americas New Yo. N r 10036 December 21, 1982 Mr. Edward A. Klein, Director Chemical Control Division U.S. Environmental Protection Agency Industry Assistance Office Office of Toxic Substances 401 M Street, S.W. Washington, D.C. 20460 Dear Mr. Klein: Thank you for your letter of December 16th. We did, in fact, receive your inquiry relating to manu facturers, processors or importers of asbestos and reporting requirements. It was our interpretation in reading the Federal Register notices that W.R. Grace was not required to file a report. Perhaps it escaped our attention that we were required to advise you of this fact. Therefore, please be advised that, to the best of our records, W.R. Grace is not a manufacturer, processor or importer of asbestos under Sections 15(3) and 16 of the Toxic Substances Control Act. I refer you to the second paragraph on page 33202 of the Federal Register which states in part: "This rule does not require reports by manufacturers or processors of products which contain asbestos as a contaminant or an impurity." Further, on page 33207, Section 763.63(b) reads in part: "This term does not include mix tures which contain asbestos as a contaminant or impurity." If you wish further information, kindly contact me. Very truly yours CEB/rrm cc: O.M. Favorito E.E. Moore 0620802