Document yrOrJ42QrBVDMMamBZg3K4NM4

FILE NAME: ALCOA (ALC) DATE: 1974 Dec 9 DOC#: ALC012 DOCUMENT DESCRIPTION: Memo TROUAS 3. HOHNEY PITTSBURGH OPTICS - 7 DR. U. 0. COLTOLL PITTSBURGH OPTICS - 29 i \ J December 9, 1974 R2: POINT COMPORT - VIOLATIONS OF ASBESTOS STANDARD______________ The citation Point Comfort received for alleged violations of the asbestos standard involved the mixing of asbestos and molasses. The mixture is used to pack the space between the collector bar and the hole provided for it in the pot shell. The operation was a surprise to all except those in the department where the work was being done. Rost of the concerned people at Point Comfort were of the opinion that their use of asbestos was well controlled if not eliminated. The use of asbestos for this operation has been discontinued since November 22, 1974. The 03HA industrial hygienist did not cite use for exposing our employee to concentrations of asbestos in excess of those permissible. Undoubtedly, this was because he took no air samples but relied only on visual observation. Some of the sections of the standard for which they were cited presumed that excessive concentrations existed or could have existed. Technically, we would be on pretty solid ground in contesting these, since the presence of excessive airborne concentrations were not firmly established. However, other violations for which we were cited required only that asbestos be Involved in the operation. Therefore, contesting the citations could, at best, result in reducing their number rather than eliminating them entirely. Furthermore, the operation as described to me was one we would not be too proud of. Point Comfort does not intend to contest the citations and I concur with this. Ve would have little to gain and much to lose by contesting. For much time and expense, we might reduce the imposed 3600 fine at the expense of aggravating the OSHA personnel who still have not finished with Point Comfort. THOMAS B. BONNET T B B :gk cc: Dr. B. D. Pinnan - Pittsburgh Office - 7 ARCH 01073Q