Document zbQNVvy1Ng3YX30X0MN3kdXZ6

E. I. du Pont de Nemours & Company Wilmington, Delaware 19898 cnvironmcntal quality committee PLAINTIFFS BCC: R. R. Bonczak C. F. Reinhardt B. W. Culpepper F. E. French, Jr. T. E. Lewis P. G. Gilby V. R G. A M. H R. A. Harrington C. B. Hagerty B. J. Reilly August 5, 1983 Document Control Officer (WH-557) Chemical Information Division Office of Toxic Substances U.S. Environmental Protection Agency 401 M Street, S.W. Washington, DC 20460 Gentlemen Du Pont is aware that EPA is currently investigating asbestos manufacture and use activities and that, as part of this effort, the Agency has requested information on industrial filters containing asbestos components. 47 Fed. Reg. 33198 (1982). Because the asbestos present in such filters is bound up so as to prevent airborne release during handling, storage and use, the filter pads are not generally labeled as contain ing asbestos. It has come to our attention that disposal of the filters by incineration or destruction by some other mode might result in the potential release of airborne levels of the bound asbestos fibers. Absent labeling of the asbestos content by the filter manufacturer, downstream customers and processors might not be adequately put on notice so as to ensure compliance with applicable OSHA requirements. 29 CFR 1910.1001. Du Pont believes that this information could be useful to EPA's assessment of exposure potential. Since 1970 Du Pont has used at one of its plants a cellulose industrial filter which contains ten percent chrysotile asbestos. Subsequent to use, Du .Pont sent the spent filter medium containing precious metal residues to various reclaimers who reprocessed the material to extract the precious metal con tent. Recently Du Pont recognized that during this reclamation activity, asbestos fibers could become airborne. However, Du Pont has no knowledge that this, in fact, occurred. Moreover, Du Pont has no reason to believe that the reclamation operations were not in compliance with applicable OSHA standards. Du Pont has notified its current reclaimer of the asbestos content of the spent filters and has retrieved both unprocessed and semiprocessed drums of the material from the reclaimer's site. Other processors, who had in the past reclaimed such process residue, are being notified that the asbestos-containing filters were included in the process material that had been reclaimed. DUP 0947984 DU 038983 2 Du Pont does not believe that the circumstances present reportable Section 8(e) information since the Administra tor is aware of the adverse effects of asbestos exposure and because such effects are documented in the scientific litera ture. 47 Fed. Reg. 23760 (1982). In addition, the Administrator is aware that industrial filters and similar articles contain asbestos. 47 Fed. Reg. 33198 (1982). Moreover, as previously noted, Du Pont has no knowledge that reclamation of the process material did, in fact, result in the generation of airborne asbestos or that reclamation operations were not in compliance with applicable OSHA standards so as to pose a substantial health or environmental risk. Should EPA disagree with this conclusion, Du Pont believes that this notice satisfies any TSCA notification obligation. Very truly yours. Robert R. Bonczek Director of Safety, Health and Environmental Affairs RRB:mdm CC: Dr. R. Leonard Vance Director of Health Standards Occupational Safety and Health Administration U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, DC 20210 BCC: ' Mr. Martin A. Vagners Scott Laboratories Ltd. 950 Brock Road South Pickering Ontario, Canada L1W 2A1 DUP 0947985 DU 038984