Document zoNX7joyJKxqdn2Z2wBj7Dqd6

BCC: R. E. Byrne, Jr. J. F. Collins W. C. Thurber file UNION CARBIDE CORPORATION METALS DIVISION P.O.BOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 716-278-3376 August 31, 1977 Ms. Linda Chaput Emissions Standards and Engineering Div. (MD13) Environmental Protection Agency Research Triangle Park, NC 27711 Dear Ms. Chaput: This letter is to confirm our telephone conversation on August 30 concerning the proposed wording of an exemption from the spraying prohibition. It is my understanding that your current wording is something like the following: "The following materials are exempt from this paragraph (e): spray-on materials in which the asbestos fiber is encapsulated and/or impregnated with a bituminous or resinous binder during spraying and which are not friable after drying." If the above is correct, we support such wording to prevent the prohibition of such products as auto undercoating and sealers, roofing compounds, etc. If "encapsulated and/or impregnated" is not acceptable, we think the word "encapsulated" is the more accurate and descriptive. Dr. Rhodes will return to the office on September 12th, and I will check with him on the spraying information he has already supplied. If we have additional data or can provide more "justification" language, he will be in touch with you. It was a pleasure talking to you and we appreciate the opportunity to express our comments. Don't hesitate to contact me before September 12, if you think I can be of any assistance. Very truly yours. Marketing Manager JLM:dal CC: R. H. Mereness H. B. Rhodes