CBIC Control Number 

357345 

< <ch:rV EQ 

OPPT CBIC 

2013 DEC 13 PM 3: 52 

Kirsten Hesla 

Chemical Control Division 

Office of Pollution Prevention & Toxics 

Hesla.Kirsten@eoa.Qov 

VIA HAND DELIVERY 

OPPT Document Control Office (DCO) 

EPA East Bldg., Rm. 6428 

1201 Constitution Ave. N.W. 

Washington, DC. 

EPA 

DEC 17 2013 

DOCKET CENTER 

Attention : Docket ID Number EPA-HQ-OPPT-2010-1039 

RE: Existing and continuing uses of decabromodiphenyl ether 

Dear Ms. Hesla : 

Veyance Technologies, Inc. 

703 S. Cleveland Massillon Rd 

Fairlawn, 011 44333 

Ph(330)664-7000 

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As you requested, Veyance Technologies, Inc. ("Veyance") is providing information on its use 

of decabromodiphenyl ether ("decaBDE," CASRN 1163-19-5), in conjunction with the 

significant new use rule ("SNUR") and test rule proposed by EPA on April 2, 2012 (77 Fed. Reg. 

19861) . Veyance appreciates you contacting us about this and providing the opportunity for 

comment. We first state the ongoing use of decaBDE that should be included in the final SNUR 

rule, and then provide additional information concerning this use. 

Ongoing Use of decaBDE 

Veyance manufactures and sells industrial power transmission products; heavy-duty and 

lightweight conveyor belts, hydraulics, rubber track; and automotive and heavy-duty truck belts, 

hose, tensioners, and air springs. As we have discussed, Veyance processes decaBDE into some 

rubber blends used to make industrial conveyor belts. These belts are used for mining in 

applications where fire resistance is required by the Mine Safety and Health Administration 

("MSHA"). We therefore request that the final SNUR recognize the following ongoing use: 

Use of decaBDE in select rubber blends for the manufacture of 

heavy conveyer belts used in mining that are subject to Mine 

Safety and Health Administration fire resistance requirements. 

P , 

Z _ v(!)(DDP ,77 LL Pj7J 

ENCINEERED PRODUCTS 

-WVEYANCE' 
p. 2 

Letter to Kirsten Hesla, EPA 

December 13, 2013 

Page 2 of 4 

Purpose of the decaBDE Use 

MSHA regulations require that conveyor belts used in underground coal mines must be flame 

resistant. 30 CFR Part 14 and §785 .1108 . These regulations implement Section 11 of the Mine 

Improvement and New Emergency Response Act of 2006 and were promulgated to prevent 

conveyor belt fires and in turn reduce injuries and deaths associated with fires in the conveyor 

belt entry. 1 The fire resistance of the conveyor belt both reduces the likelihood of fire and 

increases escape time in the event of a fire . 

Source, Processing, and Ouantity of Use 

Veyance purchases the decaBDE from a domestic supplier who in turns obtains the decaBDE 

from China. The amount purchased is on the order of 40,000 pounds per year. The decaBDE is 

mixed into rubber blends formulated according to customer requirements . The amount of 

decaBDE in the blend is approximately 4 to 8 percent by weight, with a maximum of 5.8 percent 

by volume. The rubber blends are processed through some combination of milling, extruding, 

calendaring, rolling and/or curing, depending on the needed product characteristics . In the final 

conveyor belt, the overall decaBDE content is about 1 .4%. 

Potential Exposure and Worker Protection 

The greatest amount of potential exposure occurs when decaBDE is poured from the paper bags 

in which it is received onto charge belts for the rubber blending . Workers wear particulate dust 

masks during this operation. Dust in the vicinity of mix locations is also controlled with 

negative pressure dust collection systems with fabric filtration . After incorporation into the 

rubber blend, the potential for exposure is minimal, as decaBDE is a solid with a melting 

temperature of 294 degrees Celsius and boiling point of 425 degrees Celsius. Gloves are 

provided to employees in all areas, and face shields and masks are provided in repair areas where 

grinding is done. 

Disposal 

In the rubber blending operation, waste rubber containing decaBDE is recycled back into the 

decaBDE rubber blends . From the conveyor belt production operation, approximately 2000 

pounds per years of trim and scrap (mostly cured) is landfilled, and uncured rubber, off-spec 

belts, and cured belt ends containing a few hundred pounds of decaBDE are recycled within the 

Veyance facility. 

See Regulatory Economic Analysis For Flame-Resistant Conveyor Belt, Fire Prevention And 

Detection, And Use Of Air From The Belt Entry, Final Rule, RIM 1219-AB59, U.S. Department of 

Labor, Mine Safety and Health Administration, Office of Standards, Regulations, and Variances 

(December 2008), http ://www.msha.gov/REGS/REA/E8-30639.udf. "From 1980 to 2007, there 

were 65 reportable conveyor belt entry fires . These fires caused more than two dozen injuries and 

three deaths." Id. at 1 . 
p. 3 

Letter to Kirsten Hesla, EPA 

December 13, 2013 

Page 3 of 4 

Substitutes 

Veyance has been in the process of seeking alternative flame retardants that will still enable the 

conveyor belts to meet MSHA requirements for flame resistance . Acceptable substitutes 

identified to date are subject to existing SNURs, creating implementation barriers . 

In the proposed SNUR, EPA requested comments on the following: 

EPA is projecting c-decaBDE will no longer be available and that 

processors will discontinue their activities by December 31, 2013 . 

Should EPA assume that processors will continue their activities 

beyond that date? For example, should EPA assume that 

processors will continue their activities for 6 months after 

manufacture of decaBDE ceases? Should EPA designate 

processing of decaBDE after June 30, 2014, or some other date, a 

significant new use? 

and 

EPA requests comment on whether the proposed significant new 

uses are ongoing and will still be ongoing after December 31, 

2013 . 

77 Fed. Reg. at 19880. 

Because Veyance has not yet identified a suitable decaBDE substitute for the mining conveyor 

belts, it will continue this use after December 31, 2013. Veyance will continue its work to 

develop alternative formulations . A date of June 30, 2014 to designate processing of decaBDE 

as a significant new use would increase the likelihood that an alternative will be found by the 

time of that designation. 

Test rule 

Apart from the issue of the effective date for designating processing of decaBDE as a significant 

new use, is the issue of the effective date for the test rule, if EPA decides to finalize the proposed 

test rule . The testing proposed by EPA is extensive and would be very costly . Thus, if the test 

rule effective date occurs before a suitable alternative is found, there would be strong incentive 

to stop import and processing of decaBDE with no alternative in place, which could have adverse 

and unintended knock-on effects for production of MSHA-compliant conveyor belts. We 

therefore urge that EPA not finalize the test date before June 30, 2014, and that it remain in 

communication with Veyance on this issue. 
p. 4 

Letter to Kirsten Hesla, EPA 

December 13, 2013 

Page 4 of 4 

Thank you again for the opportunity to inform you of our ongoing use of decaBDE. If you have 

any questions or need further information, do not hesitate to contact me at 330-664-7242 or 

Patrick Barrett(~a,Veyance .com . 

Sincerely, 

Patrick Barrett 

Director, Global EHS 

A. V4,.~ 

cc: Sheila Schiffman, General Counsel 

Terry Bruni, VP of Operations 

Dave Maguire, VP of Technology