Document 06xyYJdZ62wzb85d5EpDv3Yym

FILE NAME: Scotts (SCTS) DATE: 1975 Dec 8 DOC#: SCTS011 DOCUM ENT DESCRIPTION: M em o RE History of V erm iculite Scotts Asbestos PLAINTIFFS EXHIBIT SCO-31 To: Subject; ASBESTOS' ' Dick Gruenbaum Date; December 8, 1975 This memo i s e follow-up of the meeting you called on December 3 to bring you to date on the present and proposed asbestos standards as well as how these standards may a ffe c t our future because of the large volumes of vermiculite used which contains the asbestos. The OSHA Standards th a t f i r s t printed on May 29, 1971 indicated th a t 12 fibers/ml was the Tl.V for asbestos. A new standard became effectiv e on duly 7, 197? which indicated th a t the maximum 8-hour tins-weighted average of asbestos fibers not exceed 5 fibers/cc. This sane standard indicated th a t e ffe c tiv e July 1, 1976, the 8-hour time-weighted average asbestos fib e rs concentrations will be lowered to 2 fibers/cc. On September 30, 1975 a notice of proposed rule-making was published in the federal Register proposing to lower the 8-hour time-weighted . average, exposure to asbestos of 0.5 fib e rs /c c . The permissible . ceiTing. exposure 'now fn e ffe c t is 10 fib e rs /c c . The new proposed !< ' standard is'proposing a maximum of 5 fib e rs /c c ceilin g . Persons in terested in cortmentin'g on the proposed standard.should have done . ... ' ./'.? -* th is 'b y December 8 , ' 1975. : ' ` ' v-v-rl'c?'". w- Tc*: ce; Subject: 1 J'l J JS J\ VJ T 1' l ^ u U i>J i \ l u JM I L- A i I V i\ (Scoit^) fiorin PAGE ? Based on our linn'tod information regarding the asbestos conceri. Iratio n s in our production, f a c i l i t i e s , 3 feel the July 1, 1976 standard can be met> however, the nev/ proposed standard of 0.!> tib e rs/c c w ill be very d i f f i c u l t i f not impossible to meet in our Trioni?ed production area. Following is a history of the asbestos fib e rs in our vermiculite as 1 know i t -I I was f i r s t made aware of a possible asbestos problem in our vermiculite in la te 1971 by Mr. Fred F.aton from W. R. Grace Co. M/ contact through Mr, Eaton was-regarding some discussions concerning a dry dust collection system we were about to try on our vermiculite expanders. During early 197?, ) was in contact with Mr. Eaton on several ..... occasions again regarding the dust Collection. During ***'*.*each discussion,, the possible asbestos problem was men-. ;tio n e d by Mr. Eaton and fin a lly suggesting th at W. R. . Grace do some sampling in our p lan t. ' . * ['i Xi> - . . - . .*.;'r ... frS, . . . ***>^..**'** -A,i *. . * * * continued D O JW R O 02173 I V' * Tp: . , cc: Subject; Mjcih; Date: f'AGF. - 3 Mr. Eaton, Mr. Eschenbach, Safety Adm1ni strato r, find Mr. Kostic, E.nvi ronwental ist. from W, R, Grace, were granted permission to v is it our f a c ilit ie s on May 30, 197R, During th is v i s i t , eight1asbestos samples were taken in the- irio n ized plant area, primarily in the expander area, These samples were then analyzed by W. R. Grace. Results o f these te sts were 0 to 8.3 fib e rs /c c with a moan of >?. Jt.sh o u ld be noted th at during th is time four of the eight expanders were in operation using only W. Grace ore. After receiving the r e s u lts from W. R, Grace's analysis, i t was f e l t that: equipment should be purchased for per forming our own samples. Proper sampling equipment was then, purchased and again on March 8, 1973 eight samples were obtained and sent to W. K. Grace, for analysis. Six expanders were in operation during these t e s t s , re su lts of which ..ranged from 0.2 t o `8.8 fib e rs /c c with a mean of ? 5 f ibe'rs/cc:. ' Z1- . : * t. . 1 / . Th^se "tests iitdicated th a t some extensive sampling should be done to s e e -if any real problem areas could be identified. continued D O JW R G 02174 Therefore* during the month of May 1973, 33 asbestos i samples were obtained* a ll of which were sent to If. R. Grace for analysis. These te s ts were taken while running I from one to seven expanders. Results indicated a low o f 0.3 to a high of 19.3 fib o rs/c c with a mean of >4. Jt should be noted th at some d e fin ite problem areas were I id e n tifie d during th is sampling and operational changes were made where the excessively high count was obtained. I A fter the above re su lts were analyzed and discussed, i t was decided that, one of our prime dusting areas was the stoner hoods which was due to inadequate dust c o lle c tio n .' t In follow-up, a. new bag house dust collector has since been in s ta lle d to vent the stoner hoods. In addition* a . t o t a l l y enclosed vibrating conveyor system was in s ta lle d f o r conveying the expanded v e m ic u lite from 5, 6, 7 arid 8 V expanders to the storage bins. . -iS '''r ''I - ' y '1.'` ,,'" .:*. * 1" *'. * 1 _' ' .' ' : %**,`.**%*''-'v r* * * .' The f i r s t sampling done iri the expander area since the new Vequipment has been in s ta lle d was on November i ? , 1975 when 14 samples were obtained. These 14 samples have been sent 't '.('/ft *** *"'*** * * I ' - ' ' continued DOJ1VRG 02175 I s f 1 N T K K O y F 1 C E C O M M If fi* I C A J J u i\ < Subjects llates PAGE - S to W. K.Grace io r analysis, re s u lts of which arc: expected around bee-ember HO. I t should bo noted th at approximately 60 percent of the vcrmiculite used during th is sampling period was African with the remaining 60 percent being m s from Libby, Montana. Six expanders were being used during this testing. - . Per your suggestion, 1. will be following-up on the following items: 1. Obtain additional asbestos samples for analysis by ari independent laboratory. John Kilsheirner will bo sending me a l i s t of the laboratories suggested by 111. ?. 1 will, be checking with W. K. Grace in regard to what, ' i f anything, they have done or are planning on doing about the recent proposed standards. 3. Locate a laboratory th a t could analyze the vcrmiculite " ' * ' ' ,;'"' ore from d iffe re n t sources in regard to fib e r content . . .V.-.- -*.* e *.* ' ' . " ' ... ' as well as-types of f ib e r s . Will then follow-up by ' . . .. sending- samples to the laboratories for analysis. ' V ' vr . Our.objective fo r completing, the above is early January or sooner if. */># *.* -- possible.". y y.;V: vr--: ?\ - sg *u -t._4.l,..., n:^1; tv -k nienn mil Htllftoass fc John Kennodv DOJWRG 02176 ASBESTOS FIBER SAMPLING IRIONIZED EXPANDER AREA No. Of ( S) (5) Maximum'-'' Entire'-' 8 Er. Time Samples Ceiling Expander Wt. Aver. Z-aksn For Concen- Area Base- 1st .hate Exposure Aver. Exp, tration Sample FI. 1-30-76 l.CA 7 3.03 2-11-75 1.45 Area Samples . By F l oor^ 2nd 3rd Ath 5th 5th FI. FI. 71. T" FI 2.5 3.1 I-.A Name of 7th Expander T7 Operator 12 Poling 2-18-76 1.36 * 2-27-76 1.0 3-10-75 2.39 3-20-75 8 10.53 S.5 1.3 3.A 2.0 2.0 A.4 5.A 2.8 Don Shanks .18* 3-29-75 2.9 A-13-76 2.3 7 L.L 3.9 .68 .80 2.2 .52 1 ,0, Fen Ficol A-28-76 .38 7 .81 .36 L. Atherton 5-5-76 5-12-76 1.16 1.76 & 3.08 2 (^6) 1.27 .35 L. Ath^PRn 10-26-75 .80 3 1.58 1.65 5.3 .91 1.5A .91 I.AS 1.37 1.85 *O Jeff Mouser D gO2?/) ^ g5, * 8s) '-jj All numbers expressed in "number fibers longer than 5 microme ter/CC of air." Ihese are determined by obtaining at least five 15 minute samples in one eight hour working day by following expander operator doing m s normal duties. Results of samples are then totaled and averaged, thus expressed as "8 hour time weighted average exposure." This is determined by the maximum number of fibers on any one 15 minute sample during this sampling period. At leasi 15 minute sample per week is obtained in expander area. Approximately eoual time is spent on each or th( ' eight fl.cors. . Entire 15 minute sample is obtained in expander area on floor indicated. Saturday: No Production - No Activity in area. These were one hour samples. w f z \ So* ? _en.t.ire <V\ Area Samples, 3v F/ l[ oOonrr v y 8 E TlnsX^V Sarro Ceiling Expander fane of Vt. Aver. Takes for Concern- Area Base ;.Sl 2nd re 5th fif-h Expander Aver. trsrdLoii. Serin Xent T77 FT PI. PI. Operator 3-10-77 .75 oKJ Larry Stsith a Prank Lee 3-11-77 .2 3 Delnar Cox 5-17-77 .98 3 /O 9-19-77 * 1 i 3^ 2-23-78 -15 3 2-2A-7S .28 5 3r3-78 99 ,o 3-13-78 .89 3 Toyle Jones Syemac & Telhorster Jones 5: D. Gingrey Longberry Price & V. Xeislnger - ,/ d ibo ^ DOJWRG 02178 See preceeding page for coments.