Document 3JL41jdw0bLoaxzQ6OX0vjj5y

FILE NAME Brakes BRK DATE 1989 Jan 19 DOC BRK162 DOCUMENT DESCRIPTION EPA Report - Regulatory Impact Analysis of Controls on Asbestos and Asbestos Products REGULATORY IMPACT ANALYSIS OF CONTROLS ON ASBESTOS AND ASBESTOS PRODUCTS FINAL REPORT VOLUME III APPENDIX F U.S. Prepared for Christine Augustyniak Office of Toxic Substances Environmental Protection Agency Prepared by ICF Incorporated Fairfax Virginia 22031-1207 January 19 1989 II III IV VI VIII XI XII XIII XIV XVI XVII XVIII XIX XXI XXII XXIII XXIV XXVI XXVII XXVIII XXIX XXXI XXXII XXXIII XXXIV Commercial Paper Rollboard Millboard Asbestos Pipeline Wrap Beater Gaskets Grade Electrical Paper Roofing Felt Filler for Acetylene Cylinders Flooring Felt Corrugated Paper Specialty Paper Asbestos Floor Tile Asbestos Diaphragms Asbestos Pipe and Fittings Asbestos Flat Sheet Corrugated Asbestos Sheet Asbestos Shingles Drum Brake Linings Disc Brake Pads Medium Vehicles Disc Brake Pads Heavy Vehicles Brake Blocks Clutch Facings Automatic Transmission Friction Materials Friction Components Asbestos Protective Clothing Asbestos Textiles Sheet Gaskets Asbestos Packings Roof Coatings and Cements Roofing Adhesives Sealants Reinforced Plastics and Coatings Missile Liner Extruded Asbestos Asbestos Sealant Tape Separators in Arc Chutes Fuel Cells and Batteries I. COM ERCIAL PAPER A. Product Description Asbestos commercial paper can be classified into two categories -general insulation paper and muffler paper Commercial papers are used to provide insulation against fire heat and corrosion at a minimum thickness These papers are used in a variety of specialized applications and are therefore produced in many different weights and thicknesses They usually consist of approximately 95 to 98 percent asbestos fiber by weight the balance 2 to 5 percent is typically starch binder Krusell and Cogley 1982 Commercial papers are produced on conventional papermaking machines The ingredients are combined with water to produce a mixture that is fed through a series of rollers These rollers apply pressure and heat to produce a paper of uniform and desired thickness The paper is then allowed to cool before it is cut rolled and packaged Muffler paper is used by the automotive industry for exhaust emission control systems The paper is applied between the inner and outer skins of the muffler or converter to maintain the high temperature necessary for pollution control within the catalytic converter reaction chamber and to protect the outer layer from the heat Krusell and Cogley 1982 General asbestos insulation paper is used in a variety of industries The steel and aluminum industries use it as insulation in furnaces in trough linings in the smelting process and against hot metal and drippings of molten metal Asbestos paper is also used in the glass and ceramic industry for kiln insulation in foundries as mold liners and in the electrical parts and appliance industry for electrical insulation B. Producers and Importers of Asbestos Commercial Paper There were two primary processors of asbestos commercial paper in 1981 Manville Corporation now Manville Sales Corporation and Celotex 1 Corporation TSCA 1982a There were also three secondary processors of asbestos commercial paper in 1981 Metallic Gasket Division Sepco Corporation now Fluorocarbon Metallic Gasket Division Parker Hannifan Corporation and Lamons Metal Gasket Company TSCA 1982b All of these companies have stopped processing asbestos commercial paper and there are currently no primary or secondary processors of this product ICF 1986 However a representative of Quin Corporation's Erie PA plant stated that it is selling small amounts of commercial paper out of inventory The official could not quantify the amount sold in 1985 but did state that production had been discontinued ICF 1986 Because none of the other respondents to our survey indicated that they had begun the production of asbestos commercial paper in the period since the previous survey or that they were aware of any other distributors or importer of this product we have concluded that there are currently no domestic producers of asbestos commercial paper In addition a 1984 survey of importers failed to identify any importers of asbestos commercial paper ICF 1984 C. Trends 1981 production of asbestos commercial paper was 936 tons TSCA 1982a As described above there was no production of this product in 1985 D. Substitutes Asbestos fiber has been used in commercial paper because of its corrosion resistance fire resistance chemical resistance strength and durability Information on the advantages and disadvantages of asbestos commercial paper and its substitutes is summarized in Table 1 The major substitute for asbestos commercial paper is ceramic paper ICF 1985 Ceramic paper is manufactured by Carborundum Corporation Cotronics Corporation Babcock & Wilcox and Lydall Corporation This product shares many of the advantages of asbestos commercial paper such as corrosion fire 2 (2061) Paerzey <@TIOD pum (98671 TenTy 201 = {EGET} C986) OG0R Substie Asbetos (9@61) C961) KOT | ' So Ce96t) Substiues Substiues Comercial AT THOT 4qus;Tyes Poupatnyp Manufacture pue so ewe Q7GHT 9un ro Kone QEepaT eopaqe Fize Environmetal TQatd Environmental heat corsion Comercial resistant corosion Environmental TeyUOTALg resitan Uytey Low cost resistant 4Ou NOT {oy health LOelosmaneD Corp. Reat corosion Not chemical soqbesy Corp. resistant resistant Hore 50x , "O3TL osn Paper Lydal 230 tempratue proetis mesNot elctrical properties - * MA *30eq Vose Vose AE GolingswortheerVose MA Good Inexpnsive Inexpensive SAT heat properties Not temperature T Paper SOINAVZMITY eveq Wi limit Bent Temperature Temperature anpureqiag NQROMBIUTOR 10 FTemprature ae Fs By ao] dep *420 UEFQCDYODGe TreRLT Trepst redvg qonporg TEyoeU rede? 20eqg Nedeg eojCeqcy a]}umray seoTHT TED sevTSaqtys and chemical resistance However at extremely high temperatures the binders in the paper begin to burn and all that is left is the fiber The strength differential becomes more important as the binder burns away because ceramic fibers are not as strong as asbestos fibers In addition ceramic paper is more expensive than commercial paper Despite these drawbacks ceramic papers can substitute for asbestos commercial papers in any of the following applications insulation for the aluminum and steal industries foundry insulation glass making fire protecting barriers mufflers catalytic converters kiln and furnace construction and other high temperature uses Hollingsworth & Vose Company produces a cellulose electrical insulation paper This product is a good substitute for asbestos commercial paper in the electrical parts and appliance industry It is less expensive than the other substitutes but it cannot be used in high temperature applications Hollingsworth & Vose 1983 Lydall Corporation also manufactures fiberglass commercial paper This product is considered an inferior substitute because it can only operate at temperatures up to 1100 and is not as strong or dimensionally stable as asbestos commercial paper Lydall 1983 B. Summary Domestic production of asbestos commercial paper did not take place in 1985. A small amount was sold out of inventory but there is currently no more consumption of this product As a result complete substitution of asbestos in commercial paper has taken place The substitutes are more expensive than the asbestos product but they have generally been able to match its performance along the critical dimensions - & - REFERENCES Babcock & Wilcox Co. Transcribed telephone Washington D.C. T. Viverito conversation 1986 October 14 with Peter Tzanetos Augusta GA ICF Incorporated Carborundum Transcribed Washington Corp. C. telephone D.C. Demske 1986 October 14 Niagara Falls NY conversation with Peter Tzanetos ICF Incorporated Cotronics Corp. Representative 1986 October 14 Brooklyn NY Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. Hollingsworth & Vose Transcribed telephone Washington D.C. Stoute Ellsworth 1983. East Walpole MA conversation with E. Malitz ICF Incorporated ICF Incorporated 1984. Imports of Asbestos Mixtures and Products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency EPA Doc Control No. 20-8600681 ICF Incorporated 1985. Appendix H Asbestos Products and Their Substitutes in Regulatory Impact Analysis of Controls on Asbestos and Asbestos products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency ICF Incorporated 1986 December Processors of Asbestos Commercial Paper Survey of Primary and Secondary Washington D.C. Krusell N Cogley D. 1982 GCA Corp. Asbestos Substitute Performance Analysis Revised Final Report Washington D.C Office of Pesticides Toxic Substances U.S. Environmental Protection Agency Contract Number 68-02-3168 and Lydall Corporation Mr. Devoe 1983. Rochester NH Transcribed telephone conversation with E. Malitz ICF Incorporated Washington D.C. TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8601012 1982a D.C Production Data for Primary Asbestos Office of Pesticides and Toxic Protection Agency EPA Document Control No. TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8670644 1982b D.C Production Data for Secondary Asbestos Office of Pesticides and Toxic Protection Agency EPA Document Control No. II ROLLBOARD A. Product Description Rollboard is a paper product that is used to protect against fire heat corrosion and moisture It is a thin and flexible material composed basically of two sheets of paper laminated together with sodium silicate Rollboard can be cut folded wrapped and rolled In addition it can be molded around sharp corners Krusell and Cogley 1982 The primary constituent of asbestos rollboard is asbestos fiber The balance consists of binders and fillers The asbestos content can range from 60 to 95 percent by weight but 70 to 80 percent is considered typical Frequently used binders include starches elastomers silicates and cement common fillers are mineral wool clay and lime Krusell and Cogley 1982 Rollboard is manufactured in a process similar to that used for millboard production but it is produced in a continuous sheet The ingredients are mixed together and combined with water This mixture is then fed into a conventional cylinder paper machine where heat and heavy rollers are applied to produce a uniform board The material is then dried The final steps are to laminate two of these sheets together allow them to set and to package the finished rollboard product Rollboard can be used in many industrial applications 4+ it can be used as a gasket and as a proofing agent for security boxes safes and files | Its commercial uses include office partitioning and garage paneling while its residential uss include linings for stoves and electric switch boxes B. Producers and Importers of Asbestos Rollboard There were no domestic primary or secondary processors of asbestos rollboard in 1981 although a Manville Corp. now Manville Sales Corp. plant in Waukegan IL was still selling the product out of inventory TSCA 1982a TSCA 1982b In addition a 1984 survey of importers failed to 1 identify any importers of asbestos rollboard ICF 1984 The Waukegan IL plant no longer produces or sells asbestos rollboard ICF 1986 Because none of the other respondents to our survey indicated either that they had begun the production of asbestos rollboard in the period since the previous survey or that they were aware of any other distributors or importers of this product we have concluded that there are currently no domestic producers or consumers of asbestos rollboard C. Trends There was no production of asbestos rollboard in 1981 and there was still no production of asbestos rollboard in 1985. Small amounts of asbestos rollboard were being sold out of inventory in 1981 but this had ceased by 1985 D. Substitutes Most asbestos rollboards in the market today are made of ceramic fibers Information on asbestos rollboard and its substitutes is summarized in Table 1 Cotronics Corporation manufactures ceramic paper which is the primary substitute for asbestos rollboard ICF 1985 It is made from high purity asbestos refractory fibers Even though the product is sold in paper rolls it can be made into free standing shapes such as rollboards The continuous service temperature is 2300 and applications include insulation materials and high temperature gaskets for furnaces electrical wire insulation kiln construction and cushioning in furnace construction Ceramic paper has low specific heat low thermal conductivity and has resistance to thermal shock and corrosion Cotronics 1986 Carborundum Corporation manufactures two asbestos rollboard substitutes The first is Fiberfrax 550 It is a paper product made of silicate ceramic fiber and contains approximately 8 percent organic binder 2 It is Cze6t) (WET) sonuerzoy AeT809 (9067) CoEOT) LOST (9061) IN pus Y TT C9g6T) enzy JOT Table for Rolboard BotwORID pus Manufctre Sptoe 0% caFe4tpag pus Te wueT yUbUEAgoad Fire Long Oe Advantages fa7pTStz Proe -O7pAY OF par 04 Enviromental and corsion health health problems PIVOCT yRT ITALY aed Low Low Z00g SUT Se407 3064 ofmNnT7Z pus TOY Carboundam 50 temprature limit resitance Resitant chemical alation AUT AWTI TOF puR Ben strength Hen oa handling atack DIURZETOL handling atack TeaToAg BIUVIS 4oT OETI ie EQEYE eoFaquespy temperature limit 0 and FEST 970 Bigh use alkies acids tempratue limit resitance Corp. Carborundum *quoa 2300230 use limit alkalies resistance acids Cd, Corp. UOTEZIODrigdity T "92TE SwvT apy ResistanRtesistanthandling Resitant chemicalchemical atack atack Lacks Lacksstrengthstrength rigidityrigidity PTqEL Poor High stabilty soymMo) AUPNA|Yy]AIAN 2300 TA Resistant chemical and Go d stabilty Iypa WO dyogau High Eimat qouge wasntoy ud[qoag PIVOTN qoneoag P{tovoyg CyacE (ar026 qedeq Cy) soqery wRIyeqz 482719TI TONOY 20@285 resistant to most chemical attacks with the exception of acids and alkalies It also possesses good handling strength and has a continuous use temperature of 2300 Fiberfrax 550 is designed specifically for applications where high temperature protection is more critical than heat retention Typical applications of Fiberfrax 550 are industrial gaskating liquid metal backup insulation brazing furnace insulation and as an investment casting parting agent Carborundum 1986 The second asbestos rollboard substitute produced by Carborundum Corporation is Fiberfrax 970 It is also a ceramic paper product and it contains approximately 6 percent organic binder Fiberfrex 970 is noted for its exceptionally low thermal conductivity and good handling properties Fiberfrax 970 is less suitable as an asbestos rollboard substitute because it lacks strength and rigidity however it does possess some of the favorable characteristics found in Fiberfrax 550 such as high temperature stability resiliency and excellent corrosion resistance Typical applications of Fiberfrax 970 include high temperature gaskets combustion chamber linings thermal and electrical insulation and glass furnace blow pipe insulation Carborundum 1986 Babcock & Wilcox produces asbestos ceramic rollboard made of Kaowool which consists either of Kaolin a natural occurring alumina fireclay or a blend of high purity alumina and silica Kaowool rollboard has a maximum temperature use limit of 2300 and it possesses good chemical stability with resistance to most chemicals Kaowool rollboard is designed to replace asbestos rollboard in many furnace applications such as laundry and trough linings gasketing between trough sections glass conveyer rolls * The continuous use temperature of asbestos rollboard could not be determined because the product is no longer produced However it is likely to have been approximately 1000 the continuous use temperature of standard asbestos millboard a product with a very similar composition - &e boiler jacket insulation electrical appliance insulation and radiator covers Babcock & Wilcox 1986 . The use of asbestos rollboard was very limited and the substitutes are generally able to match or exceed the performance of the asbestos product The price of asbestos rollboard in 1981 was approximately 1.00 ICF 1985 The current prices for the various substitutes are presented in Table 2. It is clear that the complete substitution away from asbestos rollboard has resulted in a higher price E. Summary Domestic production or consumption of asbestos rollboard did not take place in 1985. This has resulted in complete substitution of asbestos rollboard with other substitute products The substitute products are more expensive but they have generally been able to match or exceed the performance of asbestos rollboard 5 Table 2. Prices of Asbestos Rollboard in lb and Its Substitutes Product Manufacturer Price Reference Asbestos Rollboard None A ICF 1986 Ceramic Paper Cotronics Corp. Brooklyn NY 8.27- Cotronics 1986 Fiberfrax 550 Carborundum Corp. Niagara Falls NY 5.92 Carborundum 1986 Fiberfrax 970 Carborundum Corp. Niagara Falls NY 10.24 Carborundum 1986 Kaowool R Babcock & Wilcox Augusta GA 5.70 Babcock & Wilcox 1986 A Not Applicable REFERENCES Babcock & Wilcox Co. Transcribed telephone Washington D.C. T. Viverito 1986 October 14 conversation with Peter Tzanetos Augusta GA ICF Incorporated Carborundum Transcribed Washington Corp. C. telephone D.C. Demske 1986 October 14 Niagara Falls NY conversation with Peter Tzanetos ICF Incorporated Cotronics Corp. Representative 1986 October 14 Brooklyn NY Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. ICF Incorporated 1984. Imports of Asbestos Mixtures and Products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency EPA Doc Control No. 20-8600681 ICF Incorporated 1985. Appendix H Asbestos Products and Their Substitutes in Regulatory Impact Analysis of Controls on Asbestos and Asbestos products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency ICF Incorporated 1986 December Survey of Primary and Secondary Processors of Asbestos Rollboard Washington D.C. Krusell N. Cogley D. 1982. GCA Corp. Asbestos Substitute Performance Analysis Revised Final Report Washington D.C Office of Pesticides Toxic Substances U.S. Environmental Protection Agency Contract Number 68-02-3168 and TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8601012 1982a D.C Production Data for Primary Asbestos Office of Pesticides and Toxic Protection Agency EPA Document Control No. TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8670644 20-8670644 1982b D.C Production Data for Secondary Asbestos Office of Pesticides and Toxic Protection Agency EPA Document Control No. III MILLBOARD A. Product Description Asbestos millboard is essentially a heavy cardboard product that can be used for gasketing insulation fireproofing and resistance against corrosion and rot The primary constituent of this product is asbestos fiber with the balance consisting of binders and fillers The asbestos content ranges from 60 to 95 percent but 70 to 80 percent is considered typical Frequently used binders are starches elastomers silicates and cement common fillers include mineral wool clay and lime Krusell and Cogley 1982 Millboard is manufactured in essentially the same way as paper The ingredients are mixed together and combined with water This mixture is then fed into a conventional cylinder paper machine where heat and heavy rollers are applied to produce a uniform board The material is cut lengthwise and then removed for final drying Standard size millboards are 42 x 48 inches and 1/4 to 3/4 inches thick The most popular millboards are 1/4 and 1/2 inch thick Asbestos millboards are very similar to asbestos commercial paper and are differentiated primarily by their thickness and lower fiber composition than commercial paper Millboard is also sold in different grades Differences between millboard grades reflect their ability to withstand elevated temperatures Standard asbestos millboard is able to withstand temperatures of 1000 while premium millboard can withstand temperatures well above 2000 Quin 1986a The uses of asbestos millboard are numerous Specific industrial applications include linings in boilers kilns and foundries insulation in glass tank crowns melters refiners and sidewalls in the glass industry l^>n^>ngsfor troughs and covers in the aluminum marine and aircraft industries and thermal protection in circuit breakers in the electrical industry In addition thin millboard is inserted between metal to produce 1 gaskets Commercial applications for millboard include fireproof linings for safes cleaning machines and incinerators Asbestos millboard had been used in residential applications but this application has ceased Quin 1986b B. Producers and Importers of Millboard There were five primary processors of asbestos millboard in 1981 Celotex Corporation GAF Corporation Manville Corporation Nicolet Inc. and Quin Corporation TSCA 1982a Celotex Corporation Manville Corporation now Manville Sales Corporation and Nicolet Inc. have since stopped producing asbestos millboard However Nicolet Inc. continues to sell the product out of inventory GAF Corporation sold their plant in Erie PA to Quin Corporation and that plant is still producing asbestos millboard The other Quin Corporation plant in Tilton NH still produces an asbestos product but they have decided to reclassify it as electrical paper Therefore there is currently only one domestic primary processor of asbestos millboard That plant consumed 436 tons of asbestos fiber in producing 581 tons of asbestos millboard in 1985 ICF 1986 There were eight secondary processors of asbestos millboard in 1981 TSCA 1982b Since that time four companies have stopped processing asbestos Hillboard The four companies which still process asbestos millboard are Capital Rubber & Specialty Company Fluorocarbon Metallic Gasket Division of Sepco Company Lamons Metal Gasket Company and Parker Hannafin Corporation All four companies process millboard for producing gaskets Capital Rubber and Specialty Company imported millboard in 1985 no other importers of asbestos millboard were identified ICF 1984 ICF 1986 The other three companies purchased approximately 120 tons of asbestos millboard ICF 1986 -2- C. Trends Total ammual production of asbestos millboard has declined dramatically from 2,767 tons in 1981 to 581 tons in 1985. This decline may be somewhat overstated because Quin Corporation's plant in Tilton NH believes that their 1981 millboard production should have been classified as electrical paper. Nonetheless this decline is expected to continue and Quin Corporation's plant in Erie PA plans to stop producing asbestos millboard in 1988 Quin 1986a D. Substitutes The major advantages of asbestos millboard are its resistance to heat fire rot and corrosion its tensile strength and its low price In general the substitutes can match or exceed the heat and fire resistance of asbestos millboard but they do not offer as much rot or corrosion resistance or as much tensile strength In addition all the substitutes are more expensive Despite these drawbacks the substitutes are expected to perform adequately enough to replace asbestos millboard in all its current uses For the purposes of this analysis the substitutes have been grouped into two categories -- standard boards and premium boards This has been done because the performance characteristics of the boards within each category are similar even though their exact chemical compositions are different The performance characteristics across categories are however different The advantages disadvantages and prices of asbestos millboard and its substitutes are presented in Table 1 The major substitutes for asbestos millboard fall into the standard board category The Quin Corporation produces a standard board known as mineral board which can replace asbestos millboard This product is composed of a proprietary combination of inorganic fillers It can withstand temperatures up to 1000 and can replace Billboard in many of its applications even 3 tzget} (9@6T} Substies 86s SaT9og XOTIM 9061) {'pR) 78764 pum Ceoger) (Pred 9 (ogi) P'Us T]VeNTy L-urnh Table Substiues for Asbestos Asbetos * Pe Manufcture edquNapost Corp. WATSeRY "Yuers yqBuer,s PA TIeMmhs50Corp. BT TEE 209 resitan resitant Board M07} NSTE acy WPT Board Corp. -O89 use 30 combustible soy Foz AfaT AEHT Tempratue puwe ean om asngvxeduay combustile limt Board se3uQeapy Wilcox of Fals "32,001 . , Corp. T Fals , Nonsistant qoK {een eT QeY "OD [an POINZVUITY MNpAmLIEg3ay eTmoulKg GOTWIRQ05 WOTM dsq96T"AION Eq *CH PA x05 DUEWa {ya {yg 9 {9g WE *daed vd q wT 1-utod otag 1-uypny otazWTODTW za1QRy 42090G Bqsnay ze3ety qo0Ig souse "WTODEW s0Tquy qonpoig PTIICNQI pzeog Precg BOVWEQcy parunas anymeag though it has a lower tensile strength It costs over 1.23 Quin 1986a Nicolet Inc. produces a asbestos standard board known as Nampro 901 This product is a cement millboard and can be used in gaskets electric ovens strong liners and welding pads It has a temperature use limit of 850 1200 1f strength loss is not detrimental Nicolet n.d. It costs 1.33 Nicolet 1986 It has been estimated that these two standard boards will combine to take 80 percent of the asbestos millboard market if asbestos is banned Quin 1986" The remaining substitutes for asbestos millboard fall into the premium board category They are more expensive but they have much higher temperature resistance Janos Industrial Insulation Corporation purchases a premium board called Nuboard 1800 from a British manufacturer and distributes it in the U.S. This board consists primarily of mineral fibers and silica Nuboard 1800 can withstand temperatures up to 1800 This product can replace asbestos in many of its premium uses even though it has a lower tensile strength It costs 2.92 Janos 1986 Nicolet Inc. produces a premium asbestos board known as Nampro 911 This product is an inorganic millboard and can be used in kiln liners incinerator liners induction liners and ingot liners It has a temperature use limit of 1500 2100 if strength loss is not detrimental Nicolet n.d. It costs 2.46 Nicolet 1986 Babcock & Wilcox Company produces a premium asbestos board made of Kaowool Kaowool R consists either of Kaolin a naturally occurring alumina fireclay or a blend of high purity alumina and silica Kaowool board has a maximum temperature use limit of 2300 and possesses good chemical stability with resistance to most chemicals Kaowool can replace 5- asbestos millboard in almost all its premium applications and it costs 4.70 Babcock & Wilcox 1986 Cotronics Corporation produces a premium asbestos board called Ceramic Board 360 This product is made from high purity refractory fibers which are interlaced and bonded with an inorganic binder It is resistant to oxidizing and reducing atmospheres molten ferrous metals steam and most chemicals and solvents It also has a continuous use temperature of 2300 it can be used in rigid high temperature gaskets heat shields chemical reactor insulation and brazing fixture supports it costs 1.88 Cotronics n.d. Carborundum Corporation produces a premium asbestos board called GH Board made of Fiberfrax Fiberfrax consists mainly of ceramic fibers and has a temperature use limit of 2300 In addition Fiberfrax will work well in electrical insulating applications because it has a low . dielectric constant and does not conduct electricity GH board can substitute for asbestos in all applications where tensile strength is not important and it costs 5.05 Carborundum 1986 The premium boards are estimated to take the remaining 20 percent of the asbestos millboard market if asbestos is banned Quin 1986a All the inputs for the Regulatory Cost Model are presented in Table 2 E. Summary Asbestos millboard is essentially a heavy cardboard product which can be used for gasketing insulation fireproofing and resistance against corrosion and rot It is typically used in gasketing applications and as a liner in industrial boilers furnaces and kilns The only processor of asbestos millboard in 1985 was Quin Corporation's Erie PA plant This plant consumed 435 tons of asbestos and produced 581 (986T) Unputogren #6242H103 (s9a6) (8967) .(96T} MTF OOHT (986T) Cpe) (9geT) (906T) 1-4FRMD L-UTR VETOTW YIDOqGE BSlUOMED Bousr B9TSOO TE qexsEN e2eyg Table Data for = 8S F2d 1104 unq Coeficent Consumption Ratlo Coeficient Production Ratlo Asbetos Opty) ez 7809 80.75 ton freak azaod KIAQMTNIeY 173n sz OF o qo sOVSeqy gtr 903/092 gros nog tad TS 2s 9 ZoZF Bandy #00;GTAFW MOTINPAZ WIM 9dumawed F s0a'e v/H v/a = - Aplicable TOT they poundoper they v/a vin vo $4 seqsy '09 m dano GU04 Aid v/a | 19S 8 aonposg PZBOUTIN p2v0g parog 8O4eqRy preas unyosrg Lifa 049 UF @an 10) UO, Zed BEdTId 07 Pe7INOD USEeq oady in 40q "Pumod aed seo; Uate {sun o22 ydxe oyquar 4X09 Foz JUupaEyIQ day 044 UT qow -sN seatsa, ors, tons of millboard Quin Corporation plans to stop processing asbestos in 1988 The major substitutes for asbestos millboard are mineral boards If asbestos were banned it is estimated that standard mineral boards would capture 80 percent of the market and that premium mineral boards would capture the remaining 20 percent The price of asbestos millboard is 0.88 The average price of standard mineral board is 1.28 and the average price of premium mineral board is 3.40 The projected market shares for standard board and for premium board were estimated by Ray Heidt Sales Manager Quin Corporation the only domestic producer of asbestos millboard The price of standard board was computed by averaging the prices of the two standard board products The average of Quin Corporation's mineral board 1.23 and Nicolet Inc.'s Nampro 901 1.33 is 1.28 The price of premium board was computed by averaging the prices of the five premium board products The average of Janos Corporation's Nuboard 1800 2.92 Nicolet Inc.'s Nampro 911 2.46 Cotronics Corporation's Ceramic Board 360 1.88 Babcock & Wilcox Company's Kaowool board 4.70 and Carborundum Corporation's GH Board 5.05 is 3.40 REFERENCES Babcock & Wilcox Co. Transcribed telephone Washington D.C. T. Viverito 1986 October 14 conversation with Peter Tzanetos Augusta GA ICF Incorporated Carborundum Corp. Applications Engineer 1986 November 10 Niagara Falls NY Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. Cotronics Corp. n.d. Product Literature Ceramic Board Brooklyn NY ICF Incorporated 1984. Imports of Asbestos Mixtures and Products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency EPA Doc Control No. 20-8600681 ICF Incorporated 1986 December Survey of Primary and Secondary Processors of Asbestos Millboard Washington D.C. Janos Industrial Insulation Corp. and December 5 Moonachie NJ Peter Tzanetos ICF Incorporated Sales Representatives 1986 November 10 Transcribed telephone conversations with Washington D.C. Krussel N Cogley D. 1982. GCA Corporation Asbestos Substitute Performance Analysis Revised Final Report Washington DC Officoef Pesticides and Toxic Substances U.S. Environmental Protection Agency Contract 68-02-3168 Nicolet Inc. PA 19002 n.d. Product Literature Asbestos Millboard Ambler Nicolet Inc. Sales Representative 1986 December 4 Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. Quin Corp. R. Heidt 1986a November telephone conversations with Peter Tzanetos and Incorporated Washington D.C. Erie PA Transcribed Eric Crabtree ICF Quin Corp. E. Kovykio 1986b November 11 telephone conversation with Peter Tzanetos ICF Erie PA Transcribed Incorporated Washington D.C. TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8601012 1982a D.C Production Data for Office of Pesticides Primary Asbestos and Toxic Protection Agency EPA Document Control No. TSCA Section a submission Processors 1981. Washington Substances U.S. Environmental 20-8670644 1982b D.C Production Data for Office of Pesticides Secondary Asbestos and Toxic Protection Agency EPA Document Control No. - 10 - IV ASBESTOS PIPELINE WRAP A Product Description Pipeline wrap is an asbestos felt produc. Itt is composed of at least 85 percent asbestos with the balance being cellulose fibers and binders such as starch and latex It is manufactured on conventional papermaking machines in a process similar to that of asbestos roofing felt The ingredients are combined and mixed with water This mixture is then fed through a series of machines that apply heat and heavy rollers to produce a felt of uniform thickness The felt is then coated by pulling it through a bath of hot asphalt or coal tar until it is thoroughly saturated The paper then passes over another series of rollers which set the coal tar or asphalt onto the felt Next it passes over a series of cooling rollers that reduce the temperature and provide a smooth surface finish The felt is finally dried rolled and packaged for marketing Krusell and Cogley 1982 Pipeline wrap is primarily used by the oil and gas industry for coating its pipelines.1 There is also some use by the chemical industry for underground hot water and steam piping Pipeline wrap is occasionally used in ground applications such as for special piping in cooling towers Pipeline wrap itself is only one product used in the coal tar enamel method of coating pipes The coal tar enamel process involves five steps First a primer is applied directly onto the pipe Second when the primer dries heated coal tar is applied to the pipe as it is rotated Third a glass mat is applied over the coal tar Fourth the asbestos felt is wrapped onto the pipe by speed wrapping machines Finally the pipe is coated The Department of Transportation has mandated pipelines be coated that all oil and gas 1 with kraft paper Power 1986a The asbestos felt helps protect the pipe from moisture corrosion rot and abrasion B. Producers and Importers of Asbestos Pipeline Wrap There were three primary processors and one secondary processor of asbestos pipeline wrap in 1981. The primary processors were Celotex Corporation Manville Corporation now Manville Sales Corporation and Nicolet Incorporated TSCA 1982a The secondary processor was Aeroquip Corporation TSCA 1982b There are currently no domestic processors of asbestos pipeline wrap ICF 1986 However Nicolet Inc. is selling the product out of inventory and may restart production if demand warrants it Nicolet 1986a In addition Power Marketing Group distributes asbestos pipeline wrap which it imports from Manville Sales Corp. formerly Manville Corp. plants in Canada No other importers of asbestos pipeline wrap were identified and neither firm is aware of any other producers or distributors of this product in the U.S. ICF 1984 ICF 1986 . Trends In 1981 2,150,615 squares of asbestos pipeline wrap were produced TSCA 1982b Nicolet Inc. has refused to divulge information on 1985 fiber consumption or pipeline wrap output Power Marketing Group has provided information from which one can estimate output and fiber consumption for both companies Total fiber consumption and pipeline wrap production are presented in Table 1. Finally it should be noted that 1986 output may be much lower because Nicolet Inc. has stopped producing the product and is only selling it out of inventory Kraft paper consists of wood and cellulose fibers 2 Table 1. 1985 Asbestos Fiber Consumption and Asbestos Pipeline Wrap Production" Fiber Consumption in short tons Pipeline Wrap Production in squares _ Total 3,333.3 742,383 Computations underlying these estimates are in the Attachment <square - 100 square feet + D. Substitutes The use of asbestos in pipeline wrap is desirable because of its resistance to chemicals rotting and decay its dimensional stability and its heat resistance Rood 1986 It is also unaffected by corrosive environments cannot be attacked by vermin and performs in the most severe salt water conditions Power 1986a These qualities are important for underground pipeline wrap that is used to prevent the deterioration of pipeline buried in earth or under water Power Marketing Group and Nicolet Inc. both sell a asbestos mineral felt which can be used instead of asbestos pipeline wrap Power Marketing Group sells its mineral felt for 5.80 square feet the same price as its asbestos felt This product appears to have the same advantages as the asbestos product -- resistance to chemicals rotting and decay dimensional stability and heat resistance Power 1986b However it does not have the proven track record of asbestos felt because it is a new product There are instances of asbestos pipeline wrap being in the ground for over fifty years a track record which makes companies reluctant to replace this successful and proven product Nicolet Inc. refers to its mineral felt as Safelt Safelt is a combination of minerals fibers and binders It contains a minimum of 75 percent biodegradable components Safelt is available in two types -- 960 and 966. Safelt 966 is more dense and is therefore sold in a thinner layer Nicolet n.d. They are both priced 6.20 square feet Nicolet 1986a but product literature states that application costs are lower than asbestos wrap because of their superior wrapping characteristics Nicolet n.d. This characteristic is not modeled because Nicolet officials would not quantify this advantage and coaters could neither confirm or deny its existence Power Marketing Group also sells a fiberglass felt called Duraglass It - 4 - is priced 5.80 square feet They have had problems however in using it in the coal tar enamel method because it does not seem to bond well Power Manufacturing is currently in the process of reformulating the product in order to rectify this problem Power 1986b A summary of the characteristics of the asbestos substitutes is presented in Table 2 The All American crude oil pipeline a major country pipeline is being coated with a new coal tar system which does not use any asbestos or mineral felt A 20 mil thickness of coal tar enhanced urethane is applied first It is followed by a 1.5 inch urethane foam layer The final step is to apply a covering of Polykin tape Pipeline Digest 1986 Since this method has no history we do not know its advantages and disadvantages These are the only direct substitutes for asbestos pipeline wrap in the coal tar enamel method of coating pipes However there are seven other methods of coating pipes asphalt enamel film powder bonded polyethylene tape extruded polyethylene sintered polyethylene and insulation Pipeline Digest 1986 The 1985 market shares and output levels for these processes are presented in Table 3 The coal tar enamel method is the only method of coating pipes that presently uses asbestos pipeline wrap In 1985 it accounted for 14.39 percent of the pipeline coating market Pipeline Digest 1986 In the event of an asbestos ban pipeline coaters and oil industry representatives believe that asbestos felt used in the coal tar enamel method will be replaced by mineral and fiberglass felts both of which are good substitutes Arco 1986 Energy Coatings 1986 They do not expect the market share 14.39 percent held by the coal tar enamel method to be taken over by any one or all of the other seven methods just because asbestos felt will be unavailable Thus it has 5- {Z206T) pe2usz0eN deTS09 pum (4906T) Troensy Tanog Substiutes Asbestos remoz Jamar ManufctreManufacturer Inc. a8equBapes Inc. tq Inc. daz NarketingNarketing esTdqaym pOBTa{eyIE*T{Om Historical BY Chemical , UT Bul Dimensioal resitanUGO and ourledt Pur Felt AAT TWIS As Chemical "ele 36} Marketing Group aplicton ATIqQea Dimensioal resitance MarketingGroup Group qeTel teaquespy Marketing resitance TX 447 07 qvRaqs Jeu and resitance resistance 40s Felt and Group Tea pl Chemical PR TR Dim Marketing resitance PaoTIURG Dimensioal Marketing ugmten 7 Marketing Group Group Dimensional resitance . {eRg eTqEL dnorp AGATE Iu NU) sty vyawysENWL Qe Too TR leTquycencd wo dnoig dn1p omyfyq suyey) ML Suto ML qeTOsTR zeTqUysown wo\encg 208a7 '2o9eNog onpoag Steg so yrveqay AIeog 3792 TeOUTH esyWeqt Table 3. 1985 Market Shares and Output of Pipeline Coating Processes Process Asphalt Enamel Coal Tar Enamel Film Powder Bonded Polyethylene Tape 8,251,037 Extruded Polyethylene Sintered Polyethylene Insulation 15,602,441 Output square feet Market Share percent 200,000 20,00 200,000 88,439,891 263,807,418 263,807,418 28,293,723 28,293,723 28,293,723 1.34 196,255.978 13,704,375 2.54 0.03 14.39 42.39 4.60 31.93 2.23 Source Pipeline Digest 1986 7- been assumed that substitution will be entirely for asbestos felt rather than for the coal tar enamel method The inputs for the Regulatory Cost Model are presented in Table 4. It has been assumed that Power Marketing Group or some other company will formulate a more successful fiberglass felt which will take 20 percent of the market Arco 1986 The remaining 80 percent of the market will be taken by mineral felt Because this is a new product there is no data on projected market shares As a result it is assumed that the current market shares of the producers of the asbestos product will apply to the substitutes as well This will result in a 48 percent 0.80 x 0.60 projected market share for Power Marketing Group's mineral felt and a 32 percent 0.80 x 0.40 projected market share for Safelt Nicolet's mineral felt E. Summary Asbestos pipeline wrap is a felt product used in the coal tar enamel method of coating pipes This product is not being produced in the U.S. although one company was selling it out of inventory and another company was importing it from Canada and distributing it Total domestic production of this product is estimated to have been 296,949 squares in 1985 It has been assumed that adequate substitutes exist for asbestos felt and therefore pipeline coaters will not switch to alternate methods of coating pipes in the case of a complete asbestos ban It is estimated that 20 percent of the marker will be taken by fiberglass felt that costs square The remaining 80 percent will be taken by mineral felts Because the two distributors of asbestos felt are also the major distributors of mineral felt it is assumed that they will both retain their current market shares Power Marketing's mineral felt will capture 48 percenotf the Hence We cannot Power Marketing look at the trends in market Group are not available shares because 1981 data for +8 - saurejoy (Q9GT) (861) (t46T) C9B60) (967) THMag Jemog Jemog SeTOTH remng omyg v/a 1041 4 a . Inputs Product queTe#noT2g Product inky Conf icient eznde/op Consumption exnbo/9 St Froduction Ratio 296,94 TT 0.0490 square 2.5 paed 296,949 THEN oz cz 52 gg = Azoje[NPoy 8 A eoTg og exnbs/oe6$ 02 wabs7oe9 SOQseqay N N t07 {ie}Oty 3 QoMpazyZAereuo> Eqndu; wo it 4 v/n id v^'N Aplicable At achment Atachment explantion @IeTh/EIO] JomposAUOTAZIECg 0640" /R W/8 wa O coyzewtdis andang _grezende 64S6E =. aTeortdy TTOg queays7 ponporg sO IwSgeY Vet vIn v/a roxy ATO] (W) v2] som [ETOUH Caypezs 8eang = v/e eng. market at a price of square and Nicolet's Sefelt will capture 32 percent of the market at a price of square - 10 - ATTACHMENT ATTACHMENT The asbestos fiber consumption and asbestos pipeline wrap output for Power Marketing Group and Nicolet Inc. were computed using the following methodology Power Marketing Group estimated that 100 square feet of saturated pipeline felt weigh 13 lbs Because the saturated felt is 23 percent asphalt or tar coating the unsaturated felt weighs 10.57 lbs 1.23 Because the unsaturated felt is approximately 85 percent asbestos 100 square feet of pipeline wrap contain 8.98 lbs of asbestos 10.57 * .85 Therefore the asbestos product coefficient is 0.00449 8.98 lbs./square / 2,000 lbs./ton lbs./ton tons square - 11 - REFERENCES Arco Oil & Gas Company J. Murray 1986 November 24 Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. Energy Coating Company W. Heineman 1986 telephone conversation with Peter Tzanetos November 3 Transcribed ICF Incorporated Washington D.C. ICF Incorporated 1984. Imports of Asbestos Mixtures and Products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency EPA Doc Control No. 20-8600681 ICF Incorporated 1986 December Survey of Primary and Secondary Processors of Asbestos Pipeline Wrap Washington D.C. Krusell N Cogley D. 1982. GCA Corp. Asbestos Substitute Performance Analysis Revised Final Report Washington D.C Office of Pesticides Toxic Substances U.S. Environmental Protection Agency Contract Number 68-02-3168 and Nicolet Inc. Sales Representative 1986a telephone conversation with Peter Tzanetos November 11 Transcribed ICF Incorporated Washington D.C. Nicolet Inc. R. Hittinger 1986b November 5 Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. Nicolet Inc. n.d. Product Literature Safelt Ambler PA 19002 Pipeline Digest 1986 April 7 Pipe Coating Survey Houston TX Power Marketing Group 1986a Public comment brief on asbestos pipeline wrap submitted to U.S. Environmental Protection Agency Washington D.C. Power Marketing Group J. Toerner Houston TX Transcribed telephone Incorporated Washington D.G. 1986b October 24 conversations with and October 31 Peter Tzanetos ICF Power Marketing Group G. Pytko 1987 January 30 Denver CO 80231 Letter to Peter Tzanetos ICF Incorporated Washington D.C. 20006 Rood K. 1986 October 31 Independent consultant former employee of JohnsManville Corporation Transcribed telephone conversation with Peter Tzanetos ICF Incorporated Washington D.C. TSGA Section a Submission 1982a Production Data for Primary Asbestos Processors 1981. Washington DC Office of Toxic Substances U.S. Environmental Protection Agency EPA Document Control No. 20-8601012 TSCA Section a Submission 1982b Production Data for Secondary Asbestos Processors 1981. Washington DC Office of Toxic Substances U.S. Environmental Protection Agency EPA Document Control No. 20-8670644 - 12- V. BEATER GASKETS A. Product Description Gaskets can be described as materials used to seal one compartment of a device from another in dynamic applications such as engine and exhaust manifolds Asbestos gaskets used mainly to seal connections and prevent leakage of fluids between solid surfaces can be classified into two categories beater and compressed sheet discussed in Section XXVII Compressed sheet gaskets are Asbestos beater gaskets are less dense use shorter asbestos fibers and have lower tensile strength than compressed asbestos sheet gaskets Consequently beater gaskets are used in less severe applications and at temperatures ranging up to 750 At temperatures between 250-750 asbestos beater gasketing can withstand pressure ranging between vacuum and 1,000 psi Union Carbide 1987 Beater gasketing comes in a continuous roll form reducing waste during die cutting is more dimensionally uniform and is less expensive than sheet gasketing ICF 1986 Asbestos beater gasketing is manufactured by a technique employing a paper making process using fourdrinier or cylindrical paper machines to make paper from a viscous slurry of asbestos and liquid binders The asbestos fibers are incorporated within various elastomeric binders and other fillers to form the beater paper These products are used extensively for internal combustion applications and for the sealing component of spiral wound gaskets Union Carbide 1987 Beater gaskets generally contain 60 to 80 percent asbestos in combination with 20 to 40 percent binders and are used primarily in the transportation and chemical industries as The binder is added during the beater process hence the nane beater 1 . head carburetor exhaust manifold and transmission gaskets to prevent leakage of oil fuel water gas or low pressure steam in automobiles trains airplanes and ships and flange spiral wound and general service industrial gaskets to prevent leakage and potential reactions of chemicals in reactors compressors heat exchangers distillation columns and similar apparatus ICF 1986 The particular binder used in a beater paper determines the material's suitability for use in water oil fuel or chemical environments Since the proportion of fiber to binder determines the intended temperature range different grades of asbestos beater gaskets are available for different temperature use limits Latex is the most popular binder but styrenebutadiene acrylic acrylonitrile neoprene fluoroelastomeric polymers rubber polytetrafluoroethylene PTFE and silicone polymers are also used Krusell and Cogley 1982 . Gasketing paper is usually produced in a sheet or sheet roll that varies in thickness from approximately 1/64 inch to 3/16 inch Gaskets are fabricated to specified sizes and dimensions from these sheet rolls They may be used in this form with no further fabrication required or they may be processed further by reinforcing them with wire insertions or by jacketing the paper with various metal foils plastics or cloth ICF 1986 B. Producers and Importers of Asbestos Beater Gasketing In 1985 four companies at five locations Armstrong World Industries Fulton NY Hollingsworth & Vose East Walpole MA Lydall Corp. Hoosick Falls NY and Covington TN and Quin Corporation Erie PA produced asbestos beater gasketing A fifth company Boise Cascade Corporation Beaver Falls NY produced beater gaskets in 1981 but did not supply information for the ICF survey In order to account for the estimated production of this company a methodology was developed to allocate the industry averaged trend to the responding companies Appendix A The 2- consumption in this category for 1985 is estimated therefore to be 12,436.4 tons of fibers used to produce 16,505 tons of beater gasketing Table 1 lists the total production of beater gaskets The beater gasketing market was estimated to be worth 24.8 million in 1985 based on an average price of 0.75 per pound ICF 1986 Beater gasketing is not imported to the United States Beater gasketswere however imported by foreign automobile manufacturers Kawasaki Toyota and Suzuki have in total reported imports of 361.35 tons Other auto makers also imported beater gaskets but the actual import volume for 1985 was not available ICF 1986 C. Trends . Between 1981 and 1985 Rogers Corp. Rogers CT Nicolet Inc. Norristown PA and Celotex Lockland OH three manufacturers that formerly produced asbestos beater gasketing either substituted for asbestos with other materials or discontinued their operations During those four years one company Lydall Corp. Hoosick Falls NY initiated production 3 Total production of asbestos beater gasketing paper declined by 37 percent between 1981 and 1985 resulting in a reduction from 26,039 tons to 16,505 tons ICF 1986 ICF 1985 All six manufacturers are currently producing substitutes for their products The substitutes currently hold about a 50 percent share of the gasket market ICF 1986 but as concern about asbestos grows and substitutes gain wider acceptance the production of beater asbestos gaskets is likely to decline further ICF 1986 Gaskets as opposed to gesketing processors for their customers are custom made by secondary Lydall in 1984 and location Corp. purchased the beater gasketing business subsequently moved the operation to their Hoosick of Rogers Falls NY Corp. 3 Table 1. Production of Asbestos Beater Gasketing and Asbestos Fiber Consumption Total 1985 Fiber Consumption short tons 1985 Production short tons Reference 12,436.4 12,436.4 12,436.4 16,505 ICF 1986 D. Substitutes Asbestos is a chemically inert nearly indestructible substance that can be processed into fibers Asbestos fibers partially adsorb the binder with which they are mixed during processing and subsequently intertwine within it and become the strengthening matrix of the product Gaskets made using asbestos contain as much as 80 percent asbestos fiber some of which has been employed as a filler The balance of the product is the binder which holds the asbestos in the matrix Industry leaders indicate that they have been unable to find a single substitute for asbestos that can reproduce all of its qualities and have been forced to replace asbestos fiber with a combination of substitute materials including cellulose aramid glass PTFE graphite and ceramic fibers Asbestos used as a filler has been replaced by other fillers e.g. clay mica Formulations of substitute products most often include a combination of substitute fibers and fillers in order to reproduce the properties of asbestos necessary for a particular application Formulation of substitute products is done so as to meet the performance requirements on an application application basis ICF 1986 For the purposes of this analysis the substitute products have been grouped into six major categories according to the type of asbestos substitute used cellulose fiber aramid fibrous glass polytetrafluoroethylene PTFE graphite and ceramic fiber mixtures ICF 1986 Palmetto Packing 1986 Table 2 presents the characteristics of the substitute materials The estimated current market shares for the different substitute formulations are presented in Table 3. For all beater applications asbestos producers still occupy 50 percent of the market It is evident 9@6T "9860 OL or 9G6U OT ege6 OOsDY0TeF ZING 4tac' 4ing Sutspy '96T $@6T Table Substiutes SubstiutesSubstitutes for Asbestos Asbestos Beuter Add QDI 51 TOR DI 251 yOeN LI 207 YOu 2OFAdd [RO6T gest Ot ok 961 Aime Ayar Paper Paper 's0gOPTqaey '9@6t ea6t 'seqg 2Ot JOE YouGozag 11 sot sey tadug Inexpensive KOANOSTTadueyz LTO Guproyans IJAGJEZS CTUANFGQWsIT Os Disadvntage Teoymaqts Remarks Remarks OIA ayy low resistant Up temperature . 4 only * TieWT only resitant IdSEAS 40490 UezO peaQNPUT 490-798 o4ne *sTPOE py-seqcgFibern F than *O708qSR FCF More expnsive "speoy "qaeyTsz 20} usyy BE Lnwal ICF tensile QUPSTEeL QUeIEST BUTIND stg SDT *90Z2.ASE 4nd J{eUBoT]ZepUD resilntas LTROWYD in *aueTtz as ICF AOR" Not Be TTS geywaTqng in mUTOG contact fod food Deforms Deforms Deforms heavy 10g #IOK38 the 20K 20n Palmeto e eTaL pup Fastest *ea,qredo oWISTVEX weight *qom Britle auto growing 02 QUue;r quesrofseals qUAYSTes QUPASTseL @ayTATI"D Not oil oil raitant HDpITy pendrdeTe yuEIeT "QE TT es 2EeYy ousdvouyPooy Not resilent resilient pocg OTN MoT [e2;uaYy) Woy Tpes yoog TR>;UNED QUIT YTTE TVIURD ICF e29qid qedeq 4onpoag S2oTO7{sq praniy T8079 wild aqrudeza oyumis) Table 3. Estimated Fibers Market Share for Asbestos in Beater Gasketing Substitute Fiber Cellulose 25 Aramid 30 Glass 20 PTFE 10 Graphite Ceramic 10 5 Estimated Market Share percent References ICF 1986 Palmetto Packing 1986 ICF 1986 Palmetto Packing 1986 ICF 1986 Palmetto Packing 1986 ICF 1986 Palmetto Packing 1986 Union Carbide 1987 ICF 1986 7 from the survey of asbestos processors however that the market share of asbestos beater gaskets is increasing rapidly as companies replace asbestos in some applications One obstacle to complete replacement of asbestos gaskets by substitute products is military contract specifications that require asbestos gaskets 1. CellFu ibel r o Mixs ture es Cellulose fibers are generally milled from newsprint or other waste forms of cellulose e.g. vegetable matter in the presence of additives which ease grinding and prevent fires during processing Gellulose fiber gaskets usually contain between 20 and 25 percent cellulose fiber and 50 to 55 percent fillers and thickeners The remaining 25 percent is usually an elastomeric binder ICF 1986 Traditionally cellulose fibers do not resist pressure well and crush easily However proprietary methods have been found to reinforce fibers This results in excellent crush resistance excellent dimensional stability and good sealability below 350 Cellulose gaskets can substitute for asbestos beater gaskets in low temperature applications below 350 such as with oil gas organic solvents fuels and low pressure steam Three producers of asbestos beater gaskets also produce cellulose based gaskets They are Armstrong World Industries Hollingsworth & Vose and Lydall Corporation ICF 1986 Armstrong World Industries of Fulton NY the largest producer of asbestos containing beater gaskets produces a line of asbestos cellulose based gaskets Syntheseal Armstrong indicated that the asbestos formulation costs more to produce and yields a product comparable in quality to the asbestos product for applications with an operating temperature under 350 Armstrong 1985 B Hollingsworth & Vose also produces a line of cellulose based asbestosfree gaskets The formulation includes mineral fillers and an elastomeric binder The company cited no quality problems with their asbestos gasket line that costs more to produce ICF 1986a The Lydall Corporation also produces cellulose based gaskets that cost more than the asbestos formulation Company officials indicated that these cellulose based products can only be used in temperatures below 350 ICF 1986 Reinforced cellulose based gaskets have increased in popularity in the past few years These gaskets can duplicate all asbestos performance parameters except high temperature resistance Although they can be used at a maximum continuous operating temperature of 350 their life is substantially shortened in temperatures over 95 and they cannot be used in even mild pressure applications Union Carbide 1987 But in the right operating environment manufacturers indicate that the service life of these asbestos gaskets is the same as that of asbestos gaskets ICF 1986 In the event of an asbestos ban cellulose fiber formulations in combination with clay and mineral thickeners are estimated to capture 25 percent of the gasketing marker Table 3 Prices would be expected to rise 20 percent to 0.90 per pound due to increased material and production costs ICF 1986 Palmetto Packing 1986 2. Aramid Mixture Aramid fibers are used in asbestos gaskets because they are highly heat resistant and strong ten times stronger than steel by weight Aramids are at least seven times more expensive than asbestos by weight but as they are less dense and stronger less is needed for reinforcement purposes At high temperatures above 800 F the fiber physically degrades -9 and it can only be used in applications where pressure service is below 1,000 psi Union Carbide 1987 Aramid gaskets are usually 20 percent aramid fiber by weight and 60 to 65 percent filler The remaining 20 to 25 percent is binder that keeps the fibers in a matrix Typical applications include gasketing for internal combustion engines in highway equipment diesel engines and compressors These applications require a very strong gasketing material that will withstand moderate temperatures ICF 1986 Thermo R is a trade name for the line of containing gaskets that Armstrong World Industries markets for operating temperatures over 350 Armstrong 1987 The content is a proprietary mixture of aramid fibers and other fibers and fillers that changes according to intended operating parameters Many types of Thermo R gaskets are available each with different combinations of suitable operating temperature and pressure ranges Armstrong 1987 The various types of gasket were designed for specific applications such as small engines and motors 2 sealing fuels fluids and hot oils a sealing gases water and low pressure steam and rT compressors and transmissions Armstrong 1985 Suitable temperatures can range up to 800 and pressures can range up to 1500 pounds per square inch Armstrong indicated no diminished quality with the asbestos gaskets In fact greater sealability is often found with the Thermo R gaskets Hollingsworth & Vose identified strength and high temperature resistance as the reasons for selecting aramids for asbestos beater replacement Their formulation includes mineral fillers and elastomeric binders The estimated cost of the aramid product was 1.5 to 3 times as much as the asbestos product resulting in gaskets that cost 1.69 per pound ICF 1986 4 10- Although aramid products are expensive their high temperature and pressure limits make them very attractive for gasket applications Thus the estimated market share for aramid products would be about 30 percent of the total asbestos market in the event of an asbestos ban ICF 1986 3. Fibrous Glass Mixtures Fibrous glass is generally coated with a binder such as neoprene tetrafluoroethylene TFE or graphite in the manufacturing process to make gaskets The glass fibers are relatively easy to manufacture into this material Fibrous glass gaskets can be divided into two groups E glass gaskets and S glass gaskets depending upon the type of glass fiber used in the formulation E glass is one of the more common glass fibers and it is occasionally manufactured into a gasketing which is used as a jacket around a plastic core of carbon or aramid fibers and other material OGJ 1986 E glass gaskets are suitable for applications where the operating temperature is below 1000 Above this temperature the gasketing loses 50 percent of its tensile strength The material can be used with most fluids except strong caustics The second type of fiber S glass was developed by NASA and is recognized as the superior glass fiber in use today OGJ 1986 This material is occasionally used as a jacket around a core of graphite and other fibers This beater gasketing is caustic resistant and can be used in applications with operating temperatures that reach 1500 OGJ 1986 It is estimated that glass gaskets will capture 20 percent of the total asbestos beater gasketing market and will cost twice as much as the asbestos material Thus the price will be 1.50 per pound Palmetto Packing 1986 ICF 1986 11 4 Polytetrafluoroethylene PTFE Fibers of polytetrafluoroethylene PTFE are used as substitutes for asbestos in gaskets because of their chemical resistance to all but the most powerful oxidizing agents acids and alkalies in temperatures ranging from .450 to 500 Chem Eng News 1986 PTFE also has good dielectric strength and impact resistance PTFE can be used in specialized applications because it has been approved by the FDA for contact with food and in medical equipment In addition it does not stain the fluid with which it has contact Krussel and Cogley 1982 The finished product is 3.5 times as expensive as the asbestos product resulting in gasketing material costs of 2.62 per pound PTFE gaskets will capture an estimated 10 percent of the total asbestos market in the case of an asbestos ban Palmetto Packing ICF 1986 5. Graphite Flexible graphite is made from natural flake graphite expanded several hundred times into a light fluffy material by mixing with nitric or sulfuric acid It is then calendered into a sheet without additives or binders Chem Eng News 1986 It is extremely heat resistant and inherently safe because it does not contain binders Graphite gaskets are suitable for applications where the operating temperatures reach 5000 in oxidizing atmospheres In the presence of oxygen the material is limited to use below 800 Chem Eng News 1986 The gaskets have excellent 4Other forms e.g. carbonized convenience of graphite with similar properties are also available viscose rayon but are grouped in the category for - 12 - chemical resistance with the exception of strong mineral acids and can be used up to 1,500 psi Union Carbide 1987 Graphite material is often used in oil refineries and oil field applications because of its high temperature resistance A wire can be added to increase strength in high temperature high pressure applications OGJ 1986 Graphite is an expensive material but the addition of various fillers helps keep the cost competitive with other substitute materials Graphite gaskets are estimated to cost twice as much as asbestos beater gaskets resulting in a cost of 1.50 per pound This substitute's market share is estimated to be 10 percent of the total asbestos gasketing market but this value is likely to rise to 50 percent for internal combustion engines and to 20 percent for all applications Union Carbide 1987 6. Ceramic Mixtures Ceramic mixtures are made from high purity alumina fibers that are thoroughly interlaced in the production process and bonded with either an elastomeric or inorganic binder The elastomeric binder can be used when operating temperatures do not rise above 800 while inorganic binders can be used for all operating temperatures Ceramic fiber products are heat resistant chemical resistant and very strong this enables them to be used under stressful operating conditions Three major companies that produce ceramic paper used for gasketing purposes are Cotronics Corporation Carborundum Corporation and Quin Corporation Only Quin is also an asbestos beater gasketing producer Quin indicated that their formulation for asbestos free gaskets was Sunlike other gasketing materials that exhibit a temperature dependence flexible graphite is able to withstand high pressures independent of temperatures 13 - proprietary but did state that the ceramic mixture products could capture 5 percent of the asbestos gasketing market The manufacturer stated that the ceramic mixture is not as resilient as asbestos and not as resistant to oil but claimed that this was not detrimental to the function of gaskets in most applications The price of ceramic gaskets is estimated to be three times that of the asbestos products they replace resulting in a cost of 2.25 per pound The service life of the substitute product is 5 years as is that of the asbestos gasket ICF 1986 E. Summary It appears that substitutes for asbestos containing gaskets currently exist These products cost more to produce however and may not perform as well in all applications Because no single substitute fiber exists manufacturers have been forced to replace asbestos with a combination of substitute materials including cellulose aramid glass graphite PTFE and ceramic fibers The substitute materials are a combination of fibers and fillers designed on an application basis The estimation of market shares and prices of the substitute formulations in the event of an asbestos ban relies to a large extent upon educated judgments of industry experts Table 4 summarizes the findings of this analysis and presents the data inputs for the Asbestos Regulatory Cost Model - 24 - 4061 ofpupyoes Mugyorg GP1qQIED ermez ey Bouter Asbetos Regulatory PA6I 9860 9861 '95T $62 '9R6T 96 Jot J3I ANT 491 S57 ADT JOT OutputOutput Coeficient Asbestos Production Patio Price Useful Life = = = = 0.75349 ton ODN" 9 BA 2 957/0 6 ueTeAtom /08C 1,50 5 Asbestos 16,505 0.75349 CE CS 5 years THZST 3909 A N pzwek H s1em^' 1,80 5 erea^' Jedeg 'S g N = years Lraqe,nSy 5 soyeaqy PUTAMEN K 3,380 01/08" worsoge 01/00 e324 N K TS M 26 3,000 /0RL 5 years 07 PY-Te40Mgsyduy A (60D) K Wd eu v/a v/u v/a ww 2409 NA " eTqUE Woy AB X v/a v/a /u via val via zaTZFeQDZonporz 6yESL'O = qdang COS VR v/a v/a vin v/K v/a 'ST = fUZQeynND wely qapozy ecoTeT FO{eAgcy Tea pros anorgis 4g arjqtasg Stam S Armstrong World Industries gasketing material 1985 Product literature on Thermo Armstong World Industries L. Creech Transcribed telephone conversation with Washington D.C. 1987 Mark July 1 Fulton NY Wagner ICF Incorporated Chemical Engineering News October 27 for Substitutes McGraw 1986. Asbestos Users Step Up Search ICF Incorporated 1985. Appendix H Asbestos Products and Their Substitutes in Regulatory Impact Analysis of Controls on Asbestos Asbestos Products Washington DC Office of Pesticides and Toxic U.S. Environmental Protection Agency and Substances ICF Incorporated 1986 December Survey of Primary and Secondary Processors of Asbestos Beater Gasketing Washington DC Krusell N Cogley D. 1982. GCA Corp. Asbestos Substitute Performance Analysis Revised Final Report Washington DC Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency Contract 68-02-3168 Oil and Gas Journal May 26 1986. Refining Technology Substitute Materials to Replace Asbestos in Refinery Gaskets and Packings PennWell Publication Tulsa OK 47-51 Machine Design PP 67-71 1986 July 10 Better Gaskets Without Asbestos Volume 58 Palmetto Packing S. Transcribed telephone Washington D.C. Matt 1986 January 8 and 19 North Wales PA conversations with Linda Carlson ICF Incorporated Union Carbide Corporation P. Petrunich 1987 March 4 Cleveland OH Letter with enclosures addressed to Tony Bansal ICF Incorporated Washington D.C. - 16- 16-