Document 5jdyJNkdB3aadwe7joLqB8ye

Ur. John Kilsheimer Those-. I,ist.ed Below - Suited: ASBESTOS' lrom: Dick Gruenbaum Date: December 8, 1975 This memo is a. follow-up of the meeting you called on December 3 to bring you to date on the present and proposed asbestos standards as well au how these standards may affect our future, because of the large volumes of veriniculite used which contains the asbestos. The OSHA Standards that W&&6 first printed on May 29, 1971 indicated that 12 fibers/ml was the TLV for asbestos. A new standard became effective on July 7, 1972 which indicated that the maximum 8-hour tine-weighted average of asbestos fibers not exceed 5 fibers/cc. This same standard indicated that effective July 1, 1976, the 8-hour time-weighted average asbestos fibers concentrations will be lowered to 2 fibers/cc.. " On September 30, 1975 a notice of proposed rule-making was published in tho Federal Uegister proposing to lower the 8-hour time-weighted average, exposure to asbestos of 0.5 fibers/cc. Ihe permissible . ceiling exposure 'now in effect fs 10 fibers/cc. The new proposed standard is proposing a maximum of 5 fibers/cc ceiling. Persons interested in commenting on the proposed standard.should have done . . tfti s;.by. December 8;' 1975 .. : '' ` . ': continued DOJ WRO 02172 i it j r> j\ v r r \v '%* ' To: . ' ' ' ce: Subject: . )>stf.: PAGE '/ . Based on our limited information regarding the asbestos concert . tralions in our production.facilities* ] feel the duly 1, 1376 standard can be met; however, the new proposed standard of 0.5 iibers/ec will be very difficult if not impossible to meet in our lrionized production area. : following is a history of the asbestos fibers in our vermiculite os 1 know it - I was first made aware of a possible asbestos problem in our- vermiculito in late 1371 by Hr. (red f.aton front W. R. Grace Co. fty contact through Mr. Eaton was-regarding some discussions concerning a dry dust collection system we were about to try on our vermlculite expanders. Muring early 197?, ) was in contact with Mr. Eaton on several . . occasions* again regarding the dust.collection. During . ..^veacH -discuss i'w>: the possible asbestos problem was men-. . ; tioned by Mr. Eaton and finally suggesting that W. R. ' . Grace do some sampling in our plant. . , . .V : , ' continued DOJWRG 02173 Mr. La ton, Mr, Eschenbach, Safety Administrator, ami Mr. Rustic, Environmentalist from H, R. Grace, Vfere granted permission to visit our facilities on May 30, 1972. During this visit, eight asbestos samples were taken in the Trioniyed plant area, primarily in the expander area. These samples were then analysed by VI. R. Grace. Results of tVicse tests were 0 to 8.3 fibers/cc with a mean of >?. It.should be noted that during this time four of the eight expanders were in operation using only W. R. Grace ore. : 'v '. ' V . After receiving the results from W. R. Grace's analysis, it was felt that equipment should he 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. II. Grace for analysis. Six expanders were in operation during these tests, results of which,ranged from 0.3 to 8.8 fibers/cc with a mean of 2.> fibers/cc. , , .. -.crated that some extensive sampling should be '! .. ' done to see if any r-eal problem areas could be identified. continued DOJWRG 02174 PAST - 4 Therefore, during the mouth of Hay 1973, 33 asbestos samples were obtained, ell of which were sent to W. f<. Grace for analysis. These tests were taken while running from one to seven expanders. Results indicated a low of 0.3 to a high of 59.3 fibers/cc with a mean of >4. 11 should be noted that some definite problem areas word identified during this sampling and operational changes were made where the excessively high count was obtained. After the above results were analyzed and discussed, it was decided that, one of our prime dusting areas was the sioner hoods which was due to inadequate dust collection. In follow-up, a new bag house dust collector has since beeninstalled to vent the stuner hoods. In addition, a . totally enclosed vibrating conveyor system was installed for conveying the expanded vermiculito from 5, 6, 7 and 8 expanders to the storage bins. , . .. . .The first sampling done in the expander area since the new ;V equipment has been installed was on November i?,'1975 when :V-14 samples were obtained. These 14 samples have been sent - continued DOJWRG 02175 vr C To: (re.: Subject: to V!. U.Grace ior analysis, results of which art expected around December 70. It should he noted that approximately E.0 percent of the vcrnrtculite used during this sampling period was African with the remaining f0 percent being from Libby, Montana. Six expanders were being used during this testing. . Per your suggestion, I. will be following-up on the following Items: 1. Obtain additional asbestos samples for analysis by ari independent laboratory. John Kilslifeimer will be sending nit a list of the laboratories suggested by 111. 7. 1 will, be checking with V/. R. Grace: in regard to what, ` if anything, they have done or are planning on doing about the recent proposed standards. 3. locale a laboratory that could analyze the vermiculitc . . from different sources in regard to fiber content as well as types of fibers. Will then follow-up by . .'.-'.^ sending samples to the laboratories for analysis. .Our objective for completing.the above is early January or sooner if ' possible. Sg ~~ ..... "-'-`.''i-- n.-,,i. c---. Uani- mcnn Kill Hi 1 ie.oass ft John Kennedv DOJWRO 02176 ) 1) X. !i ,o t> "U *> <.1 1r; 0h wtl ktl- t>i wo flr Wrf,f r-t ,J *>.-- Cf o c> r i..;| - fill yID. c; ft Of C cn w CO CM .1 .o {1 o c c Ae> ' jg^> Of .r: 4 <' ^"ijj 11 <d .1 ft o> to a pt >\ U| Ifl 0> o rI C*> M *O\Jf o A!rt R; < p. u S ji ?? I ,0u' i> Ul >i: o cij o 0 ti .-it |v<| *fi i un *J .t! HI In tM .) *Tf V' It t C> Iv *o < ,1i\ *Ki 0 * in g?9 oo ,t o: CO t fr |f ( >1 to Qf ft tr> I' 1 * O to fi- Of ut OJ b> m OJ fJ CM r- w V) vf> U) .'1 <.| r rt nS 0' . M` fi' S8 %f o K to rfi 60 oi If ' CJ n to O CM CM |s| <1 <1-1 V) r- .1 n .c: Jti Of i.l i C t> P1 t-0 Of (s fi O **1 11 fj .l >, o 00 . li ft f-r f ( ft 0 Of CM fl (If 0 U f 1 <0 l> ft < .ft CO <1 VP <1 _ M C>O *4 &i *0 C*\ > . W <-t > J Mi 4J l Cl mcd cft 0u 0 a* cl st>i P- Ovf oft ri [i PI W qj V> 0. kJp g *rl Of * t .! 0 |J h< n g Cl o n O O 4> CO O cf| ITl CO ir> y> cn c> >< cn un c> ,0 cn |>t Xoi f-t c n. ft ri .x: o (ft H 0 Hrl U* rt!*f 0> ** u;i w 0 t 4J ^ Of Of 0) <1 o h-t v> rO cn r? O* on CM v> tO to VO 1". r-* p r-f * I i cos' N1. t-4 t cn >>i i CM 1*4 t-4 cn o to * 00 o CM d <1* cn CM vn p^. tc< V0 t e> CM t o CM 1 i cn i r 0*1 cn <1 U*| ao o 4o>f <0 *vf Of r- < cnr O <: .O"1f t> it u V) o M uOf Of bfl 0t If o. n Gr; CwA ,ct U 'ull |0J* H01 n <rrit Of fl 0> It m> t of u Of Of 0O O0J Of K p. rl k !> Of vt>l OJ vcl: K O >ot lf-1 a 111 tt Vf CO CO o cn i*^ r vp cn r-* o* vwr> >f *CrO Jn <0>l rt q *wn u ,1rn Of O~ft crtd\t M Sbbi. fUl1 it a rco|f 1rt* tio (A u OJ .o1r 7->! rt rOOf tJ fOrff V< fij Ut 0O >0rt rt M Of *O0f 0t It of u-l t. ro if 1 o o rt >t Of aft f Of ji & o of Of 14 of Ia>t OaJ * 0O3f It 13 CJ o* KOf >rii vCll l>*> of 0 s * 66 > <mU vqftl Vdll f3Brit *cf<ti. vCil UJ M< U 00 H.s :cl >; s.Et ri of of cp fo ^ -fl ;i V) <j Of rO O O torl f fOf Cl O Of ,.g s *d m CO vr c> xt a 0 f>r U oi *0 ft p-o 3 w a K Cl. rt ft V) OHl<I* ^ff4tt .-r<t 01 najf jt-ii of ^ W>*.4 X1 6|J' Nft> r. e to *OxJf o. t O>f 40J) ori p- |J W ooE3ff Orf u > cf &o 0* M ,rt u f^r q o r: cn .i f; CO( Cl U *o %J cd Of ftf m l *0 M oo t> ft t- i `<1 v-1 a* ft tt> vf> fj M rt tfOl> qj OMf q; IOff fwt Jt3o vt rt wfit 1O*4f xt .. <w ah m'| ti n ? $ ai 3 M> t VO r- pt 1^. t VD h i[ <n pt o 63 iJg&g CO CM CM C1M <1 irn If) 4 I I O l ^rfi-h Cr>\ DOJWRO 02177 x41i 0Q1l V! A l/l */ ^h f(Ut a* a* g o n [} ai Pi fi 4pif hi fkO w .3 g r.! .} H + i\ r Pit .r? * i4n ti-tl( .TJ s-tMf .P*ii U * oHi HP* 'O n -ii 04 pi b i-O1f 0fl1 >* o g C\ Lf *8 0* 4.` fJ V> 3$ P ESrl *tc; 01 *J tfVfl Of lit to c: vl s ri t P 0* ,n 60 C! f .1 P 01 60 5 id to Hi o* a> tf u* Pr > c/. .~l| 4 Pi Of 4ff o(iif ^m 0u1 u a *<! 4 CO - 3- 8: .iJHaf E:Sj 6ti& * tc:- E* vKl H(i ,,J 0o1 V4*1 cd OX(J ro-0i) O 4* u ft V4 o Ofl4)l Vo4rf $ n. Of K rtf 0> o p; to M <>3i <o 01 oi M M Vf> 61 <0 0' P 4 (/ ) I4 'V h. CM Ofl f t tf} ^ 0\ f* t *1 rtf. Os O' cm O'! CO CO ir p-. r*. Is r- CO p-* rs r- r- 00 ps. 00 CO ps. I O r 1i 1 N- Os (O 1 fs. 1 1 Ol r~t r-l 04 * CM CO -4 1 t * 1 t 4 1 .. Ol c. V* Os 04 04 o* 01 to 4 K 0> o o u M0l 01 60 (d o- bD K V01 > 0 01 H Q, Of Of D0JWRG 02178