Document 5ynb2BD00exqkYNGr8BO5oq4

CLMEXT ASBESTOS PRODUCTS COMPAXY 214-1 Highland Avt-nur, South * P. O. Ilox 3435 / lliimingham, Alabama 152tO * Pham 2n5 933-72M W. H. BEASLEY Vico PfCaiii.'nUContrelicr January 12, 1976 Mr. Kelly M. Peil Roy F. Weston, Inc. Weston Way West Chester, Pennsylvania 19380 Dear Kelly: f t 0Q Please find enclosed the completed industry questionnaire re the asbestos study for AIA. As you recall, we agreed to mak report that would include numbers for both plants. You wl.ii notice I am attaching the flow diagram with the numbered steps for references. If further information is desired please do not hesitate to call. Sincerely, WHB:mf Enclosure bcc: Mr. A. E Mr. W. R Mr. I. L Mr. S. D Alpine Bond Taylor Weaver W. H. BWsTejr^ Manu[in turn <>f . 1 dir.<t,n-(h m, nt anil P. I'. Viju- HER 0008380 ROY F WESTON. INC. WESTON WAY WESTCHESTER. PA. 19380 PHONE: (215) 692-3030 TELEX: 83-5348 3SC ENVROMiENTAL CONSULTANTSOESXSICRS As indicated in Mr. Robert Mereness1 recent letter to you, Roy F. Weston, Inc. has been engaged by the Association to gather information and prepare a report on the technological feasibility and economic impact of the pro posed revision to the OSHA Asbestos Standard. This report will be based upon the data and opinion provided by your company. We believe it is in the best interest of your company, and the industry as a whole, to parti cipate in achieving a reasonable Standard. Weston15 plans are to contact you to discuss the attached questionnaire. Depending upon the project schedule (Weston's report will be issued to AIA/NA no later than 2 February 1976), a member of our project team will: Set up an appointment for a plant site visit, or * Record your input by telecon, or a Provide mailing instructions for your response. To assure confidential treatment of your input, the cover sheet of the questionnaire will be coded, detached from the questionnaire, and kept separate. The cover sheet and questionnaire will not be duplicated. Your data will be kept by Weston until the rule-making process is completed. At that time, your original input will be returned to you. A questionnaire for each plant is required. If you have more than one plant, please duplicate the attached questionnaire. Very truly yours, J LH:j wg Attachment Jerry L. Hebb Manager, Occupational Health Management Department HER 0008381 ROY F. WESTON. INC. WESTON WAY WESTCHESTER. PA. 19380 PHONE: (210) 632-3030 TELEX: 83-5348 ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA INDUSTRY QUESTIONNAIRE^1) Company Name Plant Address 'Corporate Affiliation Name of Plant Contact Cement Asbestos Products Company 2144 Highland Avenue South, Birmingham, Alabama 35205 ASARCO Incorporated W. H. Beasley Title Vice President-Controller Phone Number (205) 933-7281 Note: This cover-page will be detached from the remainder of the questionnaire to insure confidential handling of all information. (1) For assistance in completing the information in this questionnaire, please contact Mr. Jerry L. Hebb, Roy F. Weston, Inc., phone (215)692-3030. (2) If, for any reason, you do not choose to participate in the study by completing this questionnaire, please return it directly to Mr. Jerry L. Hebb at Roy F. Weston, Inc. CONFIDENTIAL Company Code # Plant Code # -1 HER 0008382 I. General Product/Process Information 1. Which of the following industry segments best describes the asbestoscontaining products in your operations? (Check more than one, if appropriate). X Asbestos Cement Products (pipes, sheets, siding shingles) Asbestos Paper Products (asbestos felts, latex sheets, underlayments, electrical and commercial papers) Floor Tile Coatings (roof coatings, caulks, sealants, paints, adhesives and undercoatings) 'Friction Materials (automotive linings, disc components, blocks, clutch facings) Gasket, Packing, Sealing Devices Joint Cements Asbestos Reinforced Plastics Asbestos Textiles Asbestos Drilling Muds Asphaltic Paving Distribution/Resale Miscellaneous (Specify) ;___________________________________________________ 2. Which of the following categories best describes the operation at your plant? (Check more than one, if appropriate). a. X Manufacture a product where raw asbestos is used. What tonnage of raw asbestos do you use per year? 14,000 tons b. ______ Process a product which already contains asbestos. 3. In reference to Question l, for each industry segment, give the specific asbestos end product(s) (siding, pipe, etc.) manufactured, handled, or used at this location and the annual volume of each (in pounds, tons, square feet, etc.). Industry Segment A/C Products _______________ End Product(s) Pipe ____________ _____________ Annual Volume 32,000 tons - Ragland 38,000 tons - Vnn Buren 70,000 tons - Total CONFIDENTIAL Company Code # -2- Plant Code # HER 0008383 k. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years: 2 Plants 1971 1972 1973 1974 1975 $ $ $ $ $ 6,500,000 8,000,000 io.ooo.ooo 14.700.000 i3.ooo.ooo 5. What was the level of capital expenditure for plant improvement and expansion of production facilities for asbestos containing products during the last five calendar years? (include capital expenditures for environmental control, plant improvement and expansion). 1971 1972 1973 197^ 1975 $ $ $ $ $ 2.000.000 500,000 loo.ooo 300.000 700.000 . 6. What is the total plant employment at this location? 7. Give the approximate percentage of the employees whose asbestos exposure falls in the following categories: a. Continually in the work environment (operating, production, materials handling personnel) 201 b. Frequently in the work environment (maintenance, supervisory personnel) 54 c. Only occasionally (less than 5 times per week) in the work environment (management, engineers) 10 d. Never or very infrequently enter the work environment (secretaries, sales personnel) 9 8. What unions (locals) represent your employees, if any? a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? Active Area Extent of Activity (V--Very, H--Moderate, N--None) b. What is the current pay scale range of unionized personnel? CONFIDENTIAL Company Code # -3- Plant Code # HER 0008384 i I. Control Technoloqy/Cost Information 9. Provide a brief description of each step in your operation as it relates to asbestos handling or movement. Interest is primarily in the location of dust sources (bag slitting and dumping, sanding/finishing, etc.) and in dust control at these sources (hoods, etc.) rather than in the production equipment. A block flow diagram is suggested. There should be one such diagram for each product group and/or process used. In clude raw materials entry and finished product handling. A blank page has been inserted at the end of this section for the block flow diagram(s) and description(s). If additional space is needed, please attach extra sheets. (See Attached) 10. Has control equipment been installed at each step or combination of steps in the block flow diagram(s) where asbestos is released to reduce worker exposure to airborne asbestos? Yes X No List control equipment in use: Step Type of Equipment Date Installed 1 Respirators As Needed 2 Baghouse Ragland-1965 / 1971-Van Buren 3 Baghouse Ragland-1965 / 1971-Van Buren 4-- 5 Baghouse Raeland-1965 / 1971-Van Buren 6 Baghouse Raeland-1965 / 1971-Van Buren 7 Baghouse Ragland-1965 / 1971-Van Buren 8 Baghouse Ragland-1965 / 1971-Van Buren 9 -- ------ 10 Backhouse Ragland-1965 / 1971-Van Buren 11 Baghouse Ragland-1965 / 1971-Van Buren 11. What is the total cost of control equipment listed in Question 10? a. Capital cost (installed) $ 250,000 b. Operating cost (annual) $ 100,000 (Note: give horsepower, exhaust volume, etc., if operating costs are unknown.) c. What effect has this equipment had on your process, product or production rate? Minimal_______ __________________________________ CONFIDENTIAL Company Code # k- Plant Code # HER 0008385 't' * Old this equipment increase or decrease the plant/process energy requirements (electrical power, space heating, etc.)? Increase X Decrease By how much? 12Z _________________________ 12. What process modifications or work practice changes, if any, were instituted to reduce worker exposure to asbestos? __________________ Vacuum Cleaners, Housekeeping, Method of Handling a"! Capital Cost (installed) $ 30,000 b. Operating Cost (annual) $ 5,000 c. What effects have these process modifications or work practice changes had on your process, product, or production rate? None d. Did these process modifications or work practice changes increase or decrease the plant/process energy requirements? Increase X Decrease By how much? ____________ 2% 13. Have the Control equipment or work practice changes reduced air borne asbestos levels in all of the work areas? Yes X No List the ranges of asbestos fiber counts in the work areas involved: Work Area Range of Asbestos Fiber Counts Before Modifications/ After Modifications/ Changes________________________ Changes See Flow Diagram 14. Have the control equipment or work practice changes reduced air- time-weighted average exposure to airborne asbestos in all of the work areas? Yes X No CONFIDENTIAL Company Code # 5- Plant Code if HER 0008386 (? Work Area See Flow Diagram Range of TV/A Asbestos Fiber Counts Before Modifications/ After Modifications/ Changes_________________ _______ Changes The present asbestos standard sets a maximum allowable Time-Weighted Average (TWA) exposure of 5 fibers/cc over an 8-hour period. This, by statute, will be reduced to 2 fibers/cc in July, 1976. The proposed standard would reduce this level to 0.5 fibers/cc at some time in the future. If you have already reached 0.5 fibers/cc at each step where asbestos is released into the v/ork place, please go on to Part III; if not, please complete the following: 15. At each location where asbestos dust is released, do you ^eel you have installed the "Best Available Technology?" Yes X - time 8 No Best Available Technology (BAT) is defined as control equipment, process modifications, work practice changes, or combinations thereof, which have been demonstrated to provide the most effective control or reduc tion of contaminant emission. 16. If not, what do you consider the SAT to be, and how effective will it be in reducing airborne asbestos at each location? (Can be control equipment, work practices, process modifications, or combinations thereof). Locations Estimated Asbestos BAT Fibers/cc______ CONFIDENTIAL Company Code tf -6- Plant Code # HER 0008387 17. What Is the expected cost of BAT in terms of: a. Capital Cost (installed) $ b. Operating Cost (annual) $ c. Plant/Process Energy Requirements, Increase _______________ Decrease d. Personnel Requirements, Increase __ Decrease e. Process/Product Effects, Increase $ Decrease $ Explain ____________________________________________________________ f. By what date could BAT be implemented? 18. If the Best Available Technology does not reduce worker exposure to a TWA of 0.5 fibers/cc and a ceiling of 5 fibers/cc at all points, provide your considered judgment on the possibility, cost, and timing to develop new technology to achieve this level. What approach might be used? ____________ ______ ____ ______ 19. If the proposed 0.5 fibers/cc level is adopted, what action is foreseen at your plant? III. Industrial Hygiene and Health Information 20. The existing and proposed standards require certain industrial hygiene practices where workers are exposed to airborne asbestos be Iow the established TWA or ceiling levels. Do you (provide cost data where available): Cost/ Total Plant Yes No Man-Year Cost/Year a. Provide preplacement employee medical exams? X b. Provide annual employee medical exams? _x_______ c. Provide termination employee medical exams? X $ 9. $50. $ 2. $ 2,500. $13,700. $ 550. :ntial Company Code -7- Plant Code # HER 0008388 Cost/ Total Plant Yes No Man-Year Cost/Year d. Retain medical records (20 year period)? _X_ e. Maintain records of employee exposure to asbestos fiber (3 year period)? _X^ Negligible f. Dispose of waste materials which may contain asbestos in sealed containers? __ g. Provide caution labels for all material containing un bound asbestos? __ X h. Provide initial monitoring (sampling) of the work place for airborne asbestos? $1. $ 275. Provide periodic monitoring (sampling) of the work place for airborne asbestos? X $3. $ 825. t 21. Certain provisions of the existing regulation require additionai indus trial hygiene practices where levels of airborne asbestos exceed TWA of ceiling standards. Where these requirements apply to your plant, do you: Cost/ Total Plant Yes No Man-Year Cost/Year a. Have a respirator program (for use in certain work situations or emergencies)? X $4. b. Provide worker rotation where employee is unable to func tion normally while wearing a respirator? X c. Provide protective clothing (for employee exposed to asbestos greater than the ceiling level)? X_ ____ $1. d. Provide change rooms (where special clothing is required? X_ ____ $1. e. Provide separate locker facilities (where special clothing is required)? __ _X_ __________ f. Provide laundering of special clothing? __ JC_ _________ g. Post caution signs (where levels are greater than the ceiling or TWA levels)? X $1,000. $ 275. $ 275. __________ _________ Negligible CONFIDENTIAL Company Code # -8- Plant Code # HER 0008389 22 . Do you employ a company physician? Yes _______ If yes: Full-Time ; Part-Time Part-Time hours/ week No x 23. Do you employ an industrial hygienist? Yes X If yes: Full-Time X; Part-Time Part-Time hours/ week ________ No 24. Who performs your medical examinations (clinic, resident physician, etc.) Clinic and Local Physician 25. The proposed standards expand the scope of industrial hygiene practices into areas such as: shower requirements, regulated areas, expanded respirator programs, and employee education programs. In general, how do you believe your employee will react to such practices? F-irsi-. some resistance - then will accept whatever is necessary to rornplv or be protected. IV. Economic Impact Information 26. Considering individually the major products manufactured at this location has implementation of asbestos exposure control procedures and industrial hygiene programs affected the cost of these products? Yes X No If yes, specify: Products Implementation Cost, $/Unit of Production Increase Decrease _____ Pipe________ _______ 2%_________ __________________ 27. Have you experienced a shift or change in product sales due to the cost impact described in Question 26? Yes _______ No X CONFIDENTIAL Company Code r -9- Plant Code # HER 0008390 Products ______ Sales Change, S/Ycar_________ Increase Decrease b. If sales have decreased, has the demand been satisfied by: Yes Other Asbestos Products ___ Asbestos Substitute Products ___ Imported Asbestos Products ___ No __ __ __ c. Which of the above has had the greatest impact on your sales? 28. Considering individually the major products manufactured at this location, do you expect the future implementation of SAT control procedures and expanded industrial hygiene programs to affect the cost of your products? Yes X No If yes, specify: Products Pipe Implementation Cost, S/Unit of Production Increase Decrease Unknown CONFIDENTIAL -10- Company Code # Plant Code # her 0008391 29 ould you expect to experience a shift or change in product sales due to the cost impact described in Question 28? Yes _______ No x a. If. yes, specify: Products Sales Change. S/Year Increase Decrease b. If you expect a sales decrease, will the demand be satisfied by: Yes No Other Asbestos Products ___ ___ Asbestos Substitute Products ___ ___ Imported Asbestos Products ___ ___ c. Which of the above would you expect to have the greatest impact on your sales? ________________ 30. What is the typical age of production equipment in use at your plant in your particular industrial segment? Segment Typical Production Equipment Age, Years 0-5 5 - 15 15 - 25 25+ A/C Products 5-10 yrs. _________ ________ 31. In your opinion, with the implementation of BAT and the proposed OSHA standard to control worker exposure to asbestos, what portion of the existing production equipment may continue to be economically utilized? (Consider the portion of capita] equipment retained as a percentage of the total production area investment). CONFIDENTIAL -11- Company Code _______ _ Plant Code HER 0008392 Less than 10%____________ 10 - 25% ____________ 25 - 50% ____________ 50 - 75% ____________ Greater than 75% X 32. Within your community, which estimate best describes the portion of the total work force employed at your plant? Less than 10% 10 - 25% 25 - 50% 50 - 75% ____________ X ____________ ____________ V. Infor.r.stion Regarding Manufacturers/Fabricators of Asbestos-Containing Products The proposed regulations apply to every place of employment where asbestos, or a product containing asbestos, is manufactured, processed, packaged, stored, applied, used, or otherwise handled. It is extremely important to our assessment to include estimates of the number of people involved as your products are ultimately used and the possible asbestos exposure levels of these individuals. Insofar as is possible, kindly provide the following information: 33. Who uses the asbestos-containing products you produce (construction industry, auto repair garage, fabricator, etc.)? Contractors in construction of watermains, etc. V*. Describe how your products move from your plant through the final con sumer Primarily common carriers - trucks and rail 35. Estimate numbers of people and what levels of asbestos dust exposure, if any, may occur at each step (from further processing, fabrication, installation, etc.)? Minimal CONFIDENTIAL -12- Company Code # Plant Code # HER 0008393 36. Provide names of your customers and appropriate trade association so that Weston might obtain more comprehensive information in these areas ATA and A/C Pine Producers Association JFIDENTIAL -13- Company Code # Plant Code # HER 0008394