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