Document G6gJKYn104v6LapnJK1DpMvB4

FILE NAME Powhatan PHN DATE 1972 DOC PHN027 DOCUMENT DESCRIPTION Govt Inspection Reports January 6 1972 Miss Frances h Hett Powhatan hining Company 6721 Windsor Mill Ecad Baltimore Maryland 21207 Dear Miss Ketts As explained in telephone conversations on December 21 1971 and January 5 1972 by Hr 1. R. Miller an engineer in this Section a check of the asbestos exposure experienced by your employees during crushing milling and bagging operations is required at an early date as an occupational health precaution It is proposed to accomplish the check by personal monitoring of workers who are actively performing the normal tasks directly associated with each of these specific operations Simultaneous operation of all units is not necessary for our sampling purpodes and repeat visits can be made to evaluate the effectiveness of controls at each equipment when it is in use In view of the sporadic nature of your operations it is requested that you notify Mr. Beegan 383-2738 or hr Miller 383-2739 when you schedule any crushing ailling or banging activity Notice as short as the day before the planned usage is sufficient but longer notice would be appreciated Very truly yours es os wo > a we fe Wy Zs Fe hy, James A. Beegan Head Industrial health Engineering Section Tit Tit . CC Fr. cS , Mr. boos a , . % Chaney _ Schoenenan . . Phillips sito Co. sept sept . of Balth iv of Air follution * Ind lygiale RECEIVED RECEIVED RECEIVED RECEIVED RECIVED FEB 23'72 BALTIMORE COUNTY HEALTH DEPARTMENT DEPARTMENT STATE OF MARYLAND OF HEALTH AND MENTAL HYGIENE ENVIRONMENTAL HEALTH ADMINISTRATION 610 N. HOWARD STREET MARYLAND 21201 BALTIMORE : Nell Solomon M.D. Ph.D. Secretory February 23 1972 Miss Frances E. Mett . Powhatan Mining Company 6721 Windsor Mill Road Baltimore Maryland 21207 Dear Miss Metts Mr. Thomas H. Devlin Director Bureau of Environmental Health Baltimore County Department of Health has indicated that you are interested in receiving data concerning the results of sampling for asbestos levels done at Powhatan Mining Company Inasmuch as the sampling program is still in progress some background information regarding this program is felt to be in order Asbestos has been recognized for a long time as an occupational health hazard but only in recent years has asbestos dust been looked at from the viewpoint of its potential hazard to community health Limits have not been established yet for asbestos dust as a community air pollutant How- ever on August 31 1971 your plant was inspected to assess the potential public health hazard of your operations by a party consisting of the following Baltimore County Health Department Division of Air Pollution and Industrial Hygiene = Larry Kirchner and Asit Hazra Maryland State Department of Health and Mental Hygiene Division of Air Quality Control - George P. Ferreri Chris Zerby and Richard Johnson Industrial Hygiene - James Beegan and Sunil Patel This inspection resulted in the conclusion that the plant appeared to comply with the current air quality regulations with the exception of a minor emission noted on the roof The main concern was the plant | effect of suspended particulates on the plant employees and it was decided that air samples should be taken to evaluate the occupational exposure 17 Miss Frances Mett 2 February 23 1972 On September 22 1971 a party consisting of Richard Johnson Paul Guglielmoni and James Beegan from the Maryland State Department of Health and Mental Hygiene sampled two locations in your plant These locations were at the bagging operation output from 20 impact mill and in vicinity of the ore dryer on the main level above A stack sampler fitted with filters was used for collection sampling period was 30 minutes at each location Analysis of the filters by Mt. Sinai School of Medicine in New York showed 7,800 asbestos fibers longer than 5 microns per liter of air at the bagging site and 5,500 asbestos fibers longer than 5 microns per liter of air at the dryer These concentrations were in ex- cess of the intended change Threshold Limit Value for asbestos as published by the American Conference of Governmental Industrial Hygienists The inplant atmospheric environment on the basis of these two tests was consequently marginal and additional sampling was deemed to be necessary for proper evaluation to be made Subsequently pursuant to the Williams Occupational Safety and Health Act of 1970 the Department of Labor issued an Emergency Standard for Exposure to Asbestos Dust effective upon publication in the Federal Register 12-7-71 A copy of the pertinent pages 23207 and 23208 of Federal Register Vol 36 No. 234 - Tuesday December 7 1971 is enclosed In substance the emergency standard is the intended change Threshold Limit Value of the ACGIH i.e. the hour weighted average airborne concentration of asbestos dust to which employees are exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length as determined by the membrane filter method at 400-450x magnification 4 millimeter objective phase contrast illumination with excursions above 5 fibers per milliliter but not to exceed 10 fibers per milliliter permitted up to a total of 15 minutes in an hour for up to 5 hours in an hour day Methods of control including engineering handling housekeeping and respiratory protection are also specified to prevent overexposures The depth sampling program was started on February 3rd by James Beegan William Miller and Richard Johnson at the bagging operation associated with the Hazemag 20 impact mill The two workers on this operation were monitored by attachment of personnel samplers two devices on each man In this way four minute and twelve minute samples were collected on filters The minute and eight minute filters have been forwarded to Mt. Sinai School of Medicine for analysis Four minute filters have been delivered to the State Laboratory for check analysis To date the results of the analyses have not been reported from either laboratory - Continuation of the depth sampling program is anticipated by similarly -*' monitoring workers in the vicinity of the primary crusher bagger associ- ~ ated with 30 impact mill driers and other operations productive of Miss Frances E. Mett -3- February 23 1972 of scheduled operation of fugitive asbestos dust Advance notification earnestly requested devices enumerated is again any of the producing Sincerely yours JaB James A. Beogan Head Industrial Health Engineering Section JAB Enclosure Health a cc Mr. Dale Anderson County Executive ~ of Mr. Thomas Devlin Baltimore County Department Department of Health W. L. Phillips Baltimore County of Health and Mental Mr. Mr. Jean Schueneman Maryland State Dept. Hygiene DEPARTMENT STATE OF MARYLAND OF HEALTH AND MENTAL HYGIENE pert ENVIRONMENTAL HEALTH ADMINISTRATION 610 N. HOWARD STREET ' BALTIMORE MARYLAND 21201 Neil Solomon M.D. Ph.D. Secretary cy ae April 25 1972 Kiss Frances E. Mett Powhatan Mining Company 6721 Windsor Mill Road Baltimore Maryland 21207 Dear Miss Motts On February 1972 asbestos sampling study was made by James Beagan William Miller Richard Johnson at the bagging operation associated Impact mill The two workers on this operation ware monitored by attachment of personnal samplers two devices 'per man Results of the dust counts obtained on the twelve filters analyzed by Mt. Sinai School of Medicine have been received Report of the concentration of asbestos fibers per cubic centimeter milliliter 7 follows wt Operator A Operator B First minute samples Second minute samples 5.5 6.6 9.1 11.5 9.3 14.8 13.1 11.0 Average 12 samples 9.3 asbestos fibers All of these values exceed the hour weighted average airborne con- centration of 5 fibers per milliliter permitted by the Emergency Standard for Exposure to Asbestos Dust issued by the Department of Labor and published in the Federal Register Vol 36 No. 234 - Tuesday December 7 1971 A copy of the applicable pages 23207 and 23208 was enclosed with our letter of February 23 1972. Improved controls are necessary to meet the current emergency standard In this connection engineering studies should bear in mind that a permanent limitation of 2 fibers per milliliter for an hour weighted average exposure with strong advocacy for a lower limitation is under consideration The permanent standard is expected to be adopted and published in June 1972. Engineering methods such as enclosure vacuum sweeping local exhaust ventilation etc. are specified in paragraph 1910.93a b of the Emergency Standard for Exposure to Asbestos Dust as 14 = ND ON Miss Frances B. Mett 2 April 25 1972 mandatory to meet the exposure limit Accordingly the requirements of 1910.93a d for local exhaust ventilation of machinery 1910.93a 1 for collection and disposal of asbestos waste and scrap in sealed bags or containers and 1910.93a g for cleanup of asbestos by vacuum clean- ers and prohibition of dry sweeping or blowing of dust are engineering methods required at your plant Respiratory protective devices covered in 1910.93a c are considered to be interim measures pending accomplishment of adequate engineering controls Under the permanent standard mentioned above when the new limits of exposure to asbestos dust cannot be met by limiting the concentration of asbestos dust in the work environment an employer will probably be required to utilize a program of respiratory protection and furnishing of protective clothing to effect the required protection of every worker exposed Such use will most likely be deemed a variance under the Williams Occupational Safety and Health Act of 1970. Variances are generally of limited duration and approval requires justification for the absence of adequate engineering controls On the basis of asbestos dust concentrations in your plant it is believed that respirators conforming to 1910.93a 2 of the Emergency Standard for Exposure to Asbestos Dust are satisfactory and are required to be provided and worn by your employees when engaged in the dusty operations Attention is invited to the provisions of 1910.93a c 1 11 1910.93a c and 1910.93a 6 to insure proper protection and respirator upkeep In summary the following recommendations are made for early accomplishments 1 Provide respirators approved by U. S. Bureau of Mines under the provisions of 30 CFR Part 14 Bureau of Mines Schedule 21 B and enforce wearing of them by employees engaged in dusty operations 2 Conduct general housecleaning operations with vacuum cleaning methods to remove settled dust from all surfaces 3. Check all enclosed asbestos conveying systems eliminate leaky joints and install covers at openings 4. Install enclosures and local exhaust ventilation at all grinders mills and baggers 5. Provide special devices to collect asbestos remaining in filling spouts of the baggers to prevent the material from becoming airborne or falling on floor 6. Devise procedures to prevent asbestos contamination on the outside of shipping bags , Miss Frances E. Hett 3 April 25 1972 7. Use vacuum cleaning methods on floors and discontinue dry sweeping methods 8. Use vacuum cleaning methods on clothing and equipment and discontinue compressed air blowing for those purposes Continuation of the depth sampling program held in abeyance until accomplishment of recommendations 1 2 3 6 7 and 8 which can be readily done It is realized that recommendations 4 and 5 will require extensive design engineering and fabrication Sincerely yours James A. Deegan Head Industrial Health Engineering Section JAB :: w .r ccs L. Phillips Baltimore County Dept. of Health Mr. Jean J. Schueneman Maryland State Dept. of Health and Mental Hygiene Hr John B. Craft Division of Labor and Industry