Document Gmw7D6wKedDzaENo0g9qmbprv

vt i ;<o-2 jzr,^, s METALS DIVISION P. 0. SOX 579 -4625 ROYAL AVE., NIAGARA FALLS, NEW YORK 143 ro (Name) pr# j# Shorts 1 eeve/R. W. Rebholz Division ucC-Metals Division Location 270 Park Avenue New York, NY 10017 copy to Messrs. G. R. Adams T. W. Carmody W. B. DeAtley R. F. X. Fusaro E. W. Kantz/R. G. Beverly K. S. Lane O. J. Malacarne P. W. McDaniel E. A. Piersall H. B. Rhodes G. F. Rouse E. R. Weidlein File ate October 18, 1979 originatingoept. "Calidria" Asbestos Answering letter date subject EPA Study - Asbestos Mining Counties in California . Please reference my letter (copy enclosed as Item I) on the same Subject dated 7/27/79, and the following other enclosures: Item II Item III Item IV - Item V - Extracts from SAI's proposal Letter from SAI following our meeting in San Diego Letter to SAI from H. B. Rhodes with our comments on their protocol SAI's 1979 Annual Report Harry discussed this program with Paul McDaniel on 9/14/79. I talked to Paul today and he has not yet heard from SAI. Although Harry and I will be glad to help in any way possible, I think this "project" should be handled by Division or Corporate environmental/governmental affairs groups and our Law Department. If you have any questions, please contact Harry or Paul. JLMidal Enclosures a - r- A * 0oo8 UCC 003435 J-T&M JL 1.2 Summary of Technical Approach Our proposed technical approach is described in Section 3. Here we highlight the proposed tasks and key features. This effort is divided into four principal tasks in addition to reporting (documentation) functions: epidemiological protocol design; questionnaire development; source inventory and exposure characterization; and quality assurance. The epidemiological protocol design task is both the directing and synthesizing function. This segment proceeds immediately to examine the mortality data. It is this data base in conjunction with the exposure characterization that will provide the basis for most decisions in the design of the protocol. Therefore immediate attention will be given to securing * the necessary demographic information, mortality breakdown, source inventory and other data sources. During this proposal effort we have identified and located virtually all relevant available information including mortality figures. We plan on reviewing hard copy death certificates as well as company asbestos monitoring files to support our work. This task will be directed by a medical epidemiologist with experience in all required phases of the protocol design. The questionnaire development task is clearly outlined in Section 3.3. Although we will not draft this until the supporting data have been examined enough is currently known which would allow us to proceed directly to an ad vanced point. Having just completed a questionnaire for another EPA sponsored epidemiological study, our task leader is quite familiar with EPA and 0MB appro val procedures and,of coursetmeeting study requirements in questionnaire con struction. The questionnaire will be drafted, pre-tested, redrafted, and then submitted to EPA for its initial review. Subsequent to the review the same process will be repeated. * We anticipate this procedure will allow us to fully integrate the specific requirements of the study protocol, satisfy EPA Epidemilogy Branch review, and provide the justification - quality assurance - and other necessary supporting statement requirements. $ e.cei aX viA.e.aM*j 'tLt' 4 , . A. Z/10/ 7 ' S.c. UzcU w , %'Uff ft* + v o m2- A ; G 3 U 3 UCC 003436 We interpret the source inventory and exposure characterization task as a performance requirement for this proposed study. That is, we have esti mated the effort to complete rather than plan or initiate the task. If incorrect, our budget should be modified. However, we believe our inter pretation to be correct since it is an indispensible part needed to evaluate alternative approaches to conduct the epidemiological field study. A feature of our study approach is the success we have had in obtaining details on emis sions sources and cooperation from individuals in governmental and private organizations. We anticipate no serious difficulties in assembling the most comprehensive estimate of sources, emission levels and exposure isopleths for the areas. We plan on including the three designated counties and several others such as Tuolumne and Monterey since probable high exposure areas have been identified there. Figure 1-1 shows the general areas of interest centered around King City - Coalinga in the lower left and Copperoplis-Jamestown in the upper center. The mining/mi 11ing sources and the commerical establishments registering use of asbestos have been identified and emissions estimates will be constructed. All significant sources of asbestos including the natural background, mobile sources (ore and tailings hauling, vehicle friction materials, etc.), use of serpentine rock, quarry locations, etc. will be evaluated either by means of direct environmental or occupational measurements, existing emissions factors, or available models. In addition the asbestos monitoring program personnel at EPA-RTP have decided, in conjunction with our suggestion, to monitor quarry site and vehicle induced roadway asbestos levels in the Calaveras County area. This data will be taken in October 1979 and be fully integrated into air exposure determination. This task will be performed by two team members with direct experience in constructing emissions inventories of carcinogens. ' Quality assurance has been defined as a separate task entity in order to draw attention to its role and provide a distinct focus for documentation and review. Although elements of QA have been discussed in each of the task sections 3.2-3.4, we have designated specific program deliverables in our proposal schedule which will report on this specific program component. .. UCC 003437 A UQ Figure 1-1. Cal i form'a Areas of Interest to the Program. 4- - UCC 003438 0 oo 9 Furthermore,as indicated above the supporting statement for questionnaire approval will detail the associated QA elements. All key program staff will participate in accomplishing this task. The Principal Investigator will be the task leader because of his experience and the program-wide nature of this effort. sj UCC 003439 * 3.4 Source Inventory and Exposure Characterization 3.4.1 Overview During this study we will identify, analyze and document all signifi cant sources of asbestos in the geographical areas of interest. This will include man-made as well as natural sources and the present as well as the past time period. In addition to stationary sources the impact of vehicle sources will be addressed. In the latter category are friction material emissions, the effect of traffic over roads of asbestos bearing material, and the transportation of asbestos mine ore and mill tailing. We have identified much of the source information and foresee no difficulty in com pleting this task component. After the source inventory is completed the exposure characterization component will be undertaken. Emissions estimates will be derived from several sources including particular plant monitoring; ambient monitoring data; calculations based upon vehicular traffic and modeling; and emissions data from similar plant types. It will be possible to develop estimates of ambient concentrations as a function of location within the counties and time period. Admittedly the exposure mappings will be approximate measures rather than precise determinations, however based upon our prelimininary findings there appear to be several hot spots which historically may have experienced sig nificantly elevated asbestos concentrations. We will partition exposure into airborne and waterborne routes and present the range of uncertainty to be associ ated with the determinations. The results of this task will be exposure isopi eths which can be utilized in conjunction with the mortality information to examine the relationship between the two. The source inventory and exposure characterization will be established such that during the conduct of.the epidemiological field study these may be drawn upon in both tracing an individual's occupational exposure and determining their ambient exposure contribution. Details of these sub-tasks are provided in the following section. A UCC 003440 -39- 3.4.2 Task III Methodology and Data Sources Table 3.4.-1 illustrates some of the factors associated with Task III Source Inventory and Exposure Characterization. Quite a good start has been made in accomplishing this task through the proposal period. We believe that the necessary data sources and contacts have been established which assure a comprehensive inventory and exposure determination. We plan to document the asbestos inventory and exposure back through the last thirty years and develop reasonable estimates to account for the necessary prior period. The largest industrial sources in the three county area are the mining/ milling operations. Atlas Asbestos - Mine/Mill - Fresno County Colocated mine/mi 11 started in early 1960's at same capacity. Very little control in place until 1974 Union Carbide - Mine - San Benito County; Mill - King City, Monterey County Operation under Union Carbide started in the early 1960's. Ore is biased one summer every three years and hauled each summer to stockpile at mill site. This mill is primarily a "wet" process until product goes to the driers. No official reporting on ore and tailings piles. Heavy winds frequently present 30 mph) causing widespread dispersion in the past in King City, Coaling and San Lucas. Calaveras Asbestos - Mine/Mill - Calaveras County Colocated mine/mi 11 with over 30 years of operation under dif ferent ownerships. One of the largest capacity facilitis in the county. Complaints of dust clouds over the 13 year active Melones Dam construction site and town of Jamestown. Uncovered tailings pile and daily blasting required to mine rock bearing mineral content. Emissions estimates have been gathered from both the latest Air Resources Board Emissions Inventory System and their 1972 assessment.and are presented below. A ; 63 : 4 UCC 003441 -40- Table 3.4-1 SOURCE INVENTORY AND EXPOSURE CHARACTERIZATION COMPONENTS UCC 003442 -41- 1978 Atlas Asbestos asbestos dryer conveying and handling of tailings conveying and handling of ore Union Carbide 20 tons/year total suspended particulate 24 tons/year total suspended particulate 12 tons/year total suspended particulate asbestos drying ore and tailings pile 3 tons/year total suspended particulate not available Calaveras Asbestos asbestos pit blasting 126 tons/year secondary and tertiary crushing 19 tons/year asbestos separation and mill grinding 1 tons/year dry rock storage 2 tons/year total suspended particulate total suspended particulate total suspended particulate total suspended particulate 1972 Atlas Asbestos asbestos dryer 843 tons/year conveying and handling of tailings 110 tons/year conveying and handling of ore 60 tons/year milling 66 tons/year crushing andscreening 60 tons/year Union Carbide total suspended particulate total suspended particulate total suspended particulate total suspended particulate total suspended particulate wet processing and drying 31 tons/year total suspended particulate A 163 6 UCC 003443 -42- Calaveras Asbestos (then Pacific Asbestos Corp.) plant mining primary crushing recrushing and screening fines milling dry rock storage 2254 tons/year 900 tons/year 36 tons/year 27 tons/year 27 tons/year 2250 tons/year total suspended particulate total suspended particulate total suspended particulate total suspended particulate total suspended particulate total suspended particulate The asbestos content in ore for the two western mining sites ranges be tween 30 to 60 percent whereas the eastern site (Calaveras) ranges between 5 to 6 percent. However the eastern site requires daily ore blasting and is a larger scale operation. It should be mentioned that the two deposits differ in their fibre type with the western the short fibre and the eastern the "mixed Canadian." Clearly there are omissions and inconsistencies in this reported infor mation. We propose to review the extensive plant files for emissions monitoring and process descriptions in order to complete the source detail and emissions determination. Area meteorology is available from each region and a straightforward determination of dispersion will be made using average parameters and a gaussian plume model. One major plant, Coalinga Asbestos, was located in the San Benito County area. It was owned by Johns Mansville and closed down in 1974. We are aware of the plant capacity and its design and will review region files to establish its source strength. Our estimates will be based upon the methodology we established in a previous study of coal train dust sources (Rogozen, 1977). Asbestos measurements in California ambient air were summarized recently by SAI in its California Air Resources Report Inventory of Carcinogens (Margler, 1979). The King City and San Lucas levels are the highest on the list and repre sent values taken under current plant control conditions. Comparison of the 1973 and 1972 data grossly illustrates how much control of processes may have A ; 63 . 7 UCC 003444 -43- Table 3.4-2 AMS I ErlT AIR SAMPLING LEVELS Location in California Number of Fibers/m^ King City, downwind of a mi 11ing plant King City, upwind of a mi 11ing plant San Jose ( Berkeley) Los Angeles (Downtown) Emeryville, near asbestos manufacturer White Mountain (desert) Santa Monica Freeway, up wind (at 4th) Santa Monica Freeway, down wind (at 4th) Harbor Freeway, upwind (at 146th) Harbor Freeway, downwind (at 146th) San Diego Freeway, up wind fat National) San Diego Freeway, down wind (at National) San Diego Freeway, up wind (at 122nd) San Diego Freeway, downwind (at 122nd) Los Angeles Freeways, upwind (four sites) Los Angeles Freeways, downwind (four sites) 6,000 to 1,600,000 200 to 11,000 0 to 3,500 0 to) . 4,000 v 0 to 5,700 238,000 20 to 100 700* . 700* 1,100* 1,600* 200* 800* 900* 500* 800 ** 900 San Lucas i,ooo ,ooo . -----... . Berkeley^) 1,1 ( 700,000 ) ------- " References John et al., 1976 John et al., 1976 ` Murchio et al., 1973 Myrchio et al. , U9733 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al., 1973 Murchio et al. , 1973 . Murchio et al., _ 1973 Murchio et al., 1973 Murchio et al., 1973 Wesolowski, 1975 Wesolowski, 197^ Mean values Mean value of 60 samples ^ 6Q * Q UCC 003445 -44- reduced levels. Furthermore the production of asbestos in California was 78,390 tons in 1978 which represents a*drop of 40 percent from the 1966 pro duction. Of the five sites active then only three are currently open. Figure 3-1 shows the principal asbestos deposits in California. Locations of all mines and mills are known. All quarries will be identified and located and significant asbestos deposits and outcropping will be described with the assistance of the Mining and Tunneling section of Cal OSHA. In summary, the primary attention for man-made asbestos sources will center on the past and present mining and milling sites. A good deal of plant and environmental monitoring data are available through a number of private, local, state, and federal studies. We have summarized some information re sources in Table 3.4-1 and named particular individuals within the groups and their contribution in Table 3.4-3. In this way we have uncovered pre- - viously unpublished data including the Fresno County ambient sampling of the Coalinga area done in 1973. Other man-made sources which will be considered include the users and processors of asbestos. We have searched the Occupational Cancer Control Unit files for asbestos users who have registered in the surrounding counties. These are summarized in Table 3.4-4. Other information available on them is their 4-digit Standard Industrial Classification code and their exact address. In some cases, OCCU workplace monitoring for asbestos was conducted. We have access to these files and will be able to retrieve any available monitoring data. Based upon knowing the nature of each operation we will be able to assign emissions factors for the significant sources among these. More importantly perhaps will be an ability, in the future, to associate employer in formation with asbestos expscura for members of the case or control cohort. We believe that no significant sources will remain unidentified by using these files and through discussions with each cognizant county air quality officer. We recognize that building materials, schools, demolition and various other uses of asbestos are responsible for exposure to the general population. Unless occu pationally related (such as an insulation sprayer) we will estimate the average 4 Or> 0 UCC 003-446 -49- 3 population exposure from the available literature rather than attempt to perform a detailed area survey to determine individualized dose. We will however attempt to determine the nature and extent of asbestos exposure which although widespread may be significant and unevenly distributed among the population. For example, asbestos containing talc is used as a pesticide carrier in certain parts of the counties. We can establish the areas and tonnage by consultation with state pesticide control people. Additionally, particular areas have a high concentration of use of serpentine in paving materials. Widespread use has been identified in San Joaquin, Eldorado, Amador, Placer and Calaveras counties. We will estimate the dust blowing from such roads based upon measurement data (Woods,1979) - literature and various models (such as Becker, 1979). One useful indication of environmental asbestos levels in the air will be the total suspended particulate values in the three air quality districts of interest (North Central Coast, San Joaquin, Mountain). These will provide gross measures of the seasonal variation and approximate total suspended particulates (tsp) concentrations in the area. Finally, friction material from vehicles are known to be sources of asbestos It will be straightforward for us to calculate the emissions since the Principal Investigator directed a vehicle study on brake systems which addressed asbestos friction materials (Ziskind, 1979). We will obtain vehicle traffic estimates from the state highway agency, CALTRANS, to support these determinations. In summary we will establish an inventory and estimate the strength of the following sources: 1. asbestos mining and milling (including haulage) 2. asbestos containing quarries - 3. serpentine rock use in road grading 4. stationary sources, asbestos users and processing 5. general uniform population exposure due to consumer products, building construction materials, demolition, etc. 6. vehicle friction materials * 7. natural water and air sources A n o J ') r\ -56- UCC 003447 All airborne and waterborne environmental monitoring data will be centralized in one document section and a mapping produced. We appreciate tha monitoring data taken has been nonuniform with respect to analysis method, approach, and quality. We will judge the usefulness of each data element and evaluate its value to the exposure characterization. RICHARD A. ZISKIND ^ Deputy Division Manager Fnarnv.Fnvimnment Systems Division RES: (213) 556-2307 BUS: (213)553-2705 Science Applications, Inc. 1801 Avenue of the Stars, Suite 1205, Los Angeles, California 90067 JEFFREY L. HAHN, P.E. "5 Staff Scientist - Chemical Engineer Energy-Environment Systems Division -V-- J7/ Science Applications, Inc. 1801 Avenue of the Stars. Suite 1205, Los Angeles, CA 90067 Bus: (213) 553-2705 Res: (415) 524-7201 UCC 003448 -57- ^r>ro*z^-'