Document JNw2dk1QMxENV0n3bVN6R874O

FILE NAME: ALCOA (ALC) DATE: 1982 July 29 DOC#: ALC019 DOCUMENT DESCRIPTION: Memo H Industry iyglcno T. I. ALKIRE CIVIL ENGINEERING DIVISION PITTSBURGH OFFICE - 21 AB MLFe . E. RUMBERGER SM/V CD PITTSBURGH OFFICE - 6 AB PV/ iMfclX (DSy 1982 JULY 29 RE: ASBESTOS IN THE WORKPLACE I had been interested in obtaining educational information orr the general subject of toxicity of asbestos in the workplace; what constitutes safe working levels; what is meant by the often used terms "friable," "encapsulated," "locked-in," etc.; and what exactly are the regulations regarding these materials. You suggested I contact an asbestos manufacturer to obtain such information. I subsequently spoke with a J. P. Leineweber. Ph.D., Staff Vice President and Technical Director,- Health. Safety and Environment Department,_Manv ille-- Corporat ion, Denver, Colorado^ Dr. Leineweber was very heipful, both verbally and in writing, and herewith I'm routing to you the pack of literature he sent on the subject. I'd appreciate it if you would return this to me once you've had a chance to look it over. Of particular interest might be the pamphlet "Recommended Work _ Practices for Field Fabrication of Asbestos-Cement Sheet_.^_ Someone may want to forward a copy of this to our people at Sao Luis, Brazil. The overriding tone of the material Dr. Leineweber sent me _is_ that asbestos is toxic only in large doses over periods of time. Further, asbestos is safe when used properly. It's worth noting that__Johns-Manville apparen11y...would_cp_ncux with our proposed use of asbestos/cement roofing and siding._ijj Brazil. The "asbestos" in this application is "locked in" except during fabrication when proper precautions must be taken. From the standpoint of government regulations, B. L. Clark has summarized the EPA's emission standards for asbestos _in._his.. letter to you of 1982 July 23. I feel there are some items that should be-pointed out regarding this standard. 1) The repeated references to "pipe, duct, boiler, tank, reactor turbine, furnace, or structural member..." indicate to me the author's were primarily concerned with high, free asbestos content insulations which were widely used until recent years. 2) Materials being disposed of must contain more than 1 percent by weight of asbestos and must be able "...to be crumbled, TMTLAirT7FF!^, j EXHIBIT I ARCH 003548 E. E. RUMBERGER PAGE 2 1982 JULY 29 pulverized, or reduced to powder when dry by hand pressure..." before they need be disposed of in accordance with this standard. 3) The words "visible emissions" in the standard are deceptive. By definition, emissions are only prohibited if they are both visible and they contain particulate of a,material which, m turn, contains friable asbestos. I get the feeling from all this the standard was not intended to_ apply to very small quantities of asbestos, such as in paint_ films or to asbestos materials in which the fibers are not readily airborne. In his letter to you of 1982 July 16, W. B. Garyotis referred to an incident at Point Comfort a year ago involving asphalt impregnated._asbestos felt pipe covering manufactured by JohnsManville. I was at Point Comfort at the time; and, while not directly involved, recall the incident. Alcoa Standard 33.7.9 specifies the felt and clearly notes the asbestos content. Two fiberglass materials are also listed (one by Johns-Manville) in case asbestos is considered unacceptable. Since Alcoa had not prohibited asbestos, the Contractor chose his customary product. The Contractor. Johns-Manville (who sold* either product), and Erv Bakke all recommended against replacing the asbestos containing material on the basis that it _wa_s a _ superior material_, _it would give better, long-term weatherproofing protection, and the asbestos was encapsula ted and therefore safe. In the end, the material was replaced, luckily, at no additional cost to. Alcoa. As I recall, the final decision to replace the material was based' on advice that when eventually "demolished," it would be necessary to bag, label, and specially dispose of the asbestos containing felts. As T read the EPA Standard now, I_question_ that advice. Tndeed . if the asbestos felts were. I n 'fact, 'a~ .` better waterproofing material. I wonder whether Alcoa made _thg_ best decision. I am aware of a few asbestos containing materials approved for use in the Alcoa Standards. Attachment No. 1 lists these ARCH 003549 E. E. RUMBERGER PAGE 3 1982 JULY 29 Materials and their applications. I would like your advice on Iiqw I should proceed in this matter. ' T. I. ALKIRE TIA:ef Attachment cc: J. E. Powell - Pittsburgh Office, 21 AB W. B. Garyotis - Pittsburgh Office, 2 AB T. M. Brown - Pittsburgh Office, 2 AB R. Sharkey - Pittsburgh Office, 6 AB ARCH 003550 . ** MATERIAL DESCRIPTION ATTACHMENT NO. 1 KNOWN ASBESTOS CONTAINING MATERIALS APPROVED IN ALCOA CONSTRUCTION STANDARDS BRAND NAME PERCENT CONDITION MANUFACTURER ASBESTOS OF ASBESTOS DESCRIPTION OF APPLICATION Standard 33.1.4 Asphaltic Mastic Alcoa KK Coro-Kote Colonial 11 Encapsulated Used for painting of struc Refining and in Bitumen tural steel, primarily Chemical Co. interior chlorine , atmospheres (casting buildings). Paint film 60 mils thick. Electrical Fire Retardant Flame-mastic Flamemaster Paint, Alcoa EFRP 71A Corp. NA Encapsulated Applied to electrical cables in Resin for fire prevention, internal or external, thickness 125 mil. Exterior Masonry Paint Re-New Coat Devoe, Raynolds 7.5 Nonfriable Exterior moisture sealer on masonry block buildings. Paint film 10 mils thick. Standard 33.7.5 Asphalt Coated Pipe Insulation Jacket Standard 33.7.4 Asbestos Roof Flashing Felts Asphalt Roof Cement Double Johns-Manville NA Coated Flex- tone Reinforced Johns-Manville NA base flash ing and 15-lb. finishing felt. "Asbestile" Johns-Manville NA Encapsulated in Bitumen c Encapsulated in Bitumen Wrap on calcium silicate pipe insulation for exterior pipe weatherproofing. Applied at perimeters of built-up roofs at non horizontal surfaces where felts cannot be immersed in coal tar. Encapsulated in Bitumen Used to caulk exposed joints at perimeter of built-up roofs. i i! ! i i AF*O f 003551 .sV . ''W -.V V ,