Document Lp08q0VbwDZx1bz6xNJGjjVpX

FILE NAME: Union Carbide (UC) DATE: 1975 Oct 23 DOC#: UC234 DOCUMENT DESCRIPTION: Letter from Calidria Asbestos to the Dept of Environmental Quality THE DISCOVERT COMPANY UNION CARSIOE CORPORATION MINING & METALS DIVISION P.O. BOX 579 NIAGARA FAUS, N. Y. 14302 TEL: 715-273-3376 October 23, 1975 Mr. Robert W. Flugge Deputy Commissioner Department of Environmental 95 Franklin Street Buffalo, NY 14202 Quality Union Carbide 353 Dear Mr. Flugge: . This letter and attachments provide the technical supporting information on the spraying of asbestos-containing materials which was mentioned in iny comments present ed on September 25, 1975, copy enclosed. These comments were directed to the pro posed Erie County Air Quality Code, Article 111, Title 9, Section B, on Asbestos. The spraying of asbestos has received substantial publicity as a health hazard, primarily as a result of the extensive use of sprayed-on asbestos as a fire proof ing and insulation material. Industry recognized that this practice, which involved materials containing 10 to 80% asbestos and little or no permanent binder, was hazardous; and, accordingly, it has been discontinued. However, it is our firm belief that various materials containing small quantities of asbestos can be applied safely by sprayingwith no significant hazard either to the worker or the general public, and further that such spraying can be done in total compliance with the Federal OSHA Health Standard dealing with asbestos and the EPA National Emission Standard for Hazardous Air Pollutants. The subject applications generally involve the spray ing of paints and coatings where asbestos is a minor but important constituent added to give critical properties to the material. These coatings are applied wet as a slurry or liquid thus precluding the generation of airborne asbestos dust in excess of accepted Federal threshold limits. Our data were obtained at comnercial locations under routine operating conditions. Samples were collected in the breathing zone of the operator during active spraying procedures and do not include breaks, lunch, and similar non-working conditions. The results thus represent the highest exposure level for each particular operation and the time-weighted average (TWA) during an eight hour shift would be much lower. Environmental exposure's outside the work area would be even lower than the TWA due to dilution by other air. All samples were collected on mi H i p o r e filters and counted at 400x using phase contrast illumination in accordance with Federal OSHA regula tions. The data were obtained at 21 different industrial locations throughout the United States. These or very similar operations are probably practiced to some extent in Erie County. For convenience, the data are divided into four catergories based on the char acteristics of the binder, and are presented in this manner in Tables 1 through IV . Details of the type and quantity of binder, the main uses, and the asbestos content are supplied with each category. An overall summary is shown below: A087SC SlMiART AI7B0RNE ASBESTOS FTBgR CSiitfofTmTIOHS v<ious ikoustrial sppavihs oprations Asoltcatian Hall nd C e ilin g In terio r Texture Sprays Exterior U til and Roof Sprays Resin-Based Coatings (Boat nfg.. ship coating. Building Mintanance coatings) Asphaltic Roof and Auto Under coating I 22& Binder S U e c h , PYA, Casein e tc. Vinyl 1 Acrylic latex Polyester i Epoxy Resins Asphaltic I as Sprayed 2-4 Asbestos 2-as Soraved 1-5 10-20 4 MX. 5*50 1 45 12 MX. IS MX. Stapled 7 2 3 21 M Of 24 S B $6 Airborne Asbestos F ib e r.C o n c tn tr.tln , 1hfiers/cy^u 1 - ! 2S l Averse^ 0. 0- 1.6 0.6 0. 0- 0.2 0.1 O.O-O.S 0.2 0. 03- 1.5 0.3 0 - 1.S 0.4 It is noteworthy that the highest value found was i out of the ,56 samples gave readings higher than l f t h other values for the sine operation ] ' Ti" the 0.4 flber/cc in the b r e a t h ^ lf r , . on^y three highest cases woorrding in my presentation is proposeSd,:lf?r?esEtr-rricti?vv"e:.`y in\ iv i *iew 5o?f 1 this, the S u " 1" ? " alternative "No person shall cause suffer, permit, or allow visible emissions o f aod ln^utfoo!""9 f asi," t0s-<:<>4in1ng materials used for fireproofing based y"r WOrd1n3 10 ^ carta1" - t l , . "No person shall cause, suffer, permit, or allow surface coating by the n?r^ i n9 f afbest0* or jsbestos-containiig materials, with the exception a n n H a H r*rtred in* aU^ asphjltic-based coating and laminating materials anPamnunf0nf^Kib Ii^ ^ va.and/or ma1ntenance purposes containing, as sprayed. an amount of binder not less than 50* of the weight of the asbsstn and a maximum of 15* by weight of asbestos: 9 asbestos present We appreciate the opportunity to comment on your proposed rule-makina Pipaco yrouirassrt\aLndra; rrd?, odreSi-f;ryoTuO r, fequKi?recanadd*itioofna`lV ianfsosrimsattaionn.ce T Se finIlTMcIe?ipm" eM " y truly yours, JLM/ejp cc: Dr. H.B. Rhodes bcc: R.E. Byrne, Jr. R.F.X. Fusaro J.V. Murray R.L. Schult W.C. Thurber . ionn L. Myers Marketing Manager I 40879 !