Document MGXxe0LKQJ2OXYyEeJOO9Knj7

7./.S-.3 September 10, 1971 MEMORANDUM TO MESSRS. E. Epremian B. Ingalls R. J. Klotabach P. W. McDaniel P. J. Morgan J. L. Myers H. B. Rhodes Ai240 ? Gentlemen: As you are aware, it is necessary for us to prepare an educative, document for distribution to our customers concerning asbestos safety and control. It seems apparent from customer inquiries that most of them have a "free floating anxiety" with respect to the use of asbestos, which is compounded by almost a complete lack of knowledge of the existing regulations and compliance procedures. We must, somehow, assure our customers that the hazards connected with the use of asbestos products are not mysterious and that they are "manageable" without undue difficulty. ' As a first step, I request that each person assigned a section of the document in the attachment to this letter prepare and submit a draft to me on or before September 27th. I suggest that the text of each section be as brief as possible, consistent with clarity, and that important detailed supplementary informa tion (such as copies of regulations, etc.) be appended with a short cross reference in the text. If you have any questions or comments concerning the matters covered in this letter or the attachment, I would be pleased to discuss them with you. JWR:mc Attachment UCC 016097 Very truly yours, r~> f; Vi 'Os&VrV \ J. W. Rawlings. OUTLINE FOR UNION CARBIDE INFORMATION PACKAGE \ ON ASBESTOS SAFETY AND CONTROL j_________________ (For Use With Asbestos Customers)________ II Introduction .................................. ,................................. E. Epremian. A. , *`B. C. D. Purpose of information package Summary of the hazards General'features of existing legislation How with proper precautions asbestos can be used with safety . II. Legislation........................................................................ P. J. Morgan A. Summary of existing legislation B. Outline of new laws under consideration III Compliance -' .; A. Standards ................. .................................................. P. W. McDaniel 1. Required frequency, location and procedure for sampling 2. Standard method of measuring samples 3. Specific threshold limit values B. UCC Program at King City ................................ P. W. McDaniel . 1. Program for monitoring concentrations in air at mine and mill (and possibly include typical values) 2. Protective measures and safeguards for personnel 3. Environmental pontrol . 4. Special features of UCC Asbestos .. J. L. Myers (a) pelletized material (b) packaging A240I3 C. Asbestos Users 1. Procedures for handling asbestos .. B. Ingalls (a) Unloading, storing and moving asbestos (b) Unpacking, mixing and blending (c) Disposal of empty bags 2. Equipment ...........................................................B. Ingalls (in con- (a) Exhaust and filtration sultation with systems Messrs C'Klptabach and (b) Respiratory protective Schwartz) devices UCC 016098 f'.-K ; INTZZ^MAl- CORSES POS3DSMCE To 'No.no) DivUlon loCOtiOft Copy to _ CAR32D2 CO^PO^ATSO^ Mr. J. W. Rawlings Mining & Metals Division 36th floor New York Office Mr. E. Epremian Mr. B. Ingalls Mr. R. J. Klotzbach Mr. P. J. Morgan Mr. J. L. Myers Mr. H. B. Rhodes Oaf* Originating Ocpf. Antwring Uttar data Sul*;**# HECETV^tJ SEP 27 1971 UCC-CALIDRIA NlAr-A^A F u,fi, N> 270 PARK AVENUE. NEW YORK, NEW YORK 10017 September 24, 1971 . Dear Mr. Rawlings: Attached is the write-up you requested dealing with asbestos. Also attached are copies of methods for dust determinations referred to in the text. Very truly yours. PWM: dp Attachments Paul W. McDaniel Industrial Hygiene Engineer i UCC 016099 A 2 4- 0 ! 3 A. Standards The present (9-23-71) legal standards for concentrations of air contaminants in work places are given in Part 1910.93 of the Occupational . Safety and Health Act as amended and published in the Federal Register, Volume 36, No. 157 - Friday, August 13, 1971. In this listing, which is informally known as "start-up limits", the standard for asbestos is given as follows: - (a) '12 fibers per milliliter of air greater than 5 microns or alternatively. (b) 2 million foot of aiL. cubic The listing further specifies how these values are to be determined. That is, fibers per milliliter of air are to be evaluated by the "membrane filter5 method at 430X phase contrast magnification". A detailed description (unofficial) of this method is attached. Total dust particles per cubic foot of air are to be "based on impinger samples counted by light-field techniques" A description of this system as recommended by the U. S. Bureau of Mines is attached. Either method of evaluating dust and fiber is presently acceptable, however it is the general feeling among industrial hygienists that the standard for asbestos will be lowered in the future to 5 fibers greater than 5 microns in length per milliliter of air as determined by membrane filters 'and phase contrast microscopy. When this occurs, the limit for asbestos based on total dust will have to be lowered proportionately or abandoned. There has been no indications which course will be followed with the total dust limit. UCC 016100 A 2 4 0 2 \.S -2- The definition of an adequate air sampling program for control and evaluation of exposure of personnel to asbestos will depend on the operations involved. For stable, repeated daily operations the collection of air samples once a month will usually be enough. Samples should be collected in sufficient numbers during the work day to cover the usual variations that occur in the operations. ' * For operations that are highly variable samples should usually be collected on each occasion of use of asbestos unless it can be shown by experience that the work atmosphere can be expected to be about the same each time. The number of samples collected at each sampling period should be sufficient to cover the changes that might occur during the operations. B, UCC Program at King City Mill and Mine At King City airborne asbestos is evaluated by collection on membrane filters and counts of fibers according to the procedure given for phase contrast microscopy. Samples are collected once a month at various work locations including the cabs of tractors and other moving equipment and at plant property lines. Three 10-minute air samples collected at an air flow rate of 0.1 cubic foot per minute are usually enough to describe the conditions at each location unless the operation is highly variable. In this case samples are collected until it is felt that the number is enough to fairly represent the work environment. Effort is made to insure that the time of day when samples are collected at each location is varied from month to month. Typical fiber counts at King City are 0-2 per milliliter of air at the wet side process locations and 3-14 per milliliter at dry side process UCC 016101 A240 -3- locations. The broad range of results for the dry side reflects the effect of occasional bag breakage during filling or other events that would temporarily change the dust picture. Because of this possible variation in dust concentrations at dry process areas, the wearing of res pirators is mandatory for exposed personnel and for any visitors to these locations. The'respirators supplied at King City are Wilson No. 600A equipped with Wilson filter No. R501 for dusts not significantly more' toxic than lead. Both the respirators and filters bear the U. S. Bureau of Hines seal of approval. This combination of respirator and filter has been found to be acceptable by employees. Tests with the filters have shown them to be highly efficient (987. ) in retention of asbestos fibers. Control of dust is primarily provided by the application of local exhaust ventilation at points of dust generation. This has been found to be an effective procedure by which dust can be prevented from badly contaminating the work environment when used to best advantages through well designed and well maintained systems. Dust from the exhaust system is collected in bag collectors that have been found to be quite efficient for asbestos fiber. Other control measures involve the. wetting of ore piles and the use of covers on ore trucks. Both measures significantly help reduce possible spread of dust in outside areas. UCC -016102 A24022 UNION CARBIDE CORPORATION 270 PARK AVENUE, NEW YORK, N. Y. 10017 LAW DEPARTMENT Oil 1 137] UCC-CAUORIA.' cagaha FA.'.Lr,. ..v. September 27, 1971 Mr. J. W. Rawlings Mining and Metals Division 38th Floor cc: Messrs. E. Epremian B. L. Ingalls R. J. Klotzbach P.Jrf. McDaniel L. Ifyers ^H. B. Rhodes G. E. Grayson/File - Re: "Information Package on Asbestos Safety and Control" Dear Mr. Rawlings: I am enclosing herewith a synopsis of existing and proposed legislation on this subject as per the request in your September 10, 1971 letter. As we discussed with Mr. Beverly yesterday, H.R. 2516 entitled "Asbestos Workers Health Protection Act" appears to overlap the Occupational Health and Safety Act. It is my understanding that Mr. Beverly will bring this apparent overlap to the attention of Mr. Kinney in our Washington office, and there will be no need for me to contact Mr. Kinney directly on the matter. Very truly yours, PJM:ld Enclosure 7 '/ / ` //! . >/V', . . " '-'V Patrick J. Morgan UCC .016103 's A2.40 J II. Legislation A. Summary of existing legislation ; * On May 29, 1971 Occupational Safety and Health standards *, # 2* ' with respect to asbestos were published in the Federal Register pursuant to authority of the Occupational Safety and Health Act of 1970 (84 Stat. 1593, 1600; 29 U.S.C. 655,657) Part 1910.93(a) of Title 29 of the Code of Federal Regulations which provides that "Exposure by inhalation, ingestion, skin absorption, or contact to any material or substance at a concentration above those speci fied . . . shall be avoided, or protective equipment shall be provided and used." The concentration level for asbestos is set at 12 fibers per mlililiter greater' than S mirmnc Part 1910.93(b) of Title 29 of the Code of Federal Regulations provides that to achieve compliance with the exposure limits specified in subparagraph (a), feasible administrative or engineering controls must first be determined and implemented in all cases. In cases where protective equipment, or protective equipment in addition to other measures is used as the method of protecting the employee, such protection must be approved for each specific application by a competent industrial' hygienist or other technically qualified source. UCC 016104 K2A-02 II. Legislation B. Outline of new laws under consideration 1. Clean Air Act - The Environmental Protection Agency (EPA) plans to publish standards for asbestos emission on or before September 30, 1971. 2. S. 1478, to amend the Federal Hazardous Substances Act, as amended. This proposed legislation would give EPA juris diction over the use and distribution of existing and new "chemical substances" to the extent necessary to protect health.and the environment. A "chemical substance" is defined in section 202(b) of S. 1478 as "any organic or inorganic substance which are of no pnKliV v.ooi environmental ucLeuuiueii by cne Administrator of the Environmental Protection Agency." . The bill contains the following features:' (a) Sec. 203 authorizes.the EPA to publish, after consultation with the Toxic Substances Board, proposed regulations for standards for test protocols for various classes and uses of chemical substances to the extent necessary to protect health and the environment. (b) Sec. 207 authorizes EPA to summarily seize any chemical substance which constitutes an "imminent hazard." An ! "imminent hazard" is considered to exist when there is reason to UCC 016105 believe that the manufacture, use, or distribution of a chemical substance will result in serious damage to human health or the environment prior to the completion of an administrative hearing or other formal proceeding held pursuant to the Act. Those* affected by the seizure may file objection to it and request a public hearing. (c) Sec. 209(b) provides that to the extent chemical substances are subject to regulations by other Federal laws, including the Occupational Health and Safety Act of 1970, EPA 'shall not regulate the use or distribution of a new or existing chemical substance on the basis of any possible hazard to employees in t.uusuuici.& l. tr-- suiting from household use of marketed products which contain or might contain the substance. However, if it appears to EPA that any such substance may pose a hazard when transported, or when used on or in food or as a drug or cosmetic, or may be a hazard to employees in their place of employment, or, may pose a.hazard directly to consumers resulting from household use of marketed products which contain or might contain the substance, he shall transmit any data received from manufacturers or processors relevant to such hazards to the Federal depcirtment or agency with authority to take legal action if a hazard is found to exist. 2- UCC 016106 (d) Sec. 213(a) of the bill provides that it does not apply to exports of chemical substances, unless EPA deter mines that a chemical substance will produce a significant direct or indirect hazard to human health or the environment in the United States. . (e) Sec. 213(b) makes the bill applicable to imports of chemical substances. (f) Sec. 216 provides that violations of the Act are subject to a fine of not more than $25,000 or imprisonment for not more than one year or both. (g) Sec. 217 authorizes any person to commence a r'-itr-ii fcr injunctive relief xjh I.io vwu ueiialf eicner against aiiy person alleged to violate the Act or against EPA for alleged'failure of.EPA to perform any act or duty under the Act which is not discretionary with EPA. The Subcommittee in the Environment of the Senate Committee on Commerce has scheduled hearings on this bill on October 1, 4 and 5, 1971. 3. H.R. 2516 - Asbestos Workers Health Protection Act - introduced by Rep. Patton on January 29, 1971. It is still in the Committee on Interstate and Foreign Commerce. Section 3 of this bill requires the Secretary of Health, Education and Welfare -3- UCC 016107 : &2402? to'publish in the Federal Register within one year after the date of enactment of this Act rules and regulations for the protection of the health of persons handling asbestos or asbestos products or engaged in the manufacturing of such products, including (1) rules and regulations for the labeling of asbestos products so as to fully inform handlers and ultimate users of such products of the health hazards of such products and any measures which should be taken with respect thereto ar.d (2) standards establish ing limits on the number of particles of asbestos which may be in suspension in the air breathed by humans. Sec. 4 of the bill authorizes the conduct of inspections to determine conformity with oUimai.ua pj-csttibeu iu uhe rules ana regulations published pur suant to the Act and provides that a written'report be given before leaving the premises setting forth any conditions or practices which are in violation of the rules and regulations. Section 6 provides for the issuance of cease and desist orders which are subject to judicial review,. Violations of final cease and desist orders result in.a civil penalty of $5,000 for each violation. -4UCC 016108 A240 o lie 149-2 ; |t'4 1 tik.vAU VW.'.i.-'Jk M" MININ G AND METALS DIVISION To(Nmi) Dhririae leeethm Mr. J. W. Rawlings Mining & Metals Division Union Carbide Corporation 270 Park Avenue . New York, New York 10017 Ccpyto Messrs. E. Epremian R. J. Klotzbach P. W. McDaniel P. J. Morgan J. L. Mye^s H. B. Rhodes./"'' R. E. Byrne/G. L. Dickson P. 0 BOX 579, NIAGARA FALLS. HEW YORK 1430? Oof* Originating D*pf. Anmrtng tafhr rial* Sebjttt September 24, 1971 Reseorch and Development Department CALIDRIA Asbestos 9/10/71 "Information Package on Asbestos Safety and Control" Dear Mr. Rawlings: Per your request, attached is the draft of my assigned portion of the above subject. Excerpts of Reference are appended. Very truly yours. C?. Up BLI/bsn Attach. B. L. Ingalls UCC 016109 A240 o c. ASBESTOS USFRS 1. Procedures for Handling Asbestos 3t- * ' (a) Unloading, S,,torLng, and Moving Asbestos t ' . CALIDRIA asbestos products are available as a dry highly liberated .fiber or in a more densified and low dust form of pellets or cracked pellets.* The pellets are cylindrical,approximately 1/4" dia. by 1/2" long. Cracked pellets have been reduced to a minus 3 mesh. ' CALIDRIA asbestos is packaged in 10 to 100-lb. quantities depending upon the bulk density of the product used. All bags are of a minimum 3-ply kraft paper construction. Resin Grade products RG-144 and RG-244 have the added protection of a sealed polyethylene overwrap. A 3-ply non-wet strength bleached kraft "beater bag" with water soluble glue-pasted valve and water dispersible ink is also available. Pallets of bagged product are made up of interlocking layers of bags with glue applied between layers to minimize load shifting. Wood pallets are used for transportation and storage convenience. Full pallets can be covered with shrink film or waxed cardboard shrouds. CALIDRIA pellets are particularly suitable for bulk shipping and automatic in-plant handling. Most conventional feeding and conveying equipment are applicable with pelletized product. Pellets can be transferred from pneumatic hopper car to process in a dustless sealed system under automatic control. Five manufacturers of pneumatic conveying equipment have tested and certified CALIDRIA asbestos pellets for use with their systems. . . . Carter-Day Co. Spencer Turbine Co. ' Daffin Co. . Schick Tube-Veyor Co. . Sprout-Waldron Co. ` (b) Unpacking, Mixing, and Blending . Any generation of dust during the above operations should be controlled in compliance with the recommended TLV by exhaust ventilation and/or the use of respiratory protective devices. (Dry Opened Asbestos) . Discharging asbestos from the bag by dumping should be performed under an exhaust hood or in an area with appropriate ventilation and filtration systems. The opened asbestos may also be removed and transferred to blending or mixing . equipment by a vacuum exhaust system. In some applications, beater bags may be charged directly to blending equipment without opening of the bags. - *RG-244 available in open liberated form only. ft 2 4 0 3 C UCC 016110 (Pelletized Asbestos) . Storing and feeding pellets are simplified by their free-flowing, non abrasive nature. Cone-bottom bins or hoppers with a 90 included angle are self emptying. For accurate feeding, a screw feeder orweigh-belt feeder is preferred, rather than vibrating types. The pellets can be air conveyed, but due to their granular nature, high air to solids ratios are required and some dust will be generated. Pellets are available in bulk hopper cars holding up to 90 tons, and in 50 lb. or 100-lb. multiwall paper bags. Arrangements can be made for other containers to suit customer requirements. The pelletized products contain no binders; however, there is suf ficient integrity that a moderate amount of energy is required for fiber libera tion. Some end use processes incorporate equipment with sufficient shear energy to liberate the fiber from the pellets. Examples of this capability in a liquid medium are the Banbury mixer and differential rolls in plastics processing and the hydrapulper and pulp refiners that are used in papermaking. Dry processes using impact mills will also permit the direct addition of pelletized asbestos to the process. Low energy rate equipment such as ribbon blenders, hammer mills, and agitator mixers will not effectively liberate the asbestos fiber and the higher performance efficiency provided by the CALIDRIA refining process will not be realized. When high shear equipment is not readily available, the pellets may be dry or wet opened with grinding equipment. For size analysis of the ground ' products, wet screening is recommended by either the Bauer-McNett method or by hand jigging. Some operator training is necessary in the latter method to obtain reproducible results, particularly in the finer mesh sizes. Dry grinding may be done in a variety of equipment: disc mills, grate hammer mills, air-swept mills, etc. Disc mills are suited to coarser grinds and have the advantage of requiring a minimum of air cleaning equipment. Grate hammer mills, such as the Jeffrey and the Mikro-P, are versatile in application and pro duce a minimum of "tramp" oversize but screen maintenance can be a problem, particularly if an extremely fine grind is desired. Air-swept mills, such as the Raymond Vertical and the Bauer Hurricane, are well suited to medium and fine grind ing in production.operations. A dust collector should be employed with any dry. grinding operation. Asbestos can be ground wet with water or other process liquids. Choice of equipment will depend on the nature of the liquid and the consistency of the desired mixture. At 4-8% solids in water slurries, for instance, fully liberated asbestos has the consistency of mayonnaise. Below 4% solids, asbestos slurries can usually be moved by centrifugal pumps. Positive displacement pumps, such as Moynos, are recommended in the 4 to 8% solids range. Above 40% solids, asbestoswater mixtures are crumbly, somewhat plastic masses which can be kneaded or mulled, and conveyed in belt, auger, or flight conveyors. UCC 016111 b24031 -3- For pumpable consistencies, wet grinding can be done in screened hammer mills such as Fitzpatrick or Reitz, in Cowles dissolvers, or Hochmeyer mixers, and probably others, depending on the conditions and the results desired. Sonic dispersers can also be used, usually in series with a pre-disperser. At higher solids contents, mix Mullers, Banburys, or mixers of the Littleford-Lodige type will be required. A particularly effective wet grinder for pumpable slurries consists of a high-speed (16,000 fpm tip speed) vertical hammer mill, such as a Reitz, with the grinding chamber enclosed by grooved hard alloy liner plates. Asbestos and process liquid are introduced at the bottom and overflow the top of the grinding chamber. Screen maintenance problems are eliminated, and the grind can be controlled by varying feed consistency, hammer spacing, and residence time. (c) Disposal of Empty Bags "Empty" bags can be a source of dust generation. Receptacles for dis position of the bags should be readily available and in an exhaust vented area. The bags should be bundled under a dust extraction hood for disposal, and then sealed in an air impermeable bag. The polyethylene overwrap furnished with some CALIDRIA products can be used for this purpose. The polyethylene sack should be twisted tightly, folded over, and the neck secured in.the folded position by wire tie, adhesive tape, or other equally effective method"). Generation of dust can be significantly reduced by wetting the bags preferably with a fine mist spray. Disposition of the bags is usually via a refuge collector, by burial, as waste product, or incineration (chrysotile under goes thermal decomposition to an amphorous silicate at 700C). An incinerator should employ a dust filter system. 2. Equipment (a) Exhaust and Filtration Three types of dust collectors are generally used by the asbestos industry: fabric filters, dry centrifugal collectors, and wet collectors. Centrifugal collectors are often employed as pre-cleaners for fabric filters. Wet collectors such as spray chambers or scrubbers, although effective, are used to a lesser degree. Fabric filters are used extensively by industry to control asbestos dust emission. Due to its fibrous nature, asbestos dust is relatively easy to collect. It conveys well in ducts and does not settle out or blind dust collector bags. ' Most applications for CALIDRIA asbestos should fall in the category of low velocity dust generation. Indraft face velocities required for hoods enclosing operation or over zone of dust generation are usually in the range of 150-200 fpm for low velocity dust generation, such as low speed conveyor transfer points or bag A24032 UCC 016112 -4- dumping. Active generation of dust by grinding or. dry tumbling mills may require indraft velocities of,500 fpm or greater. Conveying velocities in ducts approximate 3000 fpm.^' Union Carbide Corporation's asbestos plant facility at King City, CA. uses Mikro-Pulsaire Models 1-C-l and l-C-3 type fabric filters for grinding and bagging room dusts. This equipment safely handles the dust emission from the processing of several tons of asbestos product per hour. Operators are required to wear protective respirators. (b) Respiratory Protective Devices . Proper selection and maintenance of respirators should be made in accordance with Federal Standards established by.Jhe Occupational Safety and Health Administration of the Department of Labor^'. .. Union Carbide Corporation's asbestos plant facility at King City, CA. uses the Willson Mono Mask Number 600-A approved by the U.S. Bureau of Mines for asbestos dust'4'. ' UCC 016113 A24033 REFERENCES (1) Recommended Code of Practice for the Handling and Disposal of Asbestos Waste Materials. The Asbestosis Research Council, Environmental Control Committee, 114 Park Street, London WiY4AB, England. (2) Heating Ventilating Air Conditioning Guide Vol. 34 American Society of Heating and Ventilating Eng. Inc. (Waverly Press Inc., Baltimore, Md. 1956). (3) Federal Register, Vol. 36, No. 105-Sat. May 29, 1971, Washington, D.C. Respiratory Protection, Subpart I, sec. 1910.134 (p. 10591). (4) Bureau of Mines Information Circular 8436, Respiratory Protective Devices approved by the Bureau of Mines, U.S. Department of the . Interior, Bureau of Mines, 1969. UCC 016114 A2403 } INTERNAL CORRESPONDENCE- MINING AND rVJZTAI.5 D3V553GM To (Heme) Division location Mr. J. W. Rawlings Mining & Metals Division New York, NY Copfte Dr. E. Epremian Mr. B. L. 1 nga11s Mr. R. J. Klotzbach Mr. P. W. McDaniel Mr. P. J. Morgan ^-D-rr--'H. B. Rhodes R. E. Byrne/G. L. Dickson P. 0. BOX 579. NIAGARA FALLS. NEW YORK 1430? Oof* September 21, 1971 OrfornofinHndP.bl CALI DR I A Asbestos - Marketing Research and Development Department Aamiing letter date 9/10/71 Sehjed "Information Package on Asbestos Safety and Control" Per your request, attached is my assigned portion of the Subject. I feel that this section does not belong under "Compliance", and would suggest that it be put under "Introduction". /cb Attachment UCC 016115 A2403b 4. SPECIAL FEATURES OF UNION CARBIDE CORPORATION CAL I DR IA ASBESTOS (a) Pelletized Maferial.'" The most important contribution which Union Carbide.Corporation has made to the. safer use of asbestos is the introduction of peI Ietjzed products. "Calidria" Asbestos pellets reduce dust, cost less to ship and can Iead to additionaI savings in handling and operating costs. The high purity and high fiber content of "Ca I i dr i a-"^ Asbestos result from a proprietary hydraulic ore beneficiation'process made practical by a unique chrysotile . asbestos deposit near Coalinga, California. Pelletized asbestos ' . products are available only from Union Carbide. "Calidria" Asbestos pellets are nominally 1/2" long and 1/4" in diameter and have a bulk density of 44 pounds/ft^. Although they contain no binder or other additive, the pellets have sufficient strength to minimize fracture during transport and handling. Some products are available in a "cracked" pellet form, in which the pellets have been coarse-ground to pass a 3-mesh screen. Both the pellet and cracked pellet form contain a negligble amount of minus 325-mesh dust, the major factor contributing to airborne contamination. ' The storage and feeding of pellets is simplified by their freeflowing, non-abrasive nature; and a cone-bottom bin with a 90 included angle will self-empty. Pellets can be handled and conveyed with almost any type of conventional equipment. The pellets are friable and can be fiberized with either wet or dry grinding equipment. (b) Packaging. "Calidria" Asbestos peI Iets are normal ly packaged in 50 or 100 pound bags and are available in bulk hopper cars holding up to 90 tons. Arrangements can be made to supply pellets in other containers to suit customer requirements. Some products are available in "repulpable" or "beater" bags. These bags are pasted with water-soluble glue and printed with water-soluble ink. They are used in the paper industry to permit adding bag and contents to the papermaking system. All products are packaged in 3-ply air-vented paper bags and some are sealed in polyethylene overwraps to prevent moisture penetration and dust release. - Pallets of bagged products are made up of interlocking layers of bags with glue applied between layers to minimize load shifting. Full pallets can be covered with shrink-film or sturdy waxed cardboard protective shrouds. Most export shipments are made in containers which are loaded and sealed at the plant for delivery directly to the customer. UCC 016116 &24036 . V ! Cft/I t*/ ! , /]///} L yj~f C//L, ytfc-tFOv&FC _ {h*~-yyis^. Cj/^\ UCC 016117 & 2 A- 0 3 7