Document QMyOVZdz33N0xw6bXZVNoV1ML

FRjM T0m FLORES ENVIRONMENTAL CONTROL December 27, 1973 T0 MR. A. A. RAMBIKUR ENVIRONMENTAL CONTROL cc: Mr. W. Genter/Mr. S.W. Marshall Mr. C. F. Scott Mr. C. L. Pittman - Pittsburgh Mr. T. B. Bonney - Pittsburgh RE:ASBESTOS DUST TEST ON FLAMEMASTIC FLAME RETARDANT Samples were taken at R-45-9Y motor control center while spraying the cable trays with flamemastic flame retardant material. Two samplers were used, one on the man doing the spraying and the other one was placed at the northeast corner of the room with the face of the filter facing the wall. This was to prevent contamination of the filter by a direct hit from the spray gun. A fine fog was visible in the room while spraying as well as the pungent odor of the vehicle used in the mixture. Both men working in the room wore hoods with purge air. A noticeable amount of material was collected on the filters, but upon examination under the microscope the asbestos fibers on both filters were well below the required level. Results below: Date Test Time Sampled Location Concentration Fibers/ml Time Weighted Avg. 12-20-73 1 2 71.17 mins. 57.62 mins. On man By wall .938 .023 .139 .0028 TF:wc J ALCOA TOM FLORES APC 005233 r-4M (mkv n-a) ff ft?b<^fTC5 Du5T~ /ejT >* FZ-h^d ^AfT/C Fl*?<* Ffr.c TdtF/Y dr F-Jor , 1?<PTTC."> rt-cr*; , V^'hFz S d *dZ t.' ,? Fdip! e ~r7t>dyf /P'J //vV. s- FRo/-* F cxTkp/. Fcxsm /S' Tdv C> dAWfLetS '^ene 'JS&d, >F<2. C>r/ l~b<? FIAd dotFp 7~h^_ SfriAi / /<_3 W/Za 7~h<Z ft 5Tep T^ic y,\ 0/\U> d > pldC-^a <?F 71>p ) F i/( 7-7 e pF/^xd-Z dRerf ff ?A aa/j .p. 'F r )-i 7 ,'cr''^ THtF nety ziA ?xRd'/ //-/ Z 'J *? 77' A7J . A;' ' C 7"/ c"// 7~i/^<S ? ,'c"" 'F d 5 &a; 7/ dbc^F '> F'.-.-sF? V 7 Z~R V4 / - ' .v ? "p '' > r > <*' ~ - T~h*?rc FdF Fo X 'c~ric.<2, dZZc ^ d~h?d 'i d-Z P'V P~,/7_'7, 4- > < ft ,, , : r */ --.'^ ' :'r /'r/e :-'r> 7>T"' " 'jr /7 bex5 'M-e k e F? -' y , **>/ 1;~ l R; djS o i *" d Fp`d'/ f c x c R s R/ *' a ~v_ RC mi -JF- A 1 : f.-j &/ J.__ ciL. APC 005234 MR. A. A. RAMBIKUR POINT COMFORT OPERATIONS C. L. PITTMAN PITTSBURGH OFFICE MR, W. L, GENTER POINT COMFORT dfATIONS HooomMl# 14* t*73 'v RXt SPRAT TEST FOR FLAMEMASTIC Tm mwtfr laqairM i to rttlktr a roprosontatWo from Pittibw^ woU witaeaa tbo pluaM spray toat for FUoo atic wbea aaiiiraamti will bo uuko to determine whether or sot ubtitoa fibtn from tbo Flamemaetic wonld constitute lusord. Mr. Boomy lo ovarmi; bot la referring to bio lottor of Oetobor 11. 1973. oa tMa aobjoct. I gather that bo did oot plaa to aoad aayoae to wltaooo tbo Mot alaco Mr. Raaahikor'e atail la experienced at tboao toato. I alao dlaeoaaod tbia oaattor witb Mr. Goorgo arrah aad bo said that it waa Ms aadorstaadteg Oat m om from tbo Eavinnaaatal Hoaltb Laboratory at Morwia woold witaoaa tboao toato. Since ao oao from tbo oaglaooriag groop pUu to participate la tbo toata. yoo aro froo to procood aa aooa aa yoo have tbo material aad caa make tbo aaces* sary arraagoaaoats with Mr. RamMbar. | jJ ,_ ZZZ C. L. PITTMAN CLPjjaa cci T. B. Boaasy - 7 AB G. H. Farrah - ATC S. W. Marabail - Point Coaafort Operations A. A. Rambtkar Point Coaafort Oporatioaa fert H. D. Koofor APC 005235 y MR. A. A. RAMBIKUR, PT. COMFORT OPERATIONS THOMAS D. BONNET "N PITTSBURGH OFFICE - 7 UR. Cl L. /?T$TUAN PITTS^UR0H OF^IJE - 4 FPH October 11, 1973 > HL 0 U BE: PRECAUTIONS REQUIRED WHEN SPRAYING WITH FLAMEMASTIC I have read with Interest your letter of September 21 and the reports of environmental measurement* taken by ARLI during the spraying of Flamemastic. Although these reports give this fireproofing material a clean bill of health, there were so many non-standard procedures described that ve hesitate to accept the conclusions as valid with out additional verification. In view of the above, I am asking A1 Raabikur If he vould arrange with Sam Marshall to set up a test run during which some air samples could be collected. Z will feel much more comfortable In relying on data collected by Al's trained and experienced staff. Apparently, Flamemastic can be used and still meet the provisions of the Hazardous Air Pollutant Standards to EPA's satisfaction. Unfortunately, the 08HA regulations are more restrictive. Section 1910.93a (o)(2)(lli) clearly states that "Employees engaged In the spraying of asbestos...shall be provided with respiratory equipment... and with special clothing...." The supplied air respirator Is the type of protection required for spray application. There are no qualifications based on the concentration of airborne asbestos generated. Right or wrong, OSHA bas made the assumption that all spraying operations are bad. If we are to get any relief from the restrictive provisions, we must firat assure ourselves that exposures to asbestos during the spraying of Flamemastic are minimal. With this information in hand, we can be guided on how to proceed. In order to use less effective protection, we may very well require a ruling or variance from OSHA. If we have convincing evidence that respiratory protection is unnecessary, we can then determine if Alcoa should apply for a variance, press Dyna-Therm to apply or decide if either step is worth the effort. Thomas D. Bonney TBB:mh / cc: p6r. A. A. Ramblkur, Pt. Comfort Mr. S. W. Marshall, Pt. Comfort Mr. C. F. Scott, Pt. Comfort APC 005236 A. FROM THOMAS B. BONNEY PITTSBURGH OFFICE - 7 t i TO MR. C. L. PITTMAN ~T f~ , */! PITTSBURGH OFFICE - 4 WPH j ,vs ) January 11, 1974 RE: SPRAY APPLICATION OF FLAMEMASTIC On the basis of air sampling tests conducted by Analytical Research Laboratories, Inc., and Pt. Comfort personnel, we do not consider it essentiil that applicators wear air-supplied respirators. Although the OSHA regulation requires the use of a supplied-air respirator when spraying asbestos, the respirator is intended to be used to keep exposures below the permissible exposure limits. Since the airborne asbestos concentrations generated during the application of Flamemastic, even without the benefit of a respirator, are below prescribed limits, we reason that further reduction of asbestos exposure is not required. We have discussed this matter with Mr. Costa of Alcoa's legal staff and he is in agreement with this interpretation. Pt. Comfort apparently chooses to provide their applicators with supplied-air respirators for their personal comfort because of the odor and the exposures to other components of the flame retardant. There is no reason for them to discontinue this practice. As a matter of fact, we would recommend that applicators wear at least an approved filter respirator such as MSA's Dust-Foe, 3M's 8710 or other similar types. This will afford our employees a degree of comfort and will assure them of protection until we have a better idea of typical exposures during spraying. Additional sampling data will better describe the expected range of contaminant concentrations. Although we are confident of the data we now have, we would prefer some greater depth should we be required to defend our position. i We would appreciate it if Mr. Rambikur would arrange for additional I sampling when Flamemastic is scheduled to be applied to the cable 1 trays at Pt. Comfort. A total (dry) weight of material collected on ! the filter as well as a fiber count should be determined. The total particulate data will determine if exposures other than asbestos are of any concern. Thomas B. Bonney TBB:mh Mr. S. W. Marshall, Pt. Comfort Mr. A. A. Rambikur, Pt. Comfort Mr. C. F. Scott, Pt . Comfort ra ai rn a APC 005237