Document R0DR1RxkjB3g3krKwRKoqQoa

FILE NAME Packings and Gaskets PAG DATE 2002-2003 DOC PAG057 DOCUMENT DESCRIPTION Journal Article with Cover Letter 08-24-2004 02:53 Director of Compliance Programs 202-693-1681 984 P.002 696 a oF March 2003 W Ms. Cynthia Weaver Technical Support OSHA U.S. Dept. of Labor - OSHA - TS 230 S. Dearborn Street Room 3244 Chicago IL 60604 Boelter & Yates Inc. Environmental Engineers & Scientists . ; RECEIVED RECEIVEDRECEIVED MAR MAR 28652865 Re Regulatory Opinion Asbestos Regulations 29CFR1910.2629CFR1910.26 G vi Dear Ms. Weaver res In the course of our business we have been asked to look at the application of 29CFR 1910.26 vi to gaskets and packings containing more than % asbestos and have Asbestos fibers modified by a bonding agent coating binder or other material | conducted a search of the scientific literature and have conducted a study of gaskets and packings which was published in the November 2002 American Industrial Hygiene Association Journal My article a copy of which is attached also critiques other literature on the subject = well My study correlates with other competently conducted published and unpublished studies of gaskets and packings The range of concentrations on a hour time weighted average TWA for the ten tests of five activities documented total fiber release under worst case scenarios as follows Industrial # - Flat blade scraping Industrial 2 - Hand wire brushing Industrial 3 - Power wire brushing Industrial 4 - Making gaskets with a ball peen hammer Personal Personal Personal Personal Industrial 5 - Stem packing removal and replacement Maritime 6 - Flat blade scraping Maritime # - Hand wire brushing | Personal Personal Personal Maritime # - Power wire brushing Personal Maritime 9 - Making gaskets with a ball peen hammer | Petsonal Maritime 10 - Stem packing removal and Personal replacement _ 0.007 0.023 : 0.052 0.027 0.019 0.004 0.010 0.029 0.010 0.005 0.021 0.038 0.024 0.014 0.000 0.008 0.022 0.008 | | | Given these findings I would appreciate OSHA's opinion as to whether or not gaskets and packings require labeling per 29CFR1910.26 vi Sincerely Frederick W. Boelter CIH PE 1300 Hicains Rood Suite 301 Pork Ridge Illinois 60068-6772 - 847 / 692-4700 = tax 847 / 692-3127 08/24/2004 TUE 14:49 RX NO 9122 002 08-24-2004 02:54 Director of Compliance Programs 202-693-1681 984 = P.006 = 686 FIGURE 2. Flange.of.on Flange.of.on industrial fitting being faced with a power wire brush containing and elastomeric i.c. flexible were used in the study During cycle event this was determined visually when the flange was actually opened as shown in Figure 3. Gaskets that were not elastomeric i.c. spiral wound metal were rejected and another firring was selected for that event cycle The necessity to reject a fitting occurred only three times in the course of the 48 event cycles when a gasket was being removed All of the gasket and packing material removed was fibrous All materials were rerained and tested to verify asbestos.content When old gasket ma-terial was determined to contain asbestos content ranged from 40 to 80 chrysotile There were no crocidolite gaskets cocountered The gasket making sampling and event cycles were conducted identically to the methods used in the gasket removal and flange facing tests except that a new gasket was made A fitting was selected that had been faced in a previous gasket removal test New 1/16 thick Garlock 900 gasketing which contains 60 tO 80 chrysotile asbestos was obtained and used for the event cydes The 16 new gaskets were made using a peen hammer as shown in Figure 4 The packing removal and replacement sampling and event cy- cles were conducted identically to the methods used in the gasket removal and flange facing tests except the valve stem packing was being removed and replaced Removal and replacement of the stem packing for a particular firring occurred during the same cycle Garlock Scaling Technologies Palmyra N.Y. A valve was selected and the old packing was removed see Figure 5 and the stems were repacked with new containing packing me- terial The old packing material was all fibrous and when it contained asbestos it varied from 40 to 80 chrysotile The new containing packing material used for the event cycles was from unused new old stock NOS This was material Garlock style 733 which is a graphite impregnated 80 chrysorile square braided packing The 16 valves were packed using new valve packing tools purchased from a catalog . + Personal samples collected using OSHA monitoring methods in accordance with good industrial hygiene practice Personal samples were collected from the breathing zones of the two individuals performing the work for the duration of the 8hour test cycle Samples were collected and analyzed by PCM following OSHA 160 which is essentially the same as NIOSH method 7400 A Rules To eliminate variability analysis was performed by the same analyst at the same laboratory accredited for PCM analysis by the American Industrial Hygiene Association Personal air samplers were started at the beginning of the hour rest cycle and were stopped only during the lunch break To determine the general room air concentration the isolation chamber was subdivided into 3600 modules of 1 f each and cach module was assigned a discrete consecutive number for purposes of identification each cycle 3 random number generator was used to select 8 of the modules for sampling A sample cassette was located in the center of the randomly selected module for the duration of the cycle and samples were collected and analyzed AIHA Journal 63 November December 2002 735 08/24/2004 TUE 14:49 TX NO 9122 006 08-24-2004 02:55 Director of Compliance Programs 202-693-1681 984 = P.007 '696 ro, Gare 5 Kee ae FIGURE 3. After opening the flange the gasket was first verified as an elastomeric style following NIOSH method 7400 A Rules General room air samplers were started at the beginning and were ran during the entire hour test cycle Prior to each test cycle the room was verified to b clean following aggressive air clearance monitoring protocols using a leaf blower and fans The room cleanliness was verified as 70 mmby collecting five air samples inside the chamber and analyzing them according to EPA AHERA Appendix A PostAbatement Clearance TEM protocol To eliminate variability analysis was performed by the -analyst the laboratory accredited for TEM analysis by the National Instinite ofStandards and Technology NIST under the National Voluntary Laboratory Accreditation Program NVLAP When possible prior to selecting a particular fitting for study the presence of asbestos in the gaskets was verified however this was not possible to determine for every fitting Because it was important to maintain the integrity of the gasket to flange fate a small pinch of gasket material was removed from the flange face gap without opening the flange After the gasket removal cycle was completed the removed gasket material was reserved and a larger bulk sample was collected and analyzed In addition to the old removed gasket material bulk samples of the new gasket material used in the cycles in which a peen bammer was used to make gaskets were collected and analyzed Bulk saraples were an- alyzed by polarized light microscopy PLM following EPA AHERA Appendix E Analysis was performed by a laboratory accredited for PLM analysis by NIST under NVLAP Sampling results were formatteidn a database for analysis Sta- tistical functions were performed including maximum mean minimum and standard deviation Additionally collateral information was recorded in the database related to variable factors such as type of gasket composition of the gasket percentage of gasket adhering to a flange surface gasket surface area and minutes elapsed for removal RESULTS A factors database of some 20 was developed to record variables related to eath of the eight timings used in the six gasket re- moval testing cycles These factors included for example type of material face gasket ring gasket partial gasket or pack- ing composition of the gasket when containing 40 to 80 chrysotile percentage of gasket adhering to a flange surface 0 to 100 condition of gasket poor to excellent gasket sur- face area 6 to 60 inand minutes clapsed for removal 1 to 24 A darabase of some five factors was developed to record variables related to each of the eight valves used in the two packing removal testing cycles These factors included for example shaft outside diameter 0.56 to 1.625 inches packing housing outside diameter 1.25 to 2.625 inches packing depth 0.31 to 1.875 inches and minutes elapsed for removal 5 to 26 min 736 AIHA Journal 63 November 2002 08/24/2004 TUE 14:49 TX NO 9122 007 08-24-2004 02:55 Director of Compliance Programs 202-683-1681 984 P.008 696 FIGURE 4. Punching bolt holes in gasket made using a peen hammer a, Not surprisingly a variety of gasket conditions were encountered ranging from tightly adhered gaskets to loosely adhered gaskets Of the 48 flanges and therefore 96 Blange faces that were cleaned by either putty knife hand wire brushing or power wire brushing only 1 flange face did not require any removal of residual gasket material This happened to be related to a fiming during an industrial finting putry knife test cycle The other 95 flange faces had some material adhering to a flange face that required removal by the method being smudied Twenty flange faces were estimated to have 50 or more of the face covered with residual requiring removal Personal samples during the testing of industrial fittings ranged from 0.005 to 0.052 cc The mean of the personal samples of the five industrial cycles was 0.026 ec Standard deviations ranged from 0.001 to 0.008 ece Table I shows the personal air sample results for the five test cycles in which industrial brings were used Room air samples during the testing of industrial firings ranged from 0.005 to 0.048 cc The mean of the room air samples of the five industrial cycles was 0.023 cc Standard devistions ranged from 0.001 to 0.006 ec Table I shows the room air sample results for the five test cycles in which industrial firings were used In test cycle 1 industrial flar blade scraping seven of the eight finings used contained an asbestos gasket The average of the personal samples was 0.031 cc and the average of the area samples was 0.026 cc In rest cycle 2 industrial hand wire brushing cight of the eight finings used contained an asbestos gasket The average of the personal samples was 0.006 ",,ancd the average of the arca samples was 0.008 ec In test cycle 3 industrial power wire brushing five of the tight fistings used contained an asbestos gasket The average ofthe personal samples was 0.022 cc and the average of the area samples was 0.017 cc In test cycle 4 industrial making gaskets with a ball peen ham- mer eight of the eight fittings used had an asbestos gasket made The average of the personal samples was 0.045.f and the average of the area samples was 0.040 cc In test cycle 5 industrial stem packing removal and replacement eight of the eight valves used contained asbestos packing and all were replaced with asbestos stem packing The average of the personal samples was 0.026 ce and the average of the area samples was 0.023 cc Personal samples during the testing of maritime fittings ranged from 0.000 to 0.029 cc The mean of the personal samples of the five maritime cycles was 0.013 cc Standard devia- . dons ranged from 0.001 to 0.003 cc Table I shows the personal air sample results for the five test cycles in which maritime fittings Wort used Room air samples during the testing of maritime fintings ranged from 0.001 10 0.025 cc The mean of the room air samples of the five maritime cycles was 0.012 cc Standard deviations ranged from 0.001 10 0.003 cc Table 1 shows the room air sample results for the five test cycles in which maritime fittings Were used In test cycle 6 maritime flat blade scraping eight of the AIHA Journal 63 November 2002 737 08/24/2004 TUE 14:49 RX NO 91221 4008 08-24-2004 02:55 Director of Compliance Programs 202-693-1681 884 = P.009 696 FIGURE 5. Digging out the stem packing after a hook did not work : right fittings used contained an asbestos gasket The average of the personal samples was 0.017 ct and the average of the area samples was 0.017 ec In test cycle 7 maritime hand wire brushing four of the eight firings used contained an asbestos gasket The average of the personal samples was 0.002 cc and the average of the area samples was 0.002 cc In test cycle 8 maritime power wire brushing eight of the eight fittings used contained an asbestos gasket The average of the personal samples was 0.009 ce and the average of the area samples was 0.011 / cc In test cycle 9 maritime making gaskets with a ball peen hammer sight of tight firings used had an asbestos gasket made The average of the personal samples was 0.026 cc and the average of the area samples was 0.021 cc In test cycle 10 maritime stem packing removal and replacement six of the tight valves used contained asbestos packing and all were replaced with asbestos siem packing The average of the personal samples was 0.009 cc and the average of the area samples was 0.008 cc In summary all 48 gaskets removed were clastomeric and fi- brous and 40 of them were determined to be containing All 16 the gaskets made using a peen hammer were made from containing sheer stock All 16 packings that were removed were impregnated and fibrous and 14 of them were determined to be containing All 16 of the packings that were replaced ware from NOS containing packing DISCUSSION . he air sampling results from both the five industrial test cycles The air ave maritime test cycles were not significantly different 738 AIHA Journal 63 November December 2002 08/24/2004 TUE 14:49 RX NO 91221 009 08-24-2004 02:56 Director of Compliance Programs 202-693-1681 984 = P.010 =696 . . TABLE 1. Ten Test Cycle Sampling Results " ' Test Cycle Description * Industrial Industrial Flat Industrial Hand Industrial IndustrialIndustrial 2 blade scraping scraping wine brushing M toe ball IndustrialPower wirebrushingbrushing Se, . IndustrialIndustrialMakingMakinggaskets with a peen hammer Stom papacckkiinngg removal and replacement Industrial - MarMiatirmietime Flat blade scraping Maritime Hand wire brushing Maritime Power wire brushing Maritime Making gaskets with a peen hammer . : Maritime Stem packing removal and replacement . \ Sample totals . ' Sample Type personal room air personal air + room personal personal room air * personal room alr personal room air personal room air personal room air personal room air personal room air personal room alr personel room air No. Samples 2 ONONDON ONONDON ONONDON ONONDON ONONDON ONONDON ON ON ON ON 8 NONONO NONONO NONONO NONONO NONONO NONONO 20 20 20 20 Sampling Data Analysis Meximum cc 0.035 Mean Vico 0,034 0.007 0.010 0.023 0.020 . 0.052 0.048 0.027 0.031 0.019 0.020 0.004 0.004 0.010 0.014 0.029 0.025 0.010 0.011 0.026 . ; 0.008 . : 0.017 - 0.040 0.023 0.017 2 : 0.002 0.011 . 0.021 0.008 Unimum Ucc 0.028 Standard Devlation 0.020 _ 0.005 . . 005 0.021 _ 00..003388 0.004 0.002 0.001 0.030 0.024 0.008 0.003 0.014 0.014 0.000 0.002 0.001 0.008 0.001 _ 0.008 0,022 ' 0.017 0.002 ; 0.009 0,008 0.004 0.002 from each other This was true for the personal samples as well as for the room air samples Sampleresults for the 10 test cycles are shownin Table I. 20 samples The results of the 80 area samples and personal indicate that no single sample ever exceeded the hour TWA PEL of 0.1 cc and that only 1 personal sample 0.052 cc ever exceeded half of this value An upper confidence limit of all the personal samples was calculated be 0.069 ccTherefore based on these findings it is unlikely that exposures would ever approach the PEL while these types of activities were performed even when they were performed dry All samples were analyzed by direct preparation in accordance with NIOSH 7400. Because it was assumed all dereered fibers were asbestos it was not necessary to subsequently analyze these samples by TEM utilizing NIOSH 7402. Had definitive fiber identification been performed it would have been incorrect to use a TEM method other than NIOSH 7402 because methodologies such as EPA's AHERA or Yamate protocol as well as ISO have no relationship with the epidemiologically derived fibers per cubic centimeter exposure standards based on the PCM It would fur- ther be incorrect to compare the TEM unit of structures centimeter against the 0.1 cc allowable limits that are to be determined by PCM Intuitively one would expect greater variation based on type of activity or asbestos content For example it would be reason- able to expect the airborne fiber concentrations to be greater for power wire brushing industrial 0.022 ce maritime 0.009 / cc than they would be for flat blade scraping industrial 0.031 cc maritime 0.017 cc One would also expect that an activity that was literally identical between the industrial 0.045 cc and maritime 0,026 cc test cycles namely that of making a gasket with a peen hammer would yield more similar numbers results because it was the same hammer same sheet material similarly clean flange faces and same people doing the work in a deanroom The numerical results would appear to show some differences But analysis of the database did not yield any significant correlation between the air sample results and the multitude of recorded variables including whether the material contained asbestos One reason was that few fibers were detected on the filters so a vari- ation of few fibers counted m^dea significant difference in in the reported value Further all fibers were being counted as asbestos * whether they were or were not asbestos Also the room air sample results were not significantly different from the personal air sample results for each of the test cycles This was not surprising because thee was no ventilation in the room during testing and over an hour period it is reasonable 10 expect the personal samples would reflect the general air quality in a room with no ventilation The results of this carefully controlled study are consistent with other published studiesin which the sampling and analytical meth- ods are believed to have been properly followed for comparison against the OSHA hour TWA allowable exposure For example the results for dry scraping and power sanding reported by Cheng et al calculate as 0.03 and 0.07 /on an hour TWA respte- tively The results for production removal of remove plate sheet gasketing reported by Spence et al are shown to range between nondetection and 0.005 asbestos mL on an hour TWA Also the results for installation and removal of sheet gaskets as reported by Liukonen er al show averages ranging from 0.03 to 0.09 cc All of these studies were conducted in actual work- place situations where there were other fiber influences CONCLUSIONS his expand assessment showed that the rate of fiber release The expand expand new historic conmining gaskets and impregnated asbestos packing materials are insignificant even when the materials are manipulated dry Although there is some quantified total fiber exposure during the activities typically per formed by workers while using elastomeric containing AIHA Journal 63 December 2002 739 08/24/2004 TUE 14:49 RX NO 9122 010 08-24-2004 02:56 = Director of Compliance Programs 202-683-1681 984 P.011 = 696 gaskets and impregnated asbestos packing materials all sample re- sults showed the airborne concentrations of fibers to be well below the current OSHA PEL of 0.1 ec as sampled over an hour TWA period This is regardless of the activity being conducted and whether the activity was removal of an old clastomeric gasker or impregnated packing material or replacement with new clas- tomeric gasket or impregnated packing material , The spidy methods controlled for potential interference that could impact analytical confidence at the very low fiber concen- trations related to gasket and packing activities The study meth- ods also yield a high degree of confidence that the fiber concen- trations reported are those resulting from the respective gaskor or results were packing removal or replacement activity Further the obtained using tools and techniques as well as traditional worker methods with only dry materials dry removal and dry replace- ment techniques under conditions of no ventilation in a contained room The results of this simulation therefore represent worst case conditions and are likely higher than those that would be experienced in actual working conditions out of doors or in ventilated spaces if interfering fiber sources could be eliminated from those settings . These findings are useful for exposure assessments and dose reconstructions related to historical activities and to current activ ities in which dry methods are used . ACKNOWLEDGMENTS hanks is extended to Central Illinois Light Co. for access to This discommissioned R.S. Wallace is rich allowed the opportunity to obtain intact industrial fittings for use in the study And also thanks to the U.S. Navy for the intact maritime fittings that came from other the decommissioned destroyers U.S.S. Davis U.S.S. Ricketts or U.S.S. King REFERENCES 1. Condpuing Restrictions on Cermin Containing Producm Federal Register 58964 5 November 1993 2. Technical Amendment in Response to Court Decision on Asbestos Federal R egister 33208 28 June 1994 . 3. Liukonen LR KR SEll and HR Beckett Asbestos Exposure from Gasket Operations Bremerton Wash Industrial Hygiene Branch Naval Regional Medical Center 1978 4. Cheng RT and HJ McDermore Exposure to asbestos from 25- benos gaskets Appl Occup Environ Hyg 588 519991 5. Speace S.K and P.S.J. Rocchi Exposure masbestos masbestos Sibres during gasket removal Ann Orcup Hyg 583 5818996 6. National Institute of Occupational Safety and Health NIOSH by NZIOSH Manual of An Asbestos TEM NIOSH Method 7402. In alytical Methods 4th ed Cincinnati Ohio NIOSH 1994 Safety 7. National Institute of Occupational and Helth NIOSH Asbestos and other fibers by PCM NICISH Method 7400. In NIOSH Manual of Analyrical Methods 4,,al Cincinnati Ohio NIOSHI J ' 1994 404 4028000 8. Fowler D.P Exposure to asbestos arising material Appl Occup Environ Hyg from bandsawing gasket 9. McKinnery W.N. and R.W. Moore Evaluation ofairbome asbestos fiber levels during removal and installation valve gaskets and pack, ing Am Ind Hyg Assoc J..59531 5812 992 - 10. Millere J.B. and M.D. MountA study determining asbestos fiber release during the removal of valve packing Appl Occup Bmviron Flya 790 7913993 ' 11. Copraining Materials in Asbestos Transmission Electron Microscopy Code of Federal Regulativas Title 40 Part 763 AppendiAx Section 1 1987 12. Yamate G. S. Agarwal and R. Gibbons Methodologyfor the Maasurement of Airborne Asbestos by Electron Microscopy Draft Report EPA contact no 68-02-3266 Washington D.C Environmental Protection Agency 1984 15. International Organization for Standardization ISO Daermi- nation ofAsbestos Direct Transmixion ^ lectrondG- croscopy Method ISO 10312 Geneva ISO 1995 14. International Organization for Standardization ISO Determni- nation of Asbestos Transfer Transmission Electroa Microscopy Method ISO 13794 Genevz ISO 1999 15. American Society for Testing and Materials ASTM Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structu Number Concentration ASTM D5755-95 West Conshohocken , P ASTM 1995 \ of Tide 16. General Industry Standards Permissible Exposure LimiPELS Code Federal Regulations 29 Part.1910.1001 1994 17. American Conference of Governmental Industrial Hygienist ACGIH Threshold Limit Valuesfor Chemical Substances and Phys ical Agents & Biological Exposure Indices Cincinnati Ohio ACGIH 1998 : 18 R. .Means Co Means Facilities Maintenance & Repair Cost Duta Kingston Mass RS Means Co. 1994 19. Page J.S Enimator's Piping Hour Manual Houston Texas Gulf Publishing Co. 1987 20. Littleton CT and R.A. Dickson Industrial Piping New York McGraw 1951 21. Construction Industry Standards OSHA Reference Method datory Code of Federal Regulation Title 29 Part 1926.1101 Ap pendix A. 1994 22. Lodd N. K. Busch and J. Lynch Oompanional Exposure Samplin 22. Strategy Manual NIOSH contract 95-74-75 Cincinnat Ohio National Iristinute for Occupational Safety and Health 1977 740 AIHA Journal 63 November December 2002 08/24/2004 TUE 14:49 RX NO 9122 011