Document Rj81Gx3G5003e9jKERZE0JR0X

cziii DT'Lr<v orr;i/E ' 'i " r.1,.11 PLAINTIFF'S EXHIBIT > o~u_sj . i-iirM irAiici'i w..,iwiV(#wAirtji\| iuim?rg6 ASA-422 c jM4^>Statement of f IXHIIIT X. V. Nelson Director, Department of Environmental Sclenoee American Smelting and Refining Company Salt Lake City, Utah Public Hearing on Emission of Hazardous Pollutants Los Angelos, February 16, ISVi My name ie K. W. Nelson. I am Direotor of the Department of Environmental Sciences of the American Smelting and Refining Company. I have been in environmantal health work for JO years, 26 of them with American Smelting. Because we have an Interest in asbestos production and in all the trace metals associated with our principal products - copper, lead, and zinc - I wish to comment on the proposed national emission standards for asbestos and mercury. During World War II, ee a member of a Navy team assigned to C develop Industrial hygiene programs in shipyards building ships for the Navy and Maritime Commission, I had occasion to observe closely i all jobs dona in ship construction. One of them was the installation of aabeBtoa insulation, particularly in the boiler roans oT`'ships, Amosite, chrysotile, and crocldollte forms of asbestos were used'. We knew very wall then that inhalation of excessive asbestos dust over a period of time oould cause asbeatosla. We wex^e appalled to see that asbestos handling, cutting and application were done almost always without regard to dust exposures. Workmen would literally be covered with duBt and visibility in engine and boiler rbomS would often be diminished by floating dust. My memories of those scenes are vivid, < We urged dust oontrol wherever practicable - which was not often & the case then - and at leaBt we urged the wearing of respirators ,> -2- approved by tha U.S. Bureau of Minas for protection against pneuaoco- ni oh is-producing dust. But I must say our ^commendations vara often not followed assiduously. \ Also during the war I had occasion to in'speot an asbaatos textile plant providing Navy goods. Again 1 saw workrooms with visible dust. Every light fixture or other hanging appurtenance wae featooned with fiber masses like trees adorned with Spanish moss. Dust control ccri sis ted of Bpreys of water mist in the roc^ to keep the asbestos damp and to allay dust. The hanging fiber accumulations were evldenoe that the control was not very successful. There is no doubt in ny mind that "^he cavalier practices of insula tion installers of 30 years ago and perhaps in ensuing years v;ere respon sible for the asbestOBis discovered in-recent years and for the markedly increased incidence of lung cancer which is apparently the result of t cigarette eaoking plus massive occupational exposures to asbestos duet. My special interest in'mercury began in 191!! when Dr. E. p. Laug and l, working for the Pood and Drug Administration in Washington, developed an improved method for determining mercury in biological ii materials - a method which is etlll tha official one of the Association of Official Agricultural CheaiBts, though there have since been developed a number of better and faster methods. 1 assisted also In toxicological studies of mercury's effeots on animals, Sinoe those early experiences I have followed with ears the expand ing scientific literature on asbestos and mercury and their relation ships to environmental health. n# The first specific comment X hive on the proposed national emission standards for asbestos and mercury is that neither substancea *> In my opinion, derervcs being net aside as on especially hazardous air pollutant. Health effects from excessive exposure to airborne asbestos and mercury have been related almost exclusively to occupational situ ations which involve exposures for greater than any which the public could experience. An exception may be the "neighborhood" illness cases ascribed to asbestos, but almost oertainly such oases resulted from la aX of dust collection which would be routine today in order to main tain in-plant sirborne fiber levels within occupational health standards. My point is that almost any substance capable of being airborne and causing "irreversible, or incapaclting reversible, illness" could c be classified as a hazardous air pollutant. -Carbon monoxide is an obvious example and of oourse the total national man-hours annually of l public exposure to oarbon monoxide in Significant quantities would far exceed the total man-hours of publio exposure to asbestos or mercury. t By " Bigriigicant exposure" X mean one which would be likely to provoke significant physiological change. I My further point Is that distinguishing asbestos and meroury as "hazardous" means to the public "extremely hazardous" and arouses un necessary anxieties. Our environmental anxieties these days may indeed be overshadowing those more deserving of serious public attention. President Nixon's reoent message to Congress on environmental pollution effects on health raised questions about our classifications of hazar dous substances. He said, in discussing the identification and distri bution of adverse agents, "In sane cases the grounds for alarm are c mmm rnmmmmG c jd iffa w t.fi'f ---------- wall-founded; In oth j - ./ a^*2 beyond the evidence. The reason a for inclusion are varied nr.d not always well-founded. There has been little attempt to review the whol" range of environmental agents I systematically^ or to adopt a ceralabant basis for Judging an environ mental agent ai a hazard/ / I .would urge tha Snvirr'..r.e~oal Protection Agency to re-conalder the need for national eci-ji or. a..awards for mercury and asbestos on grounds that feare go beycnc the evidence. / paragraph 61.21,; i), fir.-;asbestos tailings as any solid waste product of asbestos minir.-, nr r. ..l:lns operations which contain asbestos. ThiB definition is too br-v.. the mining industry the word "tailings'' applies to the finely div..d product of milling or, less commonly, to c the ovensize material pani'-, ever screens. As defined now, the term "tailings" would mean vir:u-;my material from an asbestos mine. The definition should bs modified. paragraph 61.22,(a),prohibits visible emissions from any mine road surfaced with asbestos tailings. Under the existing tailings definition any road in an open pit mine surfaced with waste rock, frera the pit, or not especially surfaced at all, would be aurfaoed with asbestos tailings.^ And the rook would in all likelihood contain acme asbestos. Both becauae of this situation and beo&use we believe it impossible not to have, at any time, some visible emission from trucking on road ways, we believe the visible emission prohibition should, be dropped. It is routine practloe to prevent dusting of roadways and it would be necessary to meet the OSHA airborne asbestos standard for truck drivers C -5- and miners in the tret. These facts Mould preclude, in our opinion, an/ possibility of significant neighborhood asbestos contamination J from a mining operation. The complete prohibition of emissions seems to us an impossible requirement in paragraph 6l.22,(b),(l), referring to visible emissions from ore dumps, storage areas, conveyors, and tailings dumps. In (d), referring to building demolition, and in (a),(l) end (2), referring to asbestos spraying. Again It seems to us that good dust prevention practices should be applied, but that absolute prevention of a visible emission is impossible. Paragraph 61.22, (f), 1b objected to beoause of the uae of the word "tailings" in its overly broad sense. The restriction aa it stands would mean hauling in materials from outside a mine area when an abun C .dance of rook, overburden or other waste rock, was immediately available rcr road construction. The various categories of fabrio permeability specified in para- ., graph 61 22 (a);(c), and (d) are unnecessary. The high efficiency of fabric filter bags for collecting dust and fibers is principally a function of the filter cake which quickly builds up on the bags when in uae. It is a superfluous refinement. In our opinion, to have the various grades* A ""single specification of 52 or kO CFM/ft la recom- mended. t No risk to the public from airborne mercury in particle or vapor form has aver come to our attention. U.8. Geological Survey professlon- ' al paper 713 reports atmospheric mercury concentrations at ground level near mercury ore deposits of 20 diminishing to 0.1 ng/m* ^00 feet c I c -6- above ground. Air at ground level over precious metal ore# ha# reached 1.5 ng/m*. Afcain we raise the question of Why mercury should be set aside as a hazardous pollutant. It's relative rarity, relatival: high cost, and the lack of any observed community air problems argue against its hazardous classification. We may be creating a problem In trying to solve a non-existent one. / The five-pound per 34-hour emission limitation specified in para graph 61.53 appears to be purely arbitrary/ No allowances are made for the concentration of mercury in a given effluent or for stack height and subsequent dilution. At the very least, an option should be per mitted to meet an appropriate ambient air standard, as In the ease of c beryllium. What the ambient air standard should be is unknown at present, but 1 }ig seems very conservative. In any case, there is surely time to develop and agree upon an ambient air standard. There Is no emergency. The stack testing and record keeping would be eliminated if an ambient air option were available and chosen. Ambient air.monitoring , should be permitted on a 26-day a year schedule like that followed by the national air sampling network. After two years of such monitoring, permission to dlBoontlnue it should be granted, provided satisfactory evidence is submitted to the administration that ambient air levels have been satisfactory. Changes in plant practices that would lnorease morcury emission would automatically mean a resumption of ambient air monitoring. We appreciate this opportunity to express our views on this proposed legislation. c