Document XzVwEn2BOqrg6zJRk6r5X1Ly

March 23, 1981 Mr. J. W. Armstrong Bendix Corporation Bendlx Center Southfield, MI 48076 Subject: Environmental Protection Agency (BPA) study on the National Emission Standards for Hazardous Air Pollutants (NESHAPS) Dear Jim: jLt*L As I mentioned to you this week, I had a phone call some weeks back from Mr. John Copeland, of the EPA In Durham, NC. It was a long dis jointed phone conversation concerning NESHAPS. I was not too sure as to what Mr. Copeland wanted, but he indicated several parties at EPA whom I could meet with, if needed. As I'm not fond of meeting with regulatory people, I asked him to send me along something relevant to conversation. The attached was received from Mr. Laney of Research Triangle Institute, EPA's contractor for this work. In Mr. Laney's cover letter of February 27, 1981 he notes enclosing of (1) the Work Plan for RTI, (2) the Assignment for Batelle Columbus, and (3) Index of the Docket. The Work Plan was enclosed and is forwarded with this letter. The Assignment for Battelle was not enclosed. The Index was enclosed but is not forwarded as it was over 100 pages of what I consider meaningless references. I have enclosed everything that I received except for the Index. I plan no action on this as I'm quite aware of certain Metnber's reactions when a regulatory group approaches them because of their Membership in the Institute. I don't know whether it is better to participate before an advanced notice of proposed rulemaking or to participate after the advance notice is published. In the former case, EPA may claim that some of their recommendations are based on our statements, and in the latter case they may have firmed their positions. In any event I pass this on to you for your suggestions. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE EWD/erc Enc: FMSI-0357 E. W, Drislane Executive Director FMSI 02753 , (SHo RESEARCH TRIANGLE INSTITUTE POST OFFICE BOX 121*4 RESEARCH TRIANGLE PARK, NORTH CAROLINA 2770* OPERATIONS ANALYSIS DIVISION February 27, 1981 Mr. E. W. Drlslane Executive Director Friction Materials Standards Institute Bergen Mall Office Center E. 210 Route 4 Paramus, NJ 07652 Dear Mr. Drislane: As requested by Mr. John Copeland, U.S. Environmental Protection Agency, I have enclosed for your information the following: 1. Work Plan prepared by the Research Triangle Institute (RTI) for Phase I, Review of Asbestos Standard, 2. Work Assignment for Battelle Columbus Laboratory 3. Index of the Docket for RTI's Review of Asbestos Standard. Please feel free to call me with any questions that you may have regarding the above materials. Sincerely, ML/teh Enclosures Mike Laney Project Leader (919) S4CC000 FROM RALEIGH DURHAM AND CHAPEL FMSI 02754 HILL  LNVIROKMtHlAt PR0TEC1I0N AGINC ' Kescaich liianjle Patk. N.C. 27711 0 "iX'Jll,. CONI HAC 10*1 Battel!e, Columbus. assignment no ASMGnuCnt CHANGE NO 1 | * '"it PREPARATION OF REPORT ON FEASIBILITY OF SOURCE SAMPLING METHODS FOR ASBESTOS EMISSIONS IN INDUSTRIES USING, ' PROCESSING, OR CONTAINING ASBESTOS ' OCSCniriiGN . # Requester 0A1C December 17, 1980 . . . | Kenneth T. KnappEnvironmental Sciences Research Laboratory Research Tric.ngle Park, N.C. 27711 1 Telephone: (919) 541-3085 ' Background - No sampling method exists for measuring asbestos in the emissions of industries using, processing, or containing asbestos. Such a method is needed so that standards in these industries cen be set. An analytical method developed to determine the amount of asbestos on membrane filters has been developed and is being collaboratively'tested. Tnis can be used with a source sampling method. However, the samples collected with the source sampling method must be in such a form that they are compatible with the analytical method now being tested. _ Scope of Work ' The contractor shall make a feasibility study of source sampling methods for the collec tion of asbestos containing emissions from all major sources that use, process*;.or con tain asbestos. The sources that must be included are the ore processing plants, the asbestos-cement, asbestos felt and paper, and asbestos containing friction meterials plants. The samples collected by proposed methods must be compatible with the provi sional methods for airborne asbestos as described in EPA Report EPA-600/2-77-178. The contractor must perform sufficient laboratory and field tests to provide needed data ISTn.w-V 0' COvrnNMfNt (Si'Miit CONI nACi Cn Oun* 1 '0 01 wOn < ' iwi'i j i (On Oi ? ( 1 UUl f * ( * V S*Cma 1; tf*c 2651_________________ _ 6 months June 30, 1981 onli coot UUPMOHt S. OAT nnA'<r hi ui i lllVIVON l.ntl I 11*0 If r. 1 Mifall.f II * / rjii 1 l ' i . < H l ii i ,r*i CONIi'f;i(in s lif pm l ijimivf i< | mi t r r( ,i l M ^ OML FMSI 02755 su that adequate estimations of time and,efforts needed to develop the methods.can * be provided. The contractor shall provice by May 31, 1981 a draft of a report*n the feasibility of the needed methods. ' Reporting Requirements . *% The contractor shall: -` * *< 1. Prepare a work plan and submit it to the Project Officer within fifteen calendar days after the date of the award. 2. Submit a monthly technical progress narrative covering work accomplished during e'ach calendar month. ' ' 3. Submit by May 31, 1981 six (6) copies of a draft of the feasibility report. ' - *. ' *' 4. Submit an error free master within thirty (30) days following approval of the draft by the Task Officer. ' . \ N v* t * FMSI 02756 WORK PLAN RTI PROJECT 44U-1736-13 EPA PROJECT 80/41 PHASE I REVIEW OF ASBESTOS STANDARD Prepared for U.S. Environmental Protection Agency Contract No. 68-02-3056 Mr. John Copeland Lead Engineer November 10, 1980 Deane F. Tolman, Manager Applied Ecology Department Operations Analysis Division FMSI 02757 REVIEW OF ASBESTOS STANDARD PHASE I WORK PLAN I. INTRODUCTION This document presents a Work Plan prepared by Research Triangle Institute (RTI) for Phase I, Review of Asbestos Standard* as required by the U.S. Environmental Protection Agency (EPA) Contract Number 68-02-3056, "New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants."* The result of this review will be a recommendation to revise or not to revise the current standard. If the decision is made to revise the existing standard, a separate work plan will be developed. Thus, the work to be performed under this contract is as follows: Phase I: Review of Asbestos Standard Phase II: Revision of the Asbestos Standard (contingent upon Phase I results). In the event that a revision of the current standard is found to be necessary, information collected in Phase I will provide much of the basis for Phase II. A Background Information Document (BID) will be prepared during Phase II and will provide background information to support the revision of the asbestos standard. Because there are no published procedures for the review (and revision) of existing National Emission Standards for Hazardous Air Pollutants (NESHAP), this Work Plan was developed based on discussions with the EPA Lead Engineer and adaptation of the procedures outlined in the Contractor Procedures Manual for Development of National Emission Standards. *The current asbestos standard was promulgated in 40 CFR 61, Subpart 8. tAs a review of a National Emission Standard for Hazardous Air Pollutants, the proposed work and schedule for Phase I of this study differs from that normally performed during the Phase I work for New Source Performance Standards. 1 FMSI 02758 IT II. OBJECTIVES AND SCOPE OF WORK The sources regulated by the current asbestos standard include asbestos mills, roadways, manufacturing, demolition and renovation, spraying, fabricating, insulating, and waste disposal. The purpose of Phase I is to review the standard regulating asbestos emissions from these sources, determine its adequacy, and gather information that will assist in revising the standard if a revision is recommended. A recommendation to revise or not to revise the standard will be based upon the following: Control Technology: Standards for air cleaning equipment and work practices now specified will be reviewed. Information will be collected on improvements in control equipment and work practices that have occurred since promulgation of the current standard, as well as the feasibility of substitutes and control technologies under development. Data collected on control technology during Phase I will serve as the basis for determining Best Available Control Technology (BACT) during the Phase II study if a revision of the standard is recommended. Emission Sampling and Analysis: Routine, standardized techniques for sampling and analyzing asbestos emissions were not available during promulgation of the current standard. Thus, numerical emission limitations are not included in the existing standard. Recent information on sampling and analysis will be collected and assessed for its applicability for monitoring asbestos emissions fcom sources identified in the existing standard. Advantages and disadvantages of the various measurement methods will be discussed from the viewpoint of establishing nunerical emission standards. Health Risks: Recent data on health risks (including asbestosis, bronchogenic cancer, and mesothelioma) associated with exposure to airborne asbestos will be reviewed. Information relating asbestos-linked disease and asbestos concentrations commonly encountered in ambient air will be important in determining the need for numerical emission limits and the value at which limits should be set. EPA will supply RTI with any dose-response data or other quantitative data that may be required for the establishment of numerical emission limits. Enforcement of the Standard: Enforcement experience with the - existing asbestos-standard will be evaluated in order to identify problem areas. Lack of compliance or inability to enforce certain provisions may result in a recommendation to revise the standard. 2 FMSI 02759 ' Emission Sources: Emission sources regulated by the current standard will be reviewed, and an attempt will be made to determine if there are additional important sources of asbestos emissions that should be included in the standard. III. PLAN FOR PERFORMANCE The approach that RTI will take in the Phase I review of the existing asbestos standard is presented here. Nine tasks (shown in Figure 1) are envisioned as necessary for an adequate review of the standard and are discussed below. Project participants and total hours of participation are shown in Figure 2, Project Organization Chart. Resumes of major project participants are in Appendix 1 of this work plan. The schedule and milestone are presented in Figure 1, while Table I shows dollar and manhour expenditures for the Phase I study. It is expected that Phase I, Review of Asbestos Standard, will require 10.5 months to complete. The date of completion is set at August 28, 1981. A. Task 1: Review Background Information for Existing Standard In evaluating the need to revise the existing standard, RTI will assemble and establish a docket of the background information that provided the basis for the standard. This information will be reviewed to aid RTI in evaluating events occurring since promulgation of the standard. Furthermore, such an exercise will identify potential sources of information. ' Finally, a review of the background information will identify any areas of inadequacies in the current standard which may or may not be amenable to revision. RTI will review published EPA documents, including the following: Background Information - Proposed National Emission Standards for Hazardous Air Pollutants: Asbestos, Beryllium, Mercury (APTD-0753), December 1971. 1 1 3 FMSI 02760 ' Background Information Development of National Emission Standards for Hazardous Air Pollutants: Asbestos, beryllium, and Mercury (APTD-1503), March 1973. * Background Information on National Emission Standards for Hazardous Air Pollutants - Proposed Amendments to Standards for Asbestos an3~ Mercury (EPA-450/2-74-009a), October 1974. * Preambles to national emission standards and amendments for asbestos. Key EPA personnel that participated in the development of the current standard will be identified and interviewed. RTI will ask to examine their files on asbestos in order to assemble pertinent data. During the examination of EPA's earlier background material, information sources outside of EPA may >be identified. These might include other government agencies, industry associations and unions, individual companies within the asbestos industry, and control equipment vendors. These sources will be contacted as it is deemed necessary. B. Task 2. On-site Investigations In order for RTI staff to evaluate processes, facilities, emission problems, and control techniques involved in asbestos-related industries, RTI plans to make several on-site investigations or plant trips. Information gathered during site visits will also assist in determining which sites are suitable for emission testing it if is determined later that emission testing is required. Because of the variety of sources, RTI plans to limit to a maximum of two, the number of visits made to each type of source. In the case of the asbestos manufacturing industry, the diversity of processes requires that at least twelve plant visits be made. The sites listed below, with anticipated dates of visits, will be contacted to schedule visits following 4 FMSI 02761 approval of this work plan.* If these visits cannot be scheduled, alternates will be selected in consultation with the Lead Engineer. Week of Visit Site of Vi sit Source Category Jan. 5, 1981 Asbestos Fabricators, Inc., Charlotte, NC Fabricating Jan. 5, 1981 Jan. 5, 1981 Jan 12, 1981 Jan. 12, 1981 Jan. 19, 1981 Jan. 19, 1981 Jan 26, 1981 Feb. 2, 1981 Feb. 9. 1981 Feb. 9, 1981 Feb. 16, 1981 Raybestos-Manhattan, Marshville, NC H.A. Haynie Co., Greenville, NC Bendix, Cleveland, TN Sea Gulf Environmental Co., Louisville, KYt Asarco, Inc., Ragland, AL Jaquays Asbestos Corp., Globe, AZ Washington Asphalt Co., Seattle, WA (Left open for rescheduling of site visits as a result of cancellations) Remington Arms Co., Bridgeport, CT Raybestos-Manhattan, Stratford, CT Rogers Corp., Manchester, CT Manufacturing - Textiles Manufacturing - Fireproofing and i nsulating materi al s Manufacturi ng - Friction materi als Demolition and Renovati on Manufacturi ng - Asbestos/ Cement pipe Mi 11ing Manufacturing - Asphalt concrete Manufacturi ng - Shotgun shel1s Manufacturing - Friction materials, packing and gaskets Manufacturi ng - Plastics * The list of sites is subject to change based on the results of telephone contacts with these and other companies for information on products- and pollution control methods. In addition, site visits will be coordinated with other research activities at EPA in order to avoid duplication of efforts and to avoid placing unreasonable demands on individual companies; this may necessitate modifying the list of proposed site visits, t The location is that of the company office. Due to the temporary nature of the work, specific locations for site visits will be determined at a time closer to the dates given. 5 FMSI 02762 tr Week of Vi sit Feb. 16, 1981 Feb. 23, 1981 Feb. 23, 1981 March 2, 1981 March 2, 1981 March 9, 1981 Site of Visit Allied Chemical Corp., Solvay, NY H. B. Fuller Co., Philadelphia, PA* GAF, Whitehall, PA Johns-Manville, Manville, NO Flintkote, Chicago Heights, IL Vermont Asbestos Group, Lowel 1, VT Source Category Manufacturing - Chlorine Spraying Manufacturing - Paper, plastics Manufacturing - Asbestos/ Cement pipe, texti 1 es, paper, coatings, packing and gaskets Manufacturing - Vinyl/ Asbestos, floor tile, coatings Mi 11 i ng (To be visited during trips Waste Disposal to manufacturing facilities) March 16, 1981 (Left open for rescheduling of site visits as a result of cancellations) RTI also proposes that advantage be taken of site visits in order to visit several of the EPA Regional Officers. Information on enforcement of the current standard wi 11 be obtained during meetings with regional EPA personnel. C. Task 3. Data Collection In Task 3, data collection and analysis will begin. Data will be elicited from numerous areas. Initially, a literature search will be performed through the library facilities of EPA in the Research Triangle Park, North Carolina. Additionally, interviews and telephone contacts will be made * The location is that of the company office. Due to the temporary nature of the work, specific locations for site visits will be determined at a time closer to the dates given. 6 FMSI 02763 with trade and worker associations, vendors of control equipment, companies within the asbestos industries, and government agencies. The following is a list of sources of potentially useful information that RT1 plans to investigate during this part of the study. Additional sources will be added to the list as they are identified. Literature Sources 1. Asbestos: A Bibliography, EPA-600/3-78-066 2. Asbestos: An Information Resource, (NIH) 78-1681 3. U.S. EPA, Electron Microscopy Measurement of Airborne Asbestos Concentration: A Provisional Method Manual, EPA-600/2-77-178 4. U.S. EPA, Control Techniques for Asbestos Air Pollutants, AP-117 5. U.S. EPA, Chemical Market Input/Output Analysis of Selected Chemical Substances to Assess Sources of Environmental Contamination Task III. Asbestos. EPA-560/6-7~8-0Q5 6. U.S. EPA, Evaluation of a Commercial Vacuum System for the Removal of Asbestos, EPA-600/2-80-88 7. U.S. EPA, Sprayed Asbestos-Containing Materials in Buildings: A Guidance Document, EPA-450/2-78-014 8. U.S. EPA, Field Testing of Emission Controls for Asbestos Maufacturing Waste Piles, EPA-600/2-77^098 9. U.S. EPA, Hazardous Wastes: A Risk-Benefit Framework Applied to Cadmium and Asbestos, EPA-600/5-77-002 ~ 10. Asbestos magazine 11. Asbestos Information Association, News and Notes newsletter 12. EPA files . Government Sources (other than EPA) 1. Pearl Harbor Naval Shipyard, U.S. Navy 2. U.S. Navy Environmental Health Center 3. OSHA 7 FMSI 02764 4. NIOSH 5. Consumer Product Safety Commission (CPSC) 6. Bureau of Mines 7. Mine Safety and Health Administration (MSHA) 8. State and Regional Agencies of EPA 9. Bureau of Land Management 10. U.S. Geological Survey Trade and Worker Associations 1. Asbestos Information Association (AIA) 2. Oil, Chemical and Atomic Workers (OCAW) 3. International Association of Heat and Frost Insulators and Asbestos Workers 4. The International Brotherhood of Boilermakers Union Vendors of Control Equipment 1. Nilfisk of American, Inc. 2. Hoffman Air Systems, Division of Clarkson Industries, Inc. 3. American Cleaning Equipment Corporation 4. Diversified Vacuum Systems, Inc. 5. American Air Filter 6. Wheelabrator-Frye 7. MikroPul, Inc. 8. Western Precipitation, Division of Joy Major Mining and Manufacturing Companies in the Industry 1. Johns-Manvil1e Canada Inc. 2. Asbestos Corp., Ltd. 3. Johns-Manville 8 FMSI 02765 4. Raybestos-Manhattan 5. GAF As information is received, its contents will be reviewed specifically for current information on new control technology, feasibility of sampling and analysis, health risks, enforcement experience, and new emission sources. Relevant information will then be compiled and subject to analysis as discussed in Task 4. D. Task 4. Data Analysis Collected data will be analyzed by RTI in order to help assess the need to revise the current standard. The analysis will attempt to determine the fol 1 owi ng: Control Technology Available technology Technology currently in use Effectiveness of existing controls Current asbestos emissions Availability and feasibility of alternate control, including technology transfer Feasibility of substitutes Emission sources not amenable to controls Control technology in the foreseeable future Costs associated with control technology Sampling and Analysis Available methodology Advantages and disadvantages of various methods Availablity of routine, standardized method for compliance purposes Costs of sampling and analysis Health Risks Human dose-response data (to be supplied by ERA) Enforcement of the Standard Federal experience with enforcement Extent and approach of State enforcement 9 FMSI 02766 r Emissions Sources Sources not covered by the existing standard Significance of emissions Use of controls Need for regulatory control Industry Growth Historical growth pattern Expected growth pattern E. Task 5. EPA Review The results of the above analysis will be reviewed by EPA. RTI will meet with EPA to discuss its review and determine where there are additional data needs. The need to revise the standard will be discussed in light of the existing data. If at this stage RTI and EPA agree that it is likely that a revision of the standard is necessary, RTI will initiate appropriate actions to revise the standard, including identification of emission sources, selection of sites to be visited, contact with selected companies, and preparation of Section 114 letters to be sent to selected companies. Initiation of these steps prior to completion of the Phase I review is important in view of the time usually required to arrange plant visits and obtain information from companies. The appropriate EPA Regional enforcement offices will be informed of the tentative plans to visit plants in their Region. All of these actions will be coordinated closely with the Lead Engineer. F. Task 6. Final Data Analysis and Recommendation Regarding Standard An attempt will be made to rectify any omissions of data identified during Task 5. A report will be prepared, which will include a discussion of the findings on control technology, sampling and analysis, health risks, enforcement experience, and emission sources. The report will include a 10 FMSI 02767 recommendation to support or forgo revision of the current standard. If a revision is recomnended, the parts of the standard requiring modification will be identified, and the extent of the required revision will be determined. G. Task 7. Incorporate EPA Comments The Phase I report will be submitted to EPA for review and cormients. RTI will incorporate these comments into the report. H. Task 8. WorK Plan for Phase II. Revision of theAsbestosStandard If a revision of the standard is recommended, a work planfor Phase II will be developed. The Phase II Work Plan will detail the approach that RTI will take in revising the standard, including the level of effort required in developing a BID in support of the revision. I. Task 9. Project Documentation Throughout the review of the standard, RTI will maintain a project Docket. During development of the existing asbestos standard, a formal docket was not maintained due to the absence of regulations requiring a docket. Therefore, RTI will incorporate all of the available information that was collected during the development of the existing standard, in addition to more recent information, into the Docket for review of the standard. Information collected by RTI and data submitted by EPA will be included in the Docket in accordance with guidelines from the EPA Lead Engineer. Items to be entered into the Docket will be labeled, filed, and indexed identifying items included in the Docket. The index (to be current to within about 3 weeks) will be submitted monthly to the Lead Engineer. A copy will also be sent to Midwest Resarch Institute (MRI), Raleigh, North Carolina, which is currently performing an analysis for EPA on asbestos emissions from the surfacing of roadways. Similarly, MRI will provide RTI with a copy of its asbestos Docket index. 11 FMSI 02768 FMSI 02769 T Figure 1. Project Task Plan and Milestones fo r Phase I Figure 2. P roject Organization Chart fo r Phase ,,___. p 0) i4_> 0) 3 -O P (- <1) 4-> rc m c *-- Q CLI 0) ,-- CT cn u co -r- o u J-- 4-J _c c O O) L- "O 0 -T0) tn CO O) 0) L_ ex o_ '--" CL 3 O u C3 tn O) O c O) u to ---. x: r-- P> lO LP> o c^ 0) E C CO o L -T- *-3 > c LU *3 T? Cp fO c 0) - TD CDm-- C LO CL) LU 0) CL 0) 1 C 0) C >> UJ '--' > CDu QJ C UJ </) L 3 _Oc CNJ r-. O r-- (/) r>" .-- 5 - t/1 __I >> tO UJ c < (/> o Co 4u-> CL) +- L. tLO. o-f- 0)-----Cl. O L 3 O -C C\J ir> rH 1 4-J C<d c E *o 4-> E L- r-- to o oOJ u. >> oC7> o Uo l- LU CL) CT "O to Of c tT--- 2tEoZ CL'---' cCL L 3 O J= CO to CO 1 uo .c */> u >l0r-). -te<QoD Q- -Cl 3U tO -r- 0) m or ocu *rj CO QoL- CO JoZ o GO 1 1 1 1 1 1 1 1 1 1 1 1 1 >> 1- 0) 0) c -o <tJ <o --I 0) __1 z: 4- 0) 0) o TO o sz L. U Q. *- s: 3 O O l~ GOO' O3 -to co 4-> L- LC0)00))03 C -C O -r- to CC7> C<O\i I-- LxJ T--( C= <0 10)0 0 E *- L> cO EO) -*o- L X UJ r- O > C UjO C J3 ro ro -- -u CO CO to L CX W O or r +-> <o to O) L. L. C O 3 C -O <0 0> 0) --J 3 Q 11 1 11 I B1 1 11 1 11 1 11 1 ia i 13 FMSI 02770 T FMS1 02771 O3l fD <<O' o CL fD n-> *(0o1D "J ""1O l/l r+ a>Ow'> 'r* vcVOtf) fD 30 fD V* fD -- rO1i> fD m Ol3 lO fOt C_j.fD o Olo 3OO VO OOO fD < fO3D" 0 01 oo o a3 fD "O o TABLE I . Cost/Schedule Baseline Inform ation For Phase I .11 costs are reported in thousands o f d o lla rs , exclusive o f fe e , and Include support, tra ve l and d u p lic a tin g costs, mission te s ts costs are not included; see Appendix 2. APPENDIX 1 Resimes FMSI 02772 T KENNETH H. BABB Education B.S., Chemical Engineering, North Carolina State University, Raleigh, North Carolina, 1979. Experience 1979 to date. Research Triangle Institute, Research Triangle Park, North Carolina. Chemical Engineer in the Applied Ecology Department. Member of project team developing National Emission Standards for Hazardous Air Pollutants (NESHAPS) for benzene emissions from maleic anhydride plants. Provides engineering analysis and evaluation of data relating to cost and design. Developing emissions, energy, and cost data for New Source Performance Standards (NSPS) for coating of beverage cans and large .apliances. Also worked with team conducting survey on status of continuous emission monitoring and monitors for Environmental Protection Agency, Division of Stationary Source Enforcement. Summer 1978. National Institute of Environmental Health Sciences, Research Triangle Park, N.C. Laboratory Technician. Maintained crab population for experiments, performed various chemical analyses, evaluated data gathered from analyses, and evaluated and altered experimental procedures. Professional Memberships , American Institute of Chemical Engineers Tau Beta Pi ` \ June 1980 1-1 FMSI 02773 LAURA A. CONRAD Education B.A., Chemistry, State University College of New York, Buffalo, New York, 1973 M.S., Chemistry, State University of New York, Binghamton, New York, 1977 Experience 1980 to date. Research Triangle Institute, Research Triangle Park, North Carolina. Environmental Scientist in the Applied Ecology Department. One current project includes reviewing EPA's National Emission Standards for Hazardous Air Pollutants for Asbestos and determining whether there exists a need to revise the emission limitations of the existing standard. A second project includes the task of preparing an industry profile regarding occupational exposures to waste anesthetic gases and vapors for the Occupational Safety and Health Administration (OSHA). 1978 to 1980. Occupational Safety and Health Administration (OSHA), Washington, D.C. Industrial Hygienist. Managed a high-priority standard development project on grain handling facilities. Concentrated on the health effects associated with exposures to grain dust, pesticides, and toxic contaminants, such as aflatoxin. Prepared and published two Federal Register notices regarding rulemaking proceedings and wrote the initial draft proposal on Occupational Exposures to Hazardous Substances Found in Grain Handling Facilities. Participated both in public hearings presided by an administrative law judge and in informal public meetings presided by an OSHA panel. Conducted field trips to several U.S. grain elevators and mills and represented OSHA at several interregulatory agency and interest group meetings. Also, was a recipient of a cash award for work excellence for the Agency. ' 1977 to 1978. OSHA, Buffalo, New York. Industrial Hygienist. Enforced the Occupational Safety and Health Act. Conducted over 70 health inspections in various industrial establishments. Sampled for such substances as wood dust, grain dust, mercury, silica, lead, and several different solvents. Attended four formal industrial hygiene and safety courses at the OSHA Institute in Chicago. Attended a Los Alamos/NIOSH Respirator training course. 1975 to 1977. State University of New York, Binghamton. Teaching Assistant. Taught the freshman chemistry laboratory course in addition to chemistry problem-solving classes while attending graduate school. 1973 to 1974. Bishop Timon High School, Buffalo, New York. Chemistry Teacher. Taught general chemistry and music, and performed other assigned supervisory duties. September 1980 1-2 FMSl 02774 T" APPENDIX 2 Asbestos Emissions Measurement Program FMS1 02775 Appendix 2 Asbestos Emission Measurement Program To help determine the protection afforded by the current requirement for " no visible emission. . information is needed on asbestos emissions from the various sources. Data collected in Task 4. Data Collection will be examined for information on asbestos emissions, including atmospheric levels of asbestos. If data on asbestos emissions are considered to be inadequate, RTI proposes two alternatives for obtaining emission data. Alternative one consists of utilizing ongoing or proposed EPA research, which includes asbestos sampling in the scope of research work. Specifically, RTI may be able to utilize data that are generated as part of a proposed multiagency (e.g., NIOSH, EPA) - asbestos industry research project, "The Environmental Research Program Plan for Asbestos." The Industrial Environmental Research Laboratory - Cincinnati (IERL-Ci) is responsible for organizing the asbestos research program which will encompass three areas of study, including an industrial survey, fugitive emissions, and use and disposal of coiunercial projects. The details of the program are being prepared in a proposal by IIT Research Institute. RTI will review the proposal and will determine, in consultation with the Lead Engineer, the feasibility of utilizing the proposed research to obtain the necessary data on asbestos emissions. This will be determined at the earliest feasible time. If emissions data are not available through the asbestos research program described above, RTI will, as the second alternative, examine the feasibility of developing its own emission measurement program using the procedure given in EPA1s Contractor Procedures Manual for Development of National Emission Standards, 3.2.6, Emission Measurement Program. Briefly, this entails the 2-1 FMSI 02776 preparation of a Source Test Plan by RTI to be reviewed by the Emission Measurement Branch (EMB) for technical feasiblity, time needed for method devlopment, resources, and other relevant items. EMB then submits its comments on the adequacy of the Source Test Plan to the Lead Engineer. Presently there are no EPA reference methods for either emission sampling or atmospheric sampling of asbestos (a method for the sampling and measurement of airborne asbestos has been proposed*). Therefore, any asbestos sampling must be preceded by the development of test methods. This will require the efforts of and cooperation between EMB and the Office of Research and Development. A limited number of emission tests will be performed in Phase I, the purpose being support for the feasibility assessment of emission testing as well as the establishment of a numerical emission limitation. RTI, in consultation with the Lead Engineer, will select three or four sites for testing. Because emission testing by RTI is one alternative for obtaining emission data and may not be required, the additional costs of emission testing are estimated here and are not included in the costs in Table I. The costs shown here represent the cost of developing a Source Test Plan, the cost of arranging for the source tests, the cost of pretest survey trips, and the cost of trips to test sites for observation of emission sampling. Furthermore, the inclusion of emission testing in Phase I will likely require an extension of the Phase I schedule due to the time necessary to prepare a Source Test Plan, arrange and make pretest site surveys, sample (estimated at one week minimum * Electron Microscope Measurement of Airborne Asbestos Concentrations: A Provisional Methodology Manual, EPA->600-2-77-178, Revised June 1978. 2-2 FMSI 02777 TT per site), and analyze emissions. It is probable that emission testing would not begin until after completion of the initial on-site investigations, which are tentatively scheduled to end in March. It is estimated that for emission testing at four sites, a minimum of 8 man-weeks will be required to prepare a Source Test Plan, arrange for and participate in each pretest survey, and arrange for and observe the actual sampling. Thus, the estimated hours and minimum cost for emission testing are as follows: Man-Weeks 8 Man-Hours 320 Estimated Cost $10,560 2-3 T FMSI 02778