Document b5DMerdE2mn2VbMzYz10nY2p0

u CEMENT ASUESTOS PRODUCTS COMPANY 214-1 Highland Ai-cniir, South * P. O. Bo* 3435 / nirmi"liam, Alabama 'SS'Jnj * I'lionr 2<J5 * U53-72KI w. k. bcasley Vlt P(Ciidnl>CnUMiv January 12 , 1976 Mr. Kelly K. Peil Roy F. Wes con, Inc. Weston Way West Chester, Pennsylvania 19380 Dear Kelly: Please find enclosed the completed industry questionnaire regarding the asbestos study for AIA. As you recall, we agreed to make one report thrt would include numbers for both plants. You will notice 1 am attaching the flow diagram with the numbered steps for references. If further information is desired please do not hesitate to call. Sincerely, VHB:nf Enclosure b c c: Mr. A, E. Alpine Mr . W. R. Bond Mr. I. L. .Taylor Mr . S. D. Weaver CAPCO ALV 0032022 ROY t WESTON. INC WESTON WAY Y/ECT CHESTER. RA 19380 RHONE (21S) 692*3030 TELEX 83-3348 I As indicated in Mr. Robert Mereness' recent letter to you, Rcy F. Weston, Inc. has been engaged by the Association to gather information and prepare a report on the techr.o log i ca i feasibility end economic impact of the pro posed revision to the OSHA Asbestos Standard. This report will be based upon the data and opinion provided by your company. We believe it is in the best interest cf your company, and the industry as a whole, to parti cipate in achieving a reasonable Standard. Weston's plans are to contact ycu to discuss the attached questionnaire. Depending upon the project schedule (Weston's report will be issued to AIA/MA no later than 2 February 1976), a member of our project team will; c Set up an appointment for a plant site visit, or u Record your input by telecon, or o Provide mailing instructions for your response. To assure confidential treatment of vour input, the cover sheet of the quo s: icr.na i re will be coded, detached from the questionnaire, and kept separate. The cover sheet and questionnaire wi11 not be duplicated. Your data will be kept by Weston until the rule-making process is completed At that time, your original input will be returned to you. A questionnaire for each plant is required. If you have more than one plan please duplicate the attached questionnaire. Very truly yours, JLH:jwg Attachment Jerry l. Hebb Manager, Occupational Health Management Department CAPCO ALV 0032023 ROY f WESTON. INC WESTON WAV WEST CHESTER. PA 19J80 RHONE (215) <021030 TELEX 83-S3a8 ASBESTOS INFORMATION ASSOC IAT IOH/NOR7H AMERICA INDUSTRY QUESTIONNAIRE^*1)(2) Company Name _________ Plant Address ________ Corporate Affiliation Name of Plant Contact Cement Asbestos Products Company 2144 Highland Avenue South, Birmingham, Alabama 3S2C3 ASAR.C0 Incorporated W. H. Beasley Title Vice Presidenc-Concroller Phone Number (20S^ 933-72B1 Note: This cover page will be detached from the remainder of the questionnaire to insure confidential handling of all information. (1) For assistance in completing the information in this questionnaire, please contact Hr. Jerry L. Hebb, Roy F. Weston, Inc., phone (215)69^-3030. (2) If, for any reason, you do not choose to participate in the study by completing this questionnaire, please return-it directly to Mr. Jerry L. Hebb at Roy F. Weston, Inc. CONFIDEMTIAL Company Code S'. Plant Code r? -I- CAPCO ALV 0032024. I. General Prcduct/Process Inforcat ion 1. Which of the following industry segments best describes the asbestoscontaining products in your operations? (Check more than one, if appropriate). X " ~____ Asbestos Cement Products (pipes, sheets, siding shingles) Asbestos Paper Products (asbestos felts, latex sheets, underlayments, electrical and commercial papers) Floor Tile Coatings (roof coatings, caulks, sealants, paints, adhesives and undercoatinos) Friction Materials (automotive linings, disc components, blocks, clutch facings) Gacket, Packing, Sealing Devices Joint Cements Asbestos Reinforced Plastics Asbestos Textiles Asbestos Drilling Muds Asphaltic Paving Distributicn/Resale Miscellaneous (Specify) *_________________________________ 2. Which cf the following categories best describes the operation at your plant? (Chs-ck core than one, if appropriate). a. X Manufacture a product where raw asbestos is used. What tonnage of raw asbestos do you use per year? 14,000 tons b. ______ Process a product which already contains asbestos. 3. In reference to Question 1, for each industry segment, give the specific asbestos end product(s) (siding, pipe, etc.) manufactured, handled, or used at this location and the annual volume of each (in pounds, tons, square feet, etc.). Industry Seoment A/C Products ' ______________ End Product(s) Pipe ' ___________________ Annual Volume 32,000 tons - Ragland 38,000tons - Van Buren 70,000 tons - Total* 2 COfir IDENT1AL Comoany Code # 2- Plant Code # CAP CO ALV 003 2025 *4. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years; 2 Plants 1971 1972 1973 1974 1975 $ $ $ $ $ 6.500,000 6,000,000 10.000.000 14.700.000 i3.ooo.ooo 5. What was the level of capital expenditure for plant improvement and expansion of production facilities for asbestos containing products during the last five calendar years? (Include capital expenditures for environmental control, plant improvement and expansion). 1971 1972 1973 1974 1975 $ $ S $ 5 2.000.000 500.000 . 100.npp . 300.000 700.000 6. 'What is the total plant employment at this location? 274 7. Give the approximate percentage of the employees whose asbestos exposure falls in the following categories: a. Continually in the work environment (operating, production, materials handling personnel) 201 b. Frequently in the work environment (maintenance, supervisory personnel) 54________________________________________________________________ c. Only occasionally (less than 5 times per week) in the work environment (management, engineers) 10 d. Never cr very infrequently enter the work environment (secretaries, sales personnel) 9 8. What unions (locals) represent your employees, if any? a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? t Extent of Activity* Active Area (V--Very, H--Hoderate, N--None) b. What is the current pay CONFIDENTIAL -3- Company Code ft Plant Code ft CAPCO ALV 0032026 I I. Control Techr.olocy/Cost Information 9. Provide a brief description of each step in your operation as it relates to asbestos handling or movement. Interest is primarily in the location of dust sources (bag slitting and dumping, sanding/finishing, etc.) and in dust control at these sources (hoods, etc.) rather than in the production equipment. A block flow diagram is suggested. There should be one such diagram for each product group and/or process used. In clude raw materials entry and finished product handling. A blank page has been inserted at the end of this section for the block flow diagram(s) and description(s). If additional space is needed, please attach extra sheets. (SeeAttached) 10. Has control equipment been installed at each step or combination of steps in the block flow diagram(s) where asbestos is released to reduce worker exposure to airborne asbestos? Yes X Ho List control equipment in use: Steo Tyne of Scuioment Date Installed 1 Resoirators As Needed 2 Bajjhouse Raeland-1965 / 1971-Van Buren 3 Baehouse Raeland-1965 > 1971-Van Buren u-- 5 Barhouse Raeland-1965 / i9/i-Van Buren 6 3aehouas Raeland-1965 / 1971-Van 3uren 7 Baehouse Raeland-165 / 1971-Van Buren 8 Baehouse Ragland-1965 / '9/1-Van Suren 9-- 10 Baqhouse Raeland-1965 / 1971-Van Buren 11 Baehouse Raeland-1965 / 1971-Van Buren What is the total cost of control equipment listed in Question 10? a. Capital cost (installed) S 250,000 b. Ooeratino cost (annual) $ 100,000 (Note: give horsepower, exhaust volume, etc., if operating costs are unknown.) c. What effect has this equipment had on your process, product or production rate? Minimal_____________ CONFIOE'!T|AL Company Code ~ -^- Plant Code ft CAPCO At V 0032027 fl* d. Did this equipment increase or decrease the plent/process energy requirements (electrical power, space heating, etc.)? Increase X Decrease _____ By how much? 12%________ ____________________ ______ 12. What process modifications or work practice changes, if any, were instituted to reduce worker exposure to asbestos? ________________ Vacuum Cleaners, Housekeeping, Method of nandllng a^ Capital Cost (installed) $ 30.000 b. Operating Cost (annual) $ 5,000 c. What effects have these process modifications or work practice changes had on your process, product, or production rate? None Did tnese process mod ificaticns or work practice chances increase or decrease the plant/proccss ener|y requirements? Increase X Decrease Sy how much? 13. Have the control equipment or work practice chances reduced air borne asbestos 1 eve 1s in all of the work areas? Yes X No List the ranges of asbestos fiber counts in the work areas involved: Work Area See Flew Diagram Ranee of Asbestos Fiber Counts_______________ _ Before fModifications/ After Modifications/ Chances _____ Chances___ 1^. Have the control equipment or work practice changes reduced airtime-weiohted average exposure to airborne asbestos in all of the work areas? Yes X No :0MF IDENTIAL Company Code n -5- Plant Code # CAPCO ALV 0032028 Work Area See Flow Diagram ________Range of TWA Asbestos Fiber Counts Before Modifications/ _______ Changes__________ After Modifications/ _______ Changes The present asbestos standard sets a maximum allowable Time-Weighted Average (TWA) exposure of 5 fibers/cc over an 8-hour period. This, by statute, will be reduced to 2 fibers/cc in July, 1976. The proposed standard would reduce this level to 0.5 fibers/cc at some time in the future. If you have already reached 0.5 fibers/cc at each s-tep where asbestos is released into the work place, please go on to Part III; if not, please complete the following: 15. At cch location where asbestos dust is released, do you J'eel you have installed the "Best Available Technology?" Yes X - tine e No Best Available Technology (3AT) is defined as control equipment, process modifications, work practice changes, or combinations thereof, which have been demonstrated to provide the most effective control or reduc tion of contaminant emission. 16. If not, what do you consider the SAT to be, and how effective will it be in reducing airborne asbestos at each location? (Can be control equipment, work practices, process modifications, or combinations thereof). Locat ions Estimated Asbestos BAT ____ F1bers/cc Company Code f CAPCO ALV 0032029 17. What is the expected cost of BAT in terns of: a. Capital Cost (installed) $ b. Operating Cost (annual) $ c. Plant/Process Energy Requirements, Increase ________________ Decrease d. Personnel Requirements, Increase Decrease e. Process/Product Effects, Increase $ Oecrease $ ____________________ Exp 1 a in ___________ _________________________________________________ f. By what date could BAT be implemented? 18. If the Sest Available Technology does not reduce worker exposure to a TWA of 0.5 fibers/cc and a ceiling of 5 fibers/cs at all points, provide your considered judgment on the possibility, cost, and timing to develop new technology to achieve this level. What approach might be used? IS. If the proposed 0.5 fibers/cc level is adopted, what action is foreseen at your plant? III. Industrial Hygiene ar.d Health Information 20. Tne existing and proposed standards require certain industrial hygiene practices where workers are exposed to airborne asbestos below the established TWA or ceiling levels. Do you (provide cost date where ava i lable): t 0 Cost/ Total Plant Yes No Man-Year Cost/Year a. Provide preplacement employee medica1 exams? X b. Provide annual employee medical exams? X c. Provide termination employee medical exams ? X CON'F l Of NT l AL -7- S 9. $ 2,500.' $50. $ 2. $13,700. $ 550. Ccmoany Code # Plant Code # CAP CO ALV 0032030 /> Yes No . d. e. f. g. h. i. Retain medical records (20 year period)? _X_ Maintain records of employee exposure to asbestos fiber (3 year period)? _X_ Dispose of waste materials which may contain asbestos in sealed containers? __ Provide caution labels for all material containing un bound asbestos? __ Provide initial monitoring (sampling) of the work place for airborne asbestos? JX Provide periodic monitoring (sampling) of the work place for airborne asbestos? X X X Cost/ Total Plant Man-Year Cost/Year Negligible SI. S 275. S3. $ 825. 21. Certain provisions of the existing regulation requ ? re add ? tiona1 indus trial hygiene practices where levels of airborne asbestos exceed TVA of ceiling standards. Where these requirements apply to your plant, do you: Cost/ Total Plant Yes No Man-Year Cost/Year a. Wave a respirator program (for use in certain work situations or emergencies)? X b. Provide worker rotation where employee is unable to func tion normally while wearing a respirator? c. Provide protective clothing (for employee exposed to asbestos greater than the ceiling level)? X d. Provide change rooms (where special clothing is required? X e. Provide separate locker facilities (where special clothing is required)? f. Provide laundering of special clothing? g. Post caution signs (where levels are greater than the ceiling or TWA levels)? X X X X CSNr;PENT IAL 8- $4. $1,000. *t $1. $ 275. SI. $ 275. Negligible Company Code 5 Plant Code CAP CO ALV 0032031 /r .22 Do you employ a company physician? Yes _______ If yes: Full-Time ; Part-Time Part-Time hours/ week _________ No x 23. Do you employ an industrial hygienist? Yes X No If yes: Full-Time X ; Part-Time Part-Time hours/ week 24. Who performs your medical examinations (clinic, resident physician, etc.)? ________________Clinic and Local Physician_______________________ 25. The proposed standards expand the scope of industrial hygiene practices into areas such as: shower requirements, regulated areas, expanded respirator programs, and employee education programs. In general, how do you believe your employee will react to such practices? y<r<r. jnme rgslstance - then will accept whatever is necessary to rniniv or ha protected. IV. Economic Impact Information 26. Considering individually the major products manufactured at this location, has implementation of asbestos exposure control procedures and industrial hygiene programs affected the cost of these products? Yes X No If yes, specify: Products Imolementat?cn Cost. S/Unit of Production Increase Decrease Pipe______________ 2% ___________________ 27. Have you experienced a shift or change in product sales due to the cost impact described in Question 26? Yes No X CONrI0ENTIAL Company Code tt -9- Plant Code ft CAPCO ALV 0032032 If yes. specify: Products __Sales Change, S/Year__________________ Increase Oecrease b. If sales have decreased, has the demand been satisfied by: Yes Other Asbestos Products ___ Asbestos Substitute Products ___ Imported Asbestos Products ___ c. Which of the above has had the greatest impact on your sales? 28. Considering individually the major products manufactured at this location, do you expect the future implementation of SAT control procedures and expanded industrial hygiene programs to effect the cost of your products? Yes X No If yes, specify: Products Pipe Implementation Cost, S/Unit of Production Increase Oecrease Unknovn CC?)r lOSMTIAl. -10- Company Code # Plant Code # CAP CO ALV 0032033 29. ould you expect to experience a shift or change in product.sales due to the cost impact described in Question 28? Yes ________ No x a. If yes, specify: Products _Sales Chanoe. S/Year Increase Decrease b. If you expect a sales decrease, will the demand be satisfied by: Yes No Other Asbestos Products ___ ___ -Asbestos Substitute Products ;___ ____ Imported Asbestos Products ___ ___ c. V/hich of the above would you expect to have the greatest impact on your sales? _____ 30. What is the typical age of production equipment in use at your plant in your particular industrial segment? Segment A/C Products Typical Production Equipment Aoe. Years 0-5 5-15 15-25 25+ 5-10 yrs. ________ ________ 31. In your opinion, with the implementation cf 8AT and the proposed OSHA standard to control worker exposure to asbestos, what portion of the existing production equipment may continue to be economically utilized? (Consider the portion of capital equipment retained as a percentage of the total production area investment). CONFIDENTlAL -11" Company Code j?_________ Plant Code i? - CAPCO ALV 0032034. Less then 10% 10 - 25% 25 - 50% 50 - 75% Greater than 75% ____________ ___________ . ____________ X 32. V.'i thin your community, which estimate best describes the portion of the total work force employed at your plant? Less than 10% 10 - 25% 25 - 50% 50 - 75% _ X ____________ ____________ V. Info: .-.at fen F.ecgrdinp Mgr.ufacturers/Fsbr icators of Asbeftos-Containinc Produc t s Trie proposed regulations apply to every place of employment where asbestos, or a product cent a i e; r.a asbestos, is manufactured, processed, packaged, stored, applied, used, or otherwise handled. It is extremely important to our assessment to include estimates of the number of people involved as your products are ultimately used and the possible asbestos exposure levels of these individuals. Insofar as is possible, kindly provide the following information: 33. Who uses the asbestos-containing products you produce (construction industry, auto repair garage, fabricator, etc.)? _ Contrcctovs in construction of vacercains, etc. "" 3*+. Describe how your products move from your plant through the final con sumer Primarily common carriers - trucks and rail __________________ 35. Estimate numbers of peoole and what levels of asbestos dust exposure, if any, may occur at each step (from further processing, fabrication, installation, etc.)? Minimal CONFIDENTIAL -12- Company Code 8 Plant Code 8 CAPCO ALV 0032035 36. Provide names of your customers and appropriate trade association so that Weston might obtain more comprehensive information in these areas AIA and A/C Pipe Producers Association IF IDENTIAL -13- Company Code r Plant Code # CAP CO ALV 0032036