Document b5r91xJ6MkNo32X9ka8p237rO

8HYI80NMENXAL PROTECTION AGENCY PUBLIC HKARDP OH NATIONAL BOSSXOBB STANDARDS FOB HAZARDOUS AH POLLUIANTS C Boom UOt 312 Hortb Sprlag Street lot Angeles, California hbrnaqr 13- 16, 1972 IrfiHliit WILLIAM H. MMONHELL Mnetor Blviiloa of Stationary Sonrca Enforc--eat Ina J.i in--ulal Protection Agency 3600 Vlahara Uai Rockville, Maryland 20832 71--r Baportlag Sarrlea 130 Snaaa Straat Hen York, M. Y. 10038 Barclay 7-2314 GAF 15533 2 -------- --------------------------------------------------------------- r INDEX OF PARTICIPANTS PACE William H. Megormell (Opening StMtamt) ..................... Edward P. Wilson (Philadelphia) ....................................... Leonard J. Goldvater, H.D. (Supplemental Statement) . Dr. Karl V. Lindall.............................................................. R. C. Sutter................... W. A. Oppold ........................................................................... MacRojr Casque, M.D................................................................. D. L. hwry.......................... Morgen Worth ............. Robert E. Viding................................................................... Edgar Cement....................................... .Edmund J. Laubuaca.............................. David S. Calm......................................................................... Benton B. Bailey .................................... Martin B. Pouera ................................................................... Edmund M. Velten................................................................... William C. Eoasaek............................................................... Dr. Donald J. Sibbett.......................................................... Dr. Selina Bendix................................................................. Frank H. T1--min......................... ..................................... Dr. Bans Weill....................................................................... Dr. Thomas J. Smith (oo behalf of K. W. Nelson) ........ B. R. Williams....................................................................... Robert J. Ttockar........ ............. John F. Hunter....................................................................... Dr. Stanley Inhaw.......... ....................................... Dr. John D. Allan................................................................. Robert G. Lunch*................................................................... warren Darrell....................................................................... R. Power Fraser..................................................................... P.S. Bettoli........................................................................... Sylvan B. Lutkewitte, Jr............... Mrs. Cecils Rosenthal.............................. Lawrence F. Williams ............................................................ A1 Klaaciu* ....................................... Dr. Hector Hajar......................................................... Meier Schneider..................................................................... Oscar J. Balctam, M.D......................................... Harry L. Tate......................................................................... Arthur L. Harvey .......................... Stucco Manufacturers Ass'n., Lie. .................................. Timm lalna uTmiunmn-...-. A Dryvall Sundries Manufacturer ....................................... 8 14 17 22 34 59 77 100 114 127 147 164 208 219 243 264 279 289 294 317 327 347 354 375 390 397 403 413 424 434 441 448 463 448 479 479 498 504 513 527 530 332-- 534 <roT A 10 < O 3 i ENVIRO<gNIAL PROTECTION AGENCY: THOMAS B. YOST, ESQ. Chief, Legal Procedures Branch Division of Stationary Source Enforccoent Durham, North Carolina MR. DON R. GOODWIN Director Division of Standards Development Durham, North Carolina MR. DALE M. SLAUGHTER Chief Hasardous Pollutants Branch Durham, North Carolina MR. JACK R. THOMPSON Deputy Director HERC--HP Durham, North Carolina DR. LAURENCE A. PUMJSR Medical Science Advisor Office of Research Washington, D.C. PARTICIPANTSs EDUARD P. WILSON (Submitted for the Record) Assistant Health Conmlsslooer City of Philadelphia LEONARD J. GOLDUATEX, M.D. (Submitted for the Record) DR. KARL V. LINDELL Chairman Environmental and Occupational Health fnilrtu Quebec Asbeetoe Mining Association GAF 15535 PARTICIPANTS (Continued) HR* X* C SUTTER Vice President Dlanond Sheerock Chanlcal Conpany MX. v. a. onou> ice President, Manufacturing Cbenicals Croup 01In Corporation Stanford, Connecticut MAC aOT GASqUK, M.D. Corporate Medical Director 011a Corporation Stanford, Connectlent Production Superintendent Chlorine Plant AlfHimni Conpany of Anarlca Point Confort, Texas MR. MORGAN NORTH Morgan North Mine Mnageaent 1090 Packer Street Berkeley, California Ml. BOBSXT X. VXDtNS Tice President of Manufacturing Industrial Chantcal Division PPG Industries, lee. Barrlrnunsntal Control Stauffer Chantcal Conpany MR. IDMDSD J. LAUBUSCH Technical Manager The Chlorine Institute, Dee. 5 PARTICIPANTS (Continued): MR. DAVID 3. CAHM Chilr--B Ad Hoe Coamittee for MchiM Applied Portland Camsnt Flatter MR. BRUTON B. BAILEY Vice Praaldant and Manager of Operatlona Mow Idrla Mining and Chamlcal Coapany San Joan, California Mt. MARXZX B. POWERS Aaaiatant to tha Praaldant Brush Uallasn, be. Cleveland, Ohio Vlea Praaldant Kawacki Beryleo Industries, foe. Handing, Pennsylvania MR. WILLIAM C. RDSSACK Coordinator Safety and foduatrial Byglaae Lockheed MLaailoa 4 Spies Company, foe. Sunnyvale, California DR. DOMALD J. SIBBITI Vico Praaldant Gaomet, foeorporatad Peaona, California Dt. SRLXKA IQOn Praaldant, Beat Bay Chapter Oeaanie Society Santa Monica, California MR. FRAME H. ZDMUMAM Aabaatoa Information Aaaoclatlon/Morth America 325 Delaware Avenue Buffalo, Haw York GAF 15537 6 PARTICIPANTS (Continued): DR. HABS WEILL Professor of Medicine Tulane Oliversity School of Medicine DR. THOMAS J. SMITH, on behalf of MR. K. V. HELSOM Director, Department of Environmental Sciences American Smelting and Refining Company Salt Lake City, Utah MR. B. R. WILLIAMS ice President Construction Products Division W. R. Grace & Coapeqr not avwwMiA ase swvmui Seles Manager Pacific Asbestos Corporation Copperopolis, California MR. JOBR V. HOOTER Corporate Manager of Environmental Control BASF Wyandotte Corporation Wyandotte, Michigan DR. SIAHLKT ROKAW Tuberculosis and Respiratory Disease Association of California Los Angeles, California DR. JODI D. ATJJOI Air Quality Coalition Puget Sound Air Quality Control Region Seattle, Washington MR. ROBERT 0. LOUCHE Chief Deputy Air Pollution Control Officer Los Angeles County Air Pollution Control District MR. UASKEH DARRELL Director of Manufacturing Industrial Products Division ~CAF Corporation GAF 15538 7I PARTICIPANTS (Continued): MR. R. POWER FRASER Vice President GAP Corporation MR. P. S. BKTTOLI Technical Director Building, Induetrial & Floor Products Division GAP Corporation MR. SILVAS B. LUTKEVXTIE, JR. Production Specialist Monsanto Industrial Chemical Coapany MB. CECILS ROSENTHAL Conservation Chairman Angeles Chapter, Sierra Club MR. LAURENCE P. WILLIAMS Executive Director Oregon Environmental Connell MI. AL KLASCIUS Southern California Section American Industrial Rfglene Association DR. HECTOR BLUER Head, Occupational Health California Department ot Public Health MR. MEIER SCHNEIDER Industrial Hygiene Engineer California Department of Fublic Health OSCAR J. 1ALCH0M, M.D. Heatings Professor of Medicine University of Southern California School of Medicine MR. HARXT L. TATE Arlsonana In Defease of the Environment, Tec. ME. ARTHUR L. HARVET Chairman, National Air Cmndttee The Isaak Walton League of America --------------------------------------- ---------------------------------- GAF 15539 I 1 Mr. Dsrrsll 424 MR. MEGONNELL: Mr. Varran Darrell and Mr. P. S. Bettoli of GAP Corporation. STATEMENT BY rat. WARREN DARRELL DIRECTOR OP MANUFACTURING INDUSTRIAL PRODUCTS DIVISION GAP CORPORATION MR. DARRELL: Mr. Msgonnall. I would like, la the interest of saving tine, to request that the written tateneot, of which you hare a copy, by Mr. Fraser. Vice President of GAP, be entered into the record, and I would like to request that although 1 have a prepared statement, there will be sene departures free the enact tent. MR. MBCONNELL: All right, fine. We will reproduce Mr, Fraser's consents. MR. DARRELL: Thank you. My naue is Warren Darrell. I an Director of Manufacturing of tha industrial Products Division of GAP Corporation. X have responsibility for the nanufacturlng operations in flitsen of tho GAP plants including five nlneral product ulnlng and Billing facilities, e paper plant and several textile plants, and an asbestos nlning and nllllng GAF 15540 2 Hr. Darrtll 425 facility In Hyde Park, Vamont. Slsea 1946, Z haw bald supervisory poaltlona In asbestos nalng namsfecturlng plants and hava also baan aasoclatad with aabaatoa nlnlng oparatlona aInca 1961. I an ham to dlaciaa tba proposed anlaslon control standarda for aabaatoa, aa wall aa tba results of certain studies dealing with the effects of asbestos on the health of the general public. As yon knew, the Federal Clean Air Act of 1970 and the Hazardous Substances Section of said Act author* Isas the promulgation of those proposed standards. This Act was passed to protect the health of tba gsneral public froai certain hazardous eleaonts found In the anblent air. Asbestos, nsrcury and barylllun vara described as hazardous substances during the congressional hsarlnga on said Act. Z an going to skip a place ham. Fbr purposes of this discussion. It is aa* suaad that them Is a need to regulate asbestos diet baasd upon the nodical findings. Ve request, however, that EPA standarda regulating asbestos aulasIons be based upon all the facts that am presently available to protect the public fron hazardous quantities of said material, but that such standards not be so drawn so as to protect against riaks GAF 15541 3 Mr. Darrell 426 that do not exist and not bo ao stringent that they cannot bo compiled with on a technological basis. Those proposed standards in question encoa* pass the followingt The prohibition of emissions from stationary sources except from specified filter media; and the prohibi tion of visible emiasione from dumps, storage areas, external conveyers and tailings dumps. I am prepared to disease these areas in light of our experience with esbeatoe. Emissions From Stationary Sources* As Nr. Fraser stated, GAP operatee am asbes tos mine and mill in Vermont. This operation is a key GAP plant. Zt produces chrysotlle fiber for our domestic and foreign customers and also supplies fiber for our own menufactoring of building products. This mine end mill is a typical chrysotlle asbestos nine and is representative of some chrysotlle asbestos nines in the United States and in Ve have made a preliminary study of this mine and mill in regard to the proposals. As e result of the study, we have concluded that there is technical knowledge -a available to comply with the filter media requirements. As a matter of fact, GAP has, for the last several years, been : GAF 15542 4 Mr. Darrell 427 utilising collectors on certain dryers with success In reduc ing fiber emission significantly. However, such ccapitanee can be achieved only at great cost to the coopany. Wo estlaate that It will cost GAF in excess of $800,000 to eoaply with the proposed standard at the Veraont facility, and this dollar figure applies only to those standards that we know we can eoaply with or could technologically eoaply with. Z would just like to digress, in that the dollar figure of Itself is not of great laportance, except that, as 1 will point out later, there are certain standarda that we feel we cannot eoaply with, have no way of knowing how to eoaply with, and the expenditure of $800,000 will be wasted If certain of the standards as proposed go Into efr feet. Visible BelasIonsi 0a the other hand, we have been unable to conceive of s aethod to cope with and Measure visible emis sions, as they are presently defined la the standards, es pecially froa tailings piles. Ibis Is based upon a search throughout the industry and known technology, as well as certain govermental surveys which conclude that emissions froa tailings piles cannot be reduced to zero with the present GAF 15543 5 Mr. Darrell 428 state of technology. He are, however, continuing to Increase our knowledge of tailing* and the emissions therefroa. As you know, tailings can be plied several hundred feet high and cover large areas. He are Investigating the possible stabili sation of tailings piles with vegetation, but these Investi gations are at a preliminary stage and they could continue for nany yearn. As an aside, these have also been tried by others with varying degrees of success and lack of success In covering asbestos tailings piles with vegetation. It does not seen possible that we can reduce visible amissions to the prescribed limit of "8 visible amissions" within the two year waiver period provided In the regulations. However, a threshold question as to the treatment of tailings dumps relates to whether In fact they constitute a health hasard. There are relatively insignifi cant amounts of asbestos In eadsslons from our tailings. I would say that this Is an observation. We run Into the same measurement problems you people tun Into. However, the free asbestos fiber in ear tailings constitutes less than onehalf of one percent of the material la a tailings dump. The remainder consists mostly of serpentine rock. This GAF 15544 Mr. Darrell 429 ainute pcrcntaga of fro* aibMtoi li cho reault of a GAF program la which new equipment wee lnatalled in Vermont per mitting greater extraction of fiber from the boat rock, which boat rock eventually beeonce the talllnga Material. Gentlemen, that la the crux of our buaineaa, getting tbn fiber out of the rock in the flrat place. That la what we an trying to do. MR. MEG0HHE1X: The nore you get, the happier you an, I'w awn. MR. DARRELL: The, or have been until aoee of the ccaneata have been eade (laughter). Ihrthermore, the foreea of oatun further reduce ax&aalona of aabeatoa fiber talllnga. The conaolldatiou of the talllnga thaaaelvee, rain, or a algnlflcant anew cover during the long Vermont wlntera and the entrapnent of fibera In the poroua rock of the talllnga aerve to reduce the poaalbllity of aniaalona. Therefore, If one takea Into conalderatlon the nlnute percentage of fiber In our talllnga, the reduction of aniaalona due to natural phanonana and the dilution of aniaalona, one could conclude that any aniaalona that do t1*- occur are not of auch aignlficance to conatltute a health hazard to the general public. GAF15545 7 Hr. Darrell 430 : WS aarlouf ly question how the nlnlnun aaount of MbMtoi flbor ralaiitd from our callings pllos could bo hazardous to tfaa hoaleh of tha surrounding coanunity adjacent to our wine. Page 31 of the report published by the National Acadexy of Sciences, entitled, "Asbestos -- Ihe Heed For and Feasibility of Air Pollution Controls," concludes as follows: "Industrial experience indicates that there is no likelihood of significant asbestosis in non-occunatlonal ) exposures." And farther states: "At present, there is no evidence that the snail minhara of fibers found In nost nsnbers of the general population affect health or longevity." In addition, the SPA has agreed to the above conclusions, as stated in the background information published by tha SPA dealing with these standards. Oo Page 4 of said report, the following statansat was nade by the SPA: "For populations exposed to asbestos only in anbient air, there are no data that define the excess 9 risk, if any, of developing this disease." (Bronchogenic carclaona.) And further, "It is presently thought that { GAF 15546 8 Mr. Darrell 431 exposure to MbMtoa concentrations nuch larger than those likely to be present la eommlty air Is required for the developaeot of clinically significant asbestosis." Sr. J. C. McDonald's recent testimony sub mitted to this agency at the Hew York hearing indicates that ssothaliosN vaa not detected In parsons living near the several asbestos nines in Quebec, Canada. The CAF nine is the only one in Vernont and is isolated In the nountaina of Vemont far froa any large populated areas, as opposed to sons of the nines In Canada which are right in the toons surrounded by fairly dense populations. Thare have been no reports of nodical problana node to ns by the neighboring population doe to the aulasIons fins this nine. Accordingly, ve respectfully request that the visible enlsslon standard be clarified as applicable to GAF In vten ef the ntnute percentage of eabeatoa naterlala in visible euisalona emanating fron our tailings, no known technology to alleviate said eniaslona, and 1 would like to aay no known technology to eliniBete eonpletely aald emissions, but known technology to reduce -- that 1a not in here, but I don't feel that atat--eat was quite correct and the leek of any nedicel evidence that the general populations' health la endangered. Aa the standard now reads, visible ------------------------------------------------------------------------------ GAF 15547 I 9 Mr. Darrell 432 emissions of particulate MtCor azo prohibited even though these emissions ere not harmful, and contain little or no asbestos. We propose that only visible emissions from tellings piles containing "Harmful amounts of asbestos" be prohibited. It map be necessery tor further medical studlis to be coodmeted is regard to mhat constitutes harmful amounts. Soma specific level could be established after sufficient studies are made and the standards could be amended at that time. In light of the above, the following amend* meat to the standard la suggestedt Section 41.23(b)(1) should prohibit visible emissions of particulate natter from asbestos do^s, open storage areas for asbestos-containing materials, or asbestoscentalmlmg tailings dumps if said amissions contain amounts of asbestos that have been established as harmful to the general public. Xa conclusion, GAP reiterates its recognition of the desirability and necessity for effective amiss ion con trols. With tbs exceptions ve have discussed, me support the EPA's national Emission Standards for Asbestos. GAF 15548 10 Mr. Darrell 433 Thera la iom additional information which I have having to do with the prohibltlooa of the use of tailing# on nine roada and ao forth, but they all generally addreaa theeaelvea to the aaee general point, and I would prefer to turn thaw in in writing. MR. MEGOHHELL: Fine. They will be Included la the record. Z think there la a thread of continuity running through fcheae hearing!. There la thla coenon problan of talllnga piles, end I think the SPA will have to reconsider that before final promulgation. X don't quite understand why you say you have trouble measuring visible emissions. Anybody with eye sight can do that. Ml. DAUELL: YOu could sec e visible amiesioa, yes. Ml. MEGOBKELLt YOu meant quantitatively Ml. DAUELL: Yhe. It la the same problem. The methods used in plant aro not necessarily reliable out side of e plant. Ml. MEGOKNEU.: Yea. I think anything else Z would say would be redundant. GAF 15549 11 Mr. Darrell 434 | Incidentally, on tailings plica, have you I triad chenlcal sealing? MB. DA8RZLT.; We have not triad chanlcally aaallng. Ha have read about It. We bare two problems on talllnga pllaa, Mr. Megonnell, and (1) all tha areas are relatively consolidated and at tha surface are pebble-sized rock, half inch rock, three-eighths inch rock. You can blow pretty hard and you don't sea anything coning off these areas of the pilee. Ha think it la going down into the loose gravelly nature of the pile itself, but when you are depositing the naterial on the pile, it is up a conveyer belt and there has to be sons kind of a fall free the conveyer to the pile and than sons Mechanical spreading with a bulldozer or sanethiag to keep tha pile going, and this is an area where the mount of free-fall can be reduced. In the suanertlne yon night be able to wet it, la the wintartiaa certainly not, but all those things, and other things that we conceive of, lead us to believe that we could wake significant reductions | but not couplets elluinatlons to sero, and that is the area we are acre concerned with than the other. I will agree that if a tornado cane along, which we don't have, and tore a swath:.through the hill, then the older portions night be disturbed. GAF 15550 Mr. Darrell 435 MR. MEGONNELL: I think we vould like to, and perhaps be able to write legislation as 700 suggest hare. We can't. It can't bo written that way, but we are aware of these tailings problems, and I an sure it will get nore con sideration. MR. SLAUGHTER: I went to anpllfy a little bit. Other than the dueping and the spreading of the tellings, do you here any visible aeriesions froa the tailings duapT Would that part of the regulation be a problen other than the dueping and spreading of the telllngsT MR. DARRELL: Foeslbly In aaall areas, de pending on freshness. Wo have had an opportunity to observe another tellings pile fron another deposit thst was nlned prior to 1949 a little ways away, but It la there. This Is all eyeball stuff, and we have asked all the older residents at the pleat end other people, Ihve you ever seen anything blowing off that pile," the unused pile, and the answer has been, "Mo, we have nevar seen it." So that does not naan that sons day we night not see sonsthlng and that we night have to do sonsthlng further to these, what I call, stabilised or consolidated piles, but that does not seen to be a setter of concern to us now. It ssbs that we don't gat any visible euiaslons at these points. GAF 15551 3 Mr. Fraser 436 MB. SLAUGHTER: Hunk you. MS. MEGONNELL: Ibrak you. (Iht following ititearat m submitted for Inclusion in tha record:) MR. R. FOURS TRASKS VICK FSB8IDEHT GAT COBFOBATIOK MR. TRASKS: Gentlemen: Hr naaa la R. Power Fraser. and I aa Vlea Fraaldant of GAT Corporation. GAT'a Industrial Froducta Division la a major producar of asbestos, although our output rapraaanta laaa than 2 1/2 percent of aabestoa fiber consumed In tha United States. GAT appreciates tha opportunity to participate Is your public hearings on the proposed anlsslon standards I for asbestos, beryllium and Mercury in Industrial aad mining operations. We want to cooperate In this Important area and to assist In tha writing of standards which are both practical and yet protective of tbs environment. GAF concurs In general with the testimony given by Johns-Manvilie Corporation at the EPA hearing In GAF 15552 14 Mr. Fraser Raw York City on January 18th. Along with Johns-Manvilla, wa support tha proposal Environmental Protection Agency Ra tional Emission Standards on asbestos, with tha exception of soma Modifications that Mr. Darrell and Mr. Bettoll will discuss later. Wa feel we can adapt the proposed EPA re* qulrementa to all our thirteen (13) consusing operations In the United States, with the exception of our Hyde Park, Vermont plant. Mr. Darrell will explain why shortly. Before he speaks, I would like to glue you a brief outline of GAP activities and policies. t GAP Corporation is a worldwide company which nanufacturea and distributes a wide range of producte la five related consuner and industrial narkat areas. The areas are: chanlcala, building materials, photographic film and equipment, office business systems, and industrial products. The cannon bend uniting tha product groups is chemical re search and technology, from which GAP's "congeneric" nature evolved. Headquartered la Hew York City, we employ approxi mately 20,000 persons. At Its more then 70 nanufacturlng and pro cessing plants throughout the Ublted States, GAP endeavors to be a responsible member of the business community. In fact, the company's Management Policy specifies that GAP ~-- GAF 15553 - Mr. Fraser 438 "will conCloua to do its utmost...to b a cooperative and use ful citizen of the coanunltiea in which it operates and to contribute to the progress and welfare of these coanunitles." Wo have net pollution control requlreaents as we have understood thee. However* euch of what is called pollution la the result of the practices of aan over hundreds of pears* and solutions are being sought and even expected practically overnight. Sonet1ms* solutions to the probleas oust be delayed until the technology of how to solve the problem has been developed. Overall* CAP spent about $5 million last year and will expend la the neighborhood of $6 elllion this year on environmental control equipment. I cite these figures only to lllustrete that ay conpeny la totally coonitted in Its role of a responsible and concerned citizen. The ever-changing and sonstines conflicting regulations of the aaay agencies operating in the environmental control field necessitates our having a full staff of cor porate enviroumntal engineers to update and aodernlze our equlpeent and facilities to neat standards. This effort also includes hasid research in those areas where there is pre sently no technology to coabat certain probleas. GAP'a industrial product division nines and 16 Hr. Fraser 439 processes asbestos. Tha chrysotlle aabeatoa flbar we mine and manufacture at our Rjrda Park, Vermont plant goes Into aueh product! aa aabaatos felts, papers, caaant, and wallboard. Contributing significantly to tha safety and quality of Ufa la America, aabeatoa la of vital lnportanca to tha textile, automotive, aircraft, plastic, paint, building, filtration, electrical, cheaical, and many other iaduatrlaa. Our Vermont mine la ona of two mlnea producing the basle line of chryaotile aabeatoa fibers in the United Staten. Tha ehrysotUa variety of aabeatoa consti ) tutes about 95 percent of world asbestos supply. The Republic of South Africa, Southern Rhodesia, Svaslland, Italy, and the united States, of course, ace substantial producers. Small supplies also originate In many other countries. Total world production In 1968 was estimated at 3.5 million tons of all grades and varieties. Of this total, Canada produced about 46 percent end the USSR an estimated 25 percent. GAP's tyde I'ark asbestos plant -- located In northern Vtomont about 40 nllea west of Burlington -- employs 205 people with an annual payroll approaching $1 1/2 million. Counting their depends and families, some 800 people depend, in part, on that nlll for their livelihood. CAP pays $97,000 In local and state taxes there and spends $625,000 --------------------------------------------- -------------------------------------- GAF 15555 17 Mr. Fraser 449 yearly for tbs purcbaso of supplies and fuel*. ConaIdaring that* facts, tha Hyda Park opera tion has an enormous -- and favorable -- economic impact on tbe sparsely populated counties of Lamoille, Franklin and Orleans in the uppermost part of Vermont. Those are the counties that our Hyde Park employee* com* from. For exaqple, we employ over 31 of the work force in Lamoille County. The economic contribution of tyde Park to that three-county area of Vermont, while difficult to calculate exactly, would appear to run into milllona of dollars. It is a general consensu* that asbestos plays an Important part in our technology and economy. Therefore, GAP, as Johns-Msnville has already done, would like to express again its continuing recognition of the need for the control of asbestos amissions into the air to tbe extent such are harmful, end to pledge our determination to do whatever la necessary within the limits of technical feasibility to achieve such controls. Thank you. MB. HEGONHELLx Our next speaker Is Mr. Darrell's colleague, Mr. P. 8. Bettoli. GAF 15556 18 Hr. Bettoli 441 STATEMENT BY MR. P. 3. BETTOLZ TECHNICAL DIRECTOR BUILDING, INDUSTRIAL AND FLOOR PRODUCTS DIVISIONS OAF CORPORATION MR. BETTOLZ: Mf MM Is Philip Bettoli. I n Technical Director of the Buildlog, Industrial ad Floor Product* Divisions of GAP Corporation. I have obtsinsd Bachelor of Science in Chanlatry fron the University of California and have hem continually aaaoeiated with developeat prograaa on a variety of asbestos products for 26 years. I a here to discuss the proposed eaLsslo*' control standards for asbestos as they relate to the asbestoe using Manufacturing plants of GAP and aose field applications. GAP Corporation has nade a prelinlnery study of our Manufacturing plants in regard to the proposals. As a result of the study, it was concluded that we will be able to eonply, except in the following respects. There are visible emissions fron certain operations producing asbestos-containing materials at our roofing and flooring plants which we are certain do not con tain asbestos particles, since the asbestos Is bound into the GAF 15557 II 19 Hr. 442 producta being aanufactured at these atages of tha operation. Examples of thia are aabestoa roofing felt aaturation and coating and vinyl flooring plaatlaol fualon. In tbeae and nany other laainating and coat ing processes, the asbestos fibers are bound together or totally encapsulated by agents that preclude any particle eniasion. Strict interpretation of tha current draft calls for unwarranted filtration of any associated fanes. We know of no acceptable test nethod to establish that asbestos fiber is not being introduced into a process gas streaa or stack effluent eaittad frow those and other sources. It is, therefore, iapoeeible to scientifically verify our conclu sions. Qtotll such a nothed can be established, we request that fuses being released froa asbestos-containing aaterial in which the asbestos is bound, should be excluded froa the definition of particulate Better. We also pledge our full cooperation in helping the SPA establish an asbestos testing awthod. In addition, the present definition of par ticulate natter aakes no reference to asbestos aaterial. Accordingly, we suggest that Section 61.21(h) should read as follows: GAF 15558 20 Mr. Bettoll 443 "Particulate natter naans any asbestoscontaining aatarial which axiata la final fora aa a liquid or aolid, other than unccabined water or fuaea being emitted fro* proceaaing operationa in which the aabeatoa content ia bound.n Paragraph 61.23(d) of sub part B definea the woven cotton fabric flltera to be utilised to renove particu late natter fron certain aourcea. GAP aanufacturea filtration fabrics fron synthetic fiber felts as opposed to cotton. Many felta are at least equal and In certain service, superior to woven cotton for "dry" filtration purposes. Ha believe that they reached efficiency equilibria faster not only initially but after renoval. They also will function with a higher perneabllity rating to give equal mss sufficiency. Tor certain applications and particularly where high taaperature is involved, synthetic fiber felta are superior to cotton. We would be glad to provide cooperative and perfornsnee data to the SPA. Paragraph 61.22 -SI and 2 states that "The spraying of any product which contains asbestos on any portion of a building or structure, or any area directly open to the ataosphere is prohibited." This broad prohibition ellninates all types of spraying of asbestos-containing products, . ------------------------------------"--------------------------------------- GAF 15559 21 Hr. Bettoli 444 Including caulsIona and cutback bituminous roof coating*, adhesive* and other water-proofing compounds which contain alnor amounts of aabestoa fiber. These roofing and water proofing components contain less than 10 percent of thoroughly vetted end dispersed asbestos in a liquid binder. They are applied by relatively crude spray nonlea which do not form a fine mist of droplets, but deliver a sheath or solid liquid fan which does not create any emissions of asbestos to the atmosphere. After application, the tailings dry and the as bestos is entrapped and la prevented from entering the at mosphere. Therefore, there la no justification for restrict ing the application of these sprayed-om roofing components. We agree that there is a Justification to limit the spraying of asbestos-containing compositions that have the potential to liberate harmful amounts of asbestos particles to the ambient air. Accordingly, we suggest an alternate warding of the above section as follows j "The spraying of asbestos-containing products, which emit harmful amounts of asbestos fiber to the atmosphere, on any portion of a building or structure, or any area directly open to the atmosphere. Is prohibited.1* X think I will eliminate that next paragraph. I would further suggest that tbs word "source' --------------------------------------------------------------------------------- GAF 15560 Mr. Bettoli 44s b dfiaed on i pint basic. Tbs abora recoonendatloos have been dlseusssd with tbs technical apart! froa ths EPA. Vs turvs net with than sad will ba glad to dlsenss say otbar problena vlth your offlea la tha future. I also syupathlse with tha vary difficult task thay hava to do vlth this vlth tha lladted tlaa sad aeaeuraaaat tachaology available, sad vlll assist thaa la say vay posslbla. MS. MWOHHB.li Z aecapt your ssslstsaca. MR. BBITQLX: I'a rosy sarlous. I really ballava va ora all trying to do tha right thing and va ora Halted, sad tha aaa that Z hove act la tha organization saaa to ba quits coupataat, sad X*va baoa Is tha buslnass for 26 yasrs, sad Z kaoa thara sra saaa things that va cannot aasvar at tha present tlaa, nor do Z feel that thay would necessarily hava bean aware of certain uses where visible emissions would ba, but not at all related to ashestoe particles. MS. MEGOMBEUU Z think your paper painted i It out. lhay Taforoail no thay are going to batter define tha parts of tha process they axa referring to. Perhaps tha sizing operation would ba covered, but cartsinly not tha saturation part of tha proeaaa. GAF 15561 23 Mr- Bettoll 445 I raised the sane question you did, why cotton was specified, and I think it would bo good to got the data they do have on other types of filter cloths. As you know, the spraying of roofing and water-proofing components with lower anounts of asbestos Is being reconsidered. I have to ask you also, sir, do you have any Information on what happens to the roofing asbestos particles during danolltlonf MU BETTOLI: Well, a built up roof is node up of several layers of coating with saturated felt. They are bound together with the spray adhesive or laalnatlng, and they can then pour oo top of it additional asphalt or tile and gravel. BornaUy, those are what they call spaded or spudded up, aany years later, naybe twenty years later. They are in the fon of a solid ness. Zn soon cities, they require the watting down of any demolition, which I think, if there were asbestos free to fleet around. It would preclude Its floating around because of the wetness. MS. MEGONHELL: It's not s very effective operation when a wrecking ball hits. i KK. BETTOLI: They don't hit the roofing with a wrecking ball. I naan it's not that kind of thing. ------------------ ---- ------------------------------------------------------------ GAF 15562 24 Mr. Battoll 447 You hava imb a bituminous nanbrana or a foundation that baa boon coatad. Tha aaaa, tha backing* what paopla ganarallp call tar* tha asphalt la atlll quits tanaeloua to tha flbar* or tha flbar la not avan vialbla. It la part of thla matrix. It isn't dusty. MS. MBOOSHBU.I I can saa whsra tha amissions would probably ba much laaa. MS, BETTQLX: Zf pom taka tha plpallna to tha traaacontlnantal liana which arn protactad by asbaatoa papar from corrosion* and thaaa ara burlad wndarground* tbara ara fuaaa amlttad* though* bacanaa of tha anamala that ara usad whan thay ara wrapping tham aad bonding it to tha plpa* but java latar thay could ba piekad out aad thay wouldn't hava any dry natura to tham. Zhaaa ara aaaaas. MS. MMflWIKIJ.i Thank you, I*. Battoll. Mr. Silvan Lutkawltta of Monsanto Industrial fhamlcala Corporation. Sir* Z would Ilka to ask you to coosIdar thla: Z hava raviawsd thla atatamant. I think It la vary wall doaa. Z think it la rapatltlous of Tha Chlorlna Instltwta'a praaaotatlon yaatarday. If pom would Ilka to sumaarlsa It* baarlng In mind that tha antixa papar will ba raproducad In tha rocord* Z would approdato It* or* If poo insist* wa^ --:-------------------------------------- ------------------------------------- GAF 15563 I