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FILE NAME: Scotts (SCTS) DATE: 1978 Jan 30 DOC#: SCTS019 DOCUMENT DESCRIPTION: Report - Product Application Test [Testing Scott Products as Source Asbestos & Levels of Exposure] PLAINTIFF'S EXHIBIT SCO-3 PRODUCT APPLICATION TEST BY: Dick Gruenbaum Allan Davidson Date: January 30, 1978 cc: Dr. J, Kilsheimer Ron Wietelmann Jim Simmons Sarge Chamberlain Pete Griffin Bill Hillegass SC DENH000292 PRODUCT APPLICATION TEST PURPOSE: To determine if key Scott products are a source of asbestos fibers and if so at what level of exposure would a user be exposed. INTRODUCTION: Turf Builder and Turf Builder Plus 2 were selected for the test. Test sites selected were Darby Glen Sod Farm, Marysville, Ohio, and Saticoy Golf Course in Saticoy, California. Turf was representative of each region; bluegrass in Marysville and bermudagrass in California. Vermiculite was included in the Marysville portion of the test. The California test was conducted under the guidance of Dr. W. Clark Cooper, Consultant. TEST EQUIPMENT AND MATERIAL: 1. New Scotts PF-1 Drop Spreader modified to allow Millipore Cassette filters to be located at the drop zone of spreader. 2. Turf Builder and Turf Builder Plus 2 at both test sites and vermiculite added at Marysville test site. 3. Miscellaneous equipment to lay out plots. 4. Samplers - Three (3) Bendix Micronaire Model 390010 calibrated between 1.6 and 1.7 liters per minute and one (1) Bendix C-110 calibrated at 2.0 liters per minute. Samplers calibrated gust prior to each test. Flow meter checked after each 10,000 sq. ft. plot. SC DENH000293 - 2 - 5. Cassettes with Hillipore 0.8 micron filters - Catalog No. AAWP03700. 6. Stopwatch. TEST PROCEDURE: General: Test procedure was essentially that as presented by J. Simmons in Project Outline dated 9/7/77, copy of which is attached. Materials were applied at a 2X rate over 10,000 sq. ft. plots. Each product was replicated three times. A total of four samplers and filters were used for each plot. Two samplers and filters were mounted on the spreader such that the filter cassettes were located just behind the drop zone of the spreader. Two samplers and filters were worn by the spreader operator with cassettes in the breathing zone of the operator. One cassette was removed from the spreader and one from the operator after one-half of the plot (5,000 sq. ft.) was covered. The remaining two cassettes were removed at the completion of the plot. A total of three checks were obtained using an empty spreader over a plot area. All filters were submitted to McCrone Associates, Chicago, Illinois for fiber counts. Fiber counts completed by the OSHA/ NIOSH phase contrast method. Marysvilie: The Marysville test was completed on Oct. 24, 1977 at the Darby Glen Sod Farm. The area selected was slightly rolling with one year old Windsor bluegrass sod. Sod was being harvested to the west and about 500 yards from the test site. Wind was from the southwest and generally calm at the start to windy midway through and calm again at end of test. Turf was moist at beginning of test. The area was layed out in nine 10,000 sq. ft. SC DENH000294 - 3 - plots. Soil samples were taken from each plot prior to product application. Turf Builder Plus 2 was applied first, then Turf Builder and vermiculite. The vermiculite spreader setting was the same as would be used for a 2X rate of Kwit. A set of check filters were taken prior to each product type. Sampling periods varied from 12 to 15 minutes and 23 to 33 minutes for the 5,000 and 10,000 sq. ft. areas, respectively. A total of fifty filters were submitted to McCrone Associates for fiber counts. Two (2) blank or unopened filters were included. Fiber counts given in Table I. California The California test was completed on Nov. 15, 1977 at the Saticoy Golf Course. Area was in a small canyon which was part of the Driving Range, Turf varied from none to bermuda with patches of rye. Turf slightly damp at start of test, dry within one hour of start. Wind was calm at the start to mild (5-10 mph) from the northeast with some swirling at completion of test. Plot plan same as at Marysville except only six 10,000 sq. ft. plots needed. Three checks were taken during the period of the test at the beginning, middle, and just prior to last Turf Builder plot. Sampling same as for Marysville test with times varying from 10 to 12 minutes and 21 to 24 minutes for the 5,000 and 10,000 ft. areas respectively. A total of 37 filters were submitted to McCrone Associates for fiber counts. One (1) blank or unopened filter was included. Fiber counts are shown in Table I. A copy of Dr. Cooper's observations is attached. DISCUSSION: The apparent difference in fiber counts between the Marysville and California test is not readily apparent. A memo dated January 12, 1978 from Dick Gruenbaum SC DENH000295 - 4- on his discussion of this difference with Millipore Corporation is attached, Mr. Ian Stewart of McCrone Associates could not explain the difference except for possibly in handling of the filters the fibers were knocked off. Contaminated filters were also a possibility, Very little observable dust was noted on any of the filters except for the vermiculite test with the filters in the drop zone of the spreader. Twelve filters from the Marysville test and all but one filter in the California test have lower fiber counts than the blank filters. All fiber counts, except for the vermiculite portion of the test and one (1) Turf Builder filter from the Marysville test, are essentially the same as the check filters. This would indicate that except for the vermiculite portion of the test, no more fibers are obtained from product application than from simply running an empty spreader over an equivalent plot area for the same time period. ACKNOWLEDGEMENT: We would like to thank Chet Baker for his assistance in obtaining the Marysville site and in laying out the initial plots; Gene Moffett for his assistance in making the applications; and Dr. Hari Bhalla for his assist ance in the California portion of the test. SC DENH000296 TABLE I. PRODUCT APPLICATION TEST Product and Location Spreader 5M 10 M Fibers Fi bers/cc Fibers Fibers/cc Operator 5M 10 M Fibers Fibers/cc Fibers Fibers/cc Turf Builder Marysville 2769 6646 1661 0.13 0.27 0.067 2769 13292 2215 California 0 0 111 111 0.005 0 0 0 222 Turf Builder + 2 Marysville 554 1108 554 0.024 0.048 0.028 6646 554 1661 California 166 0.009 277 0 0 609 222 0.10 277 Check Marysville 3323 554 3323 0.15 0.026 0.17 1108 8851 2215 California 0 0 0 111 0.006 277 111 0.006 166 Vermiculite Marysville 31567 32675 26029 1.58 1.64 1.34 50951 24368 3544 Marysville Blank Filters 0 and 554 Fibers California Blank Filters 388 0.051 0.24 0.040 0.002 0 0.005 0.14 0.01 0.04 0.006 0.013 0.006 0.023 0.170 0.048 0 0.006 0.004 1.02 0.53 0.074 19383 0 554 166 111 0 1661 1661 4431 0 111 0 554 4431 554 55 55 55 2215 554 0 1.0 0 0.022 0.008 0.005 0 0.07 0.07 0.22 0 0.005 0 0.023 0.053 0.028 0.003 0.003 0.003 0.11 0.027 0 554 0 1661 111 55 166 0.012 0 0.037 0.002 0.001 0.004 2215 1108 554 0 0 55 0.047 0.021 0.014 0 0 0.001 554 554 1661 55 111 0 0.012 0.013 0.042 0.001 0.003 0 0 0 0 0 0 0 SC DENH000297 Marysville Field Data Date: October 10, 1977 Filter Numbers 7-297- Operation Spreader Filter Samp. # Run 1 Time (Min) Operator Samp. it Filter # Run Time (Min) Spreader Filter Samp.# // Run Time (Min) Operator Filter Samp. # # Run Time (Min) Remarks Soil Moisture medium, Foilage moist Soil Type - Loam Dry at end of test. 10:00 start 6 Check TB +2 - 1 4 2 14 1 8 14 1 3 14 5 14 4 2 6- 6 29 2 4 29.5 Wind calm to windy S.W. 7 . 29 Spreader setting #2 Approximately 2/3 thru first 5M went to #8 at 5M went to 9 at 7.5 went 11.5 TB + 2 - 2 4 11 14 1 10 14 6 9 33 2 12 33 Spreader setting 11.5 at 5M changed to 10.5 after 5M TB +2 - 3 6 12:45 stop 15 12 1 13 12 . 4 14 25 2 16 25 Spreader setting 10.5 14:10 Check 4 2:10 18 13 2 19 13 C-UO 17 26 1 20 26 Foilage dry - soil med. soil type loam. TB - 1 4 23 13 2 21 12 ' C-110 24 27 1 22 27 Spreader setting 2,5 to 10 5M to 10.5. TB - 2 4 28 15 2 25 15 C-110 26 28 1 27 28 Spreader setting 11.5 Windy from S.W, TB - 3 4 39 15 1 29 1.5 C-110 37 28 2 34 28 Spreader setting 11.5 5M to 11,0 Cloudy about 16:00 SC DENH000298 Marysville Field Data Date: October 10, 1977 Filter Numbers 7-297- Operation 5M Spreader Filter Run Samp, # #' Time (Min) Operator Filter Samp, # # Run Time (Kin.) Spreader Filter Samp.# 10M 1Run !Time (Min) Operator Filter Samp, # i # Run Time (Min) ' . Remarks Soil Moisture medium. Foliage moist Soil Type - Loam Dry at end of test. Check 16:25 4 Vermiculite 4 1 40 12 2 36 12 1 30 12 OllO 31 23 1 42 12 G-110 33 25 2 48 23 32 25 Verm, in fiber drums wind S.W. to calm Spreader setting 8 (Kwit) . . . Vermiculite 4 2 17:20 Verr.iiauli.te a 3 41 12 1 47 12 2 44 12 0-110 43 23 2 46 23 Verm, from #2 system feeder 7-272 11:30am. 45 12 0X10 35 24 1 . 38 24 End approximately 18:15 Filter No. 49 & 50 were blanks 8 MARYSVILLE FIELD DATA. Sampler Calibrations Date: October 10, 1977 Filter Numbers 7-297- Sampler # #2 #6 #4 #1 #3 Date 10-24-77 10-24-77 10-24-77 10-24-77 10-24-77 Flow Setting Sec/1000 ML In Line With tape 36,36,36 SXlFilter Set at tape to get 1.66 L.P.M. tape 38,38,38 8/L,Fiiter Set at tape to get 1.57 L.P.M. tape 35,35,35 8 X ^ 1 Iter Set at tape to get 1,7 L.P.M, tape 37,37,37 8/L(Filter Set at tape to get 1.62 L.P.M. tape 35,35,35 8/t^Filter Set at tape to get 1.7 L.P.M. SC DENH000300 CALIFORNIA FIELD DATA b Date: November 15, 1977 Filter Numbers 7-319- Operation Spreader Filter Samp.# # 5M_______________ ________ _______________ 10M Operator Spreader Run Filter Run Filter Run Tima Samp. # # Time Samp. # # Time (Min) (Min) (Min) Operator Filter Samp, # # . Run Time (Min) Remarks 7:40 a.m. * Check 4 2 10 6 4 10 C-110 1 21 1 3 21 Turf almost dry. TB + 2 8:15 a.m. #1 4 12 11 6 16 11 C-110 34 23 1 23 23 TB + 2 08:40 #2 4 21 12 6 10 12 C-110 36 23 1 9 23 TB + 2 09:05 #3 4 24 12 6 7 12 C-110 18 23 1 Dry turf, start 20 23 Dr. Cooper got sample. Check 09:30 Soil temp. 55 to 60c 4 25 11 6 27::. 11 C-110 33 22 1 ' 26 22 Air temp.82 to 84F. Turf Buil. 10:00 #1 4 T.3. 10:30 #2 4 Check 11:00 4 TB #3 * 22 12 6 13 12 6 28 .11 6 29 10 6 19 12 C-110 32 24 1 6 12 C-110 31 23 1 35 11 . C-110 11 21 1 5 10 C-110 15 22 1 R.H. 15 to 20% 17 24 C-110 sampler - filt 30 23 #31, hose was off er Wind - alight from 8 21 North 14 22 - 10 - CALIFORNIA FIELD DATA Sampler Calibrations Date: November 15, 1977 Filter Numbers 7-319- Sampler # C-UO #1 #2 #6 #4 Pate 11-14-77 11-14-77 11-14-77 11-14-77 11-14-77 Flow Setting; See/1000 HL In Line with tape 30,30,30 8 ^Filter Set at tape to get 2.0 L.P.M* tape 35,35,35 8/^Filter Set at tape to get 1.7 L.P.M. tape 37,37,37 8/WFilter Set at tape to get 1.62 L.P.M tape 37,37,37 8/{Filter Set at tape to get 1.62 L.P.M tape 35,36,36 8/6LFilter Set at tape to get 1.66 L.P.M SC DENH000302