Document mBpOd7po5vVr5E4pzn7BM59yO

REYNOLDS ALUMINUM REYNOLDS METALS COMPANY RICHMOND, VIRGINIA 23261 January 19, 1976 Roy F. Weston, Inc. Weston Way West Chester, PA 19380 Dear Sirs: I have reviewed Mr. Hebb's memo of December 23, 1975, and have also reviewed the questionnaire supplied by your organization regarding information concerning asbestos. I have partially filled out your questionnaire but do not find it suitable with regard to relating the uses of asbegjfcas in the aluminum indus try. We at Reynolds use a great deal of asbestos containing materials, such as marinite or marimett, in our molten metal transfer and casting operations. These materials are machined on a variety of equipment, usually of the W.W.II vintage. Hooding has been designed specifically for each of the various pieces of equipment, and local exhaust ventilation is supplied to this hooding usually be the means of a cyclone. We can presently meet the 5 fiber standard, but would have had difficulty meeting the 2 fiber standard. The possibility of us reducing our asbestos machining emissions to below the .5 fibers/cc would be extremely difficult and costly. It is my determination that if we at Reynolds were to attempt to meet the OSHA proposed standard, it would require the purchase of new machining equipment designed specifically for asbestos handling and machining. It would also require that a separate building be constructed in order to isolate such an operation. I should add here that marinite is machined into inserts, baffles, and gasket materials for use in molten metal casting operations. 002609 TXTINER RMC0086187 Roy F. Wes con, Inc. -2- January 19, 1976 As I understan i it, all aluminum casting operations require the use of marinit. inserts. There is at this point no known sub stitute for this item. Presently we at Reynolds machine such inserts in two of our plants and all other locations have this work done outside contract. If you need any further information regarding asbestos usage in our industry, please contact me instead of our plant locations. Sincerely, HMC/pcf enclosures Homer M. Cole Corporate Industrial Hygienist 002610 TX TIMER RMC0086198 f. fat 1. Li -VJ:/- ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 660 L Street, N.W / Washington, D C 20036 / (202) 223^1885 INDUS^PIAL' ':o H.M.C. R.E.B. I hope you have received my letter enclosing a memorandum from Guy G. Gabrieison, Jr. which outlines the Association's plan for an industry response to the pro posed revision of the OSHA asbestos standard. In my letter, I encouraged member ship in the Association to those of you not presently affiliated with AIA/NA. Whether you choose to join or not, we urge all recipients to participate in this industry-wide project and ask your consideration of financial support to help defray the expenses involved. AIA/NA has engaged the services of the highly reputable consulting firm Roy F. Weston, Inc. to gather information and prepare a report covering the technological feasibility and economic impact of the proposed OSHA standard. This proposed standard could, through the governmental law-making process, reduce the 8-hour time-weighted average exposure of 5 fibers/cc (2 fibers/cc as of July 1, 1976) to 0.5 fibers/cc. The study that Weston will make must be based on accurate information gathered from companies representing the various asbestos-using manufacturing processes within the industry. My letter has been sent to more than two hundred companies. We believe the effort we are making will benefit your company by helping to achieve a reasonable and realistic asbestos exposure standard in the workplace. Therefore, we ask that you provide the fullest cooperation and assist in the development of information essential to the study. Weston wilt contact you in the very near future to discuss the enclosed ques tionnaire. Depending upon the project schedule and your situation, Weston will: Set up an appointment for a plant site visit; or Record your input by telecon; or e Provide mailing instructions for your response. > 002611 TXTINER RMC0086199 As indicated in Mr. Robert Mereness' recent letter to you, Roy F. Weston, Inc. has been engaged by the Association to gather information and prepare a report on the technological feasibility and 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 of your company, and the industry as a whole, to parti cipate in achieving a reasonable Standard. Weston's plans are to contact you to discuss the attached questionnaire. Depending upon the project schedule (Weston's report will be issued to AIA/NA no later than 2 February 1976), a member of our project team will: Set up an appointment for a plant site visit, or Record your input by telecon, or Provide mailing instructions for your response. To assure confidential treatment of your input, the cover sheet of the questionnaire will be coded, detached from the questionnaire, and kept separate. The cover sheet and questionnaire will 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 plant, please duplicate the attached questionnaire. Very truly yours. JLH: jwg Attachment Jerry L. Hebb Manager, Occupational Health Management Department 002612 TXTINER RMC0086200 ASBESTOS INFORMATION ASSOC IATION/NORT^ AMERICA INDUSTRY gUESTlONNAIRE^1) Company Name D ' f \ r / f !' (<'<)'' , i ' .______ Plant Address _______' . > 1 ' i - ' > . ' ____________ Corporate Affiliation 1, i Name of Plant Contact 1 ` > * /- Title 1 1'. , Phone Number ( ) t> 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 Jlr. Jerry L. Hebb, Roy F. Weston, Inc., phone (215)692-3030. (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. CONFIDENTIAL Company Code # Plant Code # -1- 002613 TXTINER RMC0086201 I. General Product/Process Information 1. Which of the following industry segments best describes the asbestoscontaining products in your operations? (Check more than one, if appropriate). ____ Asbestos Cement Products (pipes, sheets, siding shingles) X Asbestos Paper Products (asbestos felts, latex sheets, underlay- ments, electrical and commercial papers) ____ Floor Tile ____ Coatings (roof coatings, caulks, sealants, paints, adhesives and undercoatings) ____ Friction Materials (automotive linings, disc components, blocks, clutch facings) X__ Gasket, Packing, Sealing Devices ____ Joint Cements ____ Asbestos Reinforced Plastics ____ Asbestos Textiles ____ Asbestos Drilling Muds ____ Asphaltic Paving ____ Distribution/Resale X Miscellaneous (Specify) ! >-r. < u.7 /f ~ 2. Which of the following categories best describes the operation at your plant? (Check more than one, if appropriate). a. ______ Manufacture a product where raw asbestos is used. What tonnage of raw asbestos do you use per year? b. X 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 Segment End Product(s) Annual Volume i. V ' ___________________ l-"-' ( CONFIDENTIAL Company Code # 2- Plant Code # 002614 TXTINER RMC0088202 4. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years: 1971 1972 1973 1974 1975 $ $ $ $ _________ . $_ 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 $ $ $ $ $ 6. What is the total jvl'^nt^ employment at this location? ,'J ; - I '> 1 u U > 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) __________________________________ ________________ b.)) Frequently in the work environment (maintenance, supervisory personnel) ______________________________________________ ___________________ c. Only occasionally (less than 5 times per week) in the work environment (management, engineers) ________________________________________________ _ d. Never or very infrequently enter the work environment (secretaries, sales personnel) _ 8. What unions (locals) represent your employees, if any? <\ r? \ -< v. iK' \v . i . ... ^ r . t11, a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? Active Area Extent of Activity (V--Very, M--Moderate, N--None) b. What is the current pay scale range of unionized personnel? CONFIDENTIAL Company Code # -3- Plant Code # 002615 TX TWER RMC0088203 rV7zrf~^r'-r\ u1^o)Li''vLaA. i i.* Control Technoloqy/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 descript ion(s). If additional space is needed, please attach extra sheets. 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 ^ No List control equipment in use: Step. Her ai a,r, Type of Equipment )>v t (* / i Date Installed t* l \ f . I i .I V- ; Vt 'll i ( t, 'hi h- 11. What .is the total cost of control equipment listed in Question 10? a-. Capital cost (installed) $ b. Operating cost (annual) $ (Mote: give horsepower, exhaust volume, etc., if operating costs are unknown.) c. What effect has this equipment had on your process, product or production rate? _________________________ _______________________________ CONFIDENTIAL Company Code # -4- Plant Code # 002616 TX TIMER RMC0086204 d. Did this equipment increase or decrease the plant/process energy requirements (electrical power, space heating, etc.)? Increase Decrease By how much? ' 12. What process modifications or work practice changes, if any, were instituted to reduce worker exposure to asbestos? ____ NT - l. MK r\\ Cf ' < I a. Capital Cost (installed) $ b. Operating Cost (annual) $ c. What effects have these process modifications or work practice changes had on your process, product, or production rate? _____ d. Did these process modifications or work practice changes increase or decrease the plant/process energy requirements? Increase _____ Decrease By how much? 13. Have the control equipment or work practice changes reduced air borne asbestos 1 eve 1 s in all of the work areas? Yes 'yC. No ^ List the ranges of asbestos fiber counts in the work areas involved: Work Area __________Range of Asbestos Fiber Counts Before Modifications/ After Modifications/ Changes Changes / >if ft r i>l /> ' 1 a..' , II j ^ l >\ sV > V > : ') </ < .J * 14. Have the control equipment or work practice changes reduced air- tlme-welghted average exposure to airborne asbestos in all of the work areas? Yes Y. No CONFIDENTIAL Company Code # -5- Plant Code # TXTINER RMC0086205 002617 Work Area Range of TWA Asbestos Fiber Counts Before Modifications/ After Modifications/ Changes_________________ _______ 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 step where asbestos is released into the work place, please go on to Part III; if not, please complete the following: 15. At each location where asbestos dust is released, do you feel you have installed the "Best Available Technology?" Yes _______ No Best Available Technology (BAT) 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 BAT 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). .$ (^ . v. ,lf , ' : .rV \ c Locations ' . U^ i i: .1 ,, , i . , , ' 1 -\BAT Estimated Asbestos Fibers/cc______ CONFIDENTIAL -6 TX TIMER RMC0086206 Company Code # Plant Code # 002618 17. What is the expected cost of 3AT in terms of: a. Capital Cost (installed) $ > j QG, Cf < . b_. Operating Cost (annual) $ c. Plant/Process Energy Requirements, Increase Decrease d. Personnel Requirements, Increase _________ e. Process/Product Effects, Increase $ ________ Decrease $ ____________________ Explain __________________________________________ f. By what date could BAT be implemented? Decrease 18. If the Best Available Technology does not reduce worker exposure to a TWA of 0.5 fibers/cc and a ceiling of 5 fibers/cc 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? 19. If the proposed 0.5 fibers/cc level Is adopted, what action is foreseen at your plant? 11 I .-/r j i i 11 1' l~ . u > It ! i r ' I -< 1 '' III. Industrial Hygiene and Health Information 20. The 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 data where available): Cost/ Total Yes No Man-Year Cost/Year a. Provide preplacement employee medical exams ? CL _______ too. O b. Prov i de annual employee medical exams? // c. Provide termination employee medical exams ? 'X ____ h < (t h IDENTIAL Company Code # -7- Plant Code # TXTINER RMC0086207 002619 w KI33 Yes No Cost/ Total Plant Man-Year Cos t/Year d. Retain medical records (20 year period)? e. Maintain records of employee exposure to asbestos fiber (3 year period)? * f. Dispose of waste materials which may contain asbestos in sealed containers? * g. Provide caution labels for all material containing un bound asbestos? h. Provide initial monitoring (sampling) of the work place for airborne asbestos? i. Provide periodic monitoring (sampling) of the work place for airborne asbestos? * 21. Certain provisions of the existing regulation require additional Indus trial hygiene practices where levels of airborne asbestos exceed TWA of ceiling standards. Where these requirements apply to your plant, do you: Cost/ Total Plant Yes No Man-Year Cost/Year a. dave a respirator program (for use in certain work situations or emergencies)? 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 cei1ing level)? d. Provide change rooms (where special clothing is required? 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)? CONFIDENTIAL Company Code # -8- Plant Code # TX TIMER RMC0086208 002(20 Y22. Do you employ a company physician? Yes No If yes: Full-Time Y ; Part-Time Part-Time hours/ week C-.I-5Q I | - -V < u>. iU . < 'C , 23. Do you employ an industrial hygienist? Yes If yes: FulI-Time XW-2) ; Part-T ime week (C-Ct yOxC^ti ) X />) No Part-Time hours/ 7T"s 24. 'Who performs your medical examinations (cl inic,(Resident phys iciary etc. 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 generaj, how do you believe your employee will react to such practices? V , f-i. /,, -------------------------------------------------------- ------------------------------ ---.------ ------ --. j 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 ^ No If yes, specify: Products Implementation Cost, $/Unit of Production Increase Decrease 27. Have you experienced a shift or change in product sales due to the cost Impact described in Question 26? Yes _______ No X CONFIDENTIAL Company Code # 9- Plant Code # txtiner RMC0086209 002621 a. If yes, specify: Products ___ _______ Sales Change, S/Year Increase Decrease b. If sales have decreased, has the demand been satisfied by: Yes Other Asbestos Products ___ Asbestos Substitute Products ___ Imported Asbestos Products ___ No __ __ __ 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 BAT control procedures and expanded industrial hygiene programs to affect the cost of your products? Yes _______ No If yes, specify: Products Implementation Cost. S/Unit of Production Increase Decrease CONFIDENTIAL Company Code # 10- Plant Code # txtiner RMC0086210 002622 \!Zi^u7d^] 29. Would you expect to experience a shift or change in product sales due to the cost impact described in Question 28? Yes _______ No a. If yes, specify: Products Sales Change, 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. Which 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 - ________ Typical Production Equipment Age. Years 0-5 5 - 15 15 - 25 2Jj+ ________ ________ y ______ 31. In your opinion, with the implementation of BAT 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). CONFIDENTIAL -11- Company Code # Plant Code # TXT1NER RMC0086211 002623 Less than 10% 10 - 25% 25 - 50% 50 - 75% Greater than 75% _____ ________ ________ ________ ________ 32. Within your community, which estimate besr describes the portion of the total work force employed at your plant? Less 10 25 .50 - than 25% 50% 75% 10% i UZ _____________ ___________ ___________ V. Information Regarding Manufacturers/Fabricators of Asbestos-Containing Products The proposed regulations apply to every place of employment where asbestos, or a product containing 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.)? 34. Describe how your products move from your plant through the final con sumer _________________ _______ 35. Estimate numbers of people and what levels of asbestos dust exposure, if any, may occur at each step (from further processing, fabrication, installation, etc.)? CONFIDENTIAL Company Code # 12- Plant Code # 002624 TX TIMER RMC0088212 36. Provide names of your customers and appropriate trade association so that Weston might obtain more comprehensive information in these areas CONFIDENTIAL -13- Company Code # Plant Code # 002625 TX TIMER RMC0086213