Document o9GzkbGYJ9R7kKKKy9jggvLx7

CONI-'iniiNTiAL / t memorandum TO: Mr Vining J, \`L WoIter R. L. Oliverio A, R. Cas^pbell FROM: H, A. Eschenbach cc: E. S. Wood DATE: July 20, 1978 SUBJECT: KLCB Radio Asbestos Inquiries Attached are the initial questions from the Libby radio station and proposed answers for than. Please review the answers and convey your thoughts to me as soon as possible so that our response will be reasonably expeditious. H. A. Eschenbach HAE'sg Attachment ^ ^'* '7^/s.".V;-prp ^r/'f **^ "7 DRAFT (3) Preface C(.- In any discussion of health problems with respect to mineral exposures, it is necessary to define certain of the technical terms in order to better understand the situation. Asbestos is defined by the Occupational Safety Health Administration (OSHA) to include six fibrous minerals. Chrysotile, commonly called commercial asbestos, has been and is the predominant form of asbestos used in the world. ,T : t' y The other forms of asbestos are tremolite, amosite, crocidolite, anthophyllite, and actinolite. Tremolite is not sold commercially but is a common contaminant of many other minerals including talc. f"ia Vermiculite is a plnty mineral which is considered to be ha "inert" ve*MA*rul' "e ''nuisance^dusi from a health viewpoint. This means that dt^has no known toxic properties as such, although as is the case with any airborne material, fy/r -<* `fo httxrtf it is wise to 1 fmi t thft tn the lvmg The health standards that apply to vermiculite are the same as those for starch, cellulose (paper), cement^and-* bther ftuiSonoo dusts; 1. A general review of the history of the operation with emphasis on the asbestos concentrations (air pollution). a .The mineral deposit called Vermiculite Mountain^ is a mixture^ ofj^rmiculite^ 7^// -- --------------------- --- -- - // and-tremolite and huTelso other minor mineral constituents^. Jsruas discovered during World War I when prospecting for strategic materials was at a high point. Initially thought to be purely a mineralogical curiosity, it was not f until the mid 1920's when its potential as an insulating material was re cognized. Several midwestem companies including Fischer Brothers of auto motive body fame and Armor Meat Packing became involved in early mining efforts. Mining was a summer activity until 1930. Two organizations, the Universal Insulation Company and The Zonolite Company survived until 1939 when they merged to become the Universal Zonolite Insulation Company with headquarters in Chicago. The name was shortened later to Zonolite. In 1963, Zonolite merged with what is now the Construction Products Division of W. R. Grace 6 Co ami Lite llfeaJquai ferslnovedto Cambridge, "Massachusettsr~ 2. When was it recognized that an asbestos problem existed at the Libby operation? In the late 1950's, the Zonolite management began to realize that a "dust" problem existed at Libby. While it was known that the tremolite form of asbestos was present, because of the primitive state of the science of industrial hygiene, and the universal lack of knowledge about the potential health hazards of tremolite and how to measure them, the Libby problem was v/' thought to be, similar to that of other mining farTM* --' (silicosis)- and .coal wining (blade lung):--Iw 1959. Several' ZUUUlile quuloyCtes \{ giwn n rhtrt y Pny--fflrilr n'f-nr nf fibrosis.' the medical term for scar tissue, were found in .some of these X-Rays, asbestosis or asSestos^related disease was-not diagnosed or mentioned in the reports. The X-Rays were re-^, pratrd in Infill afloi Mu fiHrr'nVTyrr-and-have been given nnnually since .then. In 1967, the United States Environmental Protection Agency (EPA) and the Montana Department of Environmental Control determined that there were excessive dust emissions from the Libby operations and began action to require reduction of those emissions. Their actions, however, were based upon general dust emissions rather than asbestos. In 1968, there was a worldwide explosion of interest in the health hazards associated with expo- *' ***`^1 * ''.i\ > * n. -3- CCIC7203 sure to asbestos. Research projects on chrysotile, which represents 95t of the asbestos used commercially, were started everywhere. It was generally believed that tremolite was far less hazardous than chrysotile and some of the other forms of asbestos, but since knowledge of the health aspects of tremolite was limited, precautionary action seemed prudent. At that time, the United States Public Health and the Montana Department of Public Health expressed concern about the tremolite -aslSeaifls at Libby, and Grace took the first steps to reduce both emissions and fiber levels and began searching " for ways to effectsdamaie^eductions. This effort continues-today.-- 3. Who recognized the problem first - local management, corporate managemoit, or was it a governmental agency? r ,, It is difficult to determine who first recognized that a Jigimicaul fiUei ` problem eAlsred kt-Libby. Obviously, the Montana pollution control agency's order to reduce emissions in 1967 caused Grace personnel at all levels to further evaluate the problem. ^ N--In 1968, reports published in scientific journals by doctors, epidemiologists, and industrial hygienists, which indicated that the health hazards associated with ^ asbestos were <er*more serious than previously believed, were beginning to appear almost daily. This caused ^great^acceleration of activity by the Bureau of Mines through its industrial hygiene service agency, the U.S. Public s Health Service, OHTManagement in Cambridge, the IGG Safely Department, and local management. In summary, it was known for years that there was tremolite asbestos at Libby. However, the knowledge that working with tremolite asbestos could be the source of a sig&iiisnt health problem for t^mTiiibby employees probably dates from this 1967-68 period and was recognized by several parties 1 *, -4-- '* CG1G72G4 at approximately the same time. The problem then was to determine what to do and how to do it. 4. Who solved the problem? Those people working back ''east" or local people? * yf* ~ ' ' It was not simply a matter of solving "a problem" but rather hundreds e-- ` perh^s-tliooSiuids uf- them. Some, required costly changes in equipment which involved approval of funds at Grace headquarters in New York, planning by CPD management and designing by engineering in Cambridge, and implementation by Libby management, engineering and maintenance. Other changes were devised and instituted locally. Such projects as air monitoring programs resulted from the efforts of the Bureau of Mines, the Montana Industrial Hygiene Department, ' r the Grace Health and Safety Department, as well as workers in Libby. In short,, there was no easy solution instituted by one person, but rather a series of steps on the part of^people nt many 1nrrt~r of Sfnto and Fed oral ncmrtrf, j Ini .il niri f.imni ulgr mihiignimil, jimI mil 1iifrr~iJii~Tniirrlr Tiilihy hosp^STT'^' r S. How long did it take to solve the problem? Evaluation of potential solutions began in 1968. While some of the less complex problems were solved at that time, it was realized by 1969 that nothing short of a new mill and screen plant could solve the environmental problems on a long-term basis. By early 1971, these facilities had been designed and financial approval obtained from the parent organization. In pressing to accelerate the imple mentation of solutions which seemed to work in the laboratory, unproven technology was introduced into the mill design which was not pilot-plant tested. This led to start-up difficulties and the need for extensive redesign and delays. V- ^ I . 1 * -5- CCiC.7205 After two startup attempts in 1973 and 1974, the mill became fully operational in 1976. During this time many other problems were eliminated and the workers protected by dust masks or other protective equipment. While the major problems were solved by the new mill in 1976, changes and improvements continue to be made as technology improves. 6. What actually was done to solve the asbestos problem? It is difficult to list all the things done to solve the problem. The approach basically was to reduce asbestos exposures to the lowest levels possible by engineering, work practices, and personal protective equipment ^ while monitoring~tniployeo hoalth to detect and- educating employees with respect to the hazards. A few specifies are: - s***?-^ a. Develop a wet process for separating vexmiculite from impurities. b. Design and construction of a new mill using the wet process. c. Design and construction of a new screen plant for sizing ore concentrate. d. Design and install air scrubbing systems at points where dry material is handled. Some of these are: (1) Head end of skip haul system. (2) Screen plant. (3) Inventory loading. (4) Inventory storage. e. Enclose cabs of all mobile equipment and install air conditioning and filtering systems. f. Install water injection systems on drilling equipment^ to roducc dustr:-- --Pave sex vice areas-tu i edneg^dast~~dnrl3fig' dry.geiigd. h. Establish an air sampling program on a continuing basis in all operations. 4.--Increase-oiling of UftpamTroads lo lulucc dusti j. Increase employee awareness of the tremolite problem. i i -6- i CG1G72C6 7. Where exactly is Grace today in Libby in regard to controlling its asbestos air pollution? At this point, with the exception of a very few jobs where technology does not exist to reduce exposures and where protective dust masks are still required, employee exposures are substantially below the current government safety standards j)f 5 fibors/cc. This has been confirmed by safety audits conducted by MSHA in October 197S, June 1976, and July 1977. Work is -- continuing to achieve even lower levels^ wherever--possible, and tha_seareh-- for hotter solutions is unending. Annual phyTfrnl rrrmmfll I juim mid Routine monitoring of employee exposures are conducted in compliance with government safety standards. 8. Roughly how many dollars have been spent in solving this air pollution problem? Approximately $15,000,000. has been spent on new or improved facilities. flnninll;i, -TA..$ 7hn, nnn <spta- in ripgrflTlTip Tha hSql voillonec programs. However, the question is not solely one of money. The philosophy has been that effective answers must be found. In short, if vermiculite cannot be mined safely tljaln it should not be mined at all. We obviously believe that we are mining it safely today. 9. Is W. R. Grace now finished with the correction of the problem? If not, what remains to be done? The major tasks have been completed, but we will continue to work on the problem until we are convinced that nothing more can be done and that we are providing the safest and healthiest workplace possible. In this regard. ' w^v '\ -7- 0G167207 several studies have shown that smokers are much more seriously affected by asbestos exposure than non-smokers. For this reason, we have encouraged our employees to stop smoking. A non-smoking rule is being considered during working hours on company property. Such a rule is now in effect for manage ment and supervisory personnel. We realize that some employees may choose to continue smoking during off-duty hours, but we hope they will think seriously about preserving their health and stop totally. 10. What is Grace's country-wide asbestos pollution problem? As in Libby, facilities throughout the United States comply with all present asbestos safety standards, and in most cases, with more stringent standards being proposed for the future. HAE:sg 7/20/78