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013413 ling Specialties Company ECtfNlCAL SERVICES DIVISION BARTLESVILLE, OKLAHOMA 74004 RECOMMENDED WORK PRACTICES fr FLOSAL DRILLING MUD ASBESTOS DRiSRaC DRiSPAC SUF CRLO DRISCOSE CMC SOITEX DESCO FlOSAL DIASEAL M DIACEL D DIACEL tWL DIACEL A *121 INTRODUCTION The following recommended work practices are intended as general guides respect ing the handling of Flosal drilling mud grade asbestos (hereafter referred to as DMA). We believe this booklet will be helpful to engineers, superintendents, contractors, foremen, and drilling crews in understanding and explaining such procedures. Field tests conducted to date indicate that the recommended work practices set forth in this booklet, if followed, should result in an employee's 8-hour time-weighted average (TWA) exposure being below 0.1 fibers per cubic centimeter (f/cc) of air. (Such exposure would be well below OSHA's currently prescribed limits of two fibers longer than five micrometers per cubic centi meter of air as an 8-hour TWA exposure and 10 fibers longer than five micrometers per cubic centimeter of air, as a ceiling concentration.) However, since field conditions do vary, these recommended work practices do not purport to be ex clusive, and adherence to these recommended work practices does not guarantee an exposure level (8-hour TWA) the same as that shown by the aforementioned field tests, nor compliance with applicable federal, state or local health and/ or safety laws or regulations. On October 11, 1978, OSHA issued Program Directive V300-16, which provides uniform inspection and compliance procedures for medical examination requirements of the asbestos standard. The principal actions taken by OSHA in this directive were to clarify the term "exposed to airborne concentrations of asbestos - fibers and to indicate the,scope and applicability of medical examination requirements under the asbestos standards as follows: a. The term "...exposed to airborne concentrations of asbestos fiber..." is administratively interpreted to mean "exposed to a minimum of 0.1 asbestos fibers longer than five micrometers per cubic centimeter of air..." b. Medical examinations will be required for any 7 to 8-hour TWA concentration of 0.1 f/cc, or for a greater concentration. ' We believe that if the following work practices are followed, one might reasonably expect 8-hour TWA exposure levels to be below those specified by OSHA Program Directive #300-16. If, however, there is reasonable cause to believe that air borne asbestos concentrations exceed 0.1 f/cc greater than five microns on an 8-hour TWA. basis, or have peak levels above 0.5 f/cc greater than five microns based on 15-minute sample periods, then the site should be monitored for airborne asbestos, and appropriate action taken as required by applicable safety or health laws and/ox. regulations. 013414 2- - PRODUCTS AND OPERATIONS DMA is furnished in flake form. . Operations to vhich these work practices apply include: . Shipping, receiving, handling, warehousing, and storage. Additions of DKA to the mud. Handling of empty sacks. . Disposing of empty sacks. ' Disposing of mud. ' SHIPPING, RECEIVING, HANDLING, WAREHOUSING, AND STORAGE DMA is furnished in loose or palletized sacks. (With palletized DKA, the pallets^-are sometimes shrink-wrapped.) The sealed, unopened sacks should he handled hy normal warehouse practices. Precautions must be taken if a sack is broken, torn or punctured. The sack should be sealed with heavy duty tape or placed in a slip-over sack (over-sized, open-mouthed bag) to prevent spillage. The slip-over sack should be securely sealed, preferably by a twist wire. Any spillage should be cleaned up with a vacuum sweeper equipped with a disposable bag. Unless additional protection is required under applicable federal or other regulations, a certified, reusable single-use air-purifying respirator should be worn by the person cleaning up. DO NOT BLOW MATERIAL WITH COMPRESSED AIR, NOR DRY-SWEEP. The material in broken or damaged sacks should be used first. In storing DMA, it is recommended that it be stacked no more than 10 sacks high. . ADDITIONS OF DMA TO THE MUD DMA should be added to the mud in the same manner as other dry mud additives. The DMA should be added directly to the mud system, preferably by emptying the sack at a uniform rate into the hopper of a cone-type jet mixer (eductor system. Figure 1). Other systems in use are also suitable for the addition of DMA, such as an eductor with suction hose attached to withdraw the DMA directly from the sack, or from a drum into which several sacks have been emptied (Figure 2). Care should be used in pouring the DMA into another container to reduce the amount of "fines" generated when air is displaced from the receiving hopper or drum. In adding DMA to the mud, it is a recommended practice to position oneself so that any air currents present are moving from the individual's back toward the receiving container, rather than blowing into the face. A light weight streamer Dr "air sock" above the hopper may be used to determine wind direction (Figure 3). 013415 -3 - HANDLING OF EMPTY SACKS . After a sack is emptied, it should he discarded in accordance with current Federal Regulations. Normally, sacks of all types should he carried away for disposal as soon as time permits. ... ... DISPOSING OF EMPTY SACKS -. When an adequate precipitator is attached to the incinerator, onshore hurial or incineration is the preferred method of disposing of empty DMA sacks from offshore sites. DO NOT BURN DMA SACKS WITHOUT A PRECIPITATOR. The empty sack should he accumulated in sealed impermeable hags until a sufficient number is on hand to require burning or hurial. ' It is preferable to bury empty DMA sacks onshore. DMA sacks are biodegradable An incinerator with an adequate precipitator can be used. DO NOT BURN DMA SACKS WITHOUT A PRECIPITATOR. '' DISPOSING OF MUD When a well is finished, there is usually little or no DMA left in the mud. Any accepted method of storing the mud for reuse, or disposing of it, can be used. . 013416 Texas EmPLOYeRS' insurance Associanon P.O.BOX 6000 I MIDLAND. TEXAS 79701 I MIDLAND AIR TERMINAL I TEL. 563-1590 November 13, 1979 Montello P. 0. Box 130 Sand Springs, Oklahoma 74083 Dear Sirs: As a safety engineer for an Industrial insurance carrier on a policyholder's oil well drilling rig I saw a number of sacks of your company's SUPER-VISBESTOS and read the warning sign you have on each sack of the material. Also noted was your offer to send for a copy of the field study on the safe use of asbestos in drilling operations. If I may, I would like to obtain a copy of the information in order that we may help our mutual customer see that he uses your product in the way that you recommend. Your help in providing the information will be greatly appreciated. Sincerely, EMPLOYERS INSURANCE OF TEXAS: vourwomo of mncnoH 013417 Texas EmPLOYBRS' insuRance Associanon P. 0. BOX 6000 I MIDLAND, TEXAS 79701 I MIDLAND AIR TERMINAL I TEL. 563-1590 November 13, 1979 Montello P. 0. Box 130 Sand Springs, Oklahoma 74083 Dear Sire: As a safety engineer for an industrial insurance carrier on a policyholder's oil well drilling rig I saw a number of sacks of your company's SUPER-V1SBEST0S and read the warning sign you have on each sack of the material. Also noted was your offer to send for a copy of the field study on the safe use of asbestos in drilling operations. If I may, I would like to obtain a copy of the information in order that we may help our mutual customer see that he uses your product in the way that you recommend. Your help in providing the Information will be greatly appreciated. Sincerely Rayburn H. Williams District Engineering Manager RHWrvw W. DOUGLAS BROWN District Engineer mPLOYMR CMUaiTV COAPORSTIOn nmovsns NaTtonaL mtunanea conponanon mPLOYens Nartonau ura mauaanea company 2520 Northwest Expressway / Oklahoma City / 946-0761 EMPLOYERS INSURANCE OF TEXAS: Texas Employers' Insurance Association | Employers Casualty Company | Employers National Insurance Company | Employers National Life Insurance Company montello 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-645-2396 March 27, 1979 013418 Mr. Jim Walker Louisiana Mud Company P. 0. Box 540 Crowley, Louisiana 70526 Dear Mr. Walker: Many thanks for your time by phone last week. We've enclosed a file folder containing monitoring results for the past several years covering the use of Super Visbestos. Please let us know if there are further questions. Mr. Walker, we appreciate your business very much. Please pass on my personal best regards to Ronald the next time you see him, and give us a call whenever we can be of service in any way. *j prAmal w M0I Kenneth N. Campbell KNCrkb Enel: (1) 4 V /^ Cdr ~~ 013419 tdJfl // /Tr^> Jf ^ / ?i5Jr - monteiio 6106 EAST 32ND PLACE. TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 April 27, 1978 013420 Mr. Robert Schneider Employer's Insurance of Wausau 4150 South Danville Suite #6 Abilene, Texas 79605 Dear Bob: Thanks for your call to us yesterday. As promised, we have enclosed a folder containing information about the use of asbestos in the drilling industry. We have also included copies of literature covering respirators. Please let us know if you have additional questions. ^CiA. ienneth N. Campbell KNC/jkp: enclosure monteHo 6106 EAST 32ND PLACE. TULSA. OKLAHOMA 7413S (918) 665-1170 / TWX 910445-2396 May 3, 1978 013421 Mr. Bill Schones United Well Fluid Service Company 249 Cherry Street Abilene. Texas 79605 Dear Bill: In a talk with Taylor Davis yesterday, he asked that we send you a folder of our OSHA information relative to Super Visbestos. We've enclosed one for your use. It is a compilation of the many field monitoring studies done over the years. All were carried on jointly with Union Carbide. Also included is a single page flyer, which points out some of the things which make drilling rig opera tions unique as a "workplace". Please let us know if you have any questions, and thanks for your interest. Sincerely, MONTELLO Kenneth N. Campbell KNC/jkp: enc (1) 4 montello 6106 EAST 32NO PLACE TULSA, OKLAHOMA 74135 (918) 685-1170 / TWX 910-845-2396 JUly 20, 1978 013422 Mr. Lloyd Smith Mud Supply Company P.0. Box 52866 Lafayette, Louisiana 70505 Dear Mr. Smith: We appreciate your call of earlier today regarding Super Visbestos. As promised, we have enclosed a file folder of monitoring information based upon the OSHA regulations. You will notice that all counts are well below the regulated limits. To our knowledge, there has never yet been a^OSHA citation in the drilling industry, which was supported by monitoring evidence of excessive air-entrained fibers. Medical evidence is largely composed of individual exposures to very high concentrations (beyond the present regulated limits), for prolonged periods of time (i.e. 10,20 and 30 years). As far as any short term effects, (a few days, weeks or months) there simply are none. The material has no acute toxicity. Again, thanks for your call. Please let us know whenever we can be of service in any way. Sincerely, MONTELLO, Inc. Kenneth N. Campbell KNC/jkp enc (folder) 013423 IMPORTANT MESSAGE FOR__________ /L*. --/ DATE. T.W 9:3^ P WHILE YOU WERE AWAY M_ OF_ ___dfyuZlD ______ ahuJL____ J&/a. zz&} PHONE No. AREA CoOoOtt MUMBfN ' ~ EXTENSION TELEPHONED CALLED TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL PLEASE CALL WILL CALL AGAIN RUSH MESSAGE . y... ...i.... ... ............................... .{Pr.'^z-t/r--tUrr-f/si ' r? i|%^----- signed^lCh+4------ ^ UTHO IN U. . A. TOM SOOt'P S # c/ ^ /r-7 , Sv S'-'* 77^ ? r (0 9r /-t J>S~C>/S7 013424 f '{/ // < fo/' l/fo y. / ^10 ' SSv-'fi X't/-^ -- ft/lA V U/-/*^ F#X /''t fy, /'/,,^e>0~/i t/ss- ____/surf/^ ^!r*'[^1. . / ( *montello 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 July 28, 1978 013425 Mr. Harry Pierce Employer's Insurance Company of Wausau 7700 Carpenter Freeway Dallas, Texas 75247 , Dear Mr. Pierce: Harry Wyatt has asked that we send you a folder of the several field monitoring reports on Super Visbestos. One is enclosed for your files. As you may be aware, Union Carbide is the manufacturer of the product, and all field testing has been in cooperation with them. Please let us know if there are further questions, or whenever we can be of service. Sincerely, MONTELLO, Inc. Kenneth N. Campbell KNC/jkp: enc 4 montello 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 November 28, 1978 013426 Mr. Frank V. Freeman Staff Drilling Engineer Delta Drilling Company P.0. Box 2012 Tyler, Texas 75710 Dear Mr. Freeman: We have your letter of November 22nd to our Mr. Johnson, requesting what we call our "OSHA file folder". One is enclosed for your use. It is composed of the results from field monitoring by Union Carbide. A comparative description of the "workplace" at the rig, and a recap of the monitoring data, are also included. We appreciate your interest in Super Visbestos, and hope you will contact us whenever we can be of service in any way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jkp: cc: Allen Johnson enc. Delta Drilling Gompany Box 2012 Telephone 214 523-1911 Tyler,Texas 75710 013427 November 22, 1978 Mr. Allen Johnson Montello, Inc. 6106 East 32 Place Tulsa, OK 74135 Dear Mr. Johnson: Montello's Technical Bulletin, August, 1973, mentions a study conducted on Super Visbestos^pto determine compliance with OSHA regulations on asbestos concentrations. If pos sible, I would appreciate receiving a copy of this study. Thank you for your assistance. Sincerely, Frank V. Freeman Staff Drilling Engineer kew # & Product Bulletin 1/77 013428 The purpose of this bulletin is to provide certain background in formation on the use of Super Visbestos in the drilling industry. Existing OSHA regulations cover all commercial applications of asbestos. A reading of these regulations makes it appear that the total range of workplace environments was intended. A more careful study, however, enables us to characterize the concept of "workplace" in some detail. Implicit are the assumptions of fixed places of employment; of regular, day-to-day exposure; of exposure on essentially a full shift basis; of comparatively large .asbestos-tonnages-being., involved; -of. specific, individuals-----being exposed with little relief; of enclosed or nearly enclosed work spaces. Even in those references to irregular workplaces, such as in construction, the inference is of specific workers, exposed for nearly a full shift, on a day-to-day basis, in at least partially enclosed surroundings. Exposure to asbestos in the drilling industry is of a substantially different type. Asbestos is added to the drilling fluid through a mud hopper. Venturi action of the fluid rushing through the bottom of this hopper creates a suction, which pulls the dry product into the liquid stream. Additions to the system are made only occasionally, typically occuring no more often than once per shift. The amounts added are small, rarely exceeding 500 pounds at a time. With three eight hour shifts per day and eight to ten men per shift, assignments are exchanged frequently, with the same worker rarely performing the job of adding materials for more than a few shifts and then only for a#small part of the shift. Dumping rates are slow, averaging an hour or so for 500 pounds. In dumping, the worker cuts the end of the 50 pound bag and allows the asbestos to fall into the suction 'end of the hop per, where the material becomes part of the liquid drilling fluid seconds later. The hopper itself is typically located in the open. (Continued on other side --) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 . A totally enclosed mixing area is a rare exception. 013429 With enactment of the regulations in 1972, Union Carbide Corpo ration and Montello, Inc. began a series of drillsite monitoring tests, in accordance with the procedures established by OSHA. A substantial body of data has been accumulated from all parts of the U.S. Many different locations (including rigs and warehouses) have been evaluated, and we believe the widely varying conditions inherent in the drilling industry have been fairly included. The results show a consistent pattern of readings which are sub stantially below both the maximum ceiling limit (10 fibers/cc >5p and the time weighted average (2 fibers/cc >5p) prescribed in the regulations. In more than 4 years since the asbestos regulations became law, we have no knowledge of any OSHA citation having been issued, based on corroborating monitoring data to establish the existence of excess air-borne fiber concentrations. In fact, where such tests have been run by compliance officers, no basis has been found for citation. (In September of 1974, a compliance office for the State of Utah carried on field monitoring tests at one of our cus tomer's locations. After analysis, a ruling of "In Compliance" was handed down.) - In addition to the continuing program of field monitoring, Union Carbide and Montello are carrying on basic research with the aim of improving both the cleanliness and the field performance of Super Visbestos. Outgrowths of this research are the high density, crushed pellet form of the product; and the introduction of indi vidually shrink filmed bags to minimize handling and storage prob lems. With Union Carbide, we will continue to work toward the s-- highest possible standards of quality and safety. 013430 August 23, 1977 Hr. Preston Champagne Loffland Brothers Company P. 0. Box 459 New Iberia, Louisiana 70560 Dear Mr. Champagne: Thank you for your time by phone earlier today. As promised, we have enclosed a folder of Information regarding field monitoring on our pro duct, Super Visbestos. We hope you will find It useful. Please let us know if we can be of further assistance. We'll be happy to answer any questions which may come up. Sincerely, H0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. . BOX 130, SAND SPRINGS, OKLAHOMA 74063 /{918)-245-6661/TWX 910-840-3007 ///'<? y --' ' (<~ <-/? -z/q //<&> 9 >yj -/.' yy ^vA> * y - d'^/'.j* <? z. w /;/ ^ y/ 7V(;^ /<y'vy/^? r)yy?_j. y y/ ^<7 '/yy b //* ?j% - ^r -z^/^/ ^ ^// j>y/ re^rn & e? *=/-^ht k? y j +&'/x ^OyiSJ^/ 013432 January 5, 1977 Mr. Robert Hailey Texland Drilling Corporation P. 0. Box 3037 Abilene, Texas 79604 Dear Mr. Hailey: Please refer to our recent phone conversation about the field moni toring tests on Super Visbestos. After the individual reports, we felt it might be useful to collect all the scattered data into a single recap format. We also prepared an updated bulletin giving general background on the use of Super Visbestos in the drilling industry. We hope you will find the contents of this updated pre sentation both helpful and informational. A second folder is enclosed for your lawyer, as requested. Under separate cover we have also sent a copy to Mr. Don Dyer of Safety Consultants in Odessa. We have spoken with our Union Carbide people in Niagara Falls about the possibility of initiating a field monitor ing series in your area of activity, as soon as practical. As al ways, they are pleased to cooperate and we plan to coordinate the "whens and wheres" with Mr. Dyer. Will keep you advised as the program develops. Thanks for your continuing interest in Super Visbestos. Please let us know whenever we can be of service in any way. Sincerely, MONTELLO, INC. Kenneth N. Campbell , KNC/jd Enc. (2) P.S. We have received the citation copy you mailed, and appreci ate having it. UtonteUo P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918J-245-6661/TWX 910-840-3007 013433 January 5, 1977 Mr. Don Dyer Safety Consultants, Inc. P. 0. Box 6564 Odessa, Texas 79762 Dear Mr. Dyer: We spoke to Mr. Robert Hailey of Texland Drilling recently, about the OSHA regulations on asbestos. He suggested that we send you a duplicate of information which we furnished him. The presentation is enclosed. We hope you will find it both informational and help ful. We have spoken to our people with Union Carbide in Niagara Falls about the possibility of initiating a series of monitoring tests in West Texas, as a part of our ongoing program. Mr. Hailey had in dicated his interest and willingness to cooperate in such a series, assuming a convenient time frame could be established. Is it poss ible that you might have other clients who would be similarly in terested? Depending upon the distance between locations, it is generally poss ible to run two or three monitoring tests per day. The series are generally designed to last about three days. Union Carbide furnishes the professional person and equipment to perform the tests. They also do the phase contrast counting on the resulting samples. Re ports are prepared for each location, and copies forwarded to all participants. We will take the liberty of contacting you shortly, in the hope that some one with your company might be willing to assist in working out the logistics for such a series. In the meantime, please let us know whenever we can be of any help. 4 Sincerely, MONTELLO, INC. Kenneth N. Campbell P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013434 January 5, 1977 Mr. Van Harry Loffland Brothers Company P. 0. Box 459 New Iberia, Louisiana 70560 Dear Mr. Harry: Please refer to our recent phone conversation about the OSHA regulations on asbestos, and our product Super Visbestos. After gathering the individual reports, we felt it might be useful to collect all the scattered data into a single recap format. We also prepared an updated bulletin giving what we hope will be a useful "overall" view of Super Visbestos in the drilling industry. All this is in the enclosed file folder. As requested, we have also included a half dozen extra business cards, along with the disposable respirator information dis cussed. We will be happy to supply extra copies of any or all of the enclosures. Many thanks for your interest in our pro ducts, and please let us know whenever we can be of further service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd c^ Vcc:: Mr.t lUa Charlie Reeves Enc. (3) P.O. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013435 January 5, 1977 Hr. Leo Dean Sharp Drilling Company First National Bank Building Midland, Texas 79701 Dear Mr. Dean: Hr. Bud Tucker called us recently and asked that we send you information on Super Visbestos, in the context of the OSHA regulations which cover asbestos. The enclosed file folder contains an updated presentation of this data. We hope you will find it useful and informative. At Bud's request, we've sent a duplicate to Mr. Leroy Cargile. Many thanks for your interest in our products. Please let us know whenever we can be of service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) & montello i 013436 January 5, 1977 Mr. Leroy Cargile Sharp Drilling Company P. 0. Box 182 Stanton, Texas 79782 Dear Mr. Cargile: Mr. Bud Tucker phoned us recently and asked that we send infor mation to you on Super Visbestos in the context of the OSHA regulations covering the use of asbestos. This information is enclosed. We hope you'll find it helpful. At Bud's re quest, we've sent the same presentation to Mr. Leo Dean in Midland. We appreciate your interest in our products, and hope you will contact us whenever we can be of service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013437 January 5, 1977 Mr. Taylor Davis American Mud Company P. 0. Box 555 Abilene, Texas 79604 Dear Taylor: We spoke to Bob Hailey earlier about the OSHA/Super Visbestos matter. Our form of presentation has been brought up to date, and we've sent him copies. At his request, we've also copied Don Dyer of Safety Consultants in Odessa with the same presen tation. Enclosed is a similar copy for your files. We're working out a program to carry on a series of field monitoring tests in West Texas soon. Will keep you advised as the plans take shape. Best regards, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) montelo P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013438 January 5, 1977 Mr. Bud Tucker 3710 Stanolind St. Midland, Texas 79701 Dear Bud: Many thanks for your call the other day. We've updated our presentation on the OSHA matter, and have sent copies to Mr. Leo Dean and Mr. Leroy Cargile of Sharp Drilling. As requested, we're enclosing two copies for your use. We appreciate your help on this one. Please let us know when ever we can help. Best regards, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (2) UtonCelo (fhck-t'/'s ~t>/ r- 013439 J* " ~0 mrftr. 0el-fr-Z //*//ey ------------ - ^ 7~>x/fit r-r / P/--7/7a 0{? X cir> ZD. gpx 303 7 t!J tn6i~>. tv/" >// cc e/ C'fafTph 77**1 " 7 9607 ^ CH/5p /-- f * isfls/r'. jO0> 7t / r~ q/r+tti-/*> 5c\ft/'y C#r^ /7*y^r /V, -2/7 c,. / cor-, SO. yox o<r&</ fic/est*; 77^/?^ 7976^ @).<r$ t/-,a/ J-/n^4 r<` V/^ 7' t>< 7# t/ 7,r- Ac s-'f, /?<> ''//&/**-(; T'-fX?" ~?96# ()'^/fn j/* r~i //* '4 fttr* cfj* /? fi, f SpK t/S'tf >r;rhr- tL,sr /(//^ jrj.ff'/*, 7a. {3*'// 7&r 7l) Lt> 0/4 nS ZhtZZs 70^60 < "t*, /* flfr. 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A A Ao >ps*<A HS * cpy-Pj c/,^.>*f COh Stffhft/ yd/~ d > AS' P P. A-. '/'ft/ ^ A/ /n S p-- f Mr. P/o J-rsA S, 013442 A / S~~P P d/y -- pPP/ PA y^iy-P f P A PP s~//p ft rPo, r~? cP PP? { C/o c A l/($e A l//f (Pf-r As /e, Ai? IS SS~< ^ fi H /n 4 / Pf4/- r / tS C d Id r'A A-7 (-1 -t 4 ^ 0>' 11 S s'/ft, C(9r? Z'ft? Cud TT^cdfr^ ( 77# 77* </ A/y #/ s!i//s. s' A a r~y^ >s^/ /A s>^r C&, 013443 ^ -e <? , fiiyf- 'yt> , ~ f /~"<^ Lf Oft / '^ / /-f /S! ^*>' /*) > "A>' 'JC / $z 5 '/'ft s-r r+ /->s S ~?9 72 ^ /r//// jta ^ A #/</?. /A/,Al*r7</ S'Ca/ st ^ &ISi (/ <5 A y</rSS2. (p ? ? A /0 $ y& h 0 // /-* <7 P/r , Ar-cy, (, - i $/ 7/) ~ .^7a t k* r~ m // $:ffr & TXm/-. ft* ** (?) *// *As* #//*/-St* - /.V/* A+** & l4t 0hu L '/r* tk $$U 9 07< * *\ " ^////*# Af ^0 c'f * fc///Ar^<y CK^T*%f, />/* tm/f* ~ . f 4 0 /*A^ A //? s>) 013444 !// $/7> -7 from the desk of ... Ken Campbell 77^ /S/c 0e//u^7 pp. /m Q</tst*/ T'-O'c* f Qch6H/V, u). t/err^ ? -C h /- 7^t> //<r A- m /( - (Jay m monteio P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 013445 January 14, 1977 Mr. Rob Moseley Petroleum & Minerals Group Safety and Environmental Control Dresser Industries, Inc. P. 0. Box 6504 Houston, Texas 77005 Dear Rob: Enclosed are copies of letters just sent to two of your people in Iran. We sent them the updated package of information on our 0SHA files. I've also enclosed two copies for you, since they include some new informa tion. We always appreciate the opportunity to work with you, Rob. Please give us a call whenever we can be of service. Best regards, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (4) 013446 April 25, 1977 Mr. George Ross, Drilling Superintendent Amoco Production Company P. 0. Box 3092 Houston, Texas 77001 Dear Mr. Ross: We spoke earlier today with Mr. A. R. Reed, and he has asked that we contact you directly. One of the products which we distribute is Super Visbestos. This asbestos product is manufactured to our specifications by Union Carbide Corporation. Super Visbestos has been widely used for many years as a mechani cal viscosifier for drilling fluids. 0SHA regulations covering the use of asbestos, were enacted back in 1972. Since that time Ucar and Montello have joined in a continuing program of field monitoring to establish a data base Indicative of the air entrained fiber counts associated with the use of Super Visbestos in drilling fluids. We have enclosed a folder containing the results of this continuing program. We make this information freely available to all interested parties, including operators, contractors, service companies and 0SHA personnel. The presentation has been useful in demonstrating the relatively low exposure levels inherent in the drilling industry. We and Ucar would welcome the opportunity to discuss this matter with you or your people further. Please feel free to contact us on this, or any of our many other products, whenever we can be of service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) P.O. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /(918J-245-6661/TWX 910-840-3007 tllp? ; .Sfc*$fr-i<rco -jftis. 013447 ^ f/iWdl tH~/*a//// (// /if'/-,' /<t ? f/iT7fiiOfcrn ' (ao / . /r~> JT> Jfie f#/ /rtrt,orto - /Aeu ffi "P- 'i/, A~fiv- M?/- y'/ r 9 "/t/p Atfir-e AfJ'P/d'f 9au$ - fit Cfc it (-7 1 'du r cJ< y*?n. atQta ,X J( C \ foifts- cuf- k. v),a^ Hl(th h<r P.'scmf' j^>ac Jc eyy /~Q $. I 4 / f-r-1 fi H A- ,j OO.Tf'x. vjas /*(/ *rp' c/ey-i fihi 8 tP u'd S j-^ A' ' Pvt '' iaJ(h// J> ^TTTWpTjt fa* Uon&t /-d m/^y /A MjTTk^ ~7AAfi/ (-/'A(/ e t-r<!\ V **?>r ,/,/( fi/p r/pI'k 'j*r-*( f tore q 00 (/ dXP'fir 0 i>/r t * /Ant pfiAfiJv/^=v' ^V^,v ^ ( / ' K ' - 't ' ' . / yrt r adm- fl/Wrf /^^fc/i4(//t/ m / fi) 77T< ukd h /// / -e *- JL /act fie i <^r ' 0, -e,--e<k (Par- J>-0/p ^ a ^s.'c/ p/if // /P fats /'o S' rr'fi/t-t/'/c /** (/ >'</ f-rt)/^ f. 013448 March 28, 1977 Mr. Joe Henderson Southwest Drilling Mud, Inc. P. 0. Box 2477 Midland, Texas 79702 Dear Joe: Harry asked that we send you five copies of our current information fol der relative to the OSHA asbestos regulations. We understand you plan to pass them on to those who cooperated in the most recent monitoring tests. Please accept and extend our most sincere thanks for all the help. The requested copies are enclosed for your use. Please call us whenever we can be of assistance in any way. Best regards, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (5) - OSHA Folders P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918b245-6661/TWX 910-840-3007 013449 March 29, 1977 Mr. Cack Roller Well Fluids 3000 West Kentucky Midland, Texas 79701 Dear Mr. Roller: Harry has asked that we send you five copies of our most recent folder covering Super Visbestos and the 0SHA regulations. They are enclosed, and we hope you will find them useful. We appreciate your continuing interest in our products. Please let us know whenever we can be of service in any way. Sincerely, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (5) 0SHA Folders uTtontelo P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013450 March 18, 1977 Mr. Taylor Davis American Mud Company P. 0. Box 555 Abilene, Texas 79604 Dear Taylor: Appreciate the time by phone earlier today. As promised, we've sent you five copies of the updated OSHA presentation. Understand you will distribute some of them to the appropriate participants in the recent test program. Taylor, we appreciate your help on this. Please let us know if you need any further copies. Best regards, M0NTELL0, INC. Kenneth N. Campbell KNC/jd P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013451 March 17, 1977 Mr. Leo Dean Sharp Drilling Company First National Bank Building Midland, Texas 79701 Dear Mr. Dean: Since our communication with you in early January, a series of field monitoring tests has been completed in the Permian Basin covering the use of our Super Visbestos. This new information has been included in our current information folder. A copy is enclosed for your consider ation. We appreciate your continuing interest in our products, and hope you will contact us whenever we can be of service. We have taken the liberty of sending the same updated folder to Mr. Leroy Cargile, and to our mu tual friend Mr. Bud Tucker. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) p P1 Lit i u lJ i U A P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013452 March 17, 1977 Mr. Don Dyer Safety Consultants, Inc. P. 0. Box 6564 Odessa, Texas 79762 Dear Don: The results of the recent field monitoring tests on Super Visbestos in the Permian Basin have now been incorporated into our regular informa tion folder. We've enclosed a copy for your use. Special thanks to you for your help in organizing this program. After your talk with Mr. John Taff of the Lubbock Area OSHA office, he called us to ask for a copy of our presentation. We were delighted to cooper ate with him, and have filled his request. He seemed very impressed with the low fiber counts typical of our applications, and indicated a desire to help in establishing a better educated, more consistent and rational approach to the matter of field compliance. We sincerely hope this will be the result. Will appreciate hearing from you if you detect any signs of improvement in relations with Mr. Taff and the other compliance offi cers. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) P.O. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013453 March 17, 1977 Mr. Robert Hailey Texland Drilling Corporation P. 0. Box 3037 Abilene, Texas 79604 Dear Mr. Hailey: Since our last mailing to you in early January, a series of field monitor ing tests has been run in the Permian Basin involving our Super Visbestos. This program was due in no small way to your help in getting us with Mr. Don Dyer of Safety Consultants in Odessa. We appreciate your cooperation very much, and have enclosed a newly up dated folder, which includes the results from the testing program. Please let us know whenever we can be of any assistance, and accept our thanks for your continuing interest in our products. Sincerely, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /{918)-245-6661/TWX 910-840-3007 013454 March 17, 1977 Mr. Leroy Cargile Sharp Drilling Company P. 0. Box 182 Stanton, Texas 79782 Dear Mr. Cargile: Since our mailing to you in early January, a series of field monitoring tests has been run on Super Visbestos in the Permian Basin. We've en closed a copy of our OSHA information folder, which has been updated to include this new data. We appreciate your continuing interest in our products, and hope you will call us whenever we can be of service. We've taken the liberty of sending the same updated folder to Mr. Leo Dean and to our mutual friend Mr. Bud Tucker. Sincerely, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (1) -v N f "Y H \ - . ' P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 March 17, 1977 Mr. Bud Tucker 3710 Standind Street Midland, Texas 79701 Dear Bud: Since writing you last January, we've completed a number of field moni toring tests on Super Visbestos in the Permian Basin. Our presentation folder has been updated to include these new results, and we've enclosed a copy for your use. Also took the liberty of sending the new folder to Mr. Leo Dean and Mr. Leroy Cargile of Sharp Drilling. Please let us know any time we can be of service. Best regards, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 01345G March 17, 1977 Mr. B. C. Davis 2724 St. Nick New Orleans, Louisiana 70114 Dear Mr. Davis: Our representative in your area is Mr. Charlie Reeves. He has asked that we send you an updated file from our growing OSHA records. It is enclosed for your use. Please contact Charlie, or our office whenever we can be of ser vice in any way. Many thanks for your interest. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd cc: Mr. Charlie Reeves Enc. (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 fA ^4/ A/ >r r-uJc,^ >r-J77?& c* tf ^tk /4 t<#/ / ' r^ SfAA7 AAf ^/7S yj AA/fftfCtC4j } (@ //**4 r/ /-n5?0134 r J / '0 9(Th*! US *' 1 i' B, J7 <> ^/S C <h L*^a~ -0 jl*___ _____ /->11 * ' 4/J (7 f'trtr't] ' * ^/ y r r *---r/ ^ 1/ / rVyf, c^V/ pa ft tn /"X^- -'7 A/r Mv5S-/1 ^ Oh P, i^fu//<, 9'S'-0M) Br-- JS> - yj 01345 May 23, 1977 Mr. Chester D. Mouser OSHA Area Office 1425 West Pioneer Drive Central Place Building Suite 230 Irving, Texas 75061 Dear Mr. Mouser: Thank you for your time by telephone earlier today. As promised, we have enclosed a file folder containing the results of monitoring tests run during the past several years. We hope you will find it of inter est. Please let us know if we can be of further service. Sincerely, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (1) 013459 May 25, 1977 Dr. Harrison B. Rhodes Union Carbide Corporation P. 0. Box 579 Niagara Falls, New York 14302 Dear Harry: Here is a copy for your files of the communication just received from Tryon Lewis. In spite of the fact that the citation was a direct quote from the regs on disposal, they apparently didn't think they would pre vail. The question of course, is "why". Perhaps it was lack of docu mentation. I've talked with Mr. Mouser, of the Ft. Worth area office, as promised. He seemed pleased with our offer of the field monitoring file folder, and a copy of our short cover letter is enclosed. Plan to follow up with him in about 10 days to go over the point where shrink filmed bags came on the scene. Best regards to all, M0NTELL0, INC. Kenneth N. Campbell KNC/jd Enc. (2) nteio P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 ' air monitoring results DURING USE OF "UNIVIS" (AN OIL-WETTED ASBESTOS PRODUCT) December 7, 1979 013460 This report provides a brief sunmary of the overall results from several drilling sites. A copy of the full report is available upon request. PLEASE NOTE: The companies which cooperated in the tests discussed herein are customers of Montello, Inc. and permitted such tests in order to ascertain whether their use of UNIVIS complies with Federal Occupational Safety and Health Act regulations. Results of these tests are made ' available to other companies solely for their use in making their own evaluations of the appropriate procedures to be followed in using UNIVIS. SAMPLES VJERE COLLECTED AND EVALUATED By F. L. Smith & B. L. Ingalls of UNION CARBIDE CORPORATION Metals Division Niagara Falls, New York INTRODUCTION 013461 This report is a brief summary of two separate air monitoring test series conducted during the use of UNIVIS. UNIVIS is an oil-wetted pelletized asbestos product developed to minimize airborne dust during its use as a viscosifier in drilling fluids. The tests were conducted to determine the effectiveness of the oil treatment in reducing dust. Test Series I involved seven different drilling sites and was conducted to determine the amount of airborne fibers generated under varying weather and other external conditions. Test Series II involved only one drill site but under extended conditions where asbestos was used on a daily basis. The conditions under which the tests were conducted are described in the following reports. The airborne asbestos fiber counts reported are not necessarily representative of those which may be found at different locations or under different conditions. Anyone using UNIVIS or any other asbestos product should be aware of the health and safety problems associated with asbestos and with pertinent regulatory requirements. Appropriate literature and other materials concerning the above are available upon request. DISCUSSION The results of two separate series of air monitoring tests during the use of UNIVIS are discussed in this report. All tests to date have shown that the proper use of an oil-wetted pellet can result in extremely low airborne emis sions of asbestos fiber. Air monitoring was conducted prior to any use of UNIVIS or other asbestos product to determine a "background" level of fibers. Based on the test data before and during the use of UNIVIS and considering the limitations of the overall test procedure, it appears that airborne fiber levels during the use of UNIVIS are essentially indistinguishable from background. TEST SERIES I Environmental and personal airborne samples were obtained at seven drilling sites located in the area of Graham, Texas, during the period June 11-22, 1979. Samples were collected at each location on the day prior to using UNIVIS and no asbestos was handled on the sites during the pre-control days. These samples were obtained in continuous sequence for durations of 2-1/2 to 5 hours. Sampling on days when UNIVIS was used represented the major portion of an 8-hour work shift. Weather conditions were hot and humid with winds of 5 to 20 mph. Rigs were operating at depths up to 4000 Jfeet. Of nearly 250 samples evaluated, the highest ceiling value during the handling and dumping of UNIVIS was 0.186 fibers/cc of air; although a higher count, 0.307 f/cc, was obtained on a personal sample prior to dumping. All other ceiling values were below 0.1 f/cc, except for one pre-control day count of 0.143, f/cc. 2- - 01346 Although ceiling value measurements are necessary for regulatory compliance, time-weighted average (TWA) 'exposures to asbestos fibers are more pertinent for safety and health considerations. The following table summarizes and compares the TV/A values measured the day before and during the use of UNIVIS: SUMMARY OF TIME-WEIGHTED AVERAGES location Sample Type Henrietta Personal Environmental Jacksboro Personal Environmental Graham #1 Personal Environmental Graham #2 Personal Environmental Newport Personal Environmental Caddo Personal Environmental Cundiff Personal * Environmental CALCULATED TV/A, f/cc Day prior to Day of use Use of UNIVIS of UNIVIS 0.041 0.0-0.009 0.028 0.007-0.010 0.023 0.003-0.009 0.043 0.002-0.005 0.002 0.0-0.004 0.008 0.008-0.013 0.010 0.0-0.006 0.005 0.004-0.017 0.004 ' 0.012-0.019 0.010 0.010 0.013 0.003-0.008 0.006 0.006-0.013 0.009 0.0-0.005 0.009 0.002-0.005 The highest personal TWA during the use of UNIV1S was 0.043 f/cc and the range was 0.005 to 0.043. The range during pre-control days was 0.002 to 0.041. Considering the limitations of the tests, there was little or no difference in the results. . During this test series, a significant number of samples were found to contain fibrous materials other than asbestos, the majority of which were organic. In most instances the extraneous fiber was readily distinguishable from chrysotile and excluded from counting. However, some fibrous material exhibited properties sufficiently similar to chrysotile that it could be counted as such, particularly by an inexperienced microscopist. To avoid any confusion, two distinct categories of fiber were counted: that which, in the operator's opirpon, was chrysotile, and "other fiber" that was similar enough that it might be counted as chrysotile. (None of the fiber counted as "other fiber" was considered to be chrysotile by the microscopist.) * 013463 Several of the samples were*also observed with polarized light to enhance detec tion accuracy. Ir. the writers' opinion, a considerable amount of the chrysotile fiber counts reported are not in fact chrysotile. However, it is virtually impossible to make any definitive analytical judgment based soley on phase contrast counting techniques. As such, the chrysotile counts reported are most likely higher than actual fiber concentrations existing at the time of tests. This is further substantiated by comparison of TWA results obtained on pre control and trial days. The mean values for TllA's based on the total fiber counts (chrysotile plus "other fiber") obtained at the seven test sites are shown in the next Table. As illustrated, there is essentially no difference in the overall fiber counts between precontrol and trial days. MEAN VALUES OF TVJA's OBTAINED AT THE SEVEN TEST SITES BASED ON TOTAL FIBER COUNTS (CHRYSOTILE PLUS' OTHER FIBER) (TTberiTcc) Environmental Precontrol Trial 0.075 *(.020-.332) 0.070 (.017-.184) 0.021 (.007-.040) 0.025 (.014-.042) (Minimum-maximum range of^FWA's) TEST SERIES II During the week of September 16, 1979, air monitoring was performed at a single drilling site in Andrews County, Texas. The purpose of these tests was.to determine the airborne asbestos concentrations over an extended period while UNIVIS was being used on a daily basis. Air samples were collected prior to the use of UN IVIS to determine background data. The highest ceiling value during the handling and dumping of UNIVIS was 0.103 fibers/cc of air; although a higher count, 0.144 fibers/cc, was obtained on a personal sample prior to bag dumping. All other counts were below 0.1 fibers/cc. The following table compares the time-weighted average (TWA) exposures on the pre-control day with data for the five days on which UNIVIS was used: Day 9/17/79 9/18/79 9/19/79 9/20/79 9/21/79 -4- SUMMARY OF TIME-WEIGHTED AVERAGES * Pounds of UNIVIS Added None 200 250 250 250 Type Sample Personal Environmental Personal Environmental Personal Environmental Personal Environmental Personal Environmental 013464 TWA, f/cc 0.019 0.0 0.019 0.005 0.016 0.002-0.004 0.016 0.003-0.005 0.010 0.005-0.006 As in previous tests with UNIVIS, there is little or no difference between results before and during the use of UNIVIS. s< CONDITIOMS AND LIMITATIONS -5- 013465 1. Any use of or reliance by Montello or any third-parties upon the information, data, analysis and conclusions set forth herein shall be at their sole risk and without any recourse to or liability on the part of Union Carbide. 2. The air monitoring samples herein were collected under weather and other conditions which may not be typical of those conditions under which UNIVIS will be used. In any case, the results set forth herein nay not be repre sentative of results in different locations or found under different weather or other external conditions at the same or different locations. 3. In compiling its report Union Carbide followed a testing procedure which it believes to be accurate and reliable but there may be other methods for evaluating fiber emissions which may produce different results. 4. Any use of products containing asbestos may be hazardous to health and the breathing of asbestos dust may cause serious bodily harm. Union Carbide makes no warranty or guarantee, either express or implied, that the results set forth in its report bear upon any health risks associated with the use of UHIVIS. It shall be the responsibility of any user of UNIVIS to deter mine that he is exercising a reasonable standard of care in its use and that he is complying with all applicable governmental regulations as to the asbestos contained therein. SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, based on NIOSH Analytical Method P&CAM 239 and OSHA methods; reference Occupational Safety and Health Administration Methods, VI. C. Dixon, pp 431, MBS special publication No. 506, U.S. Department of Commerce, November 1978. Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Mi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Results are reported for each sample as: 1. Chrysotile Asbestos - Any fiber having an aspect ratio >3 and a length >5y that is in the operator's judgment chrysotile. In the event of doubt and in the absence of further information, any fiber having the above physical dimensions will also be counted as chrysotile. & 2. Other Fiber - Any fiber having an aspect ratio *3 and a length *5y which could be mistaken for chrysotile due to its having similar properties. COMMENTS 013466 The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time-weighted average (TWA). The formula C^T^ + + CnTn describes the TWA where _ -- C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. 1 \ EAST 32ND PLACE \ ^^TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 Bulletin 1/80 INTRODUCING 013467 UN I VI S Universal viscosifier for all aqueous drilling fluids. Montello is very proud to introduce you to a new product - UNIVIS - - and the story behind its development. More than two years ago. Union Carbide and Montello began a joint effort to develop a truly "dust controlled" asbestos product. Our Super Visbestos has been a leader in performance and economy for many years, and its high density, crushed pellet structure results in very low airborne fiber counts. However, our goal is to offer you a product which under usual conditions and with reasonable care will result in counts below 0.1 fibers/cc on a 7 or 8 hour time weighted average (TWA) basis. This level (Oil fibers/cc) is important from an OSHA compliance standpoint for anyone using asbestos since it may permit an employer to avoid certain monitoring, medical examination and other OSHA requirements. After laboratory and field evaluations, documented by monitoring at several on-site locations, we are pleased to announce UNIVIS. With reasonable care in housekeeping and application, airborne fiber counts should be below 0.1/fibers/cc TWA and indistinguishable from background concentrations. The key to dust control with UNIVIS is the carefully metered addi tion of a specially selected oil to a unique 1/8 inch diameter pellet of presheared asbestos. Although more expensive than adding water, our tests indicate that the oil is much more effective and reliable in suppressing dust. This is especially true when acci- detial spills or bag breakage occur. The oil wet material retains substantially all of its dust control properties up to several weeks. The water treated material on the other hand, begins drying out almost immediately, with a commensurate decline in dust control properties. Since spills and bag breakage are sometimes unavoidable we decided not to utilize the less dependable protection of water for vital dust control. Of course an oil wet material posed packaging problems. The solution was found in the same kind of polypropylene lined multiwall kraft paper bag that has proven to be capable of withstanding diesel oil treated fertilizer packaged for certain explosives applications. 01)468 Another question arose as to the possible difficulty of adding UNIVIS to the aqueous drilling fluid. Would the oil coated surface adversely affect dispersion of the asbestos pellets into the system? Lab tests and field tests have revealed that just the reverse is true. By softening and lubricating the surface of the pellets, the oil actually enhances the rate of dispersion. In order to evaluate dust controlled UNIVIS, a monitoring pro gram was undertaken at several on-site locations. The first commercially produced truckload of UNIVIS was shipped to north central Texas, where seven rig locations were selected for eval uation. The locations were premonitored for several hours the day before UNIVIS was used to establish an accurate background count. During monitoring nearly 250 filter samples were collected and airborne concetrations were determined in accordance with OSHA requirements. A subsequent test was conducted at a single site for an extended period to determine the possible cumulative effect on airborne asbestos fibers during successive daily use of UNIVIS. The monitoring results are contianed in a lengthy report which includes complete descriptions of the test sites and conditions, analysis data, and time-weighted average (TWA) calculations. The highest TWA was less than one-half the level of 0.1 fibers/cc over the 7-8 hour period which OSHA deems significant for the purposes of employee medical examinations. Our goal of developing a dust controlled asbestos has been realized - - - - and not just for standard handling, but for the occasional and unavoidable spill. However, in your use of UNIVIS you will still want to be aware of the health and safety problems associated with asbestos and the pertinent OSHA regulations, particularly if you have any cause to believe that any exposure in excess of permissible levels may result. We will make available to you at no charge appropriate materials on these matters. A summary of the foregoing report is avaiable at no charge. Please contact us for a copy, or if you want any further information. We'll gladly accept your collect calls at 918/665-1170. SUMMARY OF AIR MONITORING RESULTS DURING USE OF `'UNIVIS" (AM OIL-WETTED ASBESTOS PRODUCT) December 7, 1979 013469 This report provides a brief summary of the overall results from several drilling sites. A copy of the full report is available upon request. PLEASE NOTE: The companies which cooperated in the tests discussed herein are customers of Montello, Inc. and permitted such tests in order to ascertain whether their use of UNIVIS complies with Federal Occupational Safety and Health Act regulations. Results of these tests are made ' available to other companies solely for their use in making their own evaluations of the appropriate procedures to be followed in using UNIVIS. SAMPLES WERE COLLECTED AND EVALUATED By F. L. Smith & B. L. Ingalls of UNION CARBIDE CORPORATION Metals Division Niagara Falls, New York INTRODUCTION 0X3470 This report is a brief summary of two separate air monitoring test series conducted during the use of UNIVIS. UNIVIS is an oil-wetted pelletized asbestos product developed to minimize airborne dust during its use as a viscosifier in drilling fluids. The tests were conducted to determine the effectiveness of the oil treatment in reducing dust. Test Series I involved seven different drilling sites and was conducted to determine the amount of airborne fibers generated under varying weather and other external conditions. Test Series II involved only one drill site but under extended conditions where asbestos was used on a daily basis. The conditions under which the tests were conducted are described in the following reports. The airborne asbestos fiber counts reported are not necessarily representative of those which may be found at different locations or under different conditions. Anyone using UNIVIS or any other asbestos product should be aware of the health and safety problems associated with asbestos and with pertinent regulatory requirements. Appropriate literature and other materials concerning the above are available upon request. DISCUSSION The results of two separate series of air monitoring tests during the use of UNIVIS are discussed in this report. All tests to date have shown that the proper use of an oil-wetted pellet can result in extremely low airborne emis sions of asbestos fiber. Air monitoring was conducted prior to any use of UNIVIS or other asbestos product to determine a "background" level of fibers. Based on the test data before and during the use of UNIVIS and considering the limitations of the overall test procedure, it appears that airborne fiber levels during the use of UNIVIS are essentially indistinguishable from background. TEST SERIES I Environmental and personal airborne samples were obtained at seven drilling ,, sites located in the area of Graham, Texas, during the period June 11-22, 1979. Samples were collected at each location on the day prior to using UNIVIS and no asbestos was handled on the sites during the pre-control days. These samples were obtained in continuous sequence for durations of 2-1/2 to 5 hours. Sampling on days when UNIVIS was used represented the major portion of an 8-hour work shift. Weather conditions were hot and humid with winds of 5 to 20 mph. Rigs were operating at depths up to 4000 .feet. Of nearly 250 samples evaluated, the highest ceiling value during the handling and dumping of UNIVIS was 0.186 fibers/cc of air; although a higher count, 0.307 f/cc, was obtained on a personal sample prior to dumping. All other ceiling values were below 0.1 f/cc, except for one pre-control day count of 0.143, f/cc. 2- - 013471 Although ceiling value measurements are necessary for regulatory compliance, time-weighted average (TWA) 'exposures to asbestos fibers are more pertinent for safety and health considerations. The following table summarizes and compares the TV/A values measured the day before and during the use of UNI VIS: SUMMARY OF TIME-WEIGHTED AVERAGES Location Sample Type Henrietta Personal Environmental Jacksboro Personal Environmental Graham #1 Personal Environmental Graham #2 Personal Environmental Newport Personal Environmental Caddo Personal Environmental Cundiff Personal * Environmental CALCULATED TWA, f/cc Day prior to Day of use Use of UNIVIS of UNIVIS 0.041 0.0-0.009 0.028 0.007-0.010 0.023 0.003-0.009 0.043 0.002-0.005 0.002 0.0-0.004 0.008 0.008-0.013 0.010 0.0-0.006 0.005 0.004-0.017 0.004 ' 0.012-0.019 0.010 0.010 0.013 0.003-0.008 0.006 0.006-0.013 0.009 0.0-0.005 0.009 0.002-0.005 The highest personal TWA during the use of UNIVIS was 0.043 f/cc and the range was 0.005 to 0.043. The range during pre-control days was 0.002 to 0.041. Considering the limitations of the tests, there was little or no difference in the results. During this test series, a significant number of samples were found to contain fibrous materials other than asbestos, the majority of which v/ere organic. In most instances the extraneous fiber was readily distinguishable from chrysotile and excluded from counting. However, some fibrous material exhibited properties sufficiently similar to chrysotile that it could be counted as such, particularly by an inexperienced microscopist. To avoid any confusion, two distinct categories of fiber were counted: that which, in the operator's opinion, was chrysotile, and "other fiber" that was similar enough that it might be counted as chrysotile. (None of the fiber counted as "other fiber" was considered to be chrysotile by the microscopist.) -3- 01347s Several of the samples were*also observed with polarized light to enhance detec tion accuracy. In the writers' opinion, a considerable amount of the chrysotil fiber counts reported are not in fact chrysotile. However, it is virtually impossible to make any definitive analytical judgment based soley on phase contrast counting techniques. As such, the chrysotile counts reported are most likely higher than actual fiber concentrations existing at the time of tests. This is further substantiated by comparison of TVIA results obtained on pre control and trial days. The mean values for TIJA's based on the total fiber counts (chrysotile plus "other fiber") obtained at the. seven test sites are shown in the next Table. As illustrated, there is essentially no difference in the overall fiber counts between precontrol and trial days. MEAN VALUES OF TVIA's OBTAINED AT THE SEVEN TEST SITES BASEO ON TOTAL FIBER COUNTS (CHRYSOTILE PLUS' OTHER FIBER) _. (Fibers/cc) Personal Precontrol Trial 0.075 *(.020-.332) 0.070 (.017-.184) Environmental Precontrol Trial 0.021 (.007-.040) 0.025 (.014-.042) (Minimum-maximum range of TWA's) TEST SERIES II During the week of September 16, 1979, air monitoring was performed at a single drilling site in Andrews County, Texas. The purpose of these tests was to determine the airborne asbestos concentrations over an extended period while UNIVIS was being used on a daily basis. Air samples were collected prior to the use of UNIVJS to determine background data. The highest ceiling value during the handling and dumping of UNIVIS was 0.103 fibers/cc of air; although a higher count, 0.144 fibers/cc, was obtained on a personal sample prior to bag dumping. All other counts were below 0.1 fibers/cc. The following table compares the time-weighted average (TWA) exposures on the pre-control day with data for the five days on which UNIVIS was used: -4SUMMARY OF TIME-WE IGHTED AVERAGES 013173 Day 9/17/79 9/18/79 9/19/79 9/20/79 9/21/79 Pounds of UNIVIS Added None 200 250 250 250 Type Sample Personal Environmental Personal Environmental Personal Environmental Personal Environmental Personal Environmental TWA, f/cc 0.019 0.0 0.019 0.005 0.016 0.002-0.004 0.016 0.003-0.005 0.010 0.005-0.006 As in previous tests with UNIVIS, there is little or no difference between results before and during the use of UNIVIS. CONDITIONS AND LIMITATIONS -5- 013474 1. Any use of or reliance by Montello or any third-parties upon the information, data, analysis and conclusions set forth herein shall be at their sole risk and without any recourse to or liability on the part of Union Carbide. 2. The air monitoring samples herein were collected under weather and other conditions which may not be typical of those conditions under which UNIVIS will be used. In any case, the results set forth herein may not be repre sentative of results in different locations or found under different weather or other external conditions at the same or different locations. 3. In compiling its report Union Carbide followed a testing procedure which it believes to be accurate and reliable but there may be other methods for evaluating fiber emissions which may produce different results. 4. Any use of products containing asbestos may be hazardous to health and the breathing of asbestos dust may cause serious bodily harm. Union Carbide makes no warranty or guarantee, either express or implied, that the results set forth in its report bear upon any health risks associated with the use of UNIVIS. It shall be the responsibility of any user of UNIVIS to deter mine that he is exercising a reasonable standard of care in its use and that he is complying with all applicable governmental regulations as to the asbestos contained therein. SAMPLE EQUIPMI NT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, based on NIOSH Analytical Method P&CAM 239 and OSHA methods; reference Occupational Safety and Health Administration Methods, VI. C. Dixon, pp 431, MBS special publication No. 506, U.S. Department of Commerce, November 1978. Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Hi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Results are reported for each sample as: 1. Chrysotile Asbestos - Any fiber having an aspect ratio >3 and a length >5p that is in the operator's judgment chrysotile. In the event of doubt and in the absence of further information, any fiber having the above physical dimensions will also be counted as chrysotile. 2. Other Fiber - Any fiber having an aspect ratio z3 and a length >5p which could be mistaken for chrysotile due to its having similar properties. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centirrteter of air sampled on an 8-hour, time-weighted average (TWA). The formula C^T-j + C^Tg + CnTn describes the TV/A where _ --- .' C * fiber count in fibers/cc and T * time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. 013476 SURVEY AIA-4: DRILLING MUD ADDITIVES The AIA-4 study covered the operations involved with the use of fibrous asbestos as an additive to the circulating muds of an oil drilling rig. The work onsite was performed by one worker, and air samples were collected both outdoors and inside of a small trailer that housed the mud hopper. The trailer was approximately 20 feet long by 8 feet wide with two open doors on opposite sides, each about 4 feet wide and extending from floor to ceiling. The mud hopper consisted of a 30-gallon drum open at the top with a suction hose connected at the bottom. The task of the worker was to slowly pour the asbestos material (dry) from a 50-pound bag into the drum. The material is fed into the drilling mud by the venturi action of the mud as it flows past the hose opening to the drum. Generally, four to six 50-pound bags of material are used during each addition and approximately 100 bags of material are used per drilling site in the area. The asbestos material is packaged in 50-pound paper bags that are sealed in a thick plastic outer covering. After the bag has been emptied, it is usually stored in a pile outside and disposed of either by burning or burial in a landfill at the site. . Conditions during the sampling varied. Generally, the wind was gusting slightly through the open doors of the trailer for both the first and second set of samples taken while the worker was^pouring the product into the hopper. During the first pouring, the material fed smoothly into the hopper and six bags were poured in a 23.5-minute time interval. Some difficulty was experienced during the second pouring as the hopper Y 01 177 appeared to be clogged and only two bags were fed over the next 23 minutes. Considerable dusting was observed during both pourings. Results for the nine air samples collected during this survey are summarized as follows: s> I 013478 Sample No. 0C0-1 0C0-2 0C0-3 0C0-4 0C0-5 OCO-6 0C0-7 0C0-8 OCO-9 Description General air, center of trailer, approxi mately 6.5 feet above floor and 4 feet from dumping operation, during dumping of 6 bags Worker exposure, pouring 6 bags of asbes tos fiber into mud hopper General air, directly over mud hopper, 6.5 feet above floor, during pouring of 6 bags General air, background, approximately 50 feet upwind of trailer General air (same location as 0C0-1), no operations performed in trailer General air (same location as OCO-3), no operations performed in trailer General air (same location as 0C0-1), during dumping of 2 bags General air (same location as OCO-3), during pouring of 2 bags Worker exposure, during dumping of 2 bags, hopper appeared to be clogged Time (minutes) 28 23.5 28.5 50 43 43 22.5 20 23 Fibers/Cubic Centimeter >5 Micron 0.95 2.4 0.75 0.016 0.090 0.036 1.7 2.9 7.0 Time-Weighted Averages Worker Type Mud hopper operator TWA 0.51 p4?9 o WASTE PIT NORTH FOR EMPTY BAGS i MUD TANK 0C0-4 6CO-3,6,8 OCO-1,5, 7 :>qTRAILER 20 feet OCO-2, M1UUD HOPPER MUD TANK WALKWAY -10 feet' STORED BAGS OF CLAY MUD PUMP STORED BAGS OF ASBESTOS WASTE POND (MUD, WATER, ASBESTOS) PIPE MUD TANK MUD TANK MACHINERY SECTION CONTROL SHED Figure 4. Work area diagram including sampling locations for survey AIA-4 013430 AIRBORNE FIBER COUNTS for Shell Oil Company At Various Locations Near Traverse City, Michigan November 18, 1974 Samples Collected And Analyzed By: E. J. Kleber Union Carbide Corporation Union Carbide Corporation Mining and Metals Division Niagara Falls, New York 013481 OBJECTIVES Determine the concentrations of airborne asbestos fiber generated during the use of New Granular Supervisbestos at a number of Shell Oil Company drilling rigs. OPERATIONS MONITORED Air Samples were collected September 24, 1974 at three drilling sites on Shell Oil properties known as Cactus #16, Cactus #21, and Cedco #37. 25 sacks weighing 50 pounds each were dumped at each location. DESCRIPTION OF LOCATIONS AND SAMPLES COLLECTED Cactus #16 - This location featured a mixing hopper with top about 3-1/2 ft. above the ground. Sacks were transported from the back of a truck located approximately 20 ft. from the hopper (Figure 1). Nine air samples were collected at this location; environmental (stationary) samples located 3-1/2 ft. off the ground, 7 ft. downwind from the hopper, were taken before the test, during the first dumping operation, between operations, during the second dump, and after the tests were complete. Personal breathing zone samples were collected from both operators during each of the two dumping operations. Sampling time included transportation of the sacks from truck to hopper, a distance of approxi mately 20 ft. 12 sacks were dumped in the first operation and 13 in the second. 2. Cactus #21 - The drilling rig operation was essentially similar to Cactus #16 with one exception. Asbestos was added to a hopper which was located in a mud house approximately 7 ft. x 7 ft. x 6 ft. The mud house was open on three sides, however, and the breeze was blowing throughout the test (Figure 2). Eight samples were collected at this location. Environmental (stationary) samples were collected 3 ft. from the hopper in the mud house during the first dumping operation; one between operations, one during the second dump and one after the completion of the operation. Personal breathing zone samples were collected from both operators during each dump. As in Cactus #16, sampling time included transportation of the sacks from truck to hopper, a distance of approxi mately 30 ft. 12 sacks were dumped in the first operation, and 13 in the second. 3. Cedco #37 - The drilling operation was essentially to Cactus #16 in that the hopper was outside and entirely exposed to the elements (Figure 3). One major difference in this test was that all 25 sacks were dumped at once. Three samples were collected at this rig. An environmental, located over the hopper, was collected upon completion of dumping. One had been attempted during dumping, but mud "blow back" spurted up from the hopper and destroyed the filter. Personal breathing zone samples were collected from both operators during the dump. All 25 sacks were dumped at one time in this operation and, again, sampling time included sack transportation, a distance of approximately 20 ft. GENERAL CLIMATIC CONDITIONS The test at Cactus #16 was marred by a sporadic light rain. The day improved slowly to scattered clouds by the time the tests ended. Temperatures hovered around 50 all day with a very gusty wind 10-25 mph. 2- - 013432 EQUIPMENT AND PROCEDURE Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.93a, using the Bayer, Zummalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type) calibrated to 2 liters per minute were used to collect personal breathing zone and environmental samples on mi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Vicker's phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS Reported as fibers greater than 5 microns in length per cubic centi meter of air sampled. A fiber is defined as a^material having an aspect ratio greater than 3:1. INTERPRETATION The OSHA regulations have been established with a limit of 5 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8hour time-weighted average (TWA). The formula C-jT^ + CgTg + CnTn describes --------ITT------- time-weighted average where C = fiber count in fibers/cc and T = time. The 8-hour time-weighted averages calculated below have been based on the assumption that New Granular Supervisbestos will be dumped only once a day. Also, due to a lack of sampling time available, environmental samples have been used in place of the normal personal breathing zone samples. They are noted and explained in each calculation. 1. Cactus #16 Calculations based on two personal breathing zones samples for each operator (M-9 and M-24 for David Kniss and M-8 and M-23 for Carl Wind) and two environmental samples (M-7 and M-20). Sample M-20, taken after completion of the test, was used to approximate the exposure during the bulk of the day. A) David Kniss (3.7)(5) , (0.4)(15) (2.2)(6) (0.2)(454) 480 , =0.27 fibers/cc TWA B) Carl Wind (5.7)(5) + (0.4)(15) + (3.9)(6) + (0.2)(454) 480 = 0.31 fibers/cc TWA -3- 2. Cactus #21 013433 Calculations based on two personal breathing zone samples for each operator (M-16 and H-8 for Don Gustafson and M-22 and D-45 for Mike Jewett) and two environmental samples (M-18 and 1-8). Sample 1-8, taken after completion of the test, was used to approximate the exposure during the bulk of the day. A) Don Gustafson (6,7)(9) + (0.3H20) + (2.1)(9) (0.3)(442) 480 = 0.45 fibers/cc TWA B) Mike Jewett (8.3)(9) 4- (0.3X20) + (2.31(9) + (0.3)(442) 480 = 0.49 fibers/cc TWA 3. Cedco #37 Calculations based on one personal breathing zone sample for each operator (1-37 for Donald Thompson and J-23 for George Arnott) and one environmental sample (M-21) which was used as exposure for the bulk of the day. A) Donald Thompson (1.9)(15) + (0.4H465) 480 =0.45 fibers/cc TWA B) George Arnott (0.7)(15) + (0.4K465) 480 = 0.41 fibers/cc TWA SUMMARY OF FIBER COUNTS 013434 Sample No. M-14 M-9 M-8 M-5 M-7 M24 H-23 M-25 M-20 M-16 M-22 Sampling Time 13 min. 5 min. 5 min. 6 min. 5 min. 6 min. 6 min. 7 min. 13 min. 9 min. 9 min. Description Fibers/cc >5x Cactus #16 Environmental - Located 3-1/2 ft. off ground, 7 ft. downwind from hopper prior to test. 0.1 Personal - Operator (David Kniss) trans porting 6 bags of New Granular Supervisbestos (NGSV) from truck to hopper and dumping them in. 3.7 Personal - Operator (Carl Wind) transporting 6 sacks of NGSV from truck to hopper and dumping them in. Sample run simultaneously with M-9. 1.4 Environmental - Located in same position as M-14 during first test (M-8 and M-9). 1.8 Environmental - Located in same position as M-14 between runs. 0.4 Personal - Operator (David Kniss) trans porting 6 sacks NGSV from truck to hopper and dumping. Sampling time includes trans porting empty sacks to pit, a distance of about 30 ft. 2.2 Personal - Operator (Carl Wind) transporting 7 sacks NGSV from truck to hopper and dumping. Sampling time includes transporting empty sacks to pit, a distance of about 30 ft. Sample run simultaneously with M-23. 3.9 Environmental - Same location as M-14 during second test (M-23 and M-24). 1.3 Environmental - Same location as M-14 after test. 0.2 Cactus #21 * Personal - Operator (Don Gustafson) trans porting 6 sacks NGSV from truck to mud house and dumping them in. 6.7 Personal - Operator (Mike Jewett) transporting 6 sacks NGSV from truck to mud house and dump ing. Sample run simultaneously with M-16. 8.3 Summary of Fiber Counts - Continued 013435 Sample No. M-17 M-18 H-8 D-45 K-ll 1-8 1-37 J-23 M-21 Sampling Time 10 min. 20 min. 9 min. 9 min. 8 min. 13 min. 15 min. 15 min. 13 min. Description Environmental - Located in mud house, 5-1/2 ft. off floor, 3 ft. from hopper during test (M-22 and M-16). Fibers/cc >5* 0.4 Environmental - Same location as M-17 between tests. 0.3 <. Personal - Operator (Don Gustafson) trans porting 7 sacks NGSV to mud house and dumping. 2.1 Personal - Operator (Mike Jewett) trans porting 6 sacks NGSV to mud house and dumping. Sample run simultaneous with H-8. 2.3 Environmental - Same position as M-17 during test (D-45 and H-8). 1.6 Environmental - Same position as M-17 after test. 0.3 Cedco #37 Personal - Operator (Donald Thompson) hauling 13 sacks NGSV from truck to hopper and dumping. 1.9 Personal - Operator (George Arnott) hauling 12 sacks NGSV from truck to hopper and dumping. 0.7 Environmental - Located directly over the hopper, after test. 0.4 FIGURE 1 013486 Disposal Pit CACTUS 16 FIGURE 2 013497 CACTUS 21 FIGURE 3 H t Mud Additives Storage Area 013433 CEDCO 37 r 013439 $&/// /V i/} ~ [AfTT-ef </(/*/**/. monteiio P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 013490 AIRBORNE FIBER COUNTS for At Various Locations Near Traverse City, Michigan November 18, 1974 Samples Collected And Analyzed By: E. 0. Kleber Union Carbide Corporation Union Carbide Corporation Mining and Metals Division Niagara Falls, New York S' 013491 OBJECTIVES Determine the concentrations of airborne asbestos fiber generated during the use of New Granular Supervlsbestos at a number of drl 111 ng rigs. OPERATIONS MONITORED _______ Air Samples were collected September 24, 1974 at three drilling sites on properties known as Cactus #16, Cactus #21, and Cedco #37. 25 sacks weighing 50 pounds each were dumped at each location. DESCRIPTION OF LOCATIONS AND SAMPLES COLLECTED 1. Cactus #16 - This location featured a mixing hopper with top about 3-1/2 ft. above the ground. Sacks were transported from the back of a truck located approximately 20 ft. from the hopper (Figure 1). Nine air samples were collected at this location; environmental (stationary) samples located 3-1/2 ft. off the ground, 7 ft. downwind from the hopper, were taken before the test, during the first dumping operation, between operations, during the second dump, and after the tests were complete. Personal breathing zone samples were collected from both operators during each of the two dumping operations. Sampling time included transportation of the sacks from truck to hopper, a distance of approxi mately 20 ft. 12 sacks were dumped in the first operation and 13 in the second. 2. Cactus #21 - The drilling rig operation was essentially similar to Cactus #16 with one exception. Asbestos was added to a hopper which was located in a mud house approximately 7 ft. x 7 ft. x 6 ft. The mud house was open on three sides, however, and the breeze was blowing throughout the test (Figure 2). Eight samples were collected at this location. Environmental (stationary) samples were collected 3 ft. from the hopper in the mud house during the first dumping operation; one between operations, one during the second dump and one after the completion of the operation. Personal breathing zone samples were collected from both operators during each dump. As In Cactus #16, sampling time Included transportation of the sacks from truck to hopper, a distance of approxi mately 30 ft. 12 sacks were dumped In the first operation, and 13 In the second. 3. Cedco #37 - The drilling operation was essentially to Cactus #16 In that the hopper was outside and entirely exposed to the elements (Figure 3). One major difference In this test was that all 25 sacks were dumped at once. Three samples were collected at this rig. An environmental, located over the hopper, was collected upon completion of dumping. One had been attempted during dumping, but mud "blow back" spurted up from the hopper and destroyed the filter. Personal breathing zone samples were collected from both operators during the dump. All 25 sacks were dumped at one time In this operation and, again, sampling time Included sack transportation, a distance of approximately 20 ft. GENERAL CLIMATIC CONDITIONS ` The test at Cactus #16 was marred by a sporadic light rain. The day improved slowly to scattered clouds by the time the tests ended. Temperatures hovered around 50 all day with a very gusty wind 10-25 mph. EQUIPMENT AND PROCEDURE -2- 013492 Sampling and dust counting were carried out In accordance with OSHA Regulation 1910.93a, using the Bayer, Zummalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type) calibrated to 2 liters per minute were used to collect personal breathing zone and environmental samples on millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Vicker's phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS Reported as fibers greater than 5 microns In length per cubic centi meter of air sampled. A fiber is defined as arterial having an aspect ratio greater than 3:1. INTERPRETATION The OSHA regulations have been established with a limit of 5 fibers greater than 5 microns In length per cubic centimeter of air sampled on an 8hour time-weighted average (TWA). The formula C1T1 + C2T2 CRTn describes ------------TT----------- time-weighted average where C * fiber count in fibers/cc and T a time. The 8-hour time-weighted averages calculated below have been based on the assumption that New Granular Supervisbestos will be dumped only once a day. Also, due to a lack of sampling time available, environmental samples have been used in place of the normal personal breathing zone samples. They are noted and explained in each calculation. 1. Cactus #16 Calculations based on two personal breathing zones samples for each operator (M-9 and M-24 for and M-8 and M-23 for flflHBi) and two environmental samples (M-7 and M-20). Sample M-20, taken after completion of the test, was used to approximate the exposure during the bulk of the day. (3.7)(5) (0.4)05) + (2.2)(6) 4 (0.2)(454) 480 * 0.27 fibers/cc TWA B) (5.7)(5) ^ (0.4)(15) (3.9)(6) 4 (0.2)(454) 480 0.31 fibers/cc TWA 2. Cactus #21 -3- 013493 Calculations based on two personal breathing zone samples for each operator (M-16 and H-8 for Don Gustafson and M-22 and D-45 for Mike Jewett) and two environmental samples (M-18 and 1-8). Sample 1-8, taken after completion of the test, was used to approximate the exposure during the bulk of the day. A) Don Gustafson (6.7)(9) (0.3R20) (2.1)(9) (0.3H442) 480 * 0.45 fibers/cc TWA B) Mike Jewett (8.3)(9) + (0.3)(20) (2.3)(9) (0.3)(442) 480 - 0.49 fibers/cc TWA 3. Cedco #37 Calculations based on one personal breathing zone sample for each operator (1-37 for and J-23 for I and one environmental sample (M-21) which was used as exposure for the bulk of the day. (1.9)115)/ (0.4)(465) 480 =0.45 fibers/cc TWA (0.7H15) + (0.41(465) 480 = 0.41 fibers/cc TWA SUMMARY OF FIBER COUNTS 013494 Sample No. M-14 M-9 M-8 M-5 M-7 M24 M-23 M-25 M-20 M-16 M-22 Sampling Time 13 min. 5 min. 5 min. 6 min. 5 min., 6 min. 6 min. 7 min. 13 min. 9 min. 9 min. Cactus #16 Description Fibers/cc --___ Environmental - Located 3-1/2 ft. off ground, 7 ft. downwind from hopper prior to test. 0.1 Personal - Operator trans- porting 6 bags of New Granular Super- visbestos (NGSV) from truck to hopper and dumping them in. 3.7 Personal - Operator (0HHHB) transporting 6 sacks of NGSV from truck to hopper and dumping them in. Sample run simultaneously with M-9. 1.4 Environmental - Located in same position as M-14 during first test (M-8 and M-9). 1.8 Environmental - Located in same position as M-14 between runs. 0.4 Personal - Operator (I transporting 6 sacks NGSV from truck to hopper and dumping. Sampling time includes trans porting empty sacks to pit, a distance of about 30 ft. 2.2 Personal - Operator transporting 7 sacks NGSV from truck to hopper and dumping. Sampling time includes transporting empty sacks to pit, a distance of about 30 ft. Sample run simultaneously with M-23. 3.9 Environmental - Same location as M-14 during second test (M-23 and M-24). 1.3 Environmental - Same location as M-14 after test. 0.2 Cactus #21 , Personal - Operator (Don Gustafson) transporting 6 sacks NGSV from truck to mud house and dumping them in. 6.7 Personal - Operator (Mike Jewett) transporting 6 sacks NGSV from truck to mud house and dump ing. Sample run simultaneously with M-16. 8.3, Summary of Fiber Counts - Continued Sample No. Sampling Time Description 013495 Fibers/cc ....>5^ M-17 10 min. Environmental - Located in mud house, 5-1/2 ft. off floor, 3 ft. from hopper during test (M-22 and M-16). 0.4 M-18 20 min. Environmental - Same location as M-17 between tests. 0.3 H-8 9 min. Personal - Operator (Don Gustafson) trans 2.1 porting 7 sacks NGSV to mud house and dumping. 0-45 9 min. Personal - Operator (Mike Jewett) trans porting 6 sacks NGSV to mud house and dumping. Sample run simultaneous with H-8. 2.3 K-11 8 min. Environmental - Same position as M-17 during test (D-45 and H-8). 1.6 1-8 13 min. Environmental - Same position as M-17 after 0.3 test. Cedco #37 1-37 15 min. Personal - Operator (flBHHHBHIB hauling 13 sacks NGSV from truck to hopper and dumping. 1.9 J-23 15 min. Personal - Operator hauling 12 sacks NGSV from truck to hopper and dumping. 0.7 M-21 13 min. Environmental - Located directly over the hopper, after test. 0.4 FIGURE 1 013496 W' Disposal Pit CACTUS 16 FIGURE 2 013497 / Truck v CACTUS 21 FIGURE 3 H t Hud Additives Storage Area 013498 CEDCO 37 6/ UNION CARBIDE CORPORATION * MINING & METALS DIVISION 013499 UNION CARBIDE THE DISCOVERY COMPANY P.O. BOX 579 NIAGARA FALLS, N. Y. 14302 TEL' 716-278-3376 December 17, 1974 Mr. Kenneth N. Campbell Montello, Inc. P. 0. Box 130 Sand Springs, OK 74063 Dear Ken: Listed below are the results of our air sampling tests conducted at Kinnco's Warehouse, Kalkaska, Michigan, September 24, 1974. As you can see, one sample just squeezed over the 10 fiber/cc ceiling concentration limit. Since Shell's Industrial Hygienist did not express any interest in the results of the warehouse fiber counts, we chose not to include them in the main report. The fiber counts follow: Sample Sampling NoTime___________________ Description? 5-^/ M-ll 13 Min. Environmental - Located in warehouse, 5 ft. off floor, attached to Super Visbestos Pallet. No activity in warehouse. M-12 4 Min. Personal - Operator (J. McDowell) removing bags of New Granular Super Visbestos from pallets and handing them to men in truck. M-4 4 Min. Personal - Operator (L. Kinney) taking bags from J. McDowell and placing in truck. Fibers/cc 0.4 10.2 3.6 If you need any more information on these tests, please let me know. If we do not get the opportunity to speak before Christmas, please accept my sincere wishes for a Happy Holiday Season. Customer Service Representative cc: Dr. H. B. Rhodes /ds UNION CARBIDE CORPORATION MINING & METALS DIVISION 013500 UNION CARBIDE THE DISCOVERY COMPANY P.O. BOX 579 NIAGARA FALLS, N. Y. 14302 TEL: 716-278-3376 December 17, 1974 Mr. Kenneth N. Campbell Montello, Inc. P. 0. Box 130 Sand Springs, OK 74063 Dear Ken: Listed below are the results of our air sampling tests conducted at Kinnco's Warehouse, Kalkaska, Michigan, September 24, 1974. As you can see, one sample just squeezed over the 10 fiber/cc ceiling concentration limit. Since Shell's Industrial Hygienist did not express any interest in the results of the warehouse fiber counts, we chose not to include them in the main report. The fiber counts follow: Sample Sampling No________ Time_________________________________Description_____________________ M-ll 13 Min. Environmental - Located in warehouse, 5 ft. off floor, attached to Super Visbestos Pallet. No activity in warehouse. M-12 4 Min. Personal - Operator (J. McDowell) removing bags of New Granular Super Visbestos from pallets and handing them to men in truck. M-4 4 Min. Personal - Operator (L. Kinney) taking bags from J. McDowell and placing in truck. Fibers/cc 7 0.4 * 10.2 3.6 If you need any more information on these tests, please let me know. If we do not get the opportunity to speak before Christmas, please accept my sincere wishes for a Happy Holiday Season. Customer Service Representative cc: Dr. H. B. Rhodes /ds o*wi 01 3 01 mctENCf SHELL OIL COMPANY 0 WESTERN E fi P REGION MID-CONTINENT DIVISION MICHIGAN OPERATIONS - MANAGER DATS OCTOBER 31, 1974 MOM INDUSTRIAL HYGIENIST ` DEPARTMENT OF OCCUPATIONAL .SAFETY AND HEALTH - WOOD RIVER SUtJECT GRANULAR ASBESTOS SURVEY Personal sampling tests were made on September 24 at three drilling sites to evaluate workers' exposure to airborne concentrations of asbestos fibers during mud mixing operations, using the Montello New Granular Super Visbestos pelleted product. Mr. E. J. Kleber, Customer Service Representative, Union Carbide Corporation, took samples concurrently along with these. The purpose of the tests was to compare the exposures using this product with those taken on June 3 and 4 using the Montello Super Visbestos material (the same asbestos in a loose fluffy form). At each of the sites, 25 bags of asbestos were carried from a truck to the hopper, opened and mixed, and with the exception of Cactus Rig #21 the empty bags were carried to a dump site. Handling conditions at each of these and the June sites were different; these tests involved sampling times of about 12 to 18 minutes with 25 bags; the June tests involved about 5 minutes with 6 bags. The table below shows the average exposure for each man for the total sampling time involved, and his time-weighted average as calculated for an 8-hour shift with an assumed background concentration of 0.2 fibers/ml for the balance of the shift not involved in the sampling period. This arbitrary background figure weighs heavily on the 8-hour average, due to the short actual exposure times, but would not be considered an excessive estimate for the purpose of these evaluations The first three sites are 'the September tests. the last two are the June tests. evaluated the same way for ease of comparison. Total Sampling Location Name Time (Minutes) (Septemberi New Granular Super Visbestos) Cactus Rig #16 C. Wind D. Kniss 11.8 11.8 Average Fibers/ml 3.40 6.34 8-Hour Average with Background ruA 0.28 0.35 Cactus Rig #21 D. Gustafson M. Jewett 18.2 18.2 6.37 2.72 0.43 0.30 Cedco Rig #37 D. Thompson G. Arnott (June: Super Visbestos) Cactus Rig #21 J. Jensen M. Porter Chapman Rig #8 E. Minnie D. Reinwater 16.3 16.3 5.25 5.25 5.0 5.0 0.60 0.58 ' 11.64 1.07 1.99 0.67 0.21 0.21 0.33 0.21 0.22 o.i'ti : r" 013502 I ' Wind Kniss WindKniss Gustafson Jewett Gustafson Jewett Thompson Arnott * Designation EPT-07 EPT-08 EPT-09 EPT-10 EPT-11 EPT-12 EPT-13 EPT-14 EPT-15 EPT-16 (n Total Count on Filter 21,800 36,000 58,500 113,600 154,000 71,000 78,000 27,800 19,600 18.800 (i> Air, Liters 10.0 10.0 13.6 13.6 19.0 19.0 17.4 17.4 32.6 32.6 c.n . Fibers per ml 2.18 3.60 4.30 8.35 8.10 3.74 4.48 1.60 0.60 0.58 The last two samples (13,16) are somewhat unusual in having an extremely large number of sub-micron particles that give a grey appearance to the filter. This fact does not, of course, influence tKe fiber count. /. /// 77' f r-. ft' O') t^/>r , i flit ///, /,' -( rr? () (/, V,'</e $ < I 4- / /y^/ ^/s r<* a-. /* -^o ^ A SHELL OIL COMPANY 013503 10 WESTERN ESP REGION MID-CONTINENT DIVISION MICHIGAN OPERATIONS - MANAGER 0ATt JULY 17, 1974 from INDUSTRIAL HYGIENIST DEPARTMENT OF OCCUPATIONAL SAFETY AND HEALTH - WOOD RIVER SUR/ect ASBESTOS SURVEY Personal sampling tests were conducted at the Cactus Rig No. 21 on June 3 and Chapman Rig No. 8 on June 4, to evaluate workers' exposure to airborne concentrations of asbestos fibers during mud mixing operations. The six sampling sheets and Bellaire report on fiber counts is enclosed for your files (Enclosure 1). At Cactus Rig No. 21, Mike Porter tossed eight bags of Super Visbestos over a stack of bags to Jack Jensen, and Jensen poured six bags into the hopper with Porter's assistance. Wind conditions were light. The hopper was at a level sufficiently high enough to place the bag opening about a foot from Porter's face while pouring the asbestos. The total time involved 5-1/4 minutes. The combined value of the two samples on Porter (1 and 3) is 11.64 fibers per cubic centimeter. J^noen'-s samples (2 and 4) combined to give 1.07 fibers/cc. te' ~t<v"'s On the Chapman Rig No. 8 site, Emerson Minnie carried six bags of Super Visbestos to the hopper and assisted Dennis Reinwater, who poured the material into the hopper. The wind was strong, blowing across the hopper towards the men. This hopper was about waist high, placing the bag opening about two feet from Reinwater's face. The total time of the operation was five minutes. Minnie's exposure (sample 5) was 1.99 fibers/cc, and Reinwater's (6) was 0.67 fibers/cc. 013504 Designation 7* - / / - - / EPT-01 P r /- y EPT-02 tS~. t EPT-03 (1st count) J/- A-< 's ^ . J EPT-03 (2nd count) -! r r ~ d EPT-04 1 A/, >- ^,v- EPT-05 ! 'k'j . A' " ir EPT-06 Total Count on Filter 25 ,800 6 ,700 112 ,000 81 ,000 4 ,500 19 ,900 6 ,700 Air, Liters 8.0 8.0 2.5 2.5 2.5 10.0 10.0 Fibers/ml Air 3.2 ' 0.8 44.8 32.4 1.8 2.0 0.7 1 /_ j ( ^: S i. ' r r r V-' C O. L* Sf ft </ /ftC, Cj $ r i A /) + '' r* ,i - 41 // r 5 4 ee# - /J7 Af)f) r/o.r. !6t. , /ft, ft'- *3. J i), / y H.i-V s;i (EFCtENCE SHELL OIL COMPANY 013505 DATE OCTOBER 31, 1974 to WESTERN E 6 P REGION MID-CONTINENT DIVISION MICHIGAN OPERATIONS - MANAGER FROM INDUSTRIAL HYGIENIST ' DEPARTMENT OF OCCUPATIONAL .SAFETY AND HEALTH - WOOD RIVER SUBJECT GRANULAR ASBESTOS SURVEY Personal sampling tests were made on September 24 at three drilling sites to evaluate workers' exposure to airborne concentrations of asbestos fibers during mud mixing operations, using the Montello New Granular Super Visbestos pelleted product. Mr. E. J. Kleber, Customer Service Representative, Union Carbide Corporation, took samples concurrently along with these. The purpose of 'the tests was to compare the exposures using this product with those taken on June 3 and 4 using the Montello Super Visbestos material (the same asbestos in a loose fluffy form). At each of the sites, 25 bags of asbestos were carried from a truck to the hopper, opened and mixed, and with the exception of Cactus Rig #21 the empty bags were carried to a dump site. Handling conditions at each of these and the June sites were different; these tests involved sampling times of about 12 to 18 minutes with 25 bags; the June tests involved about 5 minutes with 6 bags. The table below shows the average exposure for each man for the total sampling time involved, and his time-weighted average as calculated for an 8-hour shift with an assumed background concentration of 0.2 fibers/ml for the balance of the shift not involved in the sampling period. This arbitrary background figure weighs heavily on the 8-hour average, due to the short actual exposure times, but would not be considered an excessive estimate for the purpose of these evaluations The first three sites are 'the September tests. the last two are the June tests, evaluated the tame way for ease of comparison. Total Sampling Location Name Time (Minutes) (Septembers New Granular Super Visbestos) Average Fibers/ml 8-Hour Average with Background Cactus Rig #16 C. Wind D. Kniss 11.8 11.8 3.40 6.34 0.28 0.35 Cactus Rig #21 D. Gustafson M. Jewett 18.2 18.2 6.37 2.72 0.43 0.30 Cedco Rig #37 D. Thompson G. Arnott (June: Super Visbestos) Cactus Rig #21 J. Jensen M. Porter Chapman Rig #8 E. Minnie D. Reinwater 16.3 16.3 5.25 5.25 5.0 5.0 0.60 0.58 - 11.64 1.07 1.99 0.67 0.21 0.21 0.33 0.21 0.22 0.20 013506 v . Designation Wind Kniss Wind' Kniss Gustafson Jewett Gustafson Jewett Thompson Arnott EPT-07 EPT-08 EPT-09 EPT-10 EPT-11 EPT-12 EPT-13 EPT-14 EPT-15 EPT-J.6 Total Count on Filter 21,800 36,000 58,500 113,600 154,000 71,000 78,000 27,800 19,600 18,800 A.i.rA Liters 10.0 10.0 13.6 13.6 19.0 19.0 17.4 17.4 32.6 32.6 Fibers per ml 2.18 3.60 4.30 8.35 8.10 3.74 4.48 1.60 0.60 0.58 The last two samples (15,16) are somewhat unusual in having an extremely large number of sub-micron particles that giye a grey appearance to the filter. This fact does not, of course. Influence tHe fiber count. ' SM.37IU* f-MI SHELL OIL COMPANY 013507 OATI JULY 17, 1974 TO WESTERN ESP REGION MID-CONTINENT DIVISION MICHIGAN OPERATIONS - MANAGER prom INDUSTRIAL HYGIENIST DEPARTMENT OF OCCUPATIONAL SAFETY AND HEALTH - WOOD RIVER SUBJECT ASBESTOS SURVEY Personal sampling tests were conducted at the Cactus Rig No. 21 on June 3 and Chapman Rig No. 8 on June 4, to evaluate workers' exposure to airborne concentrations of asbestos fibers during mud mixing operations. The six sampling sheets and Bellaire report on fiber counts is enclosed for your files (Enclosure 1). At Cactus Rig No. 21, Mike Porter tossed eight bags of Super Visbestos over a stack of bags to Jack Jensen, and Jensen poured six bags into the hopper with Porter's assistance. Wind conditions were light. The hopper was at a level sufficiently high enough to place the bag opening about a foot from Porter's face while pouring the asbestos. The time involved 5-1/4 minutes. The combined value of the two samples on Porbor (1 and 3) is 11.64 fibers per cubic centimeter. Jenqen's samples (2 and 4) combined to give 1.07 fibers/cc. rort-er's On the Chapman Rig No. 8 site, Emerson Minnie carried six bags of Super Visbestos to the hopper and assisted Dennis Reinwater, who poured the material into the hopper. The wind was strong, blowing across the hopper towards the men. This hopper was about waist high, placing the bag opening about two feet from Reinwater's face. The total time of the operation was five minutes. Minnie's exposure (sample 5) was 1.99 fibers/cc, and Reinwater's (6) was 0.67 fibers/cc. 013508 Designation EPT-01 EFT-02 EPT-03 (1st count) EPT-03 (2nd count) EPT-04 EFT-05 EFT-06 Total Count on Filter 25,800 6,700 112,000 81,000 4,500 19,900 6,700 Air, Liters 8.0 8.0 2.5 2.5 2.5 10.0 10.0 Fibers/ml Air 3.2 0.8 44.8 32.4 1.8 2.0 0.7 013509 AIRBORNE FIBER COUNTS for Shell Oil Company At Various Locations Near Traverse City, Michigan November 18, 1974 Samples Collected And Analyzed By: E. J. Kleber Union Carbide Corporation Union Carbide Corporation Mining and Metals Division Niagara falls. New York , tr OBJECTIVES Determine the concentrations of airborne asbestos fiber generated during the use of New Granular Supervisbestos at a number of Shell Oil Company drilling rigs. OPERATIONS MONITORED Air Samples were collected September 24, 1974 at three drilling sites on Shell Oil properties known as Cactus #16, Cactus #21, and Cedco #37. 25 sacks weighing 50 pounds each were dumped at each location. DESCRIPTION OF LOCATIONS AND SAMPLES COLLECTED 1. Cactus #16 - This location featured a mixing hopper with top about 3-1/2 ft. above the ground. Sacks were transported from the back of a truck located approximately 20 ft. from the hopper (Figure 1). Nine air samples were collected at this location; environmental (stationary) samples located 3-1/2 ft. off the ground, 7 ft. downwind from the hopper, were taken before the test, during the first dumping operation, between operations, during the second dump, and after the tests were complete. Personal breathing zone samples were collected from both operators during each of the two dumping operations. Sampling time included transportation of the sacks from truck to hopper, a distance of approxi mately 20 ft. 12 sacks were dumped in the first operation and 13 in the second. 2. Cactus #21 - The drilling rig operation was essentially similar to Cactus #16 with one exception. Asbestos was added to a hopper which was located in a mud house approximately 7 ft. x 7 ft. x 6 ft. The mud house was open on three sides, however, and the breeze was blowing throughout the test (Figure 2). Eight samples were collected at this location. Environmental (stationary) samples were collected 3 ft. from the hopper in the mud house during the first dumping operation; one between operations, one during the second dump and one after the completion of the operation. Personal breathing zone samples were collected from both operators during each dump. As in Cactus #16, sampling time included transportation of the sacks from truck to hopper, a distance of approxi mately 30 ft. 12 sacks were dumped in the first operation, and 13 in the second. 3. Cedco #37 - The drilling operation was essentially to Cactus #16 in that the hopper was outside and entirely exposed to the elements (Figure 3). One major difference in this test was that all 25 sacks were dumped at once. Three samples were collected at this rig. An environmental, located over the hopper, was collected upon completion of dumping. One had been attempted during dumping, but mud "blow back" spurted up from the hopper and destroyed the filter. Personal breathing zone samples were collected.from both operators during the dump. All 25 sacks were dumped at one time in this operation and, again, sampling time included sack transportation, a distance of approximately 20 ft. GENERAL CLIMATIC CONDITIONS 'y The test at Cactus #16 was marred by a sporadic light rain. The day improved slowly to scattered clouds by the time the tests ended. Temperatures hovered around 50 all day with a very gusty wind 10-25 mph. EQUIPMENT AND PROCEDURE -2- 013511 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.93a, using the Bayer, Zummalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type) calibrated to 2 liters per minute were used to collect personal breathing zone and environmental samples on millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Vicker's phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS Reported as fibers greater than 5 microns in length per cubic centi meter of air sampled. A fiber is defined as a material having an aspect ratio greater than 3:1. INTERPRETATION The OSHA regulations have been established with a limit of 5 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8hour time-weighted average (TWA). The formula C-jT^ + CgTg + CnTn describes ------- ITT------- time-weighted average where C = fiber count in fibers/cc and T = time. The 8-hour time-weighted averages calculated below have been based on the assumption that New Granular Supervisbestos will be dumped only once a day. Also, due to a lack of sampling time available, environmental samples have been used in place of the normal personal breathing zone samples. They are noted and explained in each calculation. 1. Cactus #16 Calculations based on two personal breathing zones samples for each operator (M-9 and M-24 for David Kniss and M-8 and M-23 for Carl Wind) and two environmental samples (M-7 and M-20). Sample M-20, taken after completion of the test, was used to approximate the exposure during the bulk of the day. A) David Kniss (3.7)(5) ^ (0.4)(15) (2.2)(6) + (0.2)(454) 480 * 0.27 fibers/cc TWA B) Carl Wind (5.7)(5) + (0.4)(15) + (3.9)(6) + (0.2)(454) 480 0.31 fibers/cc TWA 2. Cactus #21 -3- 013512 Calculations based on two personal breathing zone samples for each operator (M-16 and H-8 for Don Gustafson and M-22 and D-45 for Mike Jewett) and two environmental samples (M-18 and 1-8). Sample 1-8, taken after completion of the test, was used to approximate the exposure during the bulk of the day. A) Don Gustafson (6.7H9) (0.31(20) + (2.1)(9) + (0.31(442) 480 =0.45 fibers/cc TWA B) Mike Jewett (8.3)(9) (0.31(20) (2.3119) + (0.3)(442) 480 =0.49 fibers/cc TWA 3. Cedco #37 Calculations based on one personal breathing zone sample for each operator (1-37 for Donald Thompson and J-23 for George Arnott) and one environmental sample (M-21) which was used as exposure for the bulk of the day. A) Donald Thompson (1.91(15) + (0.41(465) 480 = 0.45 fibers/cc TWA B) George Arnott (0.71(15) + (0.41(465) 480 =0.41 fibers/cc TWA SUMMARY OF FIBER COUNTS 013513 Sample No. M-14 M-9 M-8 M-5 M-7 M24 M-23 M-25 M-20 M-16 M-22 Sampling Time 13 min. 5 min. 5 min. 6 min. 5 min. 6 min. 6 min. 7 min. 13 min. 9 min. 9 min. Description Fibers/cc >5x Cactus #16 Environmental - Located 3-1/2 ft. off ground, 7 ft. downwind from hopper prior to test. 0.1 Personal - Operator (David Kniss) transporting 6 bags of New Granular Supervisbestos (NGSV) from truck to hopper and dumping them in. 3.7 Personal - Operator (Carl Wind) transporting 6 sacks of NGSV from truck to hopper and dumping them in. Sample run simultaneously with M-9. 1.4 Environmental - Located in same position as M-14 during first test (M-8 and M-9). 1.8 Environmental - Located in same position as M-14 between runs. 0.4 Personal - Operator (David Kniss) transporting 6 sacks NGSV from truck to hopper and dumping. Sampling time includes trans porting empty sacks to pit, a distance of about 30 ft. 2.2 Personal - Operator (Carl Wind) transporting 7 sacks NGSV from truck to hopper and dumping. Sampling time includes transporting empty sacks to pit, a distance of about 30 ft. Sample run simultaneously with M-23. 3.9 Environmental - Same location as M-14 during second test (M-23 and M-24). 1.3 Environmental - Same location as M-14 after test. 0.2 Cactus #21 ' ' i & Personal - Operator (Don Gustafson) trans- ' porting 6 sacks NGSV from truck to mud house and dumping them in. 6.7 Personal - Operator (Mike Jewett) transporting 6 sacks NGSV from truck to mud house and dump ing. Sample run simultaneously with M-16. 8.3 Summary of Fiber Counts - Continued Sample No. Sampling Time Description 0X3514 Flbers/cc M-17 10 min. Environmental - Located in mud house, 5-1/2 ft. off floor, 3 ft. from hopper during test (M-22 and H-16). 0.4 M-18 20 min. Environmental - Same location as M-17 between tests. 0.3 H-8 9 min. Personal - Operator (Don Gustafson) trans porting 7 sacks NGSV to mud house and dumping. 2.1 D-45 9 min. Personal - Operator (Mike Jewett) trans porting 6 sacks NGSV to mud house and dumping. Sample run simultaneous with H-8. 2.3 K-ll 8 min. Environmental - Same position as M-17 during test (D-45 and H-8). 1.6 1-8 13 min. Environmental - Same position as M-17 after 0.3 test. Cedco #37 1-37 15 min. Personal - Operator (Donald Thompson) hauling 13 sacks NGSV from truck to hopper and dumping. 1.9 J-23 15 min. Personal - Operator (George Arnott) hauling 12 sacks NGSV from truck to hopper and dumping. 0.7 M-21 13 min. Environmental - Located directly over the hopper, after test. 0.4 FIGURE 1 013515 W' Disposal Pit C ACTUS 16 FIGURE *2 013516 Truck CACTUS 21 FIGURE 3 H t Mud Additives Storage Area 013517 CEDCO 37 R C. ). J *i *in AH I MIWIIIAr. |>I|. hl'HHM T*l* Dome Petroleum Limited P.O. Box 200 Calgary, Canada T2P 2H8 013518 267 3910 (AKA 401) July 29, 1976 Montello P.O. Box 130 Sand Springs, Oklahoma U.S.A. 74063 Dear Sirs: Re: Super Visbestos Please send one complimentary copy of "Airborne Asbestos Dust Concentrations in Drilling Fluid Operations" to the attention of W. R. Bohdan at the above address. Yours very truly DOME PETROLEUM LIMITED /el industrial An environmental testing service supported by the most advanced testing facilities The Occupational Safety and Health Act of 1970 (OSHA) has created increased awareness and con cern on the industrial scene. To implement this act, certain rules and regulations pertaining to Occupa tional Health and Environmental Control have been promulgated by O.S.H.A. These rules and regulations state specific limits of employees' exposure to haz ardous substances and what action must be taken to achieve compliance as related to acceptable industrial hygiene practices. The Mining Enforcement and Safety Administration (MESA) administers certain functions under the Federal Metal and Non-metallic Mine Safety Act and establishes other rules and regu lations pertaining to air quality standards. The NGC Research Center maintains and operates Environmental Laboratories at 1650 Military Rd., Buffalo. N.Y. The most up-to-date laboratory facilities and testing procedures are used by highly trained technical personnel in determining in-plant environ mental problems. The Environmental Laboratories take great pride in its expertise in developing data and in providing analyses for its clients. Specifically the NGC Research Center can perform the following services for its clients to establish com pliance with OSHA and MESA regulations: 1. Comprehensive base-line airborne contaminants studies can be conducted at the clients' plants. Qualified NGC Research Center personnel meet with the client to decide which points of operation should be included in the survey. Appropriate per sonal monitoring and high volume samples are taken to ascertain the level of worker exposure to airborne contaminants. Samples returned to the Environmental Laboratories are analyzed and com plete reports of findings are sent to the client. 2. Capabilities include the following: a. Asbestos, fiber count--the asbestos concentra tion is determined by in-plant monitoring pro cedures and laboratory evaluation with fiber counts being conducted by up-to-date phase con trast light microscopy. b. Gravimetric Dust-samples of dust are collected in the clients plant with personal or high volume monitoring devices. The gravimetric analysis of these samples are correlated with sampling data to ascertain the level of airborne contaminants. The procedure is particularly adapted to mineral Send for our literature on Noise Control Environ mental Testing Services. Chemical analyses, including trace elements, conducted using Atomic Absorption Spectrophotometer. dusts such as quartz, mica, talc, clay, Portland cement, coal dust, limestone, lime, gypsum, etc. The procedure includes both total dust and the respirable fraction. c. Quartz--quartz concentrations are determined by X-Ray Diffraction. The quartz content of dust is generally used to determine if the dust is classi fied under the silica or the nuisance dust regu lations. d.Test methods may be developed as required to provide proper analytical procedures for those complex mineral substances or mixtures often times encountered in today 's processing technology. e. X-Ray Diffraction and atomic absorption analyses are conducted for determination of mineral com position and trace element content. 3. In the event the client has sampling capabilities, collected samples can be sent direct to the NGC Research Center for analysis. Open accounts can be set up for receiving the clients samples on a routine as-received basis. 4. Special problems can be reviewed and capabilities resolved. For further information and current fees, contact: Director of Technical Service NGC Research Center 1650 Military Rd. Buffalo, N.Y. 14217 716 873-9750 013521 Asbestos fiber counts are made on specially prepared monitor filter using Phase Contrast Microscopy. Ultrasonic probe used in the preparation of dust specimens for quartz and mineral composition determination. Special sample preparation and analyses by wet chemical procedures are conducted in this analytical laboratory. 013522 Inefficient dry powder packers are a common source of airborne dust. Transfer of minerals in mines could result in release of airborne dust. Crushers and conveyors are typical points of operation in a mine which generate airborne dust and require monitoring. Monitoring worker exposure to airborne dust at a rock pulverizing operation. High volume and personal samples of dust being obtained near a rock dryer. NATIONAL GYPSUM COMPANY RESEARCH CENTER Buffalo, New York 14217 AIRBORNE FIBER COUNTS for Montello, Inc. at Universal Resources Corporation Dannehl 2-16, N.W. Richland Canadian Company, Oklahoma Date Sampled: July 1 & 2, 1975 Date Reported: August 13, 1975 013523 Samples Collected By: H. B. Rhodes Union Carbide Corporation Samples Analyzed By: B. L. Ingalls Union Carbide Corporation Reported By: H. B. Rhodes Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York objectives 013524 To measure the airborne asbestos fiber count during the following operations: 1. Unloading of bentonite, Flosal asbestos, and crushed Super Visbestos (not overwrapped) from a truck and hand stacking in a mud house. 2. Rapid addition of 8 bags of Flosal to the mud hopper. 3. Rapid addition of 8 bags of crushed Super Visbestos to the mud hopper. OBSERVATIONS This air sampling was done in conjunction with tests to determine the characteristics of the new, wetted Flosal when it passed over the shaker screen. Conditions were typical of rig operation except that the amount of asbestos dumped in each case was several times the 2-3 bag quantity normally used. Unloading the Delivery Truck In the truck unloading tests, the material was delivered to the site in an open-bodied truck. The truck was loaded nearest the cab with 20 bags of crushed Super Visbestos, followed by 20 bags of the new (wetted) Flosal, and by 110 bags (100 lbs. each) of Wyoming bentonite. All bags were stacked five high on pallets *vV wide x 2-1/2* long. The mud house was about 10* x 20* x 9* high with doors in each end. The truck backed up to^8* from the door. One man unloaded the bags individually from the rear of the truck, carried them on his shoulder into the mud house, and stacked them about 10 high along the walls. The helper moved the pallets to the rear of the truck as needed. The Super Visbestos was carried through the mud house and stacked against a water tank about 6* from the far door. It was observed that each time a bag of SVB was lifted, there was a puff of dust from the spout. The same thing happened when it was dropped on the stack Personal samples were taken on both the driver and the helper during the handling of each of the three materials. Preparation of Cleaning Slug The mud hopper was located in the rear corner of the mud house directly adjacent to the door. It consisted of a 55-gallon drum equipped with a 2* pipe running up the center and extending about one foot above the top of the drum. The pipe had a valve at the top and a tee at the bottom of the drum. The downward side of the tee was connected by an equal diameter rubber hose about 20* long to an aspirator. _ When ingredients were to be added, the mud was circulated by a pump through the aspirator. The vacuum created pulled the dry material out of the mud hopper, through the hose, and into the liquid passing through the aspirator. -2- 013525 When the Flosal was added, the operator removed each bag from the stack, slit the end, and emptied it into the hopper. The empty bags were tossed outside the door. It took about three minutes to empty eight bags. The operator then used a shovel to push the material held up around the sides into the hole. The bags were then gathered up and taken about 100 feet to a trench for disposal. No visible dust was generated during the handling of the Flosal. A personal sample was taken on the operator during the dump. Area samples were taken adjacent to the hopper before and after dumping. A personal sample was also collected on an observer standing approximately three feet from the door during the dumping. The Super Visbestos was added in the same manner as the Flosal. After about half of the bags were dumped, the hose plugged leaving about three bags in the hopper. The hose was blown out at the mud pits and the remaining asbestos was transferred. Personal samples were taken during the dumping on the operator and on an observer standing approximately three feet from the door. The sampler was removed from the operator (at his request), however, while the plugged line was cleaned out and during the transfer of the final portion of the Super Visbestos. Area samples were collected before, during, and after dumping. A personal sample representative of general area asbestos exposure on a drilling rig was also collected. - SAMPLE EQUIPMENT AND TEST PROCEDURES 013526 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zummalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Miliipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If tremolitic talc is present in the sample, the tremolite "chips'' and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, . - having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 5 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). This allowable level-will be reduced to 2 fibers/cc on July 1, 1976. The formula C^T-j + C^T^ + CnTn describes the TWA where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS . The details of sample collection and resultant fiber counts are listed in the attached table. UNIVERSAL RESOURCES CORPORATION RIG SUMMARY OF FIBER COUNTS 013527 Sample No. Air Sample Time Minutes Operation Description Unloading Bentonite, Flosal, and Crushed Super Visbestos 7/1/75 B-63 10:22-10:53AM 31 Personal sample (Robert Wall). Truck operator unloading 110 bags of Wyo ming bentonite (100 lbs./bag). Hand carried about 20' and stacked along wall of mud house. B-77 10:56-11:06AM B-83 11:08-11:15AM 10 Personal sample (Robert Wall). Op erator unloading 20 bags of Flosal asbestos. Hand carried about 20' and stacked along wall of mud house. I 7 Personal sample (Robert Wall). Opperator unloading 20 bags of crushed Super Visbestos (notshrink filmed). Hand carried about 30' and stacked against water tank beyond far door of mud house. Airborne Fiber Count (fibers/cc >5y) Chrysotile Total Asbestos 0.3 0.3 0.3 0.3 4.5 4.5 A-83 10:25-10:54AM 29 Personal sample. Helper(Harold Willson) during unloading of bentonite. 0.9 B-67 10:56-11:04AM 8 Personal sample. Helper (Harold 6*8 Willson) Removes bags of Flosal from Super Visbestos. Moves Flosal pallet to rear of truck. Flosal pallet falls on floor of truck. B-66 11:07-1:15PM 8 Personal sample. Helper (Harold Willson) during unloading of 20 bags of crushed Super Visbestos. Rolls pallets (5 high) from front to rear of truck. Adding Flosal to the Mud System 7/1/75 * 1.3 B-87 11:25-12:23PM B-74 12:25-12:30PM 58 Area sample. Two feet to right of 0.2 mud hopper, 2-1/2' above, approximately 5' above floor. 5 Personal sample. Observer (HB.Rhodes) 0.8 standing outside door adjacent to mud hopper during dumping of 8 bags of Flosal. 0.5 6.8 1.3 0.08 0.8 Universal Resources Corporation Rig Summary of Fiber Counts - Continued 013528 Sample No. Air Sample Time Minutes Operation Description Airborne Fiber Cou (fibers/cc >5u) Chrysoti Total Asbesto B-76 12:25-12:30PM 5 Personal sample. Operator (Dale Mull) 2.1 dumping 8 bags of Flosal into mud hopper and pushing into suction line with shovel. 1.3 B-65 12:36-2:08PM 92 Area sample. In mud room after Flosal 0.1 dump. Same location as B-87. 0.02 Addition of Super Visbestos to the Mud System 7/2/75 B-73 11:49-12:02PM 13 Personal sample. Operator (Dale Mull) 1.8 adding 8 bags of crushed Super Visbestos (not shrink-wrapped) to mud hopper. Stirring with shovel to aid in suction pickup. 1.8 B-80 11:49-12:02PM 13 Personal sample. Observer (H.B. Rhodes) 0.9 standing outside door of mud hopper dur ing dumping of crushed Super Visbestos. 0.9 B-61 11:10-11:48PM B-62 B-84 B-58 11:49-12:04PM 12:26-12:52PM 12:10-12:51PM 38 Area sample. In center of door, 6" 0.1 inside, adjacent to hopper, 3' above and 3' to side of hopper. Prior to Super Visbestos dump. 15 Area sample. Same location as B-61 dur- 1.0 ing Super Visbestos dump. 26 Area sample. Same location as B-61. 0.05 After dump. 41 Personal sample. Observer (H.B.Rhodes) 0.07 in rig and mud pit area. 0.0 1.0 0.05 0.07 013529 Johns-Manvilie Corp., bestos said the company hadn't been In formed of the suit yet, but added that Four Others Are Sued "it wouldn't surprise us much." He said Cassiar and certain other producers are codefendants in a similar suit brought Over Asbestos Hazards by a Dallas woman. That silt has been pending for more than a year, he said. "The principle in the Raybestos ac tion would appear to-be the same one in NEWARK, N.J. (AP) - Johns-Manville volved in the Texas silt--namely that Corp and (our other asbestos makers were the plaintiff casts a wide net over any charged in a civil class action suit with neg one who has ever supplied the asbestos ligence leading to illness and disability of at fiber that he or she worked with," the least 163 former employes of Raybestos- official said. He said .the producers Manhattan Inc. doubtless also will decide to'" defend the The employes, who worked at a plant in latest suit "vigorously.'' ' Passaic, N.J., charged in a nit filed in fed None of the 'Other defendants in the eral court here that the five asbestos mak silt could be reached Immediately for ers supplying material to. the plant were comment.] negligent in failing to provide adequate Bach worker asked for 11 million in com waming of the health hazards of their prod pensatory damages and 11 million in puni ucts. tive damages, or a total of 1336 million. The suit charges that Johns-Manville, Raybestos made brake shoes at the Denver, Ook).; Asbestos Corp. of America, plant, which was closed in 1173, The closing Garwood, N.J.; and three Canadian con was widely publicised because many work cerns, Bell's Asbestos Co., Asbestos Corp. ers were dismissed only a few years' short and Caspar Asbestos Ltd., ignored scientific of retirement age and didn't receive any data and medical evidence that should have pensions. prompted them to take more stringent Karl Asph, attorney for the plaintiffs, safety measures. ' said most of the workers also have filed The suit also charges that the companies Workman's Compensation claims against and Metropolitan Life Insurance Co., in ef Raybestos. He said the 163 plaintiffs have fect, "warranted that their asbestos prod sidfered various Injuries up to full disabil uct^ were safe and fit for use." Metropolitan ity. -In the stft, the plaintiffs say they were Life advised the companies on employe- exposed to the risk of cancer, asbestosis, safety hazards. sarcoma, mesothelioma, scarred lungs and [In Toronto, an official of Cassiar As other illnesses. PHONE : 74749 - 776147 DRBSSCR CABLES : DRESSER JAKARTA DRESSER MINERALS INTERNATIONAL INC. P.O. BOX 27/JKT. JAKARTA INDONESIA 013530 May 25, 1976. Marketing Manager Montello, Inc. P.O. Box 130 Sand Springs, Oklahoma 74063 U.S.A. Dear Sir: Attached is a newspaper article expounding upon the perils of asbestos. This type publicity is becoming an increasing detriment to the sales of your product. Super Visbestos. Will you please provide all possible assistance to show that this material is not a health hazard? Information must be legitimate and be from internationally recognized research laboratories. In the enclosed article the author, Mrs. Nancy Tait quotes "Wet dust does not become airborne and is not inhaled". Since this lady is so dedicated to her research, may I suggest that you write to her for her approval of your product. A letter from an individual such as she could be worth more than all the reports from governmental agencies combined. Please act quickly on this matter for it is curtailing our sales. In fact, we can not afford to order additional material until we can convince our warehouse people and our customers that it is not a health hazard. At this time we cannot do this for I do not know if it is safe or not. We anxiously await your reply and literature. Sincerely yours. Enel.: JEH/es Jerry E. Haston Area Technical Service Engineer 013531 June 4, 1976 013532 Mr. Jerry E. Haston Dresser Minerals International P.O. Box 27/JKT. Jakarta Indonesia Inc. Dear Mr. Haston: Thank you for your letter of May 25th, with the enclosed article about asbestos. That article is an almost classic example of in accurate, irresponsible, "scare tactic" journalism. Such sensat ionalism is a reprehensible and scandalous disservice to a trusting public, by an unprincipled newspaper whose only possible motive is financial gain through expanding circulation. It would take a book to fully clarify the concoction of half-truths on which Mr. Toulson bases his ridiculous but attention-getting headline. We will attempt to offer certain facts which we hope will provide you with a more balanced view of asbestos usage than the highly inflammatory and slanted one which Mr. Toulson has promoted. First, it has been recognized for many years that a group of respiratory diseases are related to asbestos. It is also known that these gen erally result from inhaling excessive amounts of asbestos dust over a long period of time, (20 to 40 years). Typical industries where a measurable increase of such disease is noted, are ones where workers were regularly exposed to high dust levels on a daily basis for many years. As you know, workers exposed to asbestos in the drilling industry are only handling the material for a few minutes of each day, and they rarely if ever would have the job of "dumping" for half or more of their working life. Put another way, the exposure of workers in our industry is minute, compared with that of industries (i.e. mining, fabricating, insulating, etc.) where a measurable incidence of asbestos related disease has been found. In 1972, stringent regulations were passed in the U.S., which called for a maximum ceiling limit and a time-weighted average for exposure of workers to airborne asbestos dust. These limits were based upon the concept of dust levels at which it was felt there would be no demonstrable risk to health. The regulations are still in effect. P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 Mr. Jerry E. Haston June 4, 1976 Page 2 013533 At that time, we co-sponsored a series of field tests to monitor the dust levels associated with drilling applications. A copy of those results is enclosed for your consideration. On the last two pages, you will note that in every instance, the levels found were far below the Federal standards. Subsequent monitoring tests have borne out these findings. To further minimize the possibility of health hazard, our product (Super Visbestos) is in the form of crushed pellets. This is a substantial improvement over the dry ground, fluffy materials some times used. In addition, all of our production is in individually shrink filmed bags. This nearly eliminates "dusting" in the course of shipping, handling and warehousing. All this, coupled with the sporadic and short term exposure of workers in the drilling industry, should fairly lead one to conclude that the data on health risks associated with heavy, long-term exposure cannot be properly applied. Mr. Toulson is quite right on one point. With its thousands of commer cial applications, asbestos does indeed surround all of us. Fortun ately, his likening it to spray of machine gun bullets is pure rubbish Proof of his fallaciousness is not hard to find - - - our homes and offices and plants and streets are filled with people - - - not bullet riddled bodies. In conclusion, we will mention that we have worked closely with your own safety people in Houston. At present the appropriate Dresser office is headed by Mr. H. Robert Moseley, Jr. of the Petroleum and Minerals Group. You may wish to contact him for additional intra company information. We hope we have been of service to you, and are indeed sensitive to the problem you raise. It is most unfortunate that writers of Mr. Toulson's ilk are typically rewarded for such unwarranted and cavalier disservice to the public. Sincerely, MONTELLO,INC. Kenneth N. Campbell KNC/wj Enc. (1) & 013534 the wall street journal, Thursday, Oct 2, 197S = ........... New Rules on Worker Exposure to he i"V. - r1 kc1 / \ V- > WtU. tTMtt rJ ^srss| WASHrifQTON-Ths proposed n*W and rcvtsed Aids bmlttas; worker ^ Widely usedInduStfUt ' " to ttnt and setting' procedures for handBnfe li toxic chem- leal*. ,, . V,"i: f t the hewstaadards^cut in half tS* p*r- . TOissible exposure tolead and toluene, ` rafctriaT chemical, and reduce kfjjr *6 [amount of asbestos fibers permitted In' afr ft work placet, II |p estimated SO,000 worker* are inv< 1 manufacture, of product* containing mMp*. The department tamed ita/Bwi atafdard controlling asbesUw* which ' lung cancer and other aertotR^ph , in mid-lOW. The ndw proposed steftdardk will appear in the Federal Register. Before they become final, the Labor Department will re,ifeamputate commenta anthem, emflMh-., ffinB and tafiationary Impact statemasih, yiinj|||| hold public hearings*; , gif fte revised asbestos standard skew* worker* to be erpeed to an averages AS flher a cubic centimeter of air afar any eight-hour periodhutead of the prtssed limit of five fiber* a ,cubic centimeter of air. The staiidaid define** fiber as a parttdaTof aa- beatoa longer than fiv% inlcrometers.' A worker couidnVk* exposed* .more than five fiben a epic centimeter * air over any lb-minute period. The new level* alao are than a previouaty planned aid that would have cut girudM Mxtyearto two dar of air, average* ' , . era to retain employe year*, or for the duratkjtt career plus 30. year*. regulations require teat' kept for only three year* and others for SO year*. ` The tighter rules ter asbestos exposure wouldn't apply to tea construction industry, which would operate under present stand ards until a special set of revisions for that industry Is developed. The department said workers could be exposed to asbestos on Jobs in construction, shipbuilding, auto man* ufi ` ` ' ' 12 The Northern Miner December 11.1975 Tlortbni TTltner 013535 Asbestos and health .'iJF - ->v answered By J.D. CHRISTIAN speak pf^asbestaar. WCarKthere-1 (2) Bronchogenic cancer - The Chairman fibres? What percentage is being' fore, really talking about the fibrous ' is now medical evidence to indica Cassiar Asbestos Corp.* |discharged by my body and what' forms of rocks which are quite com- (hat asbestos exposure is associau I recently received a letter from ; percentage is being retained? If 1 am mon throughout thne world. The' widr an increased frequency ,,an associate of mine that prompted ; unfortunately going to contract as- commercial asbestiform amphib- bronchogenic cancer in worke me to speak to you-on the very im j bestosis. is there any cure for this? oles are largely found and mined in who have first developed asbestos portant and currently topical sub What is happening to me with as- South Africa and Brazil, whereas At the present time, we do not kne ject of "Asbestos and health". Let bestosis? the chrysotile variety of serpentine ` what causes the cancer, whether it me read you his short letter -- you I happen to live in Toronto. What b more widespread and is found in the chemistry of the asbestos, the may well have the same thoughts in is tpy mortality rate living in this city most countries of the world. The brous nature of the material. mind; as compared to Thetford or Sud- fact that asbestos fibres are very something else quite unrelated, Dear Mr. Christian: I have been pondering over this question of the health hazards ofas bestos and putting myself in the pm sition of an asbestos worker or a cit izen living in an asbestosdominated community. Here are buty or for that matter Regina?, I ' strong (similar to high tensile steel), you arc aware, there are many oth j would pose the same questions with i and can be broken down to ex- known carc'inogens, w.h..i.c..h....in...c.lu i respect to particles of fibre coo tremely fine dimensions (1.000th coal tar_ benzidine, tobacco, vin ! tained in volumes of water as 1 did the diameter of a human hair). chloride, x-rays and even sunshir . above with respect to air. . . . makes it a very useful material for These, along with asbestos, are cl Over a lifetime, what kind of ' reinforcing cement plastics . and rently the subjed of a great deal weight of fibre are we actually talk rubber, or it can be spun or woven research. You will also be inrterest' some questions that 1 might be ' ing about? Is it visible to the naked into yarn or doth'for dutch facings, ny. prone to ask. I'm bringing these - eye. even over a lifetime? Life is fi brake linings and protective related lungxancers have bet questions up as I think that the ma nite. but 1 don't want to die pie- dothing.* " ' found in workers Who are nor terial that has been put forth both maturely. What assurance can you Wb/ls it so dangerous?, cigarette smokers and do not ha' by the press and by the industry Is so offer me as a potential employee in highly technical that the true mean your operation that I am not going first of alLlet me say thatitis not ashesiosis. This fact has been wt documented by a number of r ing or significance of these reports is to unnecessarily shorten my life? searchers. being lost on the man in the street Yours sincerely. (3) Mesothelioma -- Mesolhe and instead he is being fired with anxiety by the sensationalism ofjar-, , This is a very sincere letter from a gons that are over his head. . . ! deeply concerned person. I have What is asbestos? Whafkinds are | replied to the best ofmy ability and there? What are the differences be-' I would like to read what I said. tween the different types of fibre? 'DearMr.X: . . . : . years, nave been touna to exist arc broadly associated with the in halation of large quantities of fibre oma is one of-those rare ai newly recognized cancer diseas and {s a malignant tumor of the li over prolonged periods of time, and ing membrane f the chest and a 1 mean 15-20 years or more. During dominal cavity. By no means arc. processing some of the fibres be such tumors associated with ? Where do these fibres come from? ' It has been made to sound like a Thank you for your very thought-' fid letter. You will appreciate that J come very fine, and without.proper dust control will readily flout mite bestos. .bu.t w.h.er.e a relationshi-p be established, the exposure c. h poison similar to arsenic. Why is it am not a medical doctor, nor a air. Naturally, some orthese will be! ?*rcty been procidil.te (blue . so dangerous? What makes h so scientist and that the opinions and dangerous? What Is happening in facts, that ! can give yen iarcply to the body when excessive amountsof your questions, have been gleaned asbestos-are taken in? What is hap pening to me when I have asbestos particles in my lungs or in my stom* ach or in my digestive tract? Is it dangerous to touch? Can it do me harm just by handling the material? What is. the meaning of five fibresper ext? We have trouble as lay people vi sualizing any fibre smaller than a human hair, so when I think of five fibres I think of five short pieces of hair inside a thimble. If I was to in hale 5.000.000 c.c of air per day. then I must "be consuming 25.000.000 fibre particles per day.. -v * From Mr. Christian's address to shaiehoWcrs at the 23rd annual neetiigef Cassiar AsbestosCorp. in April tbityear,' There have not beta any technical developments since that date u change the context of the report. Mr. Christian has informed The Northern Miner, , from studyingpublished reports from the medical and scientific world. As you. have expcessed-confusion over the use of highly tech nical terms and numbers. 1 will at tempt to express myself in everyday language, even though it may be at die expense of absoluteaceuracy. What is asbestos? The term ^asbestos" applies to all minerals which have one common attribute, namely, the ability to be separated from the parent rock in the form of a fibre. Chiysotile as bestos is die fibrous form of ser pentine rock and represents 95% of the world's commercial fibre pro duction. iCrocidilite and amosite are ihfc most important fibrous forms af another rod known as amphibtde, 'These types ofasbestos have sfighdy different jchctrifcal and * * * than cnpHt: Wbafsire the asbestos diseases? _ There arc now three recognized vestigation of-thc 236 known cas of mesothelioma -in Canada b diseases: - " (1) Asbestosis -- Thu is one vari ety of the lung disease called "pneu moconiosis". It is a progressive fi brosis of the lung, which cairmakc breathing difficult and can lead to other disabilities.'Occurrences have been dearly related to prolonged in tween 1960 and 1970 showed th only nine were associated in a> way with the Quebec chrysoti mining and 'milling industry. Sev men had been employed and tv were women whose fathers workin the industry. ' . halation of respirable sized fibres The McDonald report over a period of many years. Those A group of veiy capable Car cases of asbestosis which are ap dian doctors and scientists ha- pearing today are the result of ex-, since 1966 been studying the histo posure to heavy concentrations of of 11.572 persons born betwe. asbestos dust prevalent many yean: 1891 and 1920. who were or *re si ago. when little was known about i employed in the Quebec asbest the risks involved.''!t has been- mining industry. They have fou; shown that when tbc tevd of ex-j that the industry has a lower me posure is reduced, the incidence of] tality rate for prople of comparab asbestos* is alto reduced. V '' { ace than fee general population Quebec Hence within the indust group those who had a long histo 013536 of exposure to the two highest dust be under control and the risk of pre classifications showed a higher mature death or impairment of death rate from respiratory cancer health is very remote indeed. and pneumoconiosis than the Asbestos from our Cassiar and others. The studies are continuing Clinton mines is used for the great and the report encouragingly sug est part in the asbestos-cement in gests that a 1% risk of acquiring a dustry. followed by the asbestos tex clinically significant disease over a tile industry.'and to a much lesser working life 'of 50 years in an as- degreeln the manufacture of filters -vfcestos mine can lie achieved by compressed sheet packing.' rein maintaining threshold levels of 2-4 forced plastics, and so on. Of these.' million particles per cubic foot the textile industry, which until re Possibly. I should at this point tell cently was exclusively a dry carding you about the two methods of mea spinning and weaving process, has hazard" as "something which may Amongst insulation workers possibly occur", even though they the United States and the Unin are unable to produce any evidence Kingdom, particularly those wl. to support their contentions. No one worked in the dockyards during th denies that there have been - and war years, some very serious heali still are - problem areas. The world conditions have been found an today is faced with many, many ably researched and reported upo problems, all of which must be It is a sad story, and the result of viewed in their proper perspective, lack of knowledge at the time at and "panic" reporting and "panic" possibly the exigencies of the w legislation is not the answer. The as yean. Very valuable lessons ha bestos and other industries are been learned which will be of grt working hard to correct the con* benefit in solving the problems ditions which arc thought to create a ' flic present and th; fdrore suring the dust. The impinger had some comparatively serious method sucks in a givqn amount or dust problems. air and the fibre and dust particles In the early 1930s. in a particular present impinge on a treated glass textile factory in the United King * slide. They are counted undent mi- dom. signs of asbestosis were found crosa>pe a~nd are reported as mil in some 807 of the workers with 20 lions of particles per cubic foot of or more years' exposure. Another air. The newer method is the mem survey in 1957 of the same plant brane filter. A measured quantity of showed that in workers with 20 air is pulled through a membrane years' exposure, after the in filter which removes all the dust and stallation of dust control, the in fibre. In this method only the fibres cidence of asbestosis had dropped are counted and hence it is difficult to 3%. The lung cancer rate in work to relate the two results. This latter ers in the plant exposed to pre-1933 test is reported as the number of fi conditions was at 10 times that of bres in a cubic centimetre of air. the general population, whereas it is Both are highly susceptible to currently reported to be at the same human error. Your thimble is a level as the general population. This End estimate of a cubic centimetre. example clearly demonstrates that t it would take 2.000 fibres placed with experience, and improved tech end to end to span the width of the nology asbestos can oe handled thimble, and the thickness of the fi safely. bres would be many times less than A hazard to the public? the human hair you envisage. You have asked about the risk of The McDonald report on the as living in Toronto, as compared to . bestos mines and mills of Quebec Thetford or Regina. Most of the confirms the results of other studies studies on the relationship of as in the Soviet Union and Italy which bestos diseases, to mortality rates indicate that the risks are much have been carried out in the oc lower in the chrysotite mining and.! cupational field, and before abso milling industry than reported from lutely denying any public health the Ncw.York insulation workerspr. risk, scientists agree tnatmore data the British naval dockyards. must be collected over an extended At our Cassiar mines most of the period of time. However, a number emissions to the atmosphere are ofstudies have already been carried now under control, or in the process out and there is to date no evidence, of becoming so. Inside the build scientific or otherwise, to suggest ings. in spite Of extensive control that anyone in the general public health hazard. Unfortunately, final T*n the matter oT--pub. l-ici.zing an proofwill not be available for 20.30 reporting there is no doubt that it i or even 40 years. In the meantime, far more dramatic and eye-catchin the best that any prudent person can to use headlines such as "AS do ts to continue to research all as BESTOS KILLS*" or for example t. pects of the problem, to analyze the report "TWO MILLION FIBRE: tacts and trends as they become PER LITRE OF WATER-" than t. known, and to set goals and stand report the same thine as approxi ards which will progressively reduce mately 4/l.000ths of a milliontl die element of risk and hopefully part or a gram. Let me put these fig will finally eliminate it entirely. ures to you in another way. If S,00> What is the Industry doing? people agreedto drink two quarts o In addition to the continuous water containing 4.000.000 fibre? development of techniques "and per quart, even day for 80 years equipment to improve dust control, then they -- the 5.000 people - the Canadian asbestos mining in would have swallowed in total om dustiy. through the Institute of Oc- ^ gram of asbestos, which is a cubit cupationa! and Environmental 1 pile a little more than half an inch Health in Montreal, the Industrial ' on each side. Health Foundation in Pittsburgh, and selected hospitals and universi ties, is sponsoring or cooperating in major epidemeologica! and research projects, designed to identify and eliminate'asbestos-related health risks. There is still a great deal of re- ` Whenever I have the opportunity I assure you that I will uree all those who have the responsibility for re searching and reporting to the pub lic. through whatever media it may he1. :t,o remain as factual and*faair in ~seaarc-hhltoobwe.dHonne,. AAc^tivveosctu.Hdieisna.rret also under way in other countries, such as England. South Africa. Italy and Russia. There is already strong evidenceio suggest that the physical aspects (ix_ the length, diameterand stiffness) of a fibre is the real source of trouble, and not its chem-, ical composition. Ifthis proves to be! the case, then certain other fibrous] material may also become suspect and the work currently bring done the,r rcsearch *S possible and to avoid the "half truths". Excellent progress is being made in Canada in improving industrial health and safety, in controlling pollution, and in protecting the environment. Reg ulatory bodies are being established at various governmental levels and in cooperation with industry itselfto measure and control to the best of our combined technical ability those conditions likely to create a measures, there are still some areas has ever contacted any disease from where the wearing of masks, is re exposure to the minute amounts of quired^ These troublesomeareas are asbestos released into the commu under active study and an extensive nity air through the use. or wearing program, designed to-achicve.4he- -or wcathering-Qf finished asbestos best possible threshold levfcls; i* products. bring undertaken. . As far as water is concerned, the your pSinS qSns. Before, **" Sosm*! wouldlike to add a few by all decent thinking people. The most serious obstacle in our Conference of the Internationa! comments ofa general nature. ' Thank you once again for -your path is the shortage of pereonncL L Agency for Research on Cancer. . It has frequently been proposed letter. I hope that I have put things You are already aware nfsorne of held in Lyon. France, in the fall of that asbestos should be replaced by m a little better perspective for you. the serious effects this has had on 1972 -- which I feel should represent production over the past several as 'qualified^>rtd ^uthqrijativc an years. Incidentally; in 20 years of opinion as is available--- provided other types of materials. Thu can and has been done in some products, but in others such substi- - Yours sincerely, i. D. -Christian. operation we have not had one re me following information: tution has been either veiy ex ported case of any of the three as Question: "Is there evidence of pensive. much less effective, or even bestos-related diseases.' but we must an increased risk ofcancer resulting impossible. To foigo the many not be complacent in view of the from asbestos fibres present in benefits of asbestos products.' sim- j long latent period (30-45 years) water, beverages, food, or in fluids ply on the basis of a suspicion of' which can elapse between the first 1 used for the administration of possible hazards, would be irra exposure and the development ofI dragsT tional, and unwarranted. par mesothelioma. This, along with the ] Answer "Such evidence, as there ticularly,, so. when we are Mill ur- Quebec studies, is -the best as is. does not indicate'any . fcertain of the health hazards tint surance we can give any potential You might well ask at. tilts point. ! iriigM arise from many other re -employee that things now appear to j "Ifthis is so. theirwhy the neat hue ' placcinentinateriala. U. and cty?" In the scientific, legal add' bureaucratic world, theri are those who have a craving to. posh (he panic button nnd. who . define "a December 20, 1972 043537 Through OSHA, stringent regulations are now in effect on the use of as bestos. The impact of these regulations on the drilling industry has, until now, been a source of concern and confusion to suppliers as well as users. Several months ago, we at Montello determined to ascertain how our wet processed Super Visbestos would perform, in the context of the OSHA regulations, under the widely varying conditions found on drill ing rigs. With the invaluable assistance and cooperation of several com panies, these on-site tests and their evaluation have now been completed. Attached are copies of the reports on each of four field tests, as well as an interpretive analysis of these reports. Site selection was based on a desire to evaluate the broadest possible range of dumping environ ments. During the tests a radically new granular form of Super Visbes tos was also evaluated. Certain points are worthy of special note at this time. 1. All tests were performed on Montello's exclusive, wet processed asbestos products. The data and results cannot be safely applied, therefore, to any of the several dry ground products on the mar ket. 2. On all tests. Super Visbestos consistently fell well below the present OSHA regulations as to maximum ceiling limit and 8-hour time weighted average. 3. The New Granular form of Super Visbestos proved to be from 20% to 50% cleaner than present Super Visbestos. 4. On no test did either product exceed even the much more strin gent TWA level to be imposed by OSHA, in 1976. 5. Based on these extensive tests under varied conditions, no spe cial breathing apparatus would be required when running either Montello's Super Visbestos or the much cleaner New Granular form of Super Visbestos. We will be pleased to discuss the attached reports with any interested parties in greater detail. Please contact our Sand Sorings office if you have any questions. P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 7#t0) S --1/TWX MOMO-SOOr 1353 AIRBORNE ASBESTOS DUST CONCENTRATIONS In DRILLING FLUID OPERATIONS using WET-REFINED ASBESTOS H. B. Rhodes & E. J. Kleber Union Carbide Corporation Mining and Metals Division Niagara Falls, New York tf INTRODUCTION 013539 A survey has been made to examine the levels of asbestos dust that may occur when wet-refined asbestos is used as an ingredient in drilling fluids. Both open-air and enclosed dumping operations were checked. A range of dumping rates from 10 to 80 sacks per hour was used. Tests were run with two types of wet-refined asbestos: 1. A coarse-ground asbestos known commercially as Super-Visbestos. 2. A new version of Super-Visbestos in the form of 1/8" granular pellets. It is important to emphasize that the dust levels reported herein are specific for the wet-refined asbestos types described and do not apply to dryprocessed Cali forni a or Canadian asbestos. The reports giving the details of the dumping and sampling at four locations and the raw data obtained are appended for reference. This report provides a more general interpretation of the overall results. SUMMARY AND CONCLUSIONS The highest dust level measured during any of the seven dumping operations tested was 1.9 fibers/ml. greater than 5* in length. This is only 19% of the value allowable under OSHA regulations. Time-weighted average values were calculated for all dumps on the basis of one dumping period per eight hour shift. A background exposure value of 0.3 fiber per ml. greater than ^ was assumed in these calculations. The highest TWA found in any of the dumps was 0.4 fibers/ml. greater than 5/<. This is only 8% of the current allowable value and 20% of the projected value for 1976. As would be expected, the new granular product gave much less dust, i.e., 20-50%, than the coarse ground Super-Vi sbestos. CALCULATION PROCEDURES The OSHA regulations permit exposure to a peak fiber concentration of 10 fibers/ml. greater than 5>Kin length and an eight-hour time-weighted average of 5 fibers*. In this work, the peak exposure occurred in the breathing zone of the operator during the dumping and is reported directly as measured. The eight-hour time-weighted average is basically a simple concept that can be expressed as: ^ <|Fibers/ml. in a ~j [Time in hours over which the ~ T.W.A. = Time-Weighted Average = c particular samplej particular sample was collected 8 Where: Summation of samples collected over the 8-hour period. ' . * For convenience, in this discussion the term "fibers" will be taken to mean the entire term, "fibers/ml. greater than 5* in length." & Companies co-operating in these tests are customers of Montello and conducted the tests to ascertain that their use of the product comDlies with standards set forth in the federal Occupational Safety and Health Act. Results of these tests are made available to other companies solely for their use in making their own evaluations of procedures to be followed in using the material. No representations are made, nor are to be implied, from this report as to the safety of this material no matter how it is used. -2- 013540 In order to be strictly correct, it is necessary to sample over the entire eight-hour period to define the TWA. In these tests, however, only ashort post-dump sample was obtained. Normally, at a well, an operator dumps for a short period once a shift (or tour) and spends the remainder of the time out of the immediate dun: area. It is thus reasonable to estimate the TWA for the operator as a contination of the peak (measured) exposure during the dump and a background exposure for the remainder of the shift. The data obtained in this work indicate a reasonable and probably conservative (high) value for the background is 0.3 fibers. This number will be used in the calculation of eighthour TWA values. The airborne asbestos concentration measured in the breathing zone of the operator results from a balance between the rate of generation of airborne fiber by the handling of the asbestos and the rate of dissipation into the surrounding region. If these rates are in equilibrium during the dumping period, the peak value obtained should be a good approximation of the average condition that would prevail during a continuous eight-hour dump at the same overall conditions. The results can thus be expressed in an alternative form, i.e., total sacks dumped in eight hours with the measured peak value becoming the TimeWeighted Average. The data will also be presented in this form. REVIEW OF DATA Dust counts have been obtained for this study at four locations; three by Union Carbide and one by Complete reports are appended for reference. <a. major pm*becompany. In this section, the data will be reviewed and the technical basis for the background level and equilibrium assumptions just described will be provided. Eight-hour time-weiglited average and "total sacks in eight hours'* values will be calculated for each dump. ir- L C C CL O 6L /A;s The fiber count data taken at -- on September 27, 1972 are shown graphically in Figure 1. The Figure gives fiber count as a function of elapsed time. / !/ In this test, 20 sacks of regular Super-Visbestos were dumped over a 21-minute period. After a wait of about 10 minutes, 20 sacks of the new granular Super-Visbestos were dumped over a 26-minute period. The sample taken in the breathing zone of the operator during the dump of regular Super-Visbestos gave a count of 1.91 fibers. Wherv gran, iar Super- Visbestos was dumped 10 minutes later, the count dropped to 0.42 vtcrs. During these same periods, the downwind counts were 0.51 and 0.31 fibers, respectively, while upwind values of <0.1 and 0.15 fibers were found. The wind was a light, somewhat variable breeze so all of these values seem reasonable and internally consistent. -3- 013541 Note that both environmental samples (Positions 1 and 3) were 0.3 fiber or below during the granular Super-Visbestos dump. The assumed value of 0.3 fiber for the background level when no asbestos is being handled thus seems reasonable. The data in Figure 1 can be used to estimate TWA values for both types of asbestos dumped. For the regular Super-Visbestos, consider the exposure to be 1.91 fibers for the 30-minute period covering both the dump and subsequent time until the lower reading was obtained. For the remaining 7-1/2 hours of the shift, it is assumed that the operator dumps no more asbestos and is exposed to a back ground level of 0.3 fibers. Thus. (1.S1 fibers) (0.5 hours) + (0.3 fibers) (7.5 hours) TWA 8 hours TWA = = 0.4 fibers This is only (0.4) (100)/5 * 8% of the allowable exposure level. For the granular Super-Visbestos, consider the exposure to be 0.42 fibers for 0.5 hour and the assumed background of 0.3 fibers for 7.5 hours. Thus: TWA - fa-mojl I . 0.3 fibers This is 6% of the allowable TWA. Referring again to Figure 1, within 10 minutes after the end of the dump with regular Super-Visbestos, the asbestos level over the hopper (breathing zone. Position 2) had dropped sharply from 1.8 fibers to only 0.4 fibers. This indicates that the system responded quite rapidly to changes in conditions and the use of a peak value as representative of the continuous eight-hour dump is a valid approximation. On the basis of this assumption, an operator should be able to dump (20/21)(480) sacks per eight-hour shift at a breathing zone TWA value equal to the peak value found during the test dump. The same reasoning applied to the granular Super-Visbestos gives (20/2i)(480) or 369 sacks per shift at a TWA of about 0.4 fibers. This is only 8% of the allowable value. It should also be noted that the peak value for granular Super-Visbestos is so close to the assumed value for the background and they are both so low that the question of steady state is largely academic. All of the values calculated have been collected i'h tne overall summary. Table I. be ca f> 0/V Hear _ r--C. usfejtt .y-- The next series of tests to be examined were run Texas on September 26, 1972. These tests were intended to simulate conditions on the North Slope. Dumping was done in a small, covered enclosure 013542 4- - about 10' x 11' by 9' high. Dumps were made with one side open 8' to approximate normal conditions and with everything closed as occurs in the Arctic during extremely cold and windy weather. Both Arcovis 953 and granular Super-Visbestos were dumped but only the Super-Visbestos will be examined here. In the initial test 30 bags of granular Super-Visbestos were dumped in 29 minutes with the opening closed off. Dust levels were monitored during the dump and for a 1-1/2 hour period thereafter. The door was then opened and 30 more bags were dumped in 30 minutes. Dust levels were again measured during the dump and for approximately 1-1/3 hours thereafter. The data are shown in Figure 2 with the airborne asbestos dust concentration in fibers/ml. >5<< shown as a function of time. The exact sample point locations referred to in the Figure are given in the appended report. They are approximately: 1. In a "dead" corner adjacent to the door. 2. Directly over the hopper. (The hopper is near the wall on the opposite side from the door.) 3. Breathing zone of operator during dump. 4. Over empty sacks in rear corner near hopper. Before examining the data, it should be noted that on the previous day, a more dusty product, Arcovis 953, had been dumped with the building closed. Sample Point #1 gave a reading of 1.0 fibers on a sample collected during and after the Arcovis dump. During the first Super-Visbestos dump shown in Figure 2, Point 1 gave a value of 0.8 fiber. This dropped sharply to only 0.1 fiber when the door was opened. Also, a background sample taken over the hopper before the start of this dump had a reading of 0.7 fiber. This suggests that the closed room at the start of these dumps contained a level of 0.7 - 0.8 fibers as a residual from the previous days'tests. During the first granular Super-Visbestos dump 'room closed) the breathing zone sample, #3, showed a level of 1.8 fibers. At the same time, the adjacent region over the hopper, Point #2, was at essentially the same level, i.e. , 1.7 fibers. When the dump was finished, the level over the hopper (Point #2) dropped to the very low value of 0.2 fiber. At Point #4, near the hopper but over the empty bags, the level was only 0.1 fiber throughout the two hours. During the second dump, with the door open, the breathing zone (#3) and hopper (#2) samples were both only 0.4 fiber. The formerly dead" area (#1) was 0.1 fiber throughout. The hopper (#2) dropped to 0.1 fiber after the dump was completed. The #4 position, in the corner over the bags, went up from 0.1 fiber to the still very low level of 0.3 fiber. Recognizing the inherent inaccuracies in the dust count technique, the data obtained present an internally consistent picture. It appears that the hopper is acting as an aspirator and is removing dust-laden air from the immediate -5- 013543 vicinity. Its effect does not appear to reach as far as the opposite corner of the room. Position #1, however. The modest increase in Point #4 with the door open could be due to a "dead" area developing in the corner but the data are too limited to more than speculate. In normal practice in the Arctic, the dump is made and the operator leaves the area entirely. On this basis, it would be reasonable to use a value of 0 fibers for the tine outside of the dump in estimating the TWA exposure. In order to keep the data directly comparable with the other locations covered in this report, however, the value of 0.3 fiber will be used. The results in Figure 2 also corroborate that the 0.3 level for general background is probably quite high. The data in Figure 2 can be used to estimate the TWA values for both the closed and open dumps. For the closed dump, consider the exposure to be 1.8 fibers for 1/2 hour and 0.3 fiber for 7-1/2 hours. Thus TWA = l-1 -tiP'-3)(A5) = o.4 fibers gi ve: For the second dump, the values are 0.4 and 0.3, respectively, to TWA . iP_,4)L0,_5). * (0.3)(7.5) . Q'3| f1bers As noted previously, in both tests in this sequence the dust level over the hopper is very close to that in the breathing zone during the actually dumping but drops very sharply as soon as the dumping is stopped. This is very good evidence that conditions are steady and that the "total sacks dumped" concept can be applied. For this case the results are: Closed dump: j|^(480) * 464 sacks at a TWA of 1.8 fibers. Open dump: jUj(48) = 480 sacks _ at a TWA of 0.4 fibers. These and the foregoing TWA values have been entered in Table I. -6- Li^i t/ i~C-\ 'f/j'f-* - 7"y a c< $ 013544 A t ,//e The third series of tests were run at a rig in 4hm ThnhcweM' Texas. The mud was mixed in a 25* x 7' mud house with open doors at both ends. The hopper was adjacent to the door at one end of the house. A diagram is available in the complete report appended. The test consisted of a dump of 10 bags of Super-Visbestos at regularly spaced intervals of 6 minutes over a 60-minute period. This was followed by a 30-minute wait and then a dump of 10 bags of granular Super-Visbestos in the same manner. During the entire period, the wind outside was blowing strongly. It was in a direction, however, such that even though both doors were open there was no strong draft through the building. For these tests, samples were collected at the following points: Position 1: Opposite corner at same end of trailer as mud hopper. Position 2: End of trailer at opposite from the mud hopper. Position 3: Operator breathing zone during dumps. The dust count results obtained are shown graphically in Figure 3. For the dump of regular Super-Visbestos, the dust level in the breathing zone was 1.0 fiber. The environmental samples near the hopper and at the other end of the trailer were considerably lower and decreased with distance from the hopper. During the following half hour (12:15-12:45) the two environmental samples showed a moderate increase which also continued over the ensuing one hour dump of the granular Super-Visbestos. In the half hour after the second dump, however, the levels at both Position 1 and Position 2 dropped. The breathing zone sample collected during this dump was the same as the adjacent environmental sample at Position 1, i.e., 0.5 fiber. This pattern suggests that the second breathing zone sample is more representative of the general level at the hopper end of the trailer than a direct measure of dust generation by the granular Super-Visbestos. The correct granular Super-Visbestos level, however, should be no more than the 0.5 fiber measured. As in the previous tests, the general level of environmental samples, i.e., 0.1-0.3 fibers in the opposite end of the trailer, and 0.3-0.5 fibers directly adjacent to the dumping area, continue to support the validity of the value of 0.3 fiber as the background exposure level for the time period when asbestos is not being handled. Also the sharp drop in breathing zone level after the initial dump makes it reasonable to calculate the"total sfacks in eight hours" values for these tests. Thus: Regular Super-Visbestos: TWA = ll-MH!) .+. (P.3)(7) , 0 35 fibers |||j(480) = 82 sacks in 8 hours at a TWA of 1.03 fibers -7Granular Super-Visbestos: TWA = i>5)(1) + lQ-.3)(7) = o.33 fibers 013545 j^j(480) = 82 sacks in 8 hours at a TWA of 0.5 fibers * W ! /A s / '<r> t>, ct. ****o>*yi*\ LmuitiaL.t>,l. The last data to be considered were obtained by This was an open-air dump wherein 21 bags of granular Super- Visbestos were dumped in 15 minutes and 5 minutes were spent in cleanup and disposal of the bags. A slight wind was blowing towards the worker. Two samples , */dire .simultaneously in the breathing zone of the worker during the dwapa**^ ^ fonS^saii^ewa^coTl^eS'at'^lhe same time in the breathing zone of an observer ' standing about 3' upwind. Results are shown in the Table below. SAMPLE NO. LOCATION TIME FLOW RATE TOTAL VOLUME ASBESTOS CONC. MINUTES LITERS/MIN LITERS FIBERS/CC 1 At breathing zone of worker* 22.0 1.5 33.0 1.4 2 At breathing zone of worker, flll 21.3 2.9 61.8 0.6 3 Atbreathing zone of 20.3 Observe* 4.3 87.3 0.0 The data from the two breathing zone samples, although somewhat different, are in reasonable agreement for this kind of dust sampling and counting. The levels found are also in the same general range as the results obtained at the other three locations. The zero level found for the observer also supports the assumption of the 0.3 fiber value for TWA calculations. There is no evidence to tell whether the observed breathing zone levels had reached steady-state but based on the other tests it seems reasonable to make the same calculation. Thus: TWA = (14)(0.33) + (0.3)(7.67) _ Q33 8 . or using the 0.6 fiber reading TMA - (0.6)(0.33) + (0.31(7.67) . p 3, ' 8 (21) The corresponding sacks dumped would be /tf:\(480) = 672 at a TWA of either 1.4 or 0.6 fibers. '` LOCATION TABLE 1 AIRBORNE ASBESTOS OUST CONCENTRATIONS IN DRILLING FLUID OPERATIONS SUPER-VISBESTOS PRODUCT CONDITIONS DUMPING Rate Sacks Min. (S/HIn) Fibers/Ml OUST LEVEL*1* Peak Time-Weighted Ave. (TWA)'*' * of ttfc? Allowable'* Fibers/Ml *3* Allowable*5* 7'x25' Hud House. Open door at both ends 10 59 0.17 1.03 10 0.39 8 7`x2$` Hud House. Open door at both ends 10 59 0.17 0.5 5 0.33 7 CALCULATED VALUES** 8 HOUR CONTINUOUS CUJP OUST LEVEL Total Sa in 8 hou Time-Weionted Ave. (TWAl (3i * Of /r\ 82 1.03 82 0.5 21 10 Open air. Light breeze Open air. Light breeze 20 21 0.95 1.91 19 0.4 20 26 0.77 0.42 4 0.3 8 6 457 1.91 369 0.4 38 8 10'xll' Room. Totally enclosed 10'xll' Room. 1 side open, 8' Open air. Slight breeze 30 29 1.03 30 30 1.0 2) 15 1.4 l.B 0.4 fl.4jj X0.6*7 18 4 14 6 0.4 0.3 0.33 0.31 8 6 7 6 464 1.8 . 36 480 0.4 8 672 1.4 672 0.6 2| 12 1. Sampling and dust counting carried out In accordance with OSMA Regulation 1910, 93a. 2. Calculated at a background exposure of 0.3 flber/ml. for all time except during actual dumping. 3. Flbers/Nl. greater than \u in length. 4. Allowable * 10 fibers/ml. greater than 5. Allowable 5 fioers/nl. greater than 5//. 6. Based on continuous exposure to peak value found during short dp. Assumes dtanplng and surrounding conditions do not change. 7. Operator wore 2 sample*-.*. 013546 *T m4Z ,.0.. *.... TO TM c *CM .. 46 0,, 7,, 8, 0 . ASBESTOS FIBER COUNTS OF AIRBORNE SAMPLES COLLECTED FOR Septenfcer 27, 1972 01354? 013548 ASBESTOS FIBER COUNTS OF AIRBORNE SAMPLES COLLECTED FOR r toer}/m/. ASBESTOS FIBER COUNTS OF AIRBORNE SAMPLES COLLECTED FOR 013549 / u September 28, 1972 ^ { -V /X. ASBESTOS FIBER COUNTS OF AIRBORNE SAMPLES COLLECTED 013550 Septeirtber 27, 1972 PERSONNEL PRESENT Montello, Inc. : R. Newman Union Carbide Corporation: E. Kleber J. Myers UNION CARBIDE CORPORATION Mining and Metals Division Niagara Falls, New York OBJECTIVE 013551 Monitor airborne asbestos under "on site" conditions. INTRODUCTION q- c**+*+! Or^eptentei^^^l972 testswere conducted -at lOklahoma^to provide on-site airborne asbestos data. Two products were evaluated; Super Visbestos, a cracked pellet form of asbestos and New Granular Super Visbestos, a pelletized product. TEST METHOD 11:00 - 11:30 - 20 bags Super Visbestos added to premix pit. 11:30 - 12:00 - 20 bags New Granular Super Visbestos added to premix pit. PREMIX PIT - (See Figure 1) Pit was approximately 301 x 8' x 5' deep. The 20 bags of product were added to a hopper connected to a discharge pipe. The vacuum created by the flow of liquid through the pipe was sufficient to keep the addition rate at a little over 1 bag/min. SAMPLER LOCATIONS - (See Figure 1) The samplers were left in the same positions for both tests. They are designated position 1, 2, and 3. Position 1 - 9 ft. upwind from hopper across tank, mounted on light pole, approx. 3 ft. above top rim of premix pit. Position 2 - Located on operator as he dunps 20 bags of product. Position 3 - 7 ft. downwind from operator on top of a pile of bags, approx. 2-1/2 ft. above top rim of premix pit. Note: The terms upwind and downwind are fairly accurate. However, the wind did some shifting during the tests. EQUIPMENT Sampling and dust counting were carried out in accordance with 0SHA Regulation 1910.93a. Personal air samplers were used to collect personal breathing zone and environmental samples on Mi Hi pore Membrane Filters of 0.8 micron porosity. 013552 Air samplers were as follows: MSA Personal Sampler - Calibrated to draw 2 liters per minute of air. used in positions 3 and 4. Unico Personal Sampler "A" - Draws 1.8 liters per minute. Used in position 1. Unico Personal Sampler "B" - Draws 1.7 liters per minute. Used in position 2. Fiber counting was performed on a Leitz Microscope utilizing Phase Contrast Illuminatior at 400X and a Patterson Globe and Circle Reticle. TEST RESULTS - (See Table 1) Table 1 contains the results of the sample analysis dust counting. The count is reported as fibers greater than 5 microns in length per milliliter of air sampled. A fiber is defined as any material having an aspect ratio greater than 3. INTERPRETATION Although the figures speak for themselves, it may be worthwhile to briefly review the Time Weighted Average (TWA) aspect. The Regulations have been established with a limit of 5 fibers per milliliter greater than 5 microns in length on a Time Weighted Average. This means the figures must be arranged to show the employee's average in take of fibers per milliliter on an 8 hour day. For example, a worker dumping asbestos for one hour per day and inhaling 8 fibers per milliliter during that hour would have a TWA of 1 fiber per milliliter and for 2 hours dumping at the 8 fibers per milliliter level would be 2 fibers per milliliter, etc. The highest reading in Table 1 is 1.91 fibers per milliliter and the operator was exposed to this level for only 21 minutes. If this were his only exposure during the day, his TWA would be less than 0.1 fiber per milliliter. 013553 TABIC I SUMMARY OF DUST COUNTS ' N.B. No. 1929-34-1 >1929-34-2 1929-34-3 Field No. T i me (Minutes) Position Description Addition of 20 bags Super Visbestos 5 24 1 Envi ronmental 4 21 2 Personal 6 23 3 Environmental 1929-34-4 1929-34-5 1929-34-6 Addition of 20 bags New Granular Super Visbestos 37 27 1 Environmental 16 26 2 Personal 25 27 3 Environmental Fibers/m; >5 <0.1 1.91 0.54 0.15 0.42 0.31 o<>u 00 | Discharge Pipe 30 rhO' ....... f-./Si + ten 2 __ Jaopper > Posi1iun 3 013555 ASBESTOS f IBER COUNTS OF AIRBORNE SAMPLES COLLECTED September 25-26, 1972 PERSONNEL PRESENT Union Carbide Corporation: E. Klcber J. Myers UNION CARBIDE CORPORATION Mining and Metals Division Niagara Falls, New York 013556 OBJECTIVE Monitor airborne asbestos in simulated North Slope mud house conditions. INTRODUCTION On September 25 i 26, 1972 tests were conducted Texas in order to determine the amount of airborne asbestos that could be generated in a North Slope drilling operation. A building was constructed for the tests and all air samples were taken inside this structure. Two products were evaluated: Arcovis 955, essentially 100? liberated fiber and New Granular Super-Visbestos, a pelletized form of asbestos. TEST METHOD In order to closely simulate North Slope drilling mud preparation conditions, tests were made as follows: September 25th 9:00 a.m. - Noon - 30 bags of Arcovis 953 added to 100 barrels of diesel. "Door" open. September 25th I:30 p.m. - 4:00 p.m. 30 bags of Arcovis 953 added to 100 barrels of diesel. "Door" closed. September 26th 8:30 a.m. - 10:30 a.m. 30 bags of New Granular Super-Visbestos added to 125 barrels of water. "Door" closed. September 26th 10:30 a.m. - 12:30 p.m. 30 bags of New Granular Super-Visbestos added to 125 barrels of water. "Door" open. PHYSICAL DIMENSIONS OF BUILDING - (See Figure I) A specially constructed plywood building, approximately 9 x 10 x 11.5 feet was used for all tests. The building was enclosed on all sides except for an 8 x 9 foot opening in front. When a "Door open" test was run the opening was left alone and wind was free to blow about. When a "Door closed" test was conducted a large uiece of plastic was stapled over the opening, effectively shutting off outside wind. This fechnique was devised to simulate a cold day on the North Slope when trailer doors would be closed. SAMPLER LOCATIONS - (See Figure I) In order to obtain a hign amount of comparative data it was decided that the samplers wpuld be located in the same positions for all tests. For :jss of identification they have been labeled positions I, 2, 3, and 4. Position I - Approximately 7 feet from Hopper in corner near hoor o: t.ning. Somewhat of a "dead" area from the standpoint of air circulation. In all fr.fs this sampler ran both during dump and in the "settling" oeriod. Position 2 - Directly over Hopper. It was decided that since the operator moves about quite a bit obtaining and disposing of bags, a stationary sample would be of value to cafch any "blow back" from the fbpper. This sampler was run during the dump. Upon completion a new filter was inserted and allowed to run through the "settling" period. This accounts for two position 2 samples in each test. 013557 Position 3 - Attached to operator and run during entire dump. Position 4 - Placed over bog disposal area, approximately 5 feet from Hopper. Run after completion of dump. MISCELLANEOUS All samplers were 5-1/2 to 6 feet above the ground, except background sample on 9/25 which was 4-1/2 feet above the ground. In each test,30 bags of asbestos were added through a Hopper to approximately 100 barrels of liquid (either diesel or water) in a 170 barrel tank at the rate of I bag per minute. A 6 x 8 inch B. J. Centrifugal Pump operated at 790 6.P.M. Background sample 1929-32-12 has a rather large fiber content. This is probably due to movement in the area kicking up the previous day's dust and the placement of a pallet of asbestos during sampling time. EQUIPMENT Sampling and dust counting were carried out in accordance with OSHA Regulation 1910. 93a. Personal air samplers were used to collect personal breathing zone and environmental samples on Millipore Membrane Filters of 0.8 micron porosity. Air samplers were as follows: MSA Personal Sampler - Calibrated to draw 2 liters per minute of air. used in positions 3 and 4. Unico Personal Sampler "A" - Draws 1.8 liters per minute. Used in position I. Unico Personal Sampler "B" - Draws 1.7 liters per minute. Used in position 2. Fiber counting was performed on a Leitz Microscope utilizing Phase c ntrast Illumination at 400X and a Patterson Globe and Circle Reticle. TEST RESULTS - (See Table I) Table I contains the results of the sample analysis dust counting. The count is reported as fibers greater than 5 microns in length per milliliter of air sampled. fiber is defined as any material having an aspect ratio gre.iter tmn 3. A INTERPRETATION Although the figures speak for themselves, it may be worth*'-lo briefly review the Time Weighted Average (TWA) aspect, (he Regulations hi/-: been ! ibI ishod with a limit of 5 fibers per milliliter greater than 5 microns in length on a Time Vvsighted Average. This means the figures must be arranged to show Ike employee's average in take of fibers per milliliter on an 8 hour day. For exa-n.jie, a worker dumping asbestos for one hour per day and inhaling 8 fibers per milliliter during that hour would hove a TV/A of I fiber per milliliter and for 2 hours dumping at the 8 fibers per milliliter level would be 2 fibers per milliliter, etc. The highest reading in Table I is 5.5 013558 fibers per milliliter and the operator was exposed to this level for only 35 minutes If this were his only exposure during the day his TWA would be 0.4 fibers per mi 11iI iter. TABLE I SUNNARY OF OUST COUNTS 01 U N.B. No. Field No. T ime (Minutes) Position Description Ffbers/m' 5 September 25, 1972 1929-32-1 58 56 2 Background for 9/25 0.1 1929-32-2 1929-32-3 1929-32-4 1929-32-5 1929-32-6 OPEN SYSTEM - Addition of 30 bags Arcovis 953 to 100 barrels of diesel 62 29 52 30 70 81 54 78 56 i 10 2 Environmental - During Dump 3 Operator - During Dump 2 Environmental - After Dump 4 Environmental - After Dump 1 Environmental - During & After Dump 0.3 1.3 0.1 0.2 0.2 CLOSED SYSTEM - Addition of 30 bags Arcovis to 102 barrels of diese1/Arcovis mix 1929-32-7 1929-32-8 1929-32-9 1929-32-10 1929-32-11 57 55 82 50 63 36 35 95 95 132 2 Environmental - During Dump 5.2 3 Operator - During Dump 5.5 2 Environmental - After Dump 0.5 4 Environmental - After Dump 0.3 1 Environmental - During 4 After Dump 1.0 September 26, 1972 1929-32-12 23 3! 2 Background for 9/26 0.7 CLOSED SYSTEM - Addition of 30 bags New Granular Super Visbestos to 125 barrels of water 1929-32-13 1929-32-14 1929-32-15 1929-32-16 1929-32-17 93 95 68 92 27 29 29 85 83 114 2 Environmenta1 - During Dump 1.7 3 Operator - During Dump 1.8 2 Environmental - After Dump 0.2 4 Environmental - After Dump 0.1 1 Environmental - During 4 After Dump 0.8 OPEN SYSTEM - Addition of 30 bags New Granular Super Visbestos to 120 barrels of water 1929-32-18 1929-32-19 1929-32-20 1929-32-21 1929-32-22 90 79 19 36 74 31 30 77 77 107 2 Environmental - During Dump 0.4 3 Operator - During Dump 0.4 2 Environmental - After Dump 0.1 4 Environmental - After Dump 0.3 1 Environmenta1 - During 4 After Dump 0.1 11-1/2' 10-1/3' All monitors about 5.5' above ground level Building 9* high HopFer 3' high FIGURE l - HOPPER AND BUILDING ASBESTOS FIBER COUNTS OF AIRBORNE SAMPLES COLLECTED 013561 September 28, 1972 PERSONNEL PRESENT Montello, Inc. R. Newman H. Wyatt Union Carbide Corporation: . E. J. Kleber & UNION CARBIDE CORPORATION Mining and Metals Division Niagara Falls, New York OBJECTIVE 013562 Monitor airborne asbestos in an actual on site condition inside a mud house. INTRODUCTION A 7>caj On September 28^197^ests were conducted at a dri 11 ing sita-*fcm*t` flf) ntUafi All samples were collected in a mud house approx. 25' x 7' with a Juonset hut roof 7 ft. high at the zenith. Two asbestos products were evaluated; Super-Visbestos, essentially 100% liberated fiber, and New Granular Super-Visbestos, a pelletized form. TEST METHOD 11:15-12.45 - 10 bags Super-Visbestos added to hopper. 12:45 - 2:10 - 10 bags New Granular Super-Visbestos added to hopper. The first hour of each test was the dumping of asbestos, 1 bag every 6 minutes. The last half hour was monitored as a settling period. - SAMPLER LOCATIONS - (See Figure 1) The samplers were left in the same spots for each test. They are designated as Position 1, 2, and 3. Position 1-4 ft. from hopper in somewhat of a "dead" air area, 5-1/2 ft. above floor. Position 2 - At opposite end of mud house, 3 ft. from door, downwind from hopper, 5-1/2 ft. above ground. Position 3 - Operator dumping bags at the rate of 10/hour. EQUIPMENT Sampling and dust counting were carried out in accordance with 0SHA Regulation 1910.93a. Personal air samplers were used to collect personal breathing zone and environmental samples on Millipore Membrane Filters of 0.8 micron porosity. Air samplers were as follows: MSA Personal Sampler - Calibrated to draw 2 liters per minute of air. Used in position 3. , Unico Personal Sampler "A" - Draws 1.8 liters per minute. Used in position 1. Unico Personal Sampler "B" - Draws 1.7 liters per minute. Used in position 2. Fiber counting was performed on a Leitz Microscope utilizing Phase Contrast Illumination at 400X and a Patterson Globe and Circle Reticle. 013563 TEST RESULTS - (See Table 1) Table 1 contains the results of the sample analysis dust counting. The count Is reported as fibers greater than 5 microns in length per milliliter of air sampled. A fiber is defined as any material having an aspect ratio greater than 3. INTERPRETATION Although the figures speak for themselves, it may be worthwhile to briefly review the Time Weighted Average (TWA) aspect. The Regulations have been established with a limit of 5 fibers per milliliter greater than 5 microns in length on a Time Weighted Average. This means the figures must be arranged to show the employee's average in take of fibers per milliliter on an 8 hour de^y. For example, a worker dumping asbestos for one hour per day and inhaling 8 fibers per milliliter during that hour would have a TWA of 1 fiber per milliliter and for 2 hours dumping at the 8 fibers per milliliter level would be 2 fibers per milliliter, etc. The highest reading in Table 1 is 1.03 fibers per milliliter and the operator was exposed to this level for 59 minutes. If this were his only exposure during the day, his TWA would be less than 0.2 fiber per milliliter. 013564 N.B. No. 1929-36-1 -2 -3 -4 -5 TABLE I SUMMARY OF OUST COUNTS Field No. (Minutes) Pos i tion Description Dumping of 10 bags Super-Visbestos 33 60 41 61 47 59 9 27 34 27 1 Environmental 2 Environmental 3 Personal 1 Env. - After Dump 2 Env. - After Dump Dumping of 10 bags New Granular Super-Visbestos -6 15 -7 11 -8 10 -9 42 10 46 59 60 59 25 25 1 Environmental 2 Envi ronmental 3 Personal 1 Env. - After Dump 2 Env. - After Dump FIbers/ml _>5 jju 0.40 0.20 1.03 0.44 0.31 0.47 0.35 0.49 0.32 0.16 FIGURE 1 Mud House s Position 1 25 ft. Bags of Super-Visbestos 013565 013566 DirtctO'. Indujtnel Hygiene November 2, 1972 Environmental Health Services Division of Medical and Health Services Department A Attached is(report of sampling and determination of asbestos concentration drilling mud^at the SAFETY tjfr NOV 1J 19)2 135S7 SUMMARY A survey indicated that the asbestos exposure of the employee dumping asbestos (Visbestos, Montello Inc., Tulsa, Oklahoma) into the hopper leading to the tank, containing drilling mud at~4&e -bar., was well below the present OSHA permissible limit. I * PURPOSE1tt-n-- ii .. At he 1'nutwl . /^survey was made laduotriel Hyqj ana,- fiaviroruaental Health Services Divleioaaf ttodieaA Pfaee%wy Health ^yrviuffS--Rgpartt7MBaL> asbestos exposure during the dumping of as'oestpsipto drilling mud at iQ The operation is similar to what occurs at a drilling rig except t'nav only l/3 of the amount of asbestos is used in the latter operation. -Messrs. Mud -Engineer, Engineer, Ncw-Orleans Office, di souse the-proeedure and- survey-. Prilling-Engineer andJBBHBB -Safety were present to observe and Personal samples were collected at the breathing zone of the worker during the dumping of asbestos using 37 millimeter Millipore type (membrane) AA filter in a holder connected to a MSA or Unico pump pulling air through the filter at a constant flow rate. The determination of asbestos concentrations was made by counting asbestos fibers longer than 5 micrometers at 400-450 X magnification (4 millimeters objective) with phase contrast illumination. DESCRIPTION OF OPERATION In drilling operations a mud circulates around the drill for cooling and lubrication. The mud is treated for weight, viscosity and gel strength. Asbestos increases the effectiveness of gel* that is, keeps it from setting up like cement. The mud must be left in the annulus of the drill with gel characteristics. Bags weighing 50 pounds of Super Vlsbestos, Montello Inc., Tulsa, Oklahoma were dumped into a hopper (15" x 15" opening) over a tank containing 215 barrels of mud (l4.5 lbs/gal lignosulfonate). The Montello asbestos, produced by Union Carbide by a wet process, is in a pelletized fora. Twenty-one bags of asbestos were dumped over a period of approx imately 15 minutes. About 5 minutes was spent in disposing of the empty bags. A slight breeze was blowing dust toward the worker but the dust began to settle before reaching the breathing zone. While conducting the operation, the worker wore an unapproved iFlexoprenp paint-mask manufactured by the Plexo Products lac., Weotlabe-, Ohio. -2- RESUI SAMPLE HO LOCATION TIMS MINUTES \ At braathins^one of worker, flHHHHk 22.0 At breathing zone of worker, At breathing zone of fStryer 21.3 20.3 Two samplers were placed at the breathing z placed at the breathing zone of the survey: procedure at approximately 3 feet froa the '^Discus: The Occupational Safety and Health Adninis: 8-hour tine-weighted average airborne conct employee may be exposed shall not exceed fi centimeter of air. The ceiling (maximum) co: 5 micrometers, per cubic centimeter of air. The results of the sampling and determinate of the employee dumping asbestos was below result was below 2 fibers/cc, the limit wh: Respiratory protection need not be worn du: higher concentrations of asbestos are antic Iapproved by the Bureau of Mines or a Natio: Health (NIOSH) for protection against pneu: 0*3568 ASBI FI] pier nd _worl ires i o whic uetersj; nger os expc level. 1, 191 - at r ar' 3afe1 a as 013569 AIRBORNE ASBESTOS COUNTS for Southwest Drilling Mud (Warehouse) Midland, Texas Date Sampled: January 13, 1977 Date Reported: January 24, 1977 Samples Collected By: 6. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013570 To determine airborne asbestos emissions at the subject company's storage facilities. DESCRIPTION OF OPERATION: Warehouse was open on one side. Airborne samples were obtained prior to the transfer of asbestos to a truck. Airborne samples were also obtained after the transfer of asbestos (Environmental). Personal samples were obtained at the breathing zone of the forklift operator during the transfer of 139 bags Super Visbestos and also of:other personnel working in the loading area. SAMPLE EQUIPMENT AND TEST PROCEDURES 013571 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Miliipore membrane filters of 0.8 micron porosity. ' Fiber counting was performed on a flikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: . 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the . asbestos fibers as well as other particles which meet the fore going criteria. If tremolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula + C2T2 + CnTn describes the TWA v , IT . . v/here C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Sample Wo. SUMMARY OF FIBER COUNTS Southwest Drilling Mud (Warehouse) Midland, Texas Air Sample Time Minutes Operation Description 013572 Airborne Fiber Coun (fibers/cc >5y) Chrysoti1 Total Asbestos J-17 on: 8:20A off: 8:49A 29 J-42 J-l on: 8:22A off: 8:46A on: 8:24A off: 8:47A 24 23 6-15 J-77 J-37 J-76 A-94 on: 8:59A off: 9:15A on: 8:59A off: 9:15A on: 8:59A... off: 9:15A on: 9:20A off: 9:45A on: 9:22A off: 9:45A 16 16 16 25 23 Environmental - (Prior to the use of SVB). Located at enclosed end of warehouse~8' from floor and HO' from bags. (Bags stacked ^10' high.) 0.1 Environmental - (Prior to the use of SVB) Located ^10' from door and 4 1/2 from floor ~20' from bags. 0.1 Environmental - (PrioV to the use of SVB.) Located at enclosed end of warehouse 6' bags and 51/2' from f1 oor. - 0.1 Personal - (Jeff Darr - helped load 0.3 . truck) 139 bags SVB loaded onto truck. Personal - (Randall Brook - forklift operator.) During the handling of 139 bags SVB. 0.1 Personal - (Joe Rusnak - helped load 139 bags SVB from truck. 0.3 Environmental - (After the transfer of 139 bags SVB.) Located same as J-42. <0.1 . Environmental - (After the transfer of 139 bags SBV.) Located same as J-17. <0.1 0.1 0.1 0,1 0.3 0.1 0.3 <0.1 AIRBORNE ASBESTOS COUNTS for Robinson Drilling of Texas Inc. Rig #6 013573 Date Sampled: January 13, 1977 Date Reported: January 21, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York & OBJECTIVE: 013574 To monitor airborne asbestos emissions at the subject company's drilling location, located ~25 miles north of Bigspring, Texas, (Rig #6) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of 5 baas SVB to a hopper in the formulation of a drilling mud. Airborne samples (Environmental) were taken prior to, during and after the dump. A personal sample was obtained in the breathing area of the dump during addition of 5 bags SVB to a hopper. Samples were obtained outdoors on a moderately windy day. SAMPLE EQUIPMENT AND TEST PROCEDURES 01357L> Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Hikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: . 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the . asbestos fibers as well as other particles which meet the fore going criteria. If tremolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula C-jT^ + C2T2 + CnTn describes the TWA ~_ . . where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Sample No. 6-12 J-86 J-18 J-27 J-34 C-24 SUMMARY OF FIBER COUNTS Robinson Drilling of Texas Inc. Rig #6 013576 Air Sample Time Minutes _______ Operation Description________ Airborne Fiber Count (fibers/cc >5u) Chrysotile Total Asbestos on: 11:20A off: 11:44A on: 11:23A off: 11:46A 24 23 on: 11:48A off: 12:07P 19 on: 11:49A off: 12:04P on: 11:51A off: 12:07P on: 12:06P off: 12:16P 15 16 10 Environmental - (Prior to the use of SVB) Located 15' from,hopper and 41/2' from ground. 0 Environmental - (Prior to the use of SVB.) Located 10' downwind of bag storage area and 5' from ground. 0 Personal - (M.R. Cooper-dump operator) During the dump of 5 bags SVB into a hopper, and during bag disposal. (Operator upwind.) 0 Environmental - (During the use of SVB.) Located same as G-12. 0.1 Environmental - (During the use of SVB.) Located same as J-86. ( 8' downwind bf dump.) 0 Environmental - (After the use of SVB.) Located same as G-12. 0.4 0 0 0 0.1 0 0.4 013577 AIRBORNE FIBER COUNTS for D. B. Drilling (AMOCO) Rig #6 Hamlin, Texas Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013578 To monitor airborne asbestos emissions at the subject company's drilling facilities during the use of Super Visbestos. DESCRIPTION OF OPERATION: Airborne samples were obtained in the area of the dump prior to and during the use of SVB (Environmental). The dump area was located out doors and samples were taken on a moderately rainy day. No environmental samples were obtained after the dump due to increasingly heavy rain. A personal sample was obtained in the breathing zone of the dump operator during the addition of five bags of Super Visbestos to a hopper. A personal sample was also obtained during bag disposal. SAMPLE EQUIPMENT AND TEST PROCEDURES 013579 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Mi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenditic talc is present in the sample, the trendite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5.microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-jT-j + CgTg + CnTn describes the TWA __ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached tablets). Sample Mo. J-28 J-15 J-10 J-31 SUMMARY Uh MOtK UUUIlia D. B. Drilling (AMOCO) Hamlin, Texas Air Sample Time Minutes Operation Description 013530 Airborne Fiber Cou, (fibers/cc >5u) Chrysoti Total Asbesto on: 1:20P off: 1:40P on: 1:57P off: 2:28P on: 1:57' 30" off: 2:28P 20 31 30'30" 2 Environmental - (Prior to the use of SVB.) Located1/2* above hopper of Rig #6. Weather conditions during time of monitoring - misty rain. Personal - (Allen Morgan - dump operator, during the use of SVB.) Operation included unloading and addition of 5 bags SVB to a hopper, located outdoors. Weather conditions during time of monitoring - misty rain. Environmental -(During the use of SVB.) Located same as J-28. Weather conditions at the time of monitoring - moderate rain. Personal - (Allen Morgan, during bag disposal only.) Weather condi tions at the time of monitoring moderate rain. 0.1 0.3 0.1 1.7 0.1 0.3 0.1 1.7 AIRBORNE FIBER COUNTS for West Texas Drilling Company Rig #14 (Sun Oil Company) Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013582 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #14 located ^25 minutes south of Colorado City, Texas) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of nine bags Super Visbestos to a hopper located outdoors. Environmental samples were obtained in the breathing zone of the dump area prior to, during and after the dump. A personal sample was obtained in the breathing zone of the dump operator during the addition of nine bags Super Visbestos to a hopper, which was located outdoors. SAMPLE EQUIPMENT AND TEST PROCEDURES 013533 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumv/alde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a flikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula + C2T2 + CnTn describes the TWA ZT where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Sample Wo. West Texas Drilling Company Rig #14 (Sun Oil Company) Air Sample Time Minutes _______ Operation Description 013534 Airborne Fiber Cou (fibers/cc >5u) Chrysoti Total Asbesto J-21 on: 5:30P off: 5:50P J-24 J-20 on: 5:50P off: 6:17P on: 5:50P off: 6:17P 20 Environmental - (Prior to the use of SVB.) Located *^3' from hopper and ~6' from ground. Hopper located out doors . 0.1 27 Personal - (Randy Pel ton, dump operator) 0.3 During the addition of nine bags SVB to hopper and during bag disposal. 27 Environmental - (During the use of nine 0.4 bags SVB.) Located same as J-21. 0.1 0.3 0.4 J-16 on: 6:18P off: 6:31P 23 Environmental - (After the use of nine 0.3 bags SVB.) Located same as J-21. 0.3 013535 AIRBORNE ASBESTOS COUNTS for Grand Mud Company Abilene, Texas Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. 0. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York > OBJECTIVE: 01353b To monitor airborne asbestos emissions at the subject company's storage facilities. DESCRIPTION OF OPERATION: Operation involved the transfer of Super Visbestos from warehouse storage facilities to a truck in the loading area. Environmental samples were taken in and near the storage area prior to and during the transfer of Super Visbestos. A personal sample was obtained in the breathing zone of the forklift operator during the transfer of Super Visbestos from warehouse storage area to loading zone. Approximately one pallet was transferred. SAMPLE EQUIPMENT AND TEST PROCEDURES 013537 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C^Tj + C2T2 + CnTn describes the TUA _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Sample No. J-32 0-41 J-44 X-9 J-23 Air Sample Time ____ Minutes 5Uf,iivi>Mr ur mock cuunu Grand Mud Company Abilene, Texas 013538 Operation Description Airborne Fiber Cour (fibsrs/cc >5u) Chrysoti Total Asbesto: on: 10:38A off: 11:05A 27 on: 10:38A off: 11:05A 27 on: 11:13A off: 11 * 30A 17 on: 11:13A off: 11:21A 8 on: 11:15A off: 11.-30A 15 Environmental - (Prior to the transfer of SVB.) Located HI' from bags and 5' from floor. Near entrance to men's wash room. <0.1 Environmental - (Prior to the transfer of SVB.) Located HO' from bags and 5 1/2' from floor. On wall near 14' doors between two storage areas. 0.1 Environmental - (During the transfer of H pallet of SVB from warehouse storage area to truck.) Located same as J-41. Forklift passes through doors where pump is located. 0.1 Personal - (Mike Poind, extra forklift operator.) During the transfer of H pallet SVB from warehouse storage area to truck. 0.2 Environmental - during the transfer 0.3 of H pallet SVB from warehouse storage area to truck. Located same as J-32. <0.1 0.1 0.1 0.2 0.3 0 013589 AIRBORNE ASBESTOS COUNTS for American Mud Company Abilene, Texas Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013590 To monitor airborne asbestos emissions at the subject company's storage facilities during the transfer of Super Visbestos from storage area to pick-up truck. DESCRIPTION OF OPERATION: Operation involved the transfer of 40 bags Super Visbestos from warehouse storage area to pick-up truck in loading area. Environmental samples were obtained prior to and during the transfer of Super Visbestos. A personal sample was obtained in the breathing zone of the fork lift operator during the transfer of Super Visbestos from storage area to loading area. SAMPLE EQUIPMENT AND TEST PROCEDURES 013591 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula CjT-j + C2T2 + CnTn describes the TWA __ ^ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). . Sample Mo. . J-22 Air Sample Time ____ Minutes on: 8:45A off: 9:15A 30 E-22 on: 8:45A off: 9:15A 30 J-19 on: 9:34A off: 9:44A 10 J-25 on: 9:34A off: 10:00A 26 J-39 on: 9:34A off: 10:00A 26 SUMMARY OF FIBER COUNTS American Mud Company Abilene, Texas 013592 ______ Operation Description Airborne Fiber Cour (fibers/cc >5u) Chrysoti Total Asbestos Environmental - Prior tothe transfer of SVB. Located ^5' from floor and 4' from bags. Inside warehouse storage area. 0.1 0.1 Environmental - Prior tothe transfer of SVB. Located ^30' from bags and 31/2' from floor. Inside warehouse storage area. <0.1 <0.1 Personal - (Bernis Rains - forklift operator.) During the transfer of 40 bags SVB from warehouse storage area to loading area. 0.2 0.2 Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. . Located same as E-22. 0.1 0.1 Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. Located same as J-25. 0.1 0.1 & 013593 AIRBORNE ASBESTOS COUNTS for Cactus Drilling Rig #5 ~20 Miles Southwest of Vernal, Utah Date Sampled: September 23, 1977 Date Reported: September 28, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: 6. J. Spencer Union Carbide Corporation Reported By: 6. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE 013594 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #5) during the use of five bags of Super Visbestos. DESCRIPTION OF OPERATION Operation involved the addition of five bags Super Visbestos, bentonite, limestone and zinc chromate to a vent-type hopper in a drilling application. SAMPLE EQUIPMENT AND TEST PROCEDURES 013595 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type),.calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS _ The details of sample collection and resultant fiber counts are listed in the attached table(s). Several photographs obtained in the work zone during monitoring are included. The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C^T-j + CgT2 + CnTn describes the TWA _ where C = fiber count in fibers/cc and T = time. In the present application the worker handled asbestos for 14 minutes and left the area. Asbestos was not used again. Presumably his exposure for the other parts of the shift was zero or at most at the level of the natural background. For a zero exposure, for the time not handling asbestos, his 8-hour, time-weighted average exposure can be estimated as: 8-hour TWA = (ft-3-M^ 0.01 fibers/cc >5y In the vipinity of the hopper, the levels before and after handling ranged from 0.0 to 0.04 fibers/cc >5p. If the worker had stayed in the vicinity of the hopper throughout the shift his maximum TWA exposure is estimated as: 8-hour TWA = (-0,(W^(0,.04.)(466) . 0.05 The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. The ceiling exposure for this operation was 0.3 fibers/cc greater than 5 microns. V MVIIU VI * wbi\ vwn i v Sample No. Air Sample Time Minutes 013596 ... _______ Operation Description_________ Airborne Fiber Cou (fibers/cc >5w) r. Chrysotile M-39 M-48 M-52 on: 1:00P off: 1:39P on: 1:01P off: 1:41P on: 1:01F off: 1:41P M-19 M-49 N-95 M-44 M-46 B-9 on: 1:47P off: 2:01P on: 1:48P off: 1:59P on:. 1:48P off: 2: OOP on: 2:05P off: 3:14P on: 2:07P off: 3:16P on: 2:09P off: 3:13P 39 Area - prior to the use of asbestos. Located *20 feet south of hopper and 3-1/2 feet above ground. 0.04 40 Area - prior to the use of asbestos. Located -4 feet west of hopper ^6 feet above ground, and *2 feet above hopper. 0.02 40 Area - prior to the use of asbestos. Located -5 feet east of hopper-'3-1/2 feet above hopper and~6-l/2 feet above ground. Rig #5. 0.04 14 Personal - (Chuck Ireland) During 12 min. dump of five bags SVB, and during bag disposal. 0.3 11 Area - during the dump of five bags SVB. Located same as M-52. 0.1 12 Area - during the use of asbestos. Located same as M-48. 0.3 69 Area - after the use of asbestos. Located same as M-52. 0 69 Area - after the use of asbestos. Located same as M-48. 0.01 64 Area - after the use of asbestos. Located ^3 feet from hopper, ~2 feet above hopper and ^5 feet above ground. 0.01 013597 FIGURE 1 - Rig #5 FIGURE 2 - Hopper and dry materials storage area. FIGURE 3 - Hopper and dry materials storage area. 013598 FIGURE 4 - Addition of SVB to hopper. FIGURE 5 - Addition of SVB to hopper. AIRBORNE FIBER COUNTS for Amoco/Norton Rig #2 Lubbock, Texas Date Sampled: September 22, 1977 Date Reported: September 28, 1977 013599 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: 6. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE 013800 To monitor airborne asbestos emissions during the use of 480 pounds Super Visbestos-OX in a drilling mud application. DESCRIPTION OF OPERATION Operation involved the addition of 480 pounds Super Visbestos-OX to a hopper located outdoors. Area and personal samples were obtained prior to, during and after the use of asbestos. SAMPLE EQUIPMENT AND TEST PROCEDURES 013601 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zunwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 40QX utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Chrysotile Asbestos - Any fiber having an aspect ratio >3 and a length *5u that is in the operator's judgement chrysotile. In the event of doubt and in the absence of further information, any fiber having the above physical dimensions will also be counted as chrysotile. . 2. Possible Amphibole Asbestos - Any fiber having an aspect ratio >3 and a length >5p that is not obvious to be material other than asbestos. This includes all amphiboles and material similar in appearance. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air.sampled on an 8-hour, tineweighted average (TWA). The formula CjTj + C2T2 + CnTn describes the TWA where C fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). - Several photographs of the areas monitored have be^n included.  SUMMARY Of FIBER COUNTS 013602 Air Sample Time Minutes Operation Description Airborne Fiber Cou (fibers/cc >5p) Chrysotile Possibl Asbestos Amphibol Asbesto on: 2:12A 52 Area - prior to the use of asbestos. 0 off: 3:04A Located->'6-1/2 feet above ground, 4 feet above hopper and"6 feet from west side of hopper. 0 on: 2:21A 42 Area - prior to the use of asbestos. off: 3:03A Located "6 feet northwest of hopper, 4',above ground and *1' above hopper. 0 0 on: 2:33A 26 Personal - (Allen Johnson) Prior to the 0 off: 2:59A use of asbestos. Located in general area of rig and hopper. 0 on: 3:17A 20 Personal - (Johnnie Wheeler) During the 0.03 off: 3:37A use of 480 pounds SG-0X, in the manu facture of brine water. 0 on: 3:18A 20 Area - during the use of 480 pounds off: 3:38A SG-0X. Located same as D-60. 0.1 0 on: 3:18A 20 Area - during the use of 480 pounds off: 3:38A SG-0X. Located same as D-54. 0.03 0 on: 3:43A 56 Area - after the use of asbestos. off: 4:39A Located same as D-60. 00 on: 3:45A 58 Area - after the use of asbestos. off: 4:43A Located same as D-54. 0.1 0 on: 3:48A 59 Personal - (Allen Johnson) After the 0.04 off: 4:47A use of asbestos. Located in general area of yard and hopper. 0 on: 4:40A off: 7:25A 165 Area - after the use of asbestos. Located same as D-60. 0.01 0 on: 4:44A off: 7:25A 161 Area - after the use of asbestos. Located same as D-54. 0.03 0 on: 4:48A 22 Personal - (Allen Johnson) After the 0.03 off: 5:10A use of asbestos. Located in general area of rig. 0 on: 5:17A off: 7:29A 132 Area - after the use of asbestos. Located near mud return pool^2 feet above ground and ~10 feet from return discharge. 0.03 0 Background covered with fine black particulate and some chunky material Fibers counted were coated with fine black particulate. 013603 FIGURE #1 - Sample Location D-60 FIGURE #2 - Hopper Area Sample Shown (Upper Middle) 013604 FIGURE #3 - Personal Sample - Obtained During the Addition of SVB-OX to Hopper FIGURE #4 - Area Sample - Shown, Obtained During- the Addition of SVB-OX to Hopper ' 013605 April 25, 1977 Mr. George Ross, Drilling Superintendent Amoco Production Company P. 0. Box 3092 Houston, Texas 77001 Dear Mr. Ross: We spoke earlier today with Mr. A. R. Reed, and he has asked that we contact you directly. One of the products which we distribute is Super Visbestos. This asbestos product is manufactured to our specifications by Union Carbide Corporation. Super Visbestos has been widely used for many years as a mechani cal vlscoslfler for drilling fluids. 0SHA regulations covering the use of asbestos, were enacted back In 1972. Since that time Ucar and Montello have joined In a continuing program of field monitoring to establish a data base Indicative of the air entrained fiber counts associated with the use of Super Visbestos In drilling fluids. We have enclosed a folder containing the results of this continuing program. We make this Information freely available to all interested parties. Including operators, contractors, service companies and 0SHA personnel. The presentation has been useful in demonstrating the relatively low exposure levels inherent in the drilling Industry. We and Ucar would welcome the opportunity to discuss this matter with you or your people further. Please feel free to contact us on this, or any of our many other products, whenever we can be of service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) montello P.O. BOX 130. SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6861/TWX 910-840-3007 AIRBORNE ASBESTOS COUNTS for American Mud Company Abilene, Texas o13606 Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York 013607 OBJECTIVE: To monitor airborne asbestos emissions at the subject company's storage facilities during the transfer of Super Visbestos from storage area to pick-up truck. DESCRIPTION OF OPERATION: Operation involved the transfer of 40 bags Super Visbestos from warehouse storage area to pick-up truck in loading area. Environmental sam ples were obtained prior to and during the transfer of Super Visbestos. A personal sample was obtained in the breathing zone of the fork lift operator during the transfer of Super Visbestos from storage area to loading area. 013608 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula + C2T2 + CnTn describes the TWA fT------------ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS American Mud Company Abilene, Texas Sample No. J-22 E-22 J-19 J-25 J-39 Air Sample Time (Minutes) 30 30 10 26 26 Operation Description Environmental - Prior to the transfer of SVB. Located/-'51 from floor and 4` from bags. Inside warehouse storage area. Environmental - Prior to the transfer of SVB. Located ^30' from bags and 3 1/2' from floor. Inside warehouse storage area. Personal - (Bernis Rains - forklift operator.) During the transfer of 40 bags SVB from warehouse storage area to loading area. Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. Located same as E-22. Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. Located same as J-22. 013609 Asbestos Fiber Count (Fibers/cc> 5u) 0.1 <0.1 0.2 0.1 0.1 Ceiling concentration: 0.2 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. ' (2) The background fiber concentration was 0.1 fibers/cc. TWA = t0.lgU0.2J +. (7-833) (0.1) . QA f1bers/cc AIRBORNE ASBESTOS COUNTS for Grand Mud Company Abilene, Texas 013610 Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York 0X3611 OBJECTIVE: To monitor airborne asbestos emissions at the subject company's storage facilities. DESCRIPTIOK OF OPERATION: Operatic iiwsj] v&i the transfer of Super Visbestos from warehouse storage facilities to a truck sn loading area. Environmental samples were taken in and near tine storage area prior to and during the transfer of Super Visbestos. A personal sanple was obtained in the breathing zone of the forklift operator during the transfer of Super Visbestos from warehouse storage area to loading zone, Approximately one pallet was transferred. 013612 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Mi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjT^ + CgTg + CnTn describes the TWA rr where C = fiber count in fibers/cc and T * time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS Grand Mud Company Abilene, Texas 013613 Sample No. J-32 J-41 J-44 X-9 J-23 Air Sample Time (Minutes) 27 27 17 8 15 Asbestos Fiber Count Operation Description_________________ (Fibers/cc >5ju) Environmental - (Prior to the transfer of SVB.) Located^8' from bags and 5' from floor. Near entrance to men's wash room. <0.1 Environmental - (Prior to the transfer of SVB.) Located-^101 from bags and 5 1/2' from floor. On wall near 14' doors between two storage areas. 0.1 Environmental - (During the transfer of^l pallet of SVB from warehouse storage area to truck.) Located same as J-41. Forklift passes through doors where pump is located. 0.1 Personal - (Mike Poindexter - forklift operator.) During the transfer of^l pallet SVB from warehouse storage area to truck. 0.2 Environmental - during the transfer of/^1 pallet SVB from warehouse storage area to truck. Located same as J-32. 0.3 Ceiling concentration: 0.2 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. (2) The background fiber concentration was 0.1 fibers/cc. TWA = Mike Poindexter - .(0.133) * (0.1|) (0.25) + (7.6) (0.1) . 01 fjbers/cc AIRBORNE FIBER COUNTS for D. B. Drilling (AMOCO) Rig #6 Hamlin, Texas 013614 Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: 6. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 0X3615 To monitor airborne asbestos emissions at the subject company's drilling facilities during the use of Super Visbestos. DESCRIPTION OF OPERATION: Airborne samples were obtained in the area of the dump prior to and during the use of SVB (Environmental). The dump area was located out doors and samples were taken on a moderately rainy day. No environmental samples were obtained after the dump due to increasingly heavy rain. A personal sample was obtained in the breathing zone of the dump operator during the addition of five bags of Super Visbestos to a hopper. A personal sample was also obtained during bag disposal. 013616 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjTj + CgTg + CnTn describes the TWA _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS D. B. Drilling (AMOCO) Hamlin, Texas 013817 Sample No. J-28 Air Sample Time (Minutes) 20 J-15 31 J-10 30'30" J-31 2 Operation Description Environmental - (Prior to the use of SVB.) Located^3 1/2' above hopper of Rig #6. Weather conditions during time of monitoring - misty rain. Personal - (Allen Morgan - dump operator, during the use of SVB.) Operation included unloading and addition of 5 bags SVB to a hopper, located outdoors. Weather conditions during time of monitoring - misty rain. Environmental - (During the use of SVB.) Located same as J-28. Weather conditions at the time of monitoring moderate rain. Personal - (Allen Morgan, during bag disposal only.) Weather condi tions at the time of monitoring moderate rain. Asbestos Fiber Count (Fibers/cc >5u) 0.1 0.3 0.1 1.7 Ceiling concentration: 1.7 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration was 0.1 fibers/cc. # TWA = Allen Morgan - 1^1). jO.3), e ,(0.03) (1.7) + (7.45) (0.1) M ,,_2 AIRBORNE ASBESTOS COUNTS for West Texas Drilling Company Rig #14 (Sun Oil Company) 013618 Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York 013619 OBJECTIVE: To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #14 locate^25 minutes south of Colorado City, Texas) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of nine bags Super Visbestos to a hopper located outdoors. Environmental samples were obtained in the breathing zone of the dump area prior to, during and after the dump. A personal sample was obtained in the breathing zone of the dump operator during the addition of nine bags Super Visbestos to a hopper, which was located outdoors. 013620 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjTj + CgTg + CnTn describes the TWA __ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS West Texas Drilling Company Rig #14 (Sun Oil Company) 013621 Sample No. J-21 J-24 J-20 J-16 Air Sample Time (Minutes) 20 27 27 23 Operation Description Environmental - (Prior to the use of VB.) Located/-^' from hopper and /'6' from ground. Hopper located out doors . Personal - (Randy Pel ton, dump operator) During the addition of nine bags SVB to hopper and during bag disposal. Environmental - (During the use of nine bags SVB.) Located same as J-21. Environmental - (After the use of nine bags SVB.) Located same as J-21. Asbestos Fiber Count (Fibers/cc >5ju) 0.1 0.3 0.4 0.3 Ceiling concentration: 0.3 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration was 0.3 fibers/cc for 23 minutes after the dump and 0.1 fiber/cc for the remainder of the day. TWA - Randy Pelton - 10,4.5) (0.3) * (.38)_(0,3J._t,_[7,.17j_(p,lj . g l AIRBORNE ASBESTOS COUNTS for Southwest Drilling Mud (Warehouse) Midland, Texas 013622 Date Sampled: January 13, 1977 Date Reported: January 24, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013623 To determine airborne asbestos emissions at the subject company's storage facilities. DESCRIPTION OF OPERATION: Warehouse was open on one side. Airborne samples were obtained prior to the transfer of asbestos to a truck. Airborne samples were also obtained after the transfer of asbestos. (Environmental). Personal samples were obtained at the breathing zone of the forklift operator during the transfer of 139 bags Super Visbestos and also of other personnel working in the loading area. 013624 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Mi Hi pore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjT^ + C2T2 + CnTn describes the TWA rr-------- where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS Southwest Drilling Mud (Warehouse) Midland, Texas 013625 Sample No. J-17 Air Sample Time (Minutes) 29 Operation Description Environmental - (Prior to the use of SVB). Located at enclosed end of warehouse^' from floor and^lO' from bags. (Bags stacked/^10' high.) J-42 24 Environmental - (Prior to the use of SVB) Located/~10` from door and 4 1/2 from floor ^O' from bags. J-l 23 Environmental - (Prior to the use of SVB.) Located at enclosed end of warehouse 6' bags and 5 1/2' from floor. G-15 16 Personal - (Jeff Darr - helped load truck) 139 bags SVB loaded onto truck. J-77 16 Personal - (Randall Brook - forklift operator.) During the handling of 139 bags SVB. J-37 16 Personal - (Joe Rusnak - helped load 139 bags SVB from truck. J-76 25 Environmental - (After the transfer of 139 bags SVB.) Located same as J-42. A-94 23 Ceiling concentration: Environmental - (After the transfer of 139 bags SVB.) Located same as J-17. 0.3 fibers/cc Time weighted average concentration: Asbestos Fiber Count (Fibers/cc > 5ju) 0.1 0.1 0.1 0.3 0.1 0.3 <0.1 <0.1 The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. & (2) The background fiber concentration was 0.1 fibers/cc. TWA = Jeff Derr - 1M6U0,3)^_(7,73) (0-1). ^ fibers/cc TWA = Randall Brook - .+ I7.-.13)..(0.,1). B 0>1 fibers/cc TWA = Joe Rusnak - lM6). (Q,-3I..t.(L7.3) _(0.1| s 0>1 fibers/cc O AIRBORNE ASBESTOS COUNTS for Robinson Drilling of Texas, Inc. Rig #6 013626 Date Samples: January 13, 1977 Date Reported: January 21, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York 013627 OBJECTIVE: To monitor airborne asbestos emissions at the subject company's drilling location, located 25 miles north of Bigspring, Texas, (Rig #6) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of 5 bags SVB to a hopper in the formulation of a drilling mud. Airborne samples (Environmental) were taken prior to, during and after the dump. A personal sample was obtained in the breathing area of the dump during addition of 5 bags SVB to a hopper. Samples were obtained outdoors on a moderately windy day. 013628 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method of counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjTj + C2T2 + CnTn describes the TWA rr------------where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS Robinson Drilling of Texas, Inc. Rig #6 013629 Sample No. G-12 J-86 J-18 J-27 J-34 C-24 Air Sample Time (Minutes) 24 23 19 15 16 10 Operation Description Environmental - (Prior to the use of SVB) Located 15' from hopper and 4 1/2' from ground. Environmental - (Prior to the use of SVB.) Located 10' downwind of bag storage area and 5' from ground. Personal - (M. R. Cooper - Dump Opera tor) During the dump of 5 bags SVB into a hopper, and during bag disposal (Operator upwind). Environmental - (During the use of SVB.) Located same as G-12. Environmental - (During the use of SVB.) Located same as J-86. (8' downwind of dump.) Environmental - (After the use of SVB.) Located same as G-12. Asbestos Fiber Count (Fibers/cc 5u) 0 0 0 0.1 0 0.4 Ceiling concentration: 0.4 maximum (not breathing zone) - windy day. Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration is assumed to be 0. TWA - M. R. Cooper - 0.1 or less AIRBORNE ASBESTOS COUNTS for. American Mud Company Abilene, Texas 013630 Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013631 To monitor airborne asbestos emissions at the subject company's storage facilities during the transfer of Super Visbestos from storage area to pick-up truck. DESCRIPTION OF OPERATION: Operation involved the transfer of 40 bags Super Visbestos from warehouse storage area to pick-up truck in loading area. Environmental samples were obtained prior to and during the transfer of Super Visbestos. A personal sample was obtained in the breathing zone of the fork lift operator during the transfer of Super Visbestos from storage area to loading area. SAMPLE EQUIPMENT AND TEST PROCEDURES 013632 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a flikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COHMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula + C2T2 + CnTn describes the TWA _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). . Sample No. . J-22 Air Sample Time Minutes on: 8:45A off: 9:15A 30 E-22 on: 8:45A off: 9:15A 30 J-19 on: 9:34A off: 9:44A 10 J-25 on: 9:34A off: 10:00A 26 J-39 on: 9:34A off: 10:00A 26 SUMMARY OF FIBER COUNTS American Mud Company Abilene, Texas 013633 Operation Description Environmental - Prior to the transfer of SVB. Located ^5' from floor and 4' from bags. Inside warehouse storage area. Airborne Fiber Co (fibers/cc >5y) Chrysot Total Asbest 0.1 0.1 Environmental - Prior to the transfer of SVB. Located ~>30' from bags and 3 1/2' from floor. Inside warehouse storage area. <0.1 <0.1 Personal - (Bernis Rains - forklift operator.) During the transfer of 40 bags SVB from warehouse storage area to loading area. 0.2 0.2 Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. Located same as E-22. 0.1 0.1 Environmental - During the transfer of 40 bags SVB from warehouse storage area to loading area. Located same as J-22. 0.1 0.1 Ceiling concentration: 0.2 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. (2) The background fiber concentration was 0.1,fibers/cc. twa - LhmLL0,). o., f1bers/cc American Mud 0X3634 SURVEY AIA-9: DRILLING MUD ADDITIVES-SHIPHENT. STORAGE Survey AIA-9 was performed in the warehouse of a retail drilling mud company during the handling of bags of asbestos additives for ship ping. Sampling was done indoors, while it was drizzling rain outdoors. Work was performed in the warehouse by a lift truck operator and an unloader on the truck. Several other persons were working in the warehouse during the survey. The operations consisted of moving pallets of the bagged asbestos additive with a lift truck to the bed of the truck used for shipping the product to the customer. A full pallet was placed on the bed and an additional 10 bags of material were unloaded from the pallet to the truck by hand and stacked. A diagram of the work area is shown in Figure 9. All bags of the material were in good condition and no broken bags were observed. The condition of the warehouse was clean and the bags of material were handled carefully by the v/orkers. No visible dust was observed during the handling of the bags. Five air samples, including four general air and one breathing zone sample, were taken. The sampling data are summarized as follows: Sample No. AW-1 AW-2 AW-4 AW-5 AW-6 Description 013636 Fibers/Cubic 013635 Time Centimeter (minutes) >5 micron General air, center of warehouse on lift _ truck <o*>,n 36 0.063 General air, center of warehouse during . loading of truck ^>93^"^ ^ 10 <0.077 General air, on cab of truck during loading 10 0.078 Worker exposure, lift operator during truck _ 1 oading Q.? 3 -'/ 9# 12 0.065 General air, center of warehouse after . loading <t>9-/7~ / 10 0.077 * 100 feat 140 feat L____ _i __i_____ nL 1! . 11 STORAGE FOR CLAY /\IM n nTUCD IUIATPRIAI 5 ASBESTOS ADDITIVE STORAGE 0 0 TRUCK LOADING LIFT TRUCK PATH OF LIFT TRUCK STOR/ IGE H--H- STORAGE ' ++ MAIN OFFICE CLAY STORAGE 1-----------------------I OFFICE CLAY -- STORAGE 013637 Figure 9. Diagram showing work area and sampling locations for survey AIA-9. AIRBORNE ASBESTOS COUNTS for Grand Hud Company Abilene, Texas 013638 Date Sampled: January 12, 1977 Date Reported: February 10, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York Grand Mud Company 013642 SURVEY AIA-10: DRILLING MUD ADDITIVES--SHIPMENT. STORAGE During field survey AIA-10, air samples were collected in the ware house of a retail drilling mud firm, while workers loaded a truck with bags of asbestos additive for shipment to a job site. Sampling was per formed indoors while rain fell outside. The work area is shown in Figure 10. The operations monitored con sisted of moving a pallet of bagged asbestos additive over to a truck using a lift-truck, loading a full pallet onto the bed, and then unloading an additional 10 bags onto the truck by hand for shipment. Work was per formed by a lift-truck operator and two warehouse employees. The general condition of the warehouse was dirty with considerable airborne dust and settled dust throughout the area from past bag breakageprimarily clays. Apparently, no cleanup procedures were in effect. ' Four air samples were collected consisting of two general air and two breathing zone samples. The sampling data are summarized as follows: OBJECTIVE: 013639 To monitor airborne asbestos emissions at the subject company's storage facilities. DESCRIPTION OF OPERATION: Operation involved the transfer.of Super Visbestos from warehouse storage facilities to a truck in the loading area. Environmental samples were taken in and near the storage area prior to and during the transfer of Super Visbestos. A personal sample was obtained in the breathing zone of the forklift operator during the transfer of Super Visbestos from warehouse storage area to loading zone. Approximately one pallet was transferred. SAMPLE EQUIPMENT AND TEST PROCEDURES 013640 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenditic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5.microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C^Tj + CgTg + CnTn describes the TWA _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). . Sample No. J-32 J-41 J-44 X-9 J-23 Air Sample Time Minutes SUMMARY OF FIBER COUNTS Grand Mud Company Abilene, Texas 013641 Operation Description Airborne Fiber Cc (fibers/cc >5u) Chryso; Total Asbest on: 10:38A off: 1]:05A 27 on: 10:38A off: 11:05A 27 on: 11:13A off: 11:30A 17 on: 11:13A off: 11:21A 8 on: 11:15A off: 11:30A 15 Environmental - (Prior to the transfer of SVB.) Located ^8' from bags and 5' from floor. Near entrance to men's wash room. <0.1 Environmental - (Prior to the transfer of SVB.) Located HO' from bags and 5 1/2' from floor. On wall near 14' doors between two storage areas. 0.1 Environmental - (During the transfer of ^1 pallet of SVB from warehouse storage area to truck.) Located same as J-41. Forklift passes through doors where pump is located. 0.1 Personal - (Mike Poindexter - forklift operator.) During the transfer of ^1 pallet SVB from warehouse storage area to truck. 0.2 Environmental - during the transfer of pallet SVB from warehouse storage area to truck. Located same as J-32. 0.3 <0.1 0.1 0.1 0.2 0.3 Ceiling concentration: 0.2 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. . * gf (2) The background fiber concentration was 0.1 fibers/cc. . TWA = Mike Poindexter - ^-2) (M3.3.) -f-(P.-l|). .(0.25).+ (7,6) (0.1) _ 0>1 fibers/cc 013643 Sample No. AG-1 AG-3 AG-4 AG-5 Description Time (minutes) General air, warehouse iotxhoS* 23.5 Worker exposure, lift operator loading jt,f-y,c> truck with pallets 8 Worker exposure, helper^.^ao unloading bags from pallet 9 General air, warehouse 15 after loading uxs-'WO Fibers/Cubic Centimeter >5 micron <0.033 <0.098 0.59 0.15 Figure 10. Diagram showing work area and sampling locations for survey AIA-10. o co C3 U ite. 013645 AIRBORNE FIBER COUNTS for D. B. Drilling (AMOCO) Rig #6 Hamlin, Texas Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: 6. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York & OBJECTIVE: 013646 To monitor airborne asbestos emissions at the subject company's drilling facilities during the use of Super Visbestos. DESCRIPTION OF OPERATION: Airborne samples were obtained in the area of the dump prior to and during the use of SVB (Environmental). The dump area was located out doors and samples were taken on a moderately rainy day. No environmental samples were obtained after the dump due to increasingly heavy rain. A personal sample was obtained in the breathing zone of the dump operator during the addition of five bags of Super Visbestos to a hopper. A personal sample was also obtained during bag disposal. SAMPLE EQUIPMENT AND TEST PROCEDURES 013647 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5.microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, time- weighted average (TWA). The formula + C^2 + CnTn describes the _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). .. SaJjle Time.** igruw\l VM I wwvmx D. B. Drilling (AMOCO) Hamlin, Texas 013643 . Minutes _______ Operation Description________ Airborne Fiber Ci (fibers/cc >5y 12^1 CAhsrbyseos J-28 J-15 0-10 0-31 on: 1:20P off: 1:40P 20 Environmental - (Prior to the use of SVB.) Located~3 1/2' above hopper of Rig #6. Weather conditions during time of monitoring - misty rain. on: 1:57P off: 2:28P on: 1:57' 30" off: 2:28P 31 30'30" Personal - (Allen Morgan - dump operator, during the use of SVB.) Operation included unloading and addition of 5 bags SVB to a hopper, located outdoors. Weather conditions during time of monitoring - misty rain. Environmental -(During the use of SVB.) Located same as J-28. Weather conditions at the time of monitoring - moderate rain. 2 Personal - (Allen Morgan, during bag disposal only.) Weather condi- tions at the time of monitoring moderate rain. 0.1 0.3 0.1 1.7 0.1 0.3 0.1 1.7 Ceiling concentration: 1.7 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration was 0.1 fibers/cc. TWA - Allen Morgan - (0.3) tl0,03j. (1.7) + (7.45) (0.1) . Q 2 . & D.B. Drilling Company Eff. 1977 013649 SURVEY AIA-11: DRILLING HUD ADDITIVES, DRILLING SITE Survey AIA-11 covered the operations involving the use of an asbestos additive to the muds at an oil drilling rig. Sampling was performed out doors and the weather was cold and rainy with a slight wind. The operation at the drilling site involved one worker who was responsible for adding the material to the drilling mud through the mud hopper, which was outdoors. The operation consisted of the worker carrying a 50-pound bag of the additive to the side of the hopper, cutting the bag open, and slowly adding the asbestos material to the hopper. As the bags were emptied, the operator would put them in a pile. Upon completion of the pouring (usually 5 to 6 bags of additive), the operator would step on the bags to compress their size and then carry them off to a pit for disposal. At one point during the pouring, one of the bags tore slightly and the asbestos material spilled onto the worker's clothing. Four general air samples and two breathing zone sample were collected during the survey. The air sampling data are summarized as follows: 013650 Sample No. DB-1 DB-2 DB-3 DB-4 DB-5 DB-6 Description General air, 10 feet north of hopper dur ing cleaning /.ixo-fMO General air, 3.5 feet south of hopper dur ing cleaning iSXt- <3^0 General air, 10 feet north of hopper dur ing dump /36"- General air, 3.5 feet south of hopper dur ing dump i3$j- Worker exposure (opera tor) during dump into hopper Worker exposure, disposal of empty bags /*/ Time (minutes) 19.5 19 28 31 29.5 2 Fibers/Cubic Centimeter >5 micron 0.039 0.041 0.027 0.099 0.13 oA 0.39 i.n DRILLING RIG X Figure 11. Diagram of work area showing sampling locations for survey AIA-11. 013651 013652 AIRBORNE FIBER COUNTS for. West Texas Drilling Company Rig #14 (Sun Oil Company) Date Sampled: January 12, 1977 Date Reported: January 26, 1977 Samples Collected By: 6. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York S' OBJECTIVE: 013653 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #14 located ^25 minutes south of Colorado City, Texas) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of nine bags Super Visbestos to a hopper located outdoors. Environmental samples were obtained in the breathing zone of the dump area prior to, during and after the dump. A personal sample was obtained in the breathing zone of the dump operator during the addition of nine bags Super Visbestos to a hopper, which was located outdoors. s 013654 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If trenolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjT^ + C^Tg + CnTn describes the TUA . where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). S Sample Ho. SUMMARY OF FIBER COUNTS West Texas Drilling Company Rig #14n* Qotrt* (Sun Oil Company) UAOoOJ Air Sample Time Minutes _______ Operation Description_________ Airborne Fiber Coi (fibers/cc >5u) Chrysot Total Asbesfr J--21 on: 5:30P off: 5: BOP 0-24 0-20 on: 5:50P off: 6:17P on: 5:50P off: 6:17P 20 Environmental - (Prior to the use of SVB.) Located ^3' from hopper and ~6' from ground. Hopper located out doors . 0.1 27 Personal - (Randy Pelton, dump operator) 0.3 During the addition of nine bags SVB to hopper and during bag disposal. 27 Environmental - (During the use of nine 0.4 bags SVB.) Located same as J-21. 0.1 0.3 0.4 0-16 on: 6:18P off: 6:31P 23 Environmental - (After the use of nine 0.3 bags SVB.) Located same as 0-21. 0.3 Ceiling concentration: 0.3 fibers/cc Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration was 0.3 fibers/cc for 23 minutes after the dump and 0.1 fiber/cc for the remainder of the day. TWA - Randy Pelton - >.) (0.-.3) (-38I,l0,3)-. .(7.17J, (0.1I . West Texas Drilling Company 013656 SURVEY AIA-12: DRILLING MUD ADDITIVIES--OIL RIG Survey AIA-12 consisted of monitoring asbestos exposures at an oil drilling rig where asbestos additives were used in the drilling muds. Sampling was performed outdoors during a rainy, cold, and slightly windy day. The operation consisted of one worker carrying a 50-pound bag of additive to the side of the mudhopper, breaking open the double bag (plastic outside, paper inside), and slowly pouring the asbestos addi tive into a mudhopper. The hopper was located outdoors. After pouring, the worker crumpled up the empty bag and, at the completion of operations, brought them to a disposal area. Nine bags of asbestos were added during the survey. Three general air and two breathing zone samples were collected, and the air sampling data are summarized as follows: Sample No. WT-1 WT-2 WT-3 WT-4 WT-5 Description General air, 3 feet upwind of hopper i7&c -1744 General air, 3 feet upwind of hopper durin/gVdou'm2p-/8 5LO Worker exposure (operator) during dump and disposal of empty bags t7S^~f8l9 Observer exposed during dump . *75't-im General air, 3 feet upwind of hopper after dump ^ ,eai-'S38 013657 Time (minutes) 14.8 27.6 26.8 28 15 Fibers/Cubic Centimeter >5 micron <0.053 0.14 0.20_ (&' 0.08 0.10 * DRILLING RIG WIND .DIRECTION % MUD ADDITIVE STORAGE MUD TANK O1*2'9 MUD HOPPER t IPOURING OPERATOR OBSERVER EXPOSURE 013658- Figure 12. Work area for survey AIA-12. 013659 AIRBORNE ASBESTOS COUNTS for Southwest Drilling Mud (Warehouse) Midland, Texas Date Sampled: January 13, 1977 Date Reported: January 24, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York OBJECTIVE: 013660 To determine airborne asbestos emissions at the subject company' storage facilities. DESCRIPTION OF OPERATION: Warehouse was open on one side. Airborne samples were obtained prior to the transfer of asbestos to a truck. Airborne samples were also obtained after the transfer of asbestos (Environmental). Personal samples were obtained at the breathing zone of the forklift operator during the transfer of 139 bags Super Visbestos and also of other personnel working in the loading area. SAMPLE EQUIPMENT AND TEST PROCEDURES 013661 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Mi Hi pore membrane filters of 0.8 micron porosity. ' Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: , 1. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the asbestos fibers as well as other particles which meet the fore going criteria. If tremolitic talc is present in the sample, the tremolite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-ji^ + C2T2 + CnTn describes the TUA , ZT . where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Sample Wo. SUMMARY OF FIBER COUNTS Southwest Drilling Mud (Warehouse) Midland, Texas Air Sample Time Minutes Operation Description 013662 Airborne Fiber Cour. (fibers/cc >5u) Chrysotil Total Asbestos J-17 J-42 J-l 6-15 J-77 J-37 J-76 A-94 on: 8:20A 29 Environmental - (Prior to the use of 0.1 off: 8:49A SVB). Located at enclosed end of warehouse ~8' from floor and HO' from bags. (Bags stacked ~10' high.) on: 8:22A off: 8:46A 24 Environmental SVB) Located - (Prior to the use of ^10' from door and 41/2 1 0.1 from floor ~20' from bags. on: 8:24A 23 Environmental - (Prior to the use of 0.1 off: 8:47A SVB.) Located at enclosed end of warehouse 6' bags and 51/2' from floor. on: 8:59A 16 Personal - (Jeff Darr - helped load 0.3 off: 9:15A truck) 139 bags SVB loaded onto truck. on: 8:59A off: 9:15A on: 8:59A off: 9:15A on: 9:20A off: 9:45A 16 16 25 on: 9:22A off: 9:45A 23 Ceiling concentration: Personal - (Randall Brook - forklift operator.) During the handling of 139 bags SVB. Personal - (Joe Rusnak - helped load 139 bags SVB from truck. Environmental - (After the transfer of 139 bags SVB.) Located same as J-42. Environmental - (After the transfer of 139 bags SBV.) Located same as J-17. 0.3 fibers/cc 0.1 0.3 <0.1 <0.1 Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The loading operation took place only once during the day. (2) The background fiber concentration was 0.1 fibers/cc. 0.1 0.1 0.1 0.3 0.1 0.3 <0.1 <0.1 TWA - Jeff Derr - (P-*S) (.0.3) * (7.73) (0.1) . g , fibers/cc tWA = Randall Brook - -1g-6-)-(.0L+17-i7.3). (Q-1) = 0j fibers/cc TWA = Joe Rusnak - (0.26) (0.3) + (7.73) (0.1) 8 0.1 fibers/cc Southwestern Drilling Mud 013663 SURVEY AIA-13: DRILLING MUD ADDITIVES-SHIPPING, STORAGE During survey AIA-13, air samples were collected in a drilling mud company warehouse during handling and shipping of an asbestos additive for drilling muds. Work was performed indoors with the door to the ware house open and the wind blowing slightly. The work performed consisted of moving a pallet of bagged asbestos material to a nearby truck (inside the warehouse) using a lift truck and loading the bags on the truck by hand. Two workers and one lift-truck operator completed the work. The condition of the warehouse was clean, the materials were stored and arranged in an organized fashion, and the work was performed carefully. Two general air and two breathing zone samples were collected. The air sampling data are summarized as follows: Sample No. MW-1 MW-2 MW-3 MW-4 Description General air, middle of shed before operations General air, middle of shed during loading Worker exposure, lift-truck operator during Worker exposure, loader's exposure transferring bags from pallet to truck bed 09o/-^9/2> Eff. 1977 013664 Time (minutes) 25.5 Fibers/Cubic Centimeter >5 micron 0.031 15 <0.052 17 17.5 0.23 o.r 0.36 3 013665 Figure 13. Diagram showing work area and sample locations for survey AIA-13. 013666 AIRBORNE ASBESTOS COUNTS for. Robinson Drilling of Texas Inc. Rig #6 Date Sampled: January 13, 1977 Date Reported: January 21, 1977 Samples Collected By: G. J. Spencer Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York & OBJECTIVE: 013667 To monitor airborne asbestos emissions at the subject company's drilling location, located ~25 miles north of Bigspring, Texas, (Rig #6) during the use of Super Visbestos. DESCRIPTION OF OPERATION: Operation involved the addition of 5 bags SVB to a hopper in the formulation of a drilling mud. Airborne samples (Environmental) were taken prior to, during and after the dump. A personal sample was obtained in the breathing area of the dump during addition of 5 bags SVB to a hopper. Samples were obtained outdoors on a moderately windy day. 0X3668 SAHPLS EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. Two results have been reported for each sample - they are: , T. Total Fiber - Any material longer than 5 microns, having an aspect ratio greater than 3:1. This number will include the . asbestos fibers as well as other particles which meet the fore going criteria. If trenditic talc is present in the sample, the trendite "chips" and anthophyllite impurities (if present) would also be in this category. 2. Chrysotile Asbestos Fiber - Any fiber longer than 5 microns, > having an aspect ratio greater than 3:1 which, in the judgement of an experienced operator could be chrysotile asbestos. COMMENTS The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula CjT-j + C2T2 + CnTn describes the TWA _ Tr _ where C = fiber count in fibers/cc and T = time. The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). SUMMARY OF FIBER COUNTS Robinson Drilling of Texas Inc. Rig #6 013669 Sample Wo. 6-12 J-86 J-18 J-27 J-34 C-24 Air Sample Time Minutes on: 11:20A off: 11:44A 24 on: 11:23A off: 11:46A 23 on: 11:48A off: 12:07P 19 on: 11:49A off: 12:04P on: 11:51A off: 12:07P on: 12:06P off: 12:16P 15 16 10 Operation Description Airborne Fiber Cou (fibers/cc >5u) Chrysoti Total Asbestc Environmental - (Prior to the use of SVB) Located 15' from hopper and 4 1/2* from ground. 0 0 Environmental - (Prior to the use of SVB.) Located 10' downwind of bag storage area and 5' from ground. 0 0 Personal - (M.R. Cooper-dump operator) During the dump of 5 bags SVB into a hopper, and during bag disposal. (Operator upwind.) 0 0 Environmental - (During the use of SVB.) Located same as 6-12. 0.1 0.1 Environmental - (During the use of SVB.) Located same as J-86. (8* downwind of dump.) 0 0 Environmental - (After the use of SVB.) Located same as G-12. 0.4 0.4 Ceiling concentration: 0.4 maximum (not breathing zone) - windy day. Time weighted average concentration: The 8-hour TWA has been estimated for the conditions under which the samples were collected based on the following assumptions: (1) The dump operation took place only once during the day. (2) The background fiber concentration is assumed to be 0. TWA = M. R. Cooper - 0.1 or less .. Eff. 1977 Robinson Drilling Company . 013670 SURVEY AIA-14: DRILLING HUP ADDITIVES--OIL RIG General air and worker breathing zone samples were collected at an oil rig during the operations involving the use of asbestos drilling mud additives. The sampling was performed outdoors where the v/eather was cloudy and cool and the winds were blowing from 5 to 10 mph. Work consisted of those operations previously described, that is, one employee cutting open a 50-pound bag of additive, pouring the asbestos into the mudhopper, and at completion bringing the empty bags to a waste disposal pit. Five bags of additive were used during the survey. A diagram of the work area is shown in Figure 14. Four samples were collected and the air sampling results are summa rized as follows: Sample No. BD-1 BD-2 BD-3 BD-4 Description Time (minutes) General air, 20 feet upwind of hopper ink- u+i 28 Worker exposure, dumping sacks and disposing of empti es // ~ i Xo'x. 17.5 General air, 3 feet downwind of hopper during dumping nil - ftloi Observer, 10 feet from hopper '2-Of 15 11.5 Fibers/Cubic Centimeter >5 micron 0.027 0.13 (o) ' <0.052 <0.067 DRILLING RIG 013671 L _ R 1____ , <D ------------ BAG DISPOSAL AREA BEFORE FINAL DISCARDING .1 M CLAY AND Ml STO 11 RAi GE Figure 14. Diagram of work area with sampling locations for survey AIA-14. 013672 //77 // K t*r> S Ptnty. TAS*'f-r American Mud 013673 SURVEY AIA-9: DRILLING HUD ADDITIVES-SHIPMENT, STORAGE Survey AIA-9 was performed in the warehouse of a retail drilling mud company during the handling of bags of asbestos additives for ship ping. Sampling was done indoors, while it was drizzling rain outdoors. Work was performed in the warehouse by a lift truck operator and an unloader on the truck. Several other persons were working in the warehouse during the survey. The operations consisted of moving pallets of the bagged asbestos additive with a lift truck to the bed of the truck used for shipping the product to the customer. A full pallet was placed on the bed and an additional 10 bags of material were unloaded from the pallet to the truck by hand and stacked. A diagram of the work area is shown in Figure 9. All bags of the material were in good condition and no broken bags were observed. The condition of the warehouse was clean and the bags of material were handled carefully by the workers. No visible dust was observed during the handling of the bags. Five air samples, including four general air and one breathing zone sample, were taken. The sampling data are summarized as follows: 013674 Sample No. AW-1 AW-2 AW-4 AW-5 AW-6 Description General air, center of warehouse on lift _ truck Time (minutes) 36 General air, center of warehouse during . loading of truck _ 10 General air, on cab of rtc>// 10 truck during loading r""T~ Worker exposure, lift operator during truck ^ loading ^>033-/9/5 12 General air, center of v/arehouse after . loading $9-/7~ ^96 / 10 Fibers/Cubic Centimeter >5 micron 0.063 <0.077 0.078 0.065 0.077 * Figure 9. Diagram showing work area and sampling locations for survey AIA-9 013675 Grand Mud Company 013676 SURVEY AIA-10: PRILLING HUD APDITIVES-SHIPMEHT, STORAGE During field survey AIA-10, air samples were collected in the ware house of a retail drilling mud firm, while workers loaded a truck with bags of asbestos additive for shipment to a job site. Sampling was per formed indoors while rain fell outside. * The work area is shown in Figure 10. The operations monitored con sisted of moving a pallet of bagged asbestos additive over to a truck using a lift-truck, loading a full pallet onto the bed, and then unloading an additional 10 bags onto the truck by hand for shipment. Work was per formed by a lift-truck operator and two warehouse employees. The general condition of the warehouse was dirty with considerable airborne dust and settled dust throughout the area from past bag breakage-- primarily clays. Apparently, no cleanup procedures were in effect. ' Four air samples were collected consisting of two general air and two breathing zone samples. The sampling data are summarized as follows: 013677 Sample No. AG-1 AG-3 AG-4 AG-5 Description Time (minutes) General air, warehouse tovx'-icS* 23.5 Worker exposure, lift' operator loading /!//-///<> truck with pallets 8 Worker exposure, helper//f/./rxo unloading bags from pallet 9 General air, warehouse 15 after loading nxs-li^ Fibers/Cubic Centimeter >5 micron <0.033 <0.098 0.59 0.15 TRUCK LOADING f) o OFFICE ___ 1^__ _1 _ _1 _ CLAYSiTORAGE -1 11 _ ASBESTOS [: vvmm wV'J ADDITIVE STORAGE LIFT TRUCK ROUTE LIFT TRUCK MISCELLANEOUS BAG STORAGE 0 1--1--H--h- ' STORAGE FOR CLAY AND OTHER MATERIALS l RAILROAD LOADING DOCK Figure 10. Diagram showing work area and sampling locations for survey AIA-10. V D.B. Drilling Company Eff. SURVEY AIA-11: DRILLING HUD ADDITIVES, DRILLING SITE Survey AIA-11 covered the operations involving the use of an asbestos additive to the muds at an oil drilling rig. Sampling was performed out doors and the weather was cold and rainy with a slight wind. The operation at the drilling site involved one worker who was responsible for adding the material to the drilling mud through the mud hopper, which was outdoors. The operation consisted of the worker carrying a 50-pound bag of the additive to the side of the hopper, cutting the bag open, and slowly adding the asbestos material to the hopper. As the bags were emptied, the operator would put them in a pile. Upon completion of the pouring (usually 5 to 6 bags of additive), the operator would step on the bags to compress their size and then carry them off to a pit for disposal. At one point during the pouring, one of the bags tore slightly and the asbestos material spilled onto the worker's clothing. Four general air samples and two breathing zone sample were collected during the survey. The air sampling data are summarized as follows: 013630 Sample No. DB-1 DB-2 DB-3 DB-4 DB-5 DB-6 Description General air, 10 feet north of hopper dur ing cleaning i.l'XO-/MO General air, 3.5 feet south of hopper dur ing cleaning /3*/- '3V0 General air, 10 feet north of hopper dur ing dump /3 3"** General air, 3.5 feet south of hopper dur ing dump t5S7- Worker exposure (opera tor) during dump into hopper ,3 - Hmx L Worker exposure, disposal of empty bags 114 a 9 - H$i Time (minutes) 19.5 19 28 3! 29.5 2 Fibers/Cubic Centimeter >5 micron 0.039 0.041 0.027 0.099 0.13 0.39 t.n DRILLING RIG Figure 11. Diagram of work area showing sampling locations for survey AlA-11. 013631 West Texas Drilling Company 013682 SURVEY AIA-12: DRILLING MUD ADDITIVIES-OIl RIG Survey AIA-12 consisted of monitoring asbestos exposures at an oil drilling rig where asbestos additives were used in the drilling muds. Sampling was performed outdoors during a rainy, cold, and slightly windy day. The operation consisted of one worker carrying a 50-pound bag of additive to the side of the mudhopper, breaking open the double bag (plastic outside, paper inside), and slowly pouring the asbestos addi tive into a mudhopper. The hopper was located outdoors. After pouring, the worker crumpled up the empty bag and, at the completion of operations, brought them to a disposal area. Nine bags of asbestos were added during the survey. Three general air and two breathing zone samples were collected, and the air sampling data are summarized as follows: 013633 Sample No. WT-1 WT-2 WT-3 WT-4 WT-5 Description General air, 3 feet upwind of hopper 17*0-/7^ General air, 3 feet upwind of hopper during dump Worker exposure (operator) during dump and disposal of empty bags Observer exposed during dump General air, 3 feet upwind of hopper after dump ^ Time (minutes) 14.8 27.6 26.8 28 15 Fibers/Cubic Centimeter >5 micron <0.053 0.14 0.2Q_ (*-' 0.08 0.10 DRILLING RIG MUD ADDITIVE STORAGE o 1.2.5 MUD HOPPER i POURING .1 OPERATOR OBSERVER EXPOSURE 013684 4 Figure 12. Work area for survey AIA-12 i Southwestern Drilling Mud 013685 SURVEY AIA-13: DRILLING MUD ADDITIVES--SHIPPING, STORAGE During survey AIA-13, air samples were collected in a drilling mud company warehouse during handling and shipping of an asbestos additive for drilling muds. Work was performed indoors with the door to the ware house open and the wind blowing slightly. The work performed consisted of moving a pallet of bagged asbestos material to a nearby truck (inside the warehouse) using a lift truck and loading the bags on the truck by hand. Two workers and one lift-truck operator completed the work. The condition of the warehouse was clean, the materials were stored and arranged in an organized fashion, and the work was performed carefully. Two general air and two breathing zone samples were collected. The air sampling data are summarized as follows: Eff. 1977 013686 Sample No. MW-1 MW-2 MW-3 MW-4 Description General air, middle of shed before operations General air, middle of shed during loading Worker exposure, lift-truck operator during ^din^^ Worker exposure, loader's exposure transferring bags from pallet to truck bed 09et~^9i2> Time (minutes) 25.5 15 17 17.5 Fibers/Cubic Centimeter >5 micron 0.031 <0.052 0.23 O.f 0.36 O.'b 898 TO Figure 13. Diagram showing work area and sample locations for survey AIA-13. Robinson Drilling Company ' 013688 SURVEY AIA-14: DRILLING MUD ADDITIVES--OIL RIG General air and worker breathing zone samples were collected at an oil rig during the operations involving the use of asbestos drilling mud additives. The sampling was performed outdoors where the v/eather was cloudy and cool and the winds were blowing from 5 to 10 mph. Work consisted of those operations previously described, that is, one employee cutting open a 50-pound bag of additive, pouring the asbestos into the mudhopper, and at completion bringing the empty bags to a waste disposal pit. Five bags of additive were used during the survey. A diagram of the work area is shown in Figure 14. Four samples were collected and the air sampling results are summa rized as follows: Sample No. BD-1 BD-2 BD-3 BD-4 Description Time (minutes) General air, 20 feet upwind of hopper ink.-n+i 28 Worker exposure, dumping sacks and disposing of empties /WzT*" i'Z.o'X. 17.5 General air, 3 feet downwind of hopper during dumping niL - /T2of Observer, 10 feet from hopper //'jfa-teof 15 11.5 Fibers/Cubic Centimeter >5 micron 0.027 0.13 (0) > <0.052 <0.067 % -- It CLAY A NDMIJD STO RAGE l1 i Figure 14. Diagram of work area with sampling locations for survey AIA-14. 013639 w. o. SHAFER ELTON CILLILAND . FERRY DAVIS. JR. LUCIUS a BUNTON FAUL MCCOLLUM CONNELL ASHLEY JAMES M. O'LEARY RAY STOKER. JR TRYON O. LEWIS FRED M. <MICKEY) JONES STEFHEN L. BRANNAN WM. MICHAEL HOLMES CARY C. RILEY SHAFER, GILLILAND, DAVIS, BUNTON 8 McCOLLUM A Professional Corforation ATTORNEYS AT LAW SECOND FLOOR '013690 FIRST NATIONAL BANK BUILDING POST OFFICE DRAWER 1592 ODESSA,TEXAS 79760 TtlIPNOMK A/C May 23, 1977 Mr. Ro Texlam Jorporation 600 Fir Bank Building Abilene, TX / Re: Secretary of Labor v. Texland Drilling Corp. OSHRC Docket No. 76-5316 SOL Case No. 03540 Dear Bob: As you know the government has decided to throw in the towel on this case. I think that after looking at all of the facts they decided that they simply could not win and after a meeting several people in the Dallas office decided to dismiss the complaint. It Is disappointing that we were not able to have a hearing on this matter because we would have won it outright. On the other hand, I am gratified to see that the Citation has been dismissed and the government indicated its unwillingness to go to trial on cases of this type. I hope they show this for bearance in the future without requiring the in depth preparation which was done in this case. Therefore it is possible that within the OSHA organization this case might have some impact as to their enforcement procedures. I am herewith sending to you a copy of their Motion to Dismiss and a letter from the Judge noting this dismissal is to take place. I will probably receive an Order to that effect later. By copy of this correspondence I am notifying Ken Campbell and Harry Wyatt of Montello that I have received this document and am sending them copies. Sincerely, S nww el mm Tryon D. Lewis TDL/mvn Encs: Mr. Robert Halley cc: Mr. Ken Campbell ^ Montello P. O. Box 130 Sand Springs, OK 74063 cc: Mr. Harry Wyatt Montello P.O. Box 130 Sand Springs, OK 74063 Page 2 013691 May 23, 1977 013692 UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION RAY MARSHALL, Secretary of Labor,) United States Department of Labor,) ') Complainant, ) ) v. ) TEXLAND DRILLING CORPORATION, ) ) Defendant. ) ) OSHRC Docket No.76-5316 MOTION TO DISMISS CITATION Comes now the complainant in the above styled case and moves that the citation be withdrawn and the complaint dismissed in the above case. SOL Case No. 03540 CARIN A. CLAUSS Solicitor of Labor RONALD M. GASWIRTH Regional Solicitor HERIBERTO DE LEON Counsel for Occupational Safety and Health By: U. SIDNEY CORNELIUS, JR. Attorney Attorneys for RAY MARSHALL, Secretary of Labor, United States Department of Labor, Complainant. 013693 CERTIFICATE OF SERVICE I hereby certify that on the 20th day of May, 1977, I served one copy of motion to dismiss citation upon respondent by mailing the document in a franked envelope addressed to: Mr. Tryon D. Lewis Attorney at Law 2nd E!loor, First National Bank Building Post Office Drawer 1552 Odessa, Texas 79760 U. SIDNEY CORNELIUS, JR. Attorney UNITED STATES OF AMERICA OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION SUITE 400, FIDELITY UNION TOWER 1507 PACIFIC AVENUE DALLAS, TEXAS 75201 (214) 749-7171 May 19, 1977 013694 Tyron D. Lewis, Esq. Shafer, Gilliland, Davis, Bunton & McCollum, Inc. 2nd Floor First National Bank Bldg. PO Drawer 1552 Odessa, Texas 79760 U. Sidney Cornelius, Jr., Esq. USDOL, Solicitor's Office 555 Griffin Square, Suite 501 Dallas, Texas 75202 Re: Secretary of Labor v. Texland Drilling Corp. OSHRC Docket No. 76-5316 Gentlemen: This is to confirm that complainant has advised this office today that the Secretary is going to file a motion to dismiss the above entitled matter. Accordingly, the hearing scheduled for Abilene, Monday, May 23, 1977, is hereby cancelled. ' U.!. ULI'AM I IVIttVi I Ul LrtliUH OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CITATION and NOTIFICATION OF PENALTY Dallas/Fort Worth Area Office ISSUANCE DATE * OSHA NUI4BER 11/18/7 > F641K 8.10 > REGION * AREA * PAGE Central Place, 1425 W. Pioneer Dr. Irving, Texas 75*61 te 230 6 mo 2F.3 013695 ^rrYPE'OWtOL'ATJON(S) ^jxiTATIONUO. j]*'NSPECTION DATE: H/lO/76 OTHER INSPECTION SITE: Two Miles West Agnes, IX TO: Texland Drilling Corp., Rig #2 P. 0. Box 3037 Abilene, TK 79604 THE LAW REQUIRES that a copy of this Citation be posted immediately in a promi nent place at or near the location of the violation(s) cited below. The Citation must Attn* Mr, Dick Bowen, President remain posted until the violations cited be low have been corrected, or for 3 working days (excluding weekends and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTIES ARE DUE WITHIN IS DAYS OF RECEIPT OF THIS NOTIFICATION UNLESS CONTESTED (See enclosed Booklet) This Section Mas Be Detached Before Posting PENALTY 19 CFR 1926.25l(c)(4)(iv): The total number of visible "broken wires in ares In wire rope(s) eexceeded 10 percent of the total number of wires: Immediately One strand out of four completely severed in the eyelet loop, east of Rig #2 at gerionimo line secure point /; 19 CER 1926.301(d): ;plinters or cracks: Wooden handles of tool(s) were not free of Immediately Long handled shovel with split wooden handle, ground level, east side of Rig #2 i 9 CFR 1926.400(a), Section 5*1-900(2) National Electrical Code, NFE&. 0-1971, us adopted by 29 CER 1926.400(a): Lighting fixtures for fixed ighting was not protected from physical damage by suitable guides or ty ocationt Immediately 55. Rig #2 ' a. All mast lights from floor to ground b. Festoon lights in standby and main mud pump areas c. Festoon lights across east end of slush pits to south end of pipe rack 9 CFR 1926.402(a)(4): Attachment plugs for use in uork areas ere not so constructed as to endure rough use and were not equipped ith a suitable cord grip to prevent strain on the terminal screws: Immediately 0 Z,Home made attachment plug used attached to pigtail of light socket, dog house. Rig northeast corner 0 9 CFR 1926.402(a)(8): Cable(s) passing through work areas were t covered or elevated to protect them from damage which would ' cate a hazard to employees: Immediately 0 Electrical power supply cable across roadway. Rig $2, ground level, east side between rig and trailer house ...EA DIRECTOR OTICE TO EMPLOYEES -- The law gives an employee or his presentative the opportunity to object to any abatement date it for a violation if he believes the date to be unreasonable. Ihe contest must be mailed to the U.S. Department of Labor Area Office at the address shown above within 15 working days (excluding weekends and Federal holidays) of the receipt by ;hc employer of this citation and penalty, EMPLOYER DISCRIMINATION UNLAWFUL - The law pro hibits discrimination by an employer against an employee for ITOTAL PENAL : FOR THIS ; CITATION filing a complaint or for exercising any rights under this Act. )Makecheckoi Mo An employee who believes that he has been discriminated ; Order Payable T against may file a complaint no later than 30 days after the : "POL OSHA' discrimination with the U.S. Department of Labor Area Office ; Indicate OSHA r 1 on Remittancf at the address shown above. ill, PLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. CITATION AND NOTIFICATION OF PENALTY OSHA ? REV 5/76 ; , u.o. uu mh mvu.iv i ui lmwwh OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CITATION and NOTIFICATION OF PENALTY Dallas/Fort Worth Area Office Central Place, 1425 W. Pioneer Dr. - Suite 230 Irving, Texas 75061 < ISSUANCE DATE > 0SHANU USER __ ll/iaA* F643 5 830 > REGION * AREA PAGE 6 1230-- 3 0F 3_____ ; PENALTIES ! ARE DUE I WITHIN IS ` DAYS OF SIMMSfTYPEtOF VIOLATION (Sr. OTHER INSPECTION OATE: . 11/10/76 013696 INSPECTION SITE: Two Miles West ; RECEIPT I OF THIS ! NOTIFICATION ; UNLESS ; CONTESTED to: Texland Drilling Corop.., Rig #2,. P. 0. Box 3037 Abilene, TX 79604 Agnes, IX ! (See enclosed the law requires that a copy of this Booklet) Citation be posted immediately in a promi < nent place at or near the location of the vio- ! This Section Ma\ lation(s) cited below. The Citation must ! Be Detached remain posted until the violations cited be ' Before Posting Attn* Mr. Dick Bowen, President low have been corrected, or for 3 working - days (excluding weekends and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of '.abor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be ead in conjunction with this form.) - TEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTY 9 CFR 1926.500(c)(1)* Wall opening which had more than a four foot drop is not guarded* Immediately Rig #2# open doorway, 6'8W above ground level, drill floor, southeast comer, change house, south doorway & Immediately 9 CFR 1910.27(d)(5)t Cage protection, or ladder safety devices in lieu f cage protection, were not used on tower, water, tank, or chimney ladders /er 20 feet in unbroken length* 0 " Mast ladder approximately 95' unbroken length. Rig $2 3 9 CFR 1910.1001(h)(2)* Asbestos waste, scrap, debris, bags, conliners, equipment, and asbestos-contaminated clothing, consigned for Lsposal, which may produce airborne levels of asbestos fibers in ccess of prescribed limits was not collected and disposed of in ialed impermeable bags or other closed, impermeable containers* Immediately 0 . Approximately 10 used bags Mentello Super Visbestos - used to viscosity drill mud to clean out drill bole. Rig 2, south side, ground level, standby mud pump AREA DIRECTOR JU WAR! OTICE TO EMPLOYEES -- The law gives an employee or his piesentative the opportunity to object to any abatement date at for a violation if he believes the date to be unreasonable, "he contest must be mailed to the U.S. Department of Labor Vea Office at the address shown above within 15 working days excluding weekends and Federal holidays) of the receipt by he employer of this citation and penalty. $80. EMPLOYER DISCRIMINATION UNLAWFUL - The law pro IT0TAL PENAli hibits discrimination by an employer against an employee for : FOR THIS CITATION filing a complaint or for exercising any rights under this Act. jMakecheckorMor An employee who believes that he has been discriminated ; Ofdei Payable T* against may file a complaint no later than 30 days after the ; "POL-OSHA" discrimination with the U.S. Department of Labor Area Office t Indicate OSHA N at the address shown above. \ on Remittance MPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and ourses of action and should be read in conjunction with this notification. ; CITATION AND NOTIFICATION OF PENALTY ,,cu, , ' OSHA 7 REV. 5/76 0 v'>J OCOsJ 4J RULES AND REGULATIONS Title 29--LABOR Chapter XVII--Occupational Safety and Health Administration, Depart ment of labor PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Standard for Exposure to Asbestos Dust On December 7, 1971, an emergency temporary standard concerning exposure to asbestos fibers was published In the Federal Register (36 PH. 23307). In ac cordance with section 6(c) (3) of the Williams-Stelger Occuptaional Safety and Health Act of 1970, a notice of proposed rulemaking regarding a permanent standard for exposure to asbestos fibers was published in the Federal Register on January 12, 1972 (37 F.R. 466). The no tice invited interested persons to submit both orally and in writing, data, views, and arguments concerning the proposal. On or about January 24,1972, the Ad visory Committee on Asbestos Dust was established and requested to make writ ten recommendations with regard to the proposed standard on asbestos. On or about February 1. 1972, the Department of Health, Education, and Welfare trans mitted to the Secretary of Labor a cri teria document containing Recommends- turns for an Occupational Exposure Standard for Asbestos by the National Institute for Occupational Safety and Health (NIOBH). Public notice was given of the receipt of the recommendations and their availability for inspection and copying. On or about February 25, 1972, the Advisory Committee on Asbestos Dust submitted Its written recommendations to the Assistant Secretary of Labor for Occupational Safety and Health. Pursuant to the notice of rule making, a hearing was held on March 14 through 17.1972, for the purpose of receiving oral data, views, and arguments concerning the proposed standard. On or about March 31,1972, the presiding hearing ex aminer certified to the Assistant Secre tary of Labor for Occupational Safety and Health the record of the proceeding. The record Includes prehearing written comments, a transcript of the oral pres entations made at the hearing, and nu merous exhibits received during the course of the hearing or within the pe riod allowed after the dose of the hearing. The proposed standard dealt with (1) permissible concentrations of asbestos fibers; (2) methods of compliance; (3) warning signs; (4) monitoring; (5) med ical examinations; and (6) recordkeep ing. Each of these major proposals elic ited comments, arguments, objections, and counterproposals. They all have been examined and considered. 1. Acceptable concentrations of asbes tos dust. The proposed standard would limit occupational exposure to 8-hour time-weighted average (TWA) airborne concentrations of asbestos dust not ex ceeding five fibers longer than five micrometers per milliliter. Concentra tions above five fibers but not to exceed 10 fibers (ceiling concentration) would be permitted up to 15 minutes in an hour, but for not more than 5 hours in any one 8-hour day. NIOSH in effect has recommended that the five-fiber TWA and 10-fiber peak concentrations be permitted only for 2 years; thereafter, TWA concentra tions should be not more than 2 fibers per cubic centimeter (cm.*) of air, and peak concentrations should not exceed 10 flbers/cm.*, with no time restriction. Numerous objections and counterpro posals have been made, with regard to both the limits of asbestos fiber concen trations and the time periods to comply with them. Some, for example, have rec ommended return to a 12-fiber standard of an earlier day; i.e., a level adopted under the Walsh-Healey Public Con tracts Act In 1969. Others have recom mended a two-fiber standard to become effective In 6 months, then a one-fiber standard for 2 years, and finally a eerofiber standard after 3 years. These rec ommendations give a fair indication of the wide spread of the counterproposals. No one has disputed that exposure to asbestos of high enough intensity and long enough duration is causally related to asbestosls and cancers. The dispute is as to the determination of a specific level below which exposure is safe. Various studies attempting to establish quantita tive relations between specific levels of exposure to asbestos fibers and the ap pearance of advene biological manifes tations, such as asbestosls, lung cancers, and mesothelioma, have given rise to controversy ss to the validity of the measuring techniques used and the relia bility of the relations attempted to be established. Because of the long lapse of time between onset of exposure and biological manifestations, we have now evidence of the consequences of exposure, but we do not have, in general, accurate measures of the levels of exposure oc curring 20 or 30 years ago, which have given rise to these consequences. There are also controversies concerning the relative toxicity of the various kinds of asbestos, and varying haxards in dif ferent workplaces. It is fair to say that the controversy has centered in the area between a twofiber TWA concentration and five-fiber TWA concentration, with variations on the time needed for compliance. Many employers support a five-fiber TWA. Most medical opinion Is divided between a two-fiber standard and a five-fiber standard. In view of the undisputed grave con sequences from exposure to asbestos fibers. It is essential that the exposure be regulated now, on the basis of the best evidence available now, even though it may not be as good as scientifically de sirable. An asbestos standard can be re evaluated in the light of the results of ongoing studies, and future studies, but cannot wait for them. Uvea of employees are at stake. It is concluded that there should be one minimum standard of exposure to asbestos applicable to all workplaces ex posed to any kind, or mixture of kinds, of asbestos. Reasons of practical ad ministration preclude a variety of stand ards for different kinds of asbestos and of workplaces. Also, while the evidence tends to show that crocidolite, for in stance, is more harmful than chrysotile, the evidence is not sufficient to establish separate standards for varieties of asbestos. Because there must be one standard governing exposure to all varieties of asbestos, and in workplaces apparently more hazardous than others; because some present employees with regular ex posure to asbestos have probably al ready accumulated great doaes of asbes tos fibers, due to higher levels of ex posure in the past; because it appears that levels of exposure which may be safe with regard to asbestosls are not safe with regard to mesothelioma; be cause the statute requires the protection of every employee, even of one who may have regular exposure to asbestos during a working life which may reach, or even exceed, *40 years; and because of several other considerations which have been urged and are reflected in the record of the proceeding, the conflict in the medi cal evidence is resolved In favor of the health of employees. As of July 1, 1976, TWA concentrations of asbestos fibers longer than 5 micrometers will not be allowed to exceed two fibera/cc., with a celling value of 10 fibers/cc. The current TWA concentrations of five fibers, and FEOERAl REGISTER, VOL 37, NO. 110--'WEDNESDAY, JUNE 7, 1*72 RULES AND REGULATIONS 013698 11S" ceiling concentration* of 10 flbers/cc, fibers, so that these would not be released 6. Records. The standard, as proposed will be permitted until July 1. 1976, dur in the normal use of the products, should and as adopted, requires maintenance of ing what will be a transitional period not be required to be labeled; and (3) records of monitoring and of medical deemed necessary to allow employers to words such as "danger" and "cancer" are examinations. Most of the controversy in make the needed changes for coming unwarrantedly claiming. this area has revolved around the ques into compliance with the more stringent Both contentions have merit, and the tion whether an employer should be al standard. standard has been changed accordingly. lowed to have access to the results of The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. The operations subject to the single asbestos would have required personal monitor apprehension of those who have argued standard (textile, manufacturing, indus ing and environmental monitoring. against employer access is based on the trial. and marine installation, etc.) will Many issues have been raised concerning expectation that some employers will use meet varying degrees of difficulty in the availability and reliability of meas the medical examinations as a means of complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and plants, extensive redesign and reloca toring, and conditions in which monitor worse, as grounds for discharging current tion of equipment may be needed. It ap ing should be required. The adopted employees, who show signs of being af pears. however, the delay in the effective standard takes the objections into con fected by exposure to asbestos. Since the date of the two-Sber standard will pro sideration. It requires periodic monitor purpose of the medical examinations is vide all employers a reasonable time to ing at intervals no longer than 6 months, to monitor the health of employees ex comply. At the same time, so long as the thus allowing considerable time and dis posed to the hazards of abestos, em ceiling limit is complied with, no harm cretion, and prescribes the use of the ployees cannot in reason be granted the is reasonably expected to result from ex membrane filter method, which is an ac privilege of refusing to disclose to their posures during the transitional period. ceptable method for determination of employers results of occupational expo 2. Methods of compliance. It has been pointed out by many persons, that pro tection against asbestos libers is best obtained by controlling the generation of fibers first, and secondly, by controlling the dispersion of released fibers into the ambient air of the workplaces. Therefore, the standard requires feasible techno logical controls and appropriate work practices as the primary means of com pliance. Rotation of employees as a way of meeting the TWA concentration re quirement is allowed only in stated ex ceptional circumstances, because, as a general rule, it would be difficult to im plement. Personal protective equipment, such as respirators, cannot be relied upon because, among other reasons, they may be so uncomfortable as to be bur densome, except for short periods of time. Therefore, it is expected that res pirators and shift rotation will be used during the period necessary to install en gineering controls and to train employ ees in sound work practices, but, after technological compliance has been achieved, their use must be limited to special work situations and emergencies. Where both are practicable, shift rota tion is required. 3. Labeling. The proposed standard stopped short of requiring labeling as bestos and asbestos-containing products. The proposed standard would have re asbestos fibers. It has also been recommended that employees or their representatives should have an opportunity to observe the monitoring. The recommendation has been accepted. 5. Medical examinations. The pro posed standard would only require an appropriate medical examination on a periodic basis. The generality of the pro posal has attracted many objections and also many helpful comments. The recom mendations of NIOSH and of the Advi sory Committee on Asbestos Dust were much more specific with respect to both frequency and type of medical examina tions to be required. The comments vary as to the class of employees to be ex amined and as to the frequency of the fTtmliuHnni The adopted standard requires medical examinations both at the beginning and the termination of employments exposed to concentrations of asbestos fibers, and also requires annual medical examina tions of every employee exposed to air borne concentrations of asbestos. It has been pointed out that in certain indus tries, such as construction, an employee may work for several employers during the same year. Accordingly, the standard does not require either preemployment, or termination, or periodic examinaton of any employee who has been examined sure. It does not make sense to require employers to provide medical examina tions if they cannot know and use the results of the examinations. Tor these reasons the standard provides that em ployers may have a restricted access to some medical information. On the other hand, there Is no inten tion to allow employers to abuse medical information obtained pursuant to the Act, to the detriment of employees. Therefore, the administration of the medical records requirement will be closely watched, and, in eases of abuse, appropriate action will be considered. The issues discussed above are believed to be the major ones. Numerous other is sues have been raised in the rulemaking proceedings. Some have been referred to incidentally. Many recommendations, for instance, about work practices, are so obviously meritorious that their adop tion needs no exposition here. Other recommendations and many objections have not been adopted for a variety of reasons which should be manifest. Sev eral, for instance, have recommended the use of respirators only pursuant to a variance, or in cases of emergency and occasional short-term exposures. The recommendation with respect to vari ances undoubtedly has many merits, but is considered administratively im quired only warning signs at locations where asbestos hazards are present. However, labeling, rather than warning signs, has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Dust recom mended labels for asbestos products and in accordance with the standard within the past year. One question which has been raised goes to whether the employer or the em ployee should be allowed to choose the examining physician. The standard gives the option to the employer. Since practical. Accordingly, after consideration of the whole record of the proceeding, and pursuant to sections 6 (b) and (c) and 8(c) of the Wllliams-Stelger Occupa tional Safety and Health Act of 1970 (94 containers, and these recommendations some employers already have a medical Stat 1593, 1596, 1699; 39 VS.C. 655, became very controversial in the course examination program in operation, and, 657), 29 CFR 1910.4, and to Secretary of of the proceeding. Many counterpro proposals have been made as to the lan guage of the warning as well as to the products to be subject to the labeling requirements. Employers, in general, also, have medical departments with some expertise in the diagnosis of abestoe-related diseases, it seems more reasonable to permit them to utilize the present programs and expertise, than to Labor's Order No. 12-71 (36 PJfc. 6764), Part 1910 of Title 29 of the Code of Fed eral Regulations is amended as set forth below. strongly contend that (1) finished prod permit an employee to choose a private (1) Section 1910.93 Is amended by re ucts which effectively entrap asbestos general practitioner. vising Table 0-3 to read as follows: EEDEIA1 KEOISTEE, VOL 37, NO. 110--WEDNESDAY, JUNE 7, 1973 11320 11910.93 Air contaminants. Taslx 04-Mmui Dtww Subctanaa Mppcf M|A0 Silica: Crystalline: Quarts (respirable)............ . 3flOf lOxzif/ll1* Quartz (total duet) %aiOrM Crl'tobollte: C H the value calculated from tha count or maa formula* tor quart*. Trlilymltc: Use M the value calculated from the fortntilae tor quart*. Amorphous, Including natural dlutomoceous earth................. %ao.+t ' JO SOmr/M* %o, Silicates (lew than 1% crys talline silica): Mica..................................... Soapstone............................. ThIc...................................... 99 Portland cement.................. *0 firaphite (natural)................. IS t 'oat dust (respirable fraction lets than 6% SIOi)................................... For more than fi7) SIOj.................... or 10mg/ll* Inert or Nuisance Oust: |{esitirable froctiuu............ Total dust............................ %8JOr+J 16 Bmg/M* SO lSmg/M* Not*: Conversion factors-- mppcfX13.3 million partlelee per cubic meter - particles per c.e. I Millions of particles per cubic foot of air, based on Impinger samples counted by UghtOeld technics. i The percentage of crystalline 41k* In the formula Is the amount determined from ato-borne samples, except In those Instances In which ether methods bavs been shown to be applicable. ` As determined by the membrane filter method at tju X phase contrast magnification. * llntb concentration and percent quarts tor tha application of this limit are to be determined from llte fraction passing a slit-selector with the following chorarl eristics: Annuls uarmc diametiT touii iU`ii5ity sphere) Percent paaring elector 2 2 5 76 3.6 M 6.U 1U a0s Tlie measurements under this note refer to the use of an AKC instrument. If the respirable fraction of coal dust IS determined with a MR E the figure corresponding to that(2.4 Mg/M* in tbe table for ohu dust Is 44 Mg/M*. 2. A new 11910.93a is added to Part 1910, reading as follows: 1910.93a Asbestos. (a) Definitions. Nor the purpose of this section, (1) "Asbestos" includes chryaotlle, amosite, crocidolite, tremollte, anthophyllite, and actinolite. (2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers. (b) Permissible exposure to airborne concentrations of asbestos fibers--(1) Standard effective July 7, 1972. Ihe 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. (2) Standard effective July 1, 1976. The 8-hour time-weighted average air borne concentrations of asbestos fibers RULES ANO REGULATIONS to which say employee may be exposed shall not exceed two fibers, looser than 6 micrometers, per cubic centimeter of air, as determined by the method pre scribed in parssmph (e) of this section. (3) CeOtng concentration. No em ployee shell be exposed at any time to airborne concentrations of asbestos fibers In excess of 10 fibers, longer than S micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. (c> Methods of compliance--<1> Engingering methods, (i) engineering con trols. Engineering controls, such as. but not limited to, isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (ii) Local exhaust ventilation, (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed. installed, and maintained in accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI Zfl.2-1971, which is in corporated by reference herein. (b) See ! 1910.8 concerning the avail ability of ANSI 29.2-1971, and the maintenance of a historic file In connec tion therewith. The address of the Amer ican National Standards Institute is given in 11910.100. (ill) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers In excess of the exposure limits pre scribed in paragraph (b) of this section, such as, but not limited to, saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision (U) of this subparagraph. (2) Work practices--(1) Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut. scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the ex posure limits prescribed in paragraph (b) of this section, unless the usefulness of the product would be diminished thereby. (ii) Particular products and opera tions. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively tbe release of airborne asbestos fibers in excess of the limits prescribed in paragraph (b) of this section. (ill) Spraying, demolition, or removal. Employees engaged in tbe spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or Insulated with asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment in accord ance with paragraph (d) (2) (ill) of this section and with special clothing in ac cordance with paragraph (d> (3) of this section. 013699 (d) Personal protective equipment-- (1)Compliance with the exposure limits prescribed by paragraph (b) of this sec tion may not be achieved by the use of respirators or shift rotation of em ployees, except: (1) During the time period necessary to install the engineering controls and to institute the work practices required by paragraph (e) of this section; (ii) In work situations in which the methods prescribed in paragraph (c) of this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of this section; or (111) In emergencies. (iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (I), (ii). or (ill) of this subpara graph. and both are practicable, person nel rotation shall be preferred and used. (2) Where a respirator is permitted by subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior, or the National In stitute for Occupational Safety and Health, Department of Health, Educa tion. and Welfare, und*r the provisions of 30 CFR Part 11 (37 FJt. 6244, Mar. 25. 1972), and shall be used In accordance with subdivisions (i). (ii). Oil), and (iv) of this subparagraph. (I) Air purifying respirators. A reusa ble or single use air purifying respirator, or a respirator described in subdivision (it) or (ill) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed In paragraph (b) of this section, when the celling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. (II) Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, when the ceiling or the 8-hour timeweighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those limits. (ill) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand, supplied-air respirator shall be used to reduce tbe concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in.paragraph (b) of this section, when the celling or the 8-hour timeweighted average airborne concentra tions of asbestos fibers are reasonably expected to exceed 100 times those limits. (iv) Establishment of a respirator pro gram. (a) The employer shall establish a respirator program in accordance with ftDtlAl Itoism, VOL 37, NO. 110--WCDNKDAY, JUNE 7, 1972 RULES AND REGULATIONS 013700 ii32i the requirements of the American Na where asbestos fibers are released to be subparagraph shall conform to the re tional Standards Practices for Respira monitored in such a way as to determine quirements of 20" x 14" vertical format tory Protection, ANSI Z88.2-1969, which whether every employee's exposure to signs specified in 11910.148(d)(4), and is incorporated by reference herein. asbestos fibers Is below the limits pre to this subdivision. The signs shall dis b. See 11910.6 concerning the avail scribed in paragraph (b) of this sec play the following legend in the lower ability of ANSI Z88.2-1969 and the main tion. If the limits are exceeded, the em panel, with letter sizes and styles of a tenance of an historic Hie in connection ployer shall immediately undertake a visibility at least equal to that specified therewith. The address of the American compliance program in accordance with in this subdivision. National Standards Institute is given in 11910.100. (c) No employee shall be assigned to tasks requiring the use of respirators if, paragraph (c) of this section. (2) Personal monitoring--(i) Sam ples shall be collected from within the breathing zone of the employees, on legend Asbestos'____________ Notation 1" Sans Serif, Gothic or Block. based upon his most recent examination, membrane filters of 0.8 micrometer po- Oust Hazard ti" Sana Serif, an examining physician determines that rossity mounted in an open-face filter Gothic or the employee will be unable to function holder. Samples shall be taken for the Block. normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by his use of a respirator; Such employee shall be rotated to another job or given the determination of the 8-hour timeweighted average airborne concentra tions and of the ceiling concentrations of asbestos fibers. (ii) Sampling frequency and patterns. Avoid Breathing Dust... Wear Assigned Protective Equipment. Do Not Remain In Area Unless Tour Work Re quires It. 14" Gothic. 14" Gothic. 54 " Gothic. opportunity to transfer to a different po After the initial determinations required Breathing Asbestos Dust 14 point Gothic. sition whose duties he is able to perform by subparagraph (1) of this paragraph, Hay Be Hazardous To with the same employer, in the same geo samples shall be of such frequency and Tour Health. graphical area and with the same senior ity. status, and rate of pay he had Just prior to such transfer, if such a different position is available. (3) Special clothing: The employer shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph <b> of this section. (4> Change rooms: (i) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed in paragraph (b) of this section, the em ployer shall provide change rooms for employees working regularly at the place. (ii) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (3) Environmental monitoring--(i) samples shall be collected from areas of a work environment which sue represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter bolder. Samples shall be taken for the determination of the 8hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers. (ii) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable Spacing between lines shall be at least equal to the height of the upper of any two lines. (2) Caution labels--(i) Labeling. Cau tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. (ii) Label specifications. The caution labels required by subdivision (i) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caution Contains Asbestos Fibers <ill> Laundering: (a) Laundering of accuracy the levels of exposure of the Avoid Creating Dust asbestos contaminated clothing shall be employees. In no case shall sampling be Breathing Asbestos Dust Hay Cause done so as to prevent the release of air at intervals greater than 6 months for Serious Bodily Barm borne asbestos fibers in excess of the ex posure limits prescribed in paragraph (b) of this section. (b> Any employer who gives asbestoscontaminated clothing to another person for laundering shall inform such person of the requirement in (a) of this subdi vision to effectively prevent the release of airborne asbestos fibers in excess of the exposure limits prescribed in para graph (b) of this section. (c) Contaminated clothing shall be employees whose exposures to asbestos (h) Housekeeping--(1) Cleaning. All may reasonably be foreseen to exceed external surfaces in any place of employ the exposure limits prescribed in para ment shall be maintained free of accu graph (b) of this section. mulations of asbestos fibers if, with their (4) Employee observation of monitor dispersion, there would be an excessive ing. Affected employees, or their rep concentration. resentatives. shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels. (1) Cau , Asbestos waste, scrap, debris, bags, containers, equip ment, and asbestos-contaminated cloth ing, consigned for disposal, xUsJUQRL produce in any reasonably foreseeable* (i) tion signs, d) Posting. Caution signs transported in sealed Impermeable bags, shall be provided and displayed at each or other closed, impermeable containers, location where airborne concentrations and labeled in accordance with para of asbestos fibers-may be In excess of the ` graph (g) of this section. (e) Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at~400-450 X (magnification) (4 millimeter objective) with phase contrast illumination. (f) Monitoring--(1) Initial determi nations. Within 6 months of the publi cation of this section, every employer exposure limits prescribed in paragraph (b) of t%ls section shall be collected and (b) of this section. Signs shall be posted disposed of in sealed impermeable bags, at such a distance from such a location or other closed. Impermeable containers. so that an employee may read the signs (i) Recordkeeping--(1) Exposure rec and take necessary protective steps be ords. Every employer shall maintain rec fore entering the area marked by the ords of any personal or environmental signs. Signs shall be posted at all ap monitoring required by this section. Rec proaches tq areas ^ontaMfig exeesgfifi. ords shall be maintained for a period of concentrations of airborne asbestos at least 3 years and shall be made avail fibers. 1 1 ~ able upon request to the Assistant Secre (it) Sign specifications. The warning tary of Labor for Occupational Safety shall cause every place of employment signs required by subdivision (i) of this and Health, the Director of the National FEDERAL REGISTER, VOL 37, NO. 110--WEDNESDAY, JUNE 7, 1972 11322 RULES AND REGULATIONS Institute for Occupational Safety and Health, and to authorized representa tives of either. (2> Employee access. Every employee and former employee shall have reason able access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the em ployee's own exposure to asbestos fibers. <31 Employee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed in paragraph <b> of this section shall be notified in writing of the expo sure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely notified of the cor rective action being taken. (j) Medical examinations--<1) Gen eral. The employer shall provide or make available at his cost, medical examina tions relative to exposure to asbestos re quired by this paragraph. <2> Preplacement. The employer shall provide or make available to each of his employees, within 30 calendar days fol lowing his first employment in an occupation exposed to rirborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram (posterior-anterior 14 x 17 Inchest, a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second <FEVY). (3) Annual examinations. On or be fore January 31. 1973, and at least an nually thereafter, every employer shall provide, or make available, comprehen sive medical examinations to each of his employees engaged in occupations ex ited to airborne concentrations of as bestos fibers. Such annual examination shall include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 Inches), a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV.). (4) Termination of employment. The employer shall provide, or make avail able. within 30 calendar days before or after the termination of employment of any employee engaged in an occupation exposed-to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 inches). a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEVi). <5> Recent examinations. No medical examination is required of any em ployee. If adequate records show that the employee has been examined in ac cordance with this paragraph within the past 1-year period. (6) Medical records--(i) Mainte nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained by employers for at least 20 years. (il) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, for inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of NIOSH, to authorized physi cians and medical consultants of either of them, and, upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the Infor mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. 3. A new 5 1910.19 is added to Subpart B of Part 1910, reading as follows: 1910.19 Asbraloidual. Section 1910.93a shall apply to the ex posure of every employee to asbestos dust in every employment and place of employment covered by 11910.12, { 1910.13. } 1910.14, f 1910.15, or I 1910.10, in lieu of any different standard on ex posure to asbestos dust which would otherwise be applicable by virtue of any of those sections. Effective date. Paragraph (b)(2) of { 1910.93a shall become effective July 1, 1976. All other provisions of if 1919.93a, 1910.93, and 1910.19 shall become effec tive July 7,1972. The current emergency temporary standard remains in effect until July 7, 1972. (Secs. S, 8, M SUt. 1593, 1598; 29 U S C. 658, 657: 29 CVR 19)0.4: Secretary of Labor's Order No. 12-71, 38 TM. S764) Signed at Washington, D.C., this 2d day of June 1972. O. C. OUZNTHIK, Assistant Secretary of Labor. |FR Doc.72-8574 Piled 6-6-72:8:48 am] 013701 r A service covering the executive's responsibilities under the new Federal Occupational Safety & Health Act- a , fr** l.Tf f nr M&M Publications: Employee Relations In Act Businessman & The Law White Collar Management A Marketing In Action Manufacturing & The Law Protection Management p*tc' Safety & Security For Supervisors (samples on request) MAN & MANAGER, INC. 799 Broadway, New York, N. Y. 10003 ,`r t ia mt ij a //it* f?ti * < t May 1, 1977 ^ *"'64, OSHA ALERT ------------- 013702 1239. In the first clear-cut U. S. Supreme Court test of OSHA, the Court unanimously upheld the enforcement provisions of the Job Safety Act. It rejected arguments by two contractors that the imposition of penalties with out a jury trial was unconstitutional--and it upheld fines levied by OSHA against them totaling $5, 600. anagement is asking these questions about OSHA; 1240. We use asbestos insulation in our office building and some of the fibers get into the air. Does that mean we have to take air samples--and give our employees physical exams? Not necessarily. Bell Laboratories raised this point with OSHA--and received the following reply: + When an employer suspects there are airborne concentrations of asbestos, it should take initial tests to determine the extent of employee exposure. + If employee exposure does not exceed 0. 1 fibers greater than 5 microns in length per cubic centimeter on an 8-hour basis, physical exams are not required. + Continuous air sampling is not required unless employee exposure exceeds 2 fibers greater than 5 microns per cubic centimeter on a 3hour time-weighted basis. Q-1241. What's all the excitement about a new health Standard covering lead exposure? A. OSHA wants to amend its regulations to limit worker exposure to airborne lead to not more than 100 micrograms per cubic meter of air over an 8-hour workday. The agency estimates that initial cost of compliance will run anywhere from $4. 1 to $9. 8 million--and that annual compliance costs will approximate $2. 5 to $4. 8 million. A draft 'economic impact' statement predicts that 1*7 to 19 independent lead smelters and a number of marginal battery plants will be forced out of business. Hearings on the proposed new regulation are now underway. The Lead Industries Association has launched a strong campaign in opposition, claim ing the regulation will not materially improve worker health. . Q-l 242. We give our employees periodic medical exams--and keep the results in their personnel files. Does the government have the right to look at these records? 1S77. Man & ?/ar.ager, Inc. Published monthly. President and Editor. Lawrence Stessin; Secretary-Treasurer, Stanley A. Spano; Editorial Vife ^resident. A'nctd *.a;aicn; Senior Editor. Elmer Ellentuck; Associate Editor, Len Smedresman; Assistant Editor. Bruce Singer: Copy Editor. Dorothy Kaden. Ec tc'*ai dice: 799 Broadway, Ne*. York, N.Y. 10003. Business Cf?*ce: Helen Beldegreen. t/ana&er; S7 Terminal Drive, Plamview, N.Y. 11803 (516-822 10*v). Pnce $36 yearly. Annual Inde*. All rights of reproduction in any form strictly reserved. March 26, 1975 U S. DEPARTMENT OF LABOR OCCUPATIONAL SAFCTY A MCALTH ADMINISTRATION ROOM HI. MTROktUM RUILOIMO 4 SOUTH ROULOCR STRICT TULSA. OKLAHOMA ?4J 013703 Mr. Ken Campbell Montello, Inc. P.O. Box 130 Sand Springs, Oklahoma 74063 RE: Asbestos - 29 CFR 1910.93(a)(g)(1)(1) Dear Mr. Campbell: The following Information Is provided regarding your Inquiry and to confirm our telephone conversation of March 24, 1975. a. Caution signs are required where In the judgement of the compliance officer, based upon air sample results or visual observation, backed up with documentation that airborne concentrations of asbestos may be in excess of exposure limits. b. Signs shall be posted at all approaches to areas containing excessive concentrations of airborne asbestos fibers. These signs are required where airborne concentrations of asbestos exceed exposure limits. It is hoped that this information will assist in providing a safe and healthful workplace and complying with applicable standards. Sincerely, J. T. KNORFP Area Director JTK/bl OCCUI'Al IONAL SAFETY AND HUAL1H ADMINISIHAUON , CITATION and NOTIFICATION OF PENALTY Dallas/Fort Worth Area Office T ISSUANCE DATE ' 0SHA NUMIER II/I8/7 > F6435 830 > REGION AREA PAGE Central rla.ee, 1425 W. Pioneer Dr. - Si#te 230 Irving, Texas 7JD6l 6 1780 -2 ", 3 AMl* f OTHER 1 VI TO: Texland Drilling Corp., Rig #2 P. 0. Box 3037 Abilene, TL 79604 Attn: Mr. Dick Bowen, President 1 NSPECTION DATE: 11/10/76 013704 INSPECTION SITE: Two Miles West Agnes, TX THE LAW REQUIRES that a copy of this Citation be posted immediately in a promi nent place at or near the location of the violation(s) cited below. The Citation must remain posted until the violations cited be low have been corrected, or for 3 working days (excluding weekends and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within IS working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) PENALTIES ARE DUE WITHIN 15 DAYS OF RECEIPT OF THIS N0TIFICAT UNLESS CONTESTEr (See endosec Booklet) This Section Be Detached Before Postir ITEM NUMBER STANOARD. REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION * DATE BY WHICH VIOLATION MUST PENALT BE CORRECTED -- 3r 29 CFR 1926.25l(c)(4)(iv)s Hie total number of visible broken wires in ./ires in wire rope(s) exceeded 10 percent of the total number of wires: Immediately 0 One strand out of four completely severed in the eyelet loop, east of Rig 2 at gerionimo line secure point ; 29 CFR 1926.30i(d): splinters or cracks: Vooden handles of tool(s) were not free of Long handled shovel with split wooden handle, ground level, east side of Rig #2 l 29 CFR 1926.400(a), Section 3>l-9(b)(2) National Electrical Code, NFRi '0-1971, as adopted by 29 CFR 1926.400(a): Lighting fixtures for fixed .ighting was not protected from physical damage by suitable guides or by Location: Immediately Immediately 0 55. Rig#fc a. All mast lights from floor to ground b. Festoon lights in standby and main mud pump areas c. Festoon lights across east end cf slush pits to south end of pipe rack 9 CFR 1926.402(a)(4): Attachment plugs for use in work areas ere not so constructed as to endure rough use and were not equipped ith a suitable cord grip to prevent strain on the terminal screws: Home made attachment plug used attached to pigtail of light socket, dog house. Rig $2, northeast corner Immediately 0 0 9 CFR 1926.402(a)(8): Cable(s) passing through work areas were t covered or elevated to protect them from damage which would .cate a hazard to employees: Immediately 0 Electrical power supply cable across roadway. Rig #2, ground level, east side> between rig and trailer house *' C2 ' A..EA OIRECTOR OTICE TO EMPLOYEES -- The law gives an employee or his .presentative the opportunity to object to any abatement date "t for a violation if he believes the date to be unreasonable, rhe contest must be mailed to the U.S. Department of Labor EMPLOYER DISCRIMINATION UNLAWFUL - The law pro hibits discrimination by an employer against an employee for filing a complaint or for exercising any rights under this Act. An employee who believes that he has been discriminated TOTAL Pcrj; FOR 1 HI CITATIQf Wakecheckor f Older Payable Area Office at the address shown above within 15 working days (excluding weekends and Federal holidays) of the receipt by .he employer of this citation and penalty. against may file a complaint no later than 30 days after the discrimination with the U.S. Department of Labor Area Office at the address shown above. "POL OSH Indicate OSH - on Rcimtf.i EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. CITATION AND NOTIFICATION OF PENALTY OSH A 7 REV 5/76 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CITATION and NOTIFICATION OF PENALTY Dallas/Fort Worth Area Office Central Place, 1425 W* Pioneer Dr. - Suite 230 Irving, Texas 75061 t ISSUANCE DATE > OSH A NUMBED l/l8/7< ^6435-830 > AEGIIOON AREA * FACE _6 1730- OF | OTHER1| INSPECTION OATE: 11/10/76 INSPECTION SITE: 013705 Two Miles West Agnes, TX to: Tcxland Drilling Corop.. Rieg #2 P. 0. Box 3037 Abilene, TX 79604 the law requires that a copy of this Citation be posted immediately in a promi nent place at or near the location of the violation(s) cited below. The Citation must remain posted until the violations cited be Attn: Mr. Dick Bowen, President low have been corrected, or for 3 working days (excluding weekends and Federal holi days) whichever is longer. "his citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. i'ou must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of .abor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be ead in conjunction with this form.) TEM NUMBER .TANDARO. REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTIES ARE 0UE WITHIN IS DAYS OF RECEIPT OF THIS N0TIFICATU UNLESS C0NTESTE0 (See enclosed Booklet) This Section h Be Detached Before Posting PENALTY ) CFR 1926.500(c)(l)s Vail opening which had more than a four foot drop is not guarded: Immediately Rig 2, open doorway, 6'8" above ground level, drill floor, southeast corner, change house, south doorway >- .* Immediately ) CTO 1910.27(d)(5): Cage protection, or ladder safety devices in lieu cage protection, were not used on tower, water, tank, or chimney ladderjs er 20 feet in. unbroken length: Mast ladder approximately 95* unbroken, length. Rig $2 l . > CFR 1910.1001(h)(2)* Asbestos waste, scrap, debris, bags, con-iners, equipment, and asbestos-contaminated clothing, consigned for jsposal, which may produce airborne levels of asbestos fibers in :cess of prescribed limits was not collected and disposed of in aled impermeable bags or other closed, impermeable containers: Immediately Approximately 10 used bags Mentello Super Visbestos - used to viscosity drill mud to clean out drill hole. Rig 2, south side, ground level, standby mud pump AREA DIRECTOR _A VARIS OTICE ToEMPLOYEES -- The law gives an employee or his EMPLOYER DISCRIMINATION UNLAWFUL - The law pro nesentative the opportunity to object to any abatement date hibits discrimination by an employer against an employee for for a violation if he believes the date to be unreasonable, filing a complaint or for exercising any rights under this Act. contest must be mailed to the U.S. Department of Labor An employee who believes that he has been discriminated Office at the address shown above within 15 working days against may file a complaint no later than 30 days after the ding weekends and Federal holidays) of the receipt by discrimination with the U.S. Department of Labor Area Office oloyer of this citation and penalty. at the address shown above. YER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and if action and should be read in conjunction with this notification. CITATION AN0 NOTIFICATION OF PENALTY ,,ri,, ,, : rw c $80. 0TAL PENAl FOR THIS CITATION akecheckorMf )f(Jer Puyjbie "POl-OSHA ndicate OSHA on RemiMant in*i/n CITATION TO: . INDUSTRIAL COMMISSION OF UTAH OewpatlofiH Safety and Haalth Division CSHpNO. N0002 UOSHO-1 NO.' W\ 018 7f F "1 ARIA REGION Don J. Christiansen, w' 1700 08 Administrator 448 South 400 East y ' \ > Salt lake City, Utah 84111 Lj ,-Afy 3. Citation Number I 4. Pagaof S. Si TYPE OF ALLEGED VIOLATION(S): None 7. An Inspection was made on September 12 . 10 Zl_of a place of employment located at: B. Vnrnal and Rnncnunlt Mamhouses and Yards ___________________ and described as follows: 9. Achnctns loading, unloading, trucking and.warehousing-------- ---.. On the basis of the inspection it la alleged that you have violated the Utah Occupational Safety and Health Act of 1073, in rise following respects: 10. Item number ii. Standard, regulation or section of the Act allegedly violated 12. Description of alleged violation 13. Date by which Waged violation must be corrected In compliance t - ...............................................................-- - x- .... .. > THIS NC TiCE [ViUST BE POSTED tt V - # - - -- --------- ------- ---------------- - -------------~------ -------- ---------------- The law requires that a copy of this citation shall be prominently posted in a conspicuous place at or near each place that an alleged violation referred to in the citation occurred. The citation must remain posted until all alleged violations cited therein are corrected, or for 3 working days, whichever period is longer. RIOHTS OF EMPLOYEES Any employee or representative of employees who believes that any period of time fixed In this citation for the correction of a violation is un reasonable has the right to contest such time for correction by submitting a letter to the Utah Occupations) Safety end Health DMsJon at the address shown above within 30 days of the Issuance of this citation. "No parson shall dtsehargs or In any manner discriminate against any employe* because such employee has filed sny complaint or Instituted or ^rrf to be instituted any proceeding under or related to thbAjt or Has testified or I* about to testify In such proceeding or beceute of the exarch* by tueh employee on heheH of Mmeelf nr other* of eny rleM^flnrcferi by thh Act." See. 11 (21 lei of the Utah Oeenpeilonel Salary end lleetth AM Ar*i ssi lofx. /( / (i s'** /y' y . .. t 14. Administrator'* Signature. o.i.December 11 ,* 14 ' jiarjr <*>. iiy 1 P"*'*1 RMJL *' 1 < I .1 I M | 4. -"-""T" ^ 1-- ----- --------i n'y 1h "^ ----- -m--- -------v--- (NOTICE: Addition/ Important Information On Revert* Side) UOSHD Form-2 July 1. 1973 013707 AIRBORNE ASBESTOS COUNTS for Cactus Drilling Rig #5 ~20 Miles Southwest of : ' Vernal, Utah Date Sampled: September 23, 1977 Date Reported: September 28, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: Reported By: G. J. Spencer Union Carbide Corporation '* G. J. Spencer Union Carbide Corporation Union Carbide Corporatfon Metals Division Niagara Falls, New York OBJECTIVE 013708 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #5) during the use of five bags of Super Visbestos. DESCRIPTION OF OPERATION Operation involved the addition of five bags Super Visbestos, bentonite, limestone and zinc chromate to a vent-type hopper in a drilling application. SAMPLE EQUIPMENT AND TEST PROCEDURES 013709 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. ' Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS .. - - The details of sample collection arid resultant fiber counts are listed in the attached table(s). ` Several photographs obtained in the work zone during monitoring are included. The OSHA regulations permit a maximum limit of 2 fibers greater than 5.microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-jT-j + C2T2 + CnTn describes the TWA . __ where C = fiber count in fibers/cc and T = time. In the present application the worker handled asbestos for 14 minutes and left the area. Asbestos was not used again. Presumably his exposure for the other parts of the shift was zero or at most at the level of the natural background. For a zero exposure, for the time not handling asbestos, his 8-hour, time-weighted average exposure can be estimated as: 8-hour TWA = (P r 3)114JM0.0) (466) * q.01 fibers/cc >5y . In the vicinity of the hopper, the levels before and after handling ranged from 0.0 to 0.04 fibers/cc >5y. If the worker had stayed in the vicinity of the hopper throughout the shift his maximum TWA exposure is estimated as: 8-hour TWA - (0-3)(H) M0.04)(466) . 0.05 The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. The ceiling exposure for this operation was 0.3 fibers/cc greater than 5 microns. Air Sample Time Minutes on: 1:00P off: 1:39P on: 1:01P off: 1:41P on: 1:01P off: 1:41P 39 40 40 on: 1:47P off: 2:01P 14 on: 1:48P off: 1:59P on:. 1:48P off: 2:OOP on: 2:05P off: 3:14P on: 2:07P off: 3:16P on: 2:09P off: 3:13P . 11 12 69 69 64 Ooeration Description ----- - 013710 Airborne Fiber Cos (fibers/cc >5y) "' Chrysotile Asbestos Area - prior to the use .of asbestos. Located ~20 feet south of hopper and 3-1/2 feet above ground. Area - prior to the use of asbestos. Located ~4 feet west of hopper-'6 feet above ground, and **2 feet above hopper. Area - prior to the use of asbestos. Located ~5 feet east of hopper~3-1/2 feet above hopper and~6-l/2 feet above ground. Rig #5. Personal - (Chuck Ireland) During 12 min. dump of five bags SVB, and during bag disposal. Area - during the dump of five bags SVB. Located same as M-52. Area - during the use of asbestos. Located same as M-48. Area - after the use of asbestos. Located same as M-52. Area - after the use of asbestos. Located same as M-48. Area - after the use of asbestos. Located ^3 feet from hopper, "1 feet above hopper and ^5 feet above ground. 0.04 0.02 0.04 0.3 0.1 0.3 0 0.01 0.01 0137U FIGURE 1 - Rig #5 FIGURE 2 - Hopper and dry materials storage area. FIGURE 3 - Hopper and dry materials storage area. 013712 FIGURE 4 - Addition of SVB to hopper. FIGURE 5 - Addition of SVB to hopper. vvi ~L - 013713 Don J. Christensen, Administrator Utah State Industrial Commission 444 South 4th Host Salt Lake City, Utah DATE: August 22, 1977 REFERENCE NO: 77-14 ANA LYSIS Type and Percent ASBESTOS Laboratory Field Sample Sample Number Number Type Volume 0157 #1 BULK TYPE ASBESTOS ' \ ASBESTOS '. . . ', ; - \ - *,, 'i _ . ' Vo ' ' / * \ :` * . .' . 1 ' . '. * . ; COMMENTS: 013714 AIRBORNE ASBESTOS COUNTS for Cactus Drilling Rig #5 ^20 Miles Southwest of Vernal, Utah Date Sampled: September 23, 1977 Date Reported: September 28, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York 013715 OBJECTIVE To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #5) during the use of five bags of Super Visbestos. DESCRIPTION OF OPERATION Operation involved the addition of five bags Super Visbestos, bentonite, limestone and zinc chromate to a vent-type hopper in a drillinq application. SAMPLE EQUIPMENT AND TEST PROCEDURES 013716 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Several photographs obtained in the work zone during monitoring are included. The OSHA regulations permit a maximum limit of 2 fibers greater than 5.microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-jT-j + C2T2 + CnTn describes the TWA _ where C = fiber count in fibers/cc and T = time. In the present application the worker handled asbestos for 14 minutes and left the area. Asbestos was not used again. Presumably his exposure for the other parts of the shift was zero or at most at the level of the natural background. For a zero exposure, for the time not handling asbestos, his 8-hour, time-weighted average exposure can be estimated as: 8-hour TWA - (-3);,lAirJ0,0;,;A66) s ,, fibers/cc >5u . In the vicinity of the hopper, the levels before and after handling ranged from 0.0 to 0.04 fibers/cc >5y. If the worker had stayed in the vicinity of the hopper throughout the shift his maximum TWA exposure is estimated as: 8-hour TWA = 1P---D 0iJ1 + 10^1(4.6,6), = 0>05 The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. The ceiling exposure for this operation was 0.3 fibers/cc greater than 5 microns. vu* w trm i v* I AlSi.it UVWIHW Sample Ho. Air Sample Time_____ Minutes _ ;' 013717 Airborne Fiber Coi (fibers/cc >5p) _______ Operation Description_________ Chrysotile Asbestos M-39 M-48 M-52 on: 1:00P off: 1:39P on: 1:01P off: 1:41P on: 1:01 P off: 1:41P M-19 M-49 N-95 M-44 M-46 B-9 on: 1:47P off: 2:01P on: 1:48P off: 1:59P on:. 1:48P off: 2: OOP on: 2:05P off: 3:14P on: 2:07P off: 3:16P on: 2:09P off: 3:13P 39 Area - prior to the use.of asbestos. Located ~20 feet south of hopper and 3-1/2 feet above ground. 0.04 40 Area - prior to the use of asbestos. Located -4 feet west of hopper -'6 feet above ground, and ~2 feet above hopper. 0.02 40 Area - prior to the use of asbestos. Located ~5 feet east of hopper- 3-1/2 feet above hopper and~6-l/2 feet above ground. Rig #5. 0.04 14 Personal - (Chuck Ireland) During 12 min. dump of five bags SVB, and during bag disposal. 0.3 11 Area - during the dump of five bags SVB. Located same as M-52. 0.1 12 Area - during the use of asbestos. Located same as M-48. 0.3 69 Area - after the use of asbestos. Located same as M-52. 0 69 Area - after the use of asbestos. Located same as M-48. 0.01 64 Area - after the use of asbestos. Located --3 feet from hopper, ~2 feet above hopper and -5 feet above ground. 0.01 . & 013718 FIGURE 2 - Hopper and dry materials storage area. FIGURE 3 - Hopper and dry materials storage area. FIGURE 4 - Addition of SVB to hopper. FIGURE 5 - Addition of SVB to hopper. Chapter G 93a Pules and Regulations Page 171 013720 in accordance with 93a.3.1.2 of this Part. 93a. 3.2 Work practices. 93a.3.2.1 Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut, scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the exposure limits prescribed in 93a.2 of this Part, unless the usefulness of the product would be . diminished thereby. _ ` 93a.3.2.2 Particular products and operations. No asbestos cement, mortar, coating, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed in 93a.2 of this Part. 93a.3.2.3 Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos insulation or coverings shall be provided with respiratory equipment in accordance with 93a. 4.2.3 of this Part and with special clothing in accordance with 93a.4.3 of this Part. 93a.4 Personal protective eouip- msnL. 93a.4.1 Compliance with the exposure limits prescribed by 93a.2 of this Part may not be achieved by the use of respirators or shift rotation of employees, except: 93a.4.1.1 During the time period necessary to install the engineering controls and to institute the work practices required by 93a. 3 of this Part. m . * 93a .4.1.2 In work situations in which the methods prescribed in 93a.3 of this Part are either technically not feasible or feasible to an extent insufficient to reduce the airborne concentrations of asbestos fibers below the limits prescribed by 93a.2 of this Part; or *93a.4.1.3 In emergencies. . 93a.4.1.4 Where'both respirators and personnel rotation are allowed by subdivisions 93a.4.1.1, .2, or .3 of this Part, and both are practicable, personnel rotation shall be preferred and used. 93a.4.2 Where a respirator is permitted by 93a.4.2.1, it shall be selected from among those approved by the Bureau of Mines, Department of the Interior, or the National In stitute for Occupational Safety and Health, and shall be used in accord ance with 93a.4.2.1, .2, .3, and .4 of this Chapter. 93a.4.2.1 Air purifying respi rators. A reusable or single use air purifying respirator, or a respirator described in 93a.4.2.2 or 93a.4.2.3 of this Chapter, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in 93a.2 of this Part, 'when the ceiling or tne 6-nour hime- weighted average airborne concen trations of asbestos fibers are ^pjisnnah) y expected to exceed no more than 10 thnxt* limit*._______________ 93a.4.2.2 Powered air purifying respirators. A full facepiece Utah Occupational Safety and Health Division Utah Biomedical Test Laboratory 520 Wakara Way Salt take City, Utah 84108 Phone 801 581-8267 LABORATORY REPORT Vcitt'vL-' . 013721 TO: Don J. Christensen, Administrator Utah State Industrial Commission 444 South 4th Hnst Salt Lake City, Utah DATE: August 22, 1977 REFERENCE NO: 77-14 ANA LYSIS Type and Percent ASBESTOS Laboratory Field Sample Sample Number Number Type Volume TYPE ASBESTOS ' % ASBESTOS 0157 #1 BULK ------------- r--------- --------- 9 if '7d .. . ;^ - ; ' *,V * COMMENTS: BASIN MUD SERVICE 't . P.O.BOX 1075 VERNAL. UTAH B407S ...; 013722 September 6, 1977 Industrial Commission of Utah Occupational Safety and Health Division 448 South 400 East : Salt Lake City, Utah 84111 : - ; . t Attention: Don J. Christiansen,. Administrator ' .. * 7 Dear Sir; . ;- In reference to your "UOSHA Form -2*? of, July 12, 1977 citing our company for allowing our employees to. be exposed to asbestos fibers on July 2, 197-7-;we are requesting a formal hearing for the followings reasons: 1. Our employees do not incorporate said material with the mud mix. ;, :r.: 2. In a conversation with our supplier'we have found that the past tests have shown to have far less than 10 fibers longer than 5 micro meters, per cubic centimeter of air, as noted in regulation 93a2.3 Chapter G page 93a. of Utah Occupational Safety and Health Rules and Regulations. 7/e would appreciate having enough notification to collect information needed in our defense from our suppliers and or contractors. Sincerely, , Kenneth K. Carlson Production Manager KC/dj cc: Chuck Petrey, Montello, Inc. Larry Dernback, Manning Co. file 013723 ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA XK3SCKX8afeXXXX36XaOfiXaKX3aOHX30C!XK30eXOEK3( 1745 Jefferson Davis Hwy., Crystal Square 4, Suite 509, Arlingotn, VA. 22202 1 September 1977 Mr. Harry Wyatt Mantello, Inc. P. O. Box 130 Sand Springs, Oklahoma 74063 Dear Mr. Wyatt: I enjoyed talking with you yesterday. Pursuant to our conver sation, I am enclosing the case that Dr. Rhodes had mentioned to you. Hopefully it will be of some assistance. If there is any way that this Association can be for additional service to you in the future, please do not hesitate to call. Good luck in Utah. Warm regards. MEG:pi \ 013724 FILE these Decisions in your Occupational Safety & Health Reporter Decisions binder in page number order behind the Cases tab. OOCUPATIOML SAFETY & HEALTH REPORTER Number ISTHE BUREAU OF NATIONAL AFFAIRS. INC. June 16.1977 DECISIONS IN THIS ISSUE 5 OSHC 1465 -- 1494 Inspection--Warranties* Search-- Constitutionality Ky Ct App: Kentucky Depart ment oF Labor is not entitled to court order comp riling inspection of dosed areas of employers busi ness premises without warrant based on showing of probable cause, absent showing that busi ness Is inherently dangerous or is subject to Federal or state regula tion or is pervasively regulated. .. 1465 Discrimination--Union Business Agent's Access to Workplace DC WPa: Employer's refusal to permit union's business represen r tative to enter employer's premises for monthly safety meeting, con trary to past practice and in ap parent retaliation for union's filing of safety complaint with OSHA, constitutes violation of Section 11(e) of Act......................... 1467 Air Contaminants--Asbestos-- Proof of "Release" RevComm: Monitoring require ment of asbestos standard, 29 CFR 1910.1001, is not triggered by "genuine possibility" of re lease but only by actual release of asbestos fibers; accordingly. Secre tary's failure to establish that em ployer's process of replacing asbestos insulation resulted in re lease of fibers requires vacation of citation for violation of 29 CFR 1910.1001(f)(1)................................. 1473 Jurisdiction -- Affecting Com merce--Business in Dissolution RevComm: Employer whose business was in process of dissolu tion but had employees engaged in dismantling mac'-: -ry to be sold as scrap metal . engaged in business affecting u amerce... 149] Jurisdiction--Federal Agencies-- Truck Maintenance Shop RevComm: Fact that Bureau of Motor Carrier Safety of Federal Highway Administration has adopted no regulations concern ing truck maintenance shop safety warrants finding that employer is not exempt from coverage of (Continued on following page) TABLE OF CASES American Barrel Company, Inc....................................................................... .-.................... .. 1491 Braswell Motor Freight Lines, Inc............................................................................................. 1469 Burk Construction Corporation..................................................................................................1488 Capitol Erection and Engineering Company, Inc............................................... .................. 1493 Consolidated Freightways Corporation............. ............... 1481 D & H Pump Service, Inc...........................................................................................................1485 Goodyear Tire & Rubber Company......................................................................................... 1473 Kennedy Tubular Products, Marshall v.................................................................................... 1467 K hi Engineering Company........................................................................................................ 1487 Spencer Leathers........................................................................................................................... 1484 Western Steel Company..............................................................................................*1............ 1489 Wheeling-Pittsburgh Steel Corporation................................................................................... 1477 Willamette Iron & Steel Company............................................................................................147S Yocom v. Bumette Tractor Company, Inc............................................................................... 1465 Section 3 Copyright 1977 by The Bureau of National Affairs, Inc. fcrrrr . k1 &#tsi [ ! '^1*1 . .i *:!>* F 013725 C* Goodyear Tire & Rubber Company 5 0 C1473 assesses no penalty in light of respondent's good faith efforts to have handrails erected. 1 dissent from vacating the notification of failure to correct items 5, 7, and 11.* In my view, the Judge correctly held that re spondent failed to abate these violations, and the violation as to each should there fore be affirmed. My disagreement with the majority's de cision is rooted in the different meanings that we ascribe fo the term "abatement." Under the majority's interpretation, abate ment of a violation requires only that the violative condition be brought into momen tary compliance with the literal terms of the standard. ! submit that this is an un duly narrow reading of the term "abate ment" that poorly serves the purposes of the Act. In my view, "abatement" contemplates an initial remedying of noncomplying con ditions as well as a continuing duty on the part of an employer to take all reasonable steps necessary to ensure that compliance with a standard's requirements is main tained. The Murphy Co., 1 BNA OSHC 1618, 1973-74 CCH OSHD para. 17.532 (No. 445, 1974) (Cleary', Commissioner, concurring and dissenting opinion). The undesirability of the majority's position is amply demonstrated by the facts of the instant case. . The original citation alleging a failure to comply with the standards herein involved was issued on July 3. The violations were ordered to be corrected by July 29. Respon dent did not contest the citation, and the citation therefore became a final order of the Commission by operation of law. On August 5, a reinspection of respondent's facility was made. On this date, less than one week after abatement was to be com pleted, the same oily rag receptvdi was found uncovered,6 7th*e same fire ext: ishers were found sitting on the shop fit v and 61 do not join the majority's discussion of items 9 and 10 involving an alleged failure to comply with 29 CFR 1910.215(J(2) and (4), as it is unne*e>>uiy. Tne Judge vacated these items on the b.'vU of lack of cmptoyee espowire to the hazards Involved. In his brief, the Secretary expressly states that the ludge's vacation of these items is not being challenged before the Com mission. These items, therefore, are not before cs for review. Cf. Stjr Circle Wall Svs'.ems. Inc.. 4 BSA OSHC ton. 1975-76 CCH OSHD para. 20.502 (No. 3271, 1976). 6The applicable standard. 29 CFK 1910.106^X9X5). a Tire protection standard, requires that combustible waste and residues be "kept to a minimum, stored in covered facial receptacles and disposed of daily.'' Plainly, respondent has failed to do this. 7The standard at 24 CFR 1910.157(aX5) requires the mounting of portable fire extinguishers. It does not provide for mounting only some of the time. certain of the same electrical switches an ' panels were found with wires exposed.* Even if respondent's evidence that it cov ered the receptacle and electrical outlets, and that it mounted the fire extinguishers, is credible, I would conclude that these actions alone do not fulfill respondent's continuing duty to control the hazards in volved. To do so in view of the fleeting nature of the "compliance" achieved in this case is to compromise unnectssariW the safety of employees.9 GOODYEAR TIRE & RUBBER COM PANY Review Commission Decision SECRETARY OF LABOR, Complain ant v. GOODYEAR TIRE & RUB3ER COMPANY, Respondent, OSAHRC Doc ket No. 13442, May 12. 1977. James F. Gruben, Dallas, Tex., for com plainant. Dale R. Martin, Cincinnati, Ohio, for respondent. Review Commission Judge J. Paul Brenton. Before Bamako, Chairman; Moran and Cleary, Commissioners. AIR CONTAMINANTS Asbestos--Proof of "Release" t-220.03 Monitoring requirement of asbestos stan dard, 29 CFR 19: 1001, is not triggered by "genuine possii" ly" of release but only by actual release of asbestos fibers; ac cordingly, Secretary's failure to establish that employer's process of repine'.: asbestos insulation resulted in release o. ners re quires vacation of citation for violation of 29 CFR 1910.1: 1(f)(1). *Sectto-> 1910.W(j) of 29 CFR Part 1010 hc.-rporates by reference the 1970 National Fleetri-'d Cod* requiring In* guarding of live parts of electrical equip ment. As the Administrative Law Jud^e observed. "To put a cover in place and then promptly rcr.w<: it cr permit it to be knocked off and remain off is not genuine abatement of a violation.*' J.D.-22. ^To cite the noncomplying conditions observed dunn-i the reinsp-etioft as "repeat** siolations. as is sth cesjed in the majority opinion. would be an unsa:i`.ct^r>' method of dealing with this type of situation, cvpec'uHy in vie-* of the fact that my colleagues* interpretation of the tern "repeated" limits its application to some form of sp^ravated conduct. See the separate opinions in G**o*ge i/vmun Conitr. Co.. (Nc*. 13559 |5 OSHC 13151. April 26. 1977). 013726 I-wi-i-i U. . 5 OSHC 1474 Goodyear Tire & Rubber Company Full Text of Decision BARNAKO, Chairman: The issue in this case is whether Respon dent violated the monitoring and record keeping requirements of the standard for asbestos.1 Respondent was cited for al legedly failing to monitor an operation wherein asbestos insulation on pipes was removed and replaced with non-asbestos insulation. Judge J. Paul Brenton dismissed the charges on the grounds that Complain ant failed to establish a prima facie case that asbestos fibers were released during the operation. For the reasons that follow we affirm Judge Brenton's decision. Respondent is engaged in the manufac ture of petrochemicals and latex rubber at its Houston, Texas plant. The plant con tains approximately ICO miles of pipe, most of it out-of-doors. One quarter of the piping is insulated with various materials, some of which is asbestos insulation. Most of the asbestos insulation is covered and contained with metal jacketing. Respondent ceased installing asbestos insulation in 1972. Thereafter, whenever leaks in the piping occur and repairs are necessary, any asbestos insulation in the vicinity of the leaks is removed and replaced by non-asbestos insulation. Since most of the insulated pipe carries caustic liquids, ar line is thoroughly flushed as part of the repair procedure, and this results in com plete saturation of the insulation before its removal. The job of removing insulation is per formed by one of four different employees who are pipefitters. The operation is per *AI the lime of the inspection the standard was c*vtitird at 29 C.F.R. 19!0.9Jj. !: is now codilied at 29 C.F.R. 1910.1001. 40 F.R. 23072 (May 23. 1975). The monitoring provision Mates as folio*-*: # 1910.1001(0 Monitoring. (J) Initial determinations. Within 6 months of the publication of this section, every employer shall cause every place of employment where asbestu* fibers are releaved to be monitored in such a way as to determine whether every employee's exposure to asbestos fibers is brio* the limits pre scribed in paragraph (b) of this section. If the limits are exceeded, the employer shall immediately under take a compliance program in accordance with para graph (c) oi this section. The relevant portion of the recordkeeping provision states as follows: )910.l00l(i) Recordkeeping. (|) Exposure records. Every employer shall maintain records of any per sonal or environmental monitoring required by this section. Records shall be maintained for a period of at least 20 years and shall be made available upon request to the Assistant Secretary of Labor for Occu pational Safety and Health, the Director of the Na tional Institute for Occupational Safety and Health, and to authored representatives of either. After recodification this provision was changed by substituting *20 years'* for **3 years.** 41 Fed. Reg* 11504 (March l<* 197M formed on the average of once monthly and takes between five and ten minutes. When changing insulation employees wear protective clothing and respirators in accord ance with Respondent's instructions. Infrequently, the pipefitters replace dry insulation in buildings where "dryers" are located. The amount of insulation removed is less than ten feet and the job is performed when no one else is in the building. Any dry asbestos insulation removed is placed in plastic bags and put in the trash. During the inspection a few pieces of asbestos insulation were discovered in a storage loft contrary to Respondent's in structions. However, only the pipefitter working on replacement entered the loft while this insulation was stored there. Complainant's compliance officer testi fied that, generally, whether fibers are re leased is determined by sampling the air in the vicinity of the asbestos. He stated he did not know if asbestos fibers were being released at Respondent's plant since he did not take any air samples. He opined that, from his past experience working with as bestos fibers at other plants, there was some release of asbestos fibers in the atmo sphere of Respondent's plant. He also testified that his area director and one of Complainant's industrial hygienists were of the opinion that due to the type of opera tion, there was a release of Fibers. Respondent's pipe department foreman maintained that dust is not created when old insulation is removed as it is already saturated. He testified that all asbestos in sulation is covered, the pipefitters perform ing this work always wear respiratory equip ment, 90 percent of the work is out-of-doors. A former employee testified that he had always worn a respirator when changing insulation. The Judge ruled that since the standard requires monitoring only "where asbestos fibers are released", it does not operate to require monitoring where asbestos is merely present and/or in use. He stated that one essential element of proof was "some fact or circumstance from which it may be reason ably rationalized that at least a trace of this kind of liber was being released". Regarding the asbestos insulation on the pipes, the Judge pointed out that most of it was completely saturated upon removal. He observed that any dry insulation that was replaced because it had been knocked loose from the pipes was contained with metal jacketing, and there was no evidence that this jacketing had been punctured so as to allow release of asbestos fibers. TVi o Inrlrvu IV> i4 --- - - -- - f ' / ( V t f V Goodyear Tire & Rubber Company 5 OSHC 1475 of insulation, dry or wet, does not prove were released. McCormick, Law of Evi release. The evidence as a whole, he con dence. Sec. 339, at 794 (2d ed. 1972). We cluded, failed to sustain the inference that therefore reject the argument that he need fibers were released into the atmosphere only show a "genuine possibility" of release. in the presence of employees. Accordingly, Complainant relies on Amoco Oil Co., he vacated the alleged violations of the as 76 OSAHRC 39/A2, BNA 3 OSHC 1745, bestos standard. CCH OSHD para. 20,183 (1975). In that On review Complainant contends that a case, the administrative law judge found a prirna facie case is established by showing violation based on evidence that certain a genuine possibility of the release of asbestos work practices at an Amoco refinery caused fibers and employee access thereto. Com the airborne release of asbestos fibers. That plainant argues that the evidence of record is not the case here, and this case is dis establishes the possibility of release and tinguishable because release cannot be in employee access. Complainant also argues ferred from the nature of Respondent's that the standard does not require proof work practices. of exposure inasmuch as the standard speaks only of release. Even if exposure is neces sary to sustain a violation. Complainant contends that evidence of Respondent's precautionary measures is irrelevant because the standard is directed toward obtaining a reading of asbestos in the atmosphere and rot the amount inhaled by employees.1 Finally, Complainant argues that Respon dent, by alleging that asbestos release did not occur, has the burden of proof on this matter. Complainant also relies on the compli ance officer's testimony to establish that an inference of release can be drawn. We note, however, that the compliance officer's testi mony was equivocal.4 In weighing the evi dence, the Judge found his testimony in sufficient. The Judge's evaluation is sup ported by the record and we accept it. Okland Construction Co., 76 OSAHRC 30/F4, BNA 3 OSHC 2023, CCH OSHD para. 20,441 (1976). As noted above. Complainant would Complainant also urges that we find a have us read the standard to require mon violation based on our decision in GAF itoring by a showing of "the genuine possi Corp., 75 OSAHRC 3/A2, BNA 3 OSHC bility of asbestos release in Respondent's 16S6, CCH OSHD para. 20,163 (1975), plant and employee access thereto."3 The pet. for review filed. No. 76-1028 (D.C. standard does not rely, however, on the Cir., Jan. 13, 1976). In GAF a divided mere possibility of release before triggering Commission affirmed citations for violations the monitoring requirement. It requires of the medical examination requirements monitoring only "where asbestos fibers are of the asbestos standard upon a showing released" (emphasis added). Complainant that employees were exposed to some con has the burden of proving that the standard centration of airborne asbestos. In this case, was violated. 29 C.F.R. 2200.73. He must there has been no similar showing. Further carry that burden by a preponderance of more, in placing the burden of proving the evidence. Armor Elevator Co., 5 release upon Complainant we do not go so OSAHRC 260, BNA 1 OSHC 1409, CCH far as to require that he prove the concen OSHD para. 16,958 (1973). Thus, to prove tration of asbestos fibers has reached any- a violation. Complainant must establish specified level in order to establish a prirna that it is more likely than not that fibers facie case. In this respect our decision in this case is consistent with GAF Corp. See 3Respondtnt argues that, even if fibers are released, the sporadic n-Uult vf the etpovuic of its employee, 111 \U'* of (he sue of the plant and infrequent nature of Western Electric. Inc., No. 8902, BNA 4 OSHC 2021, CCH OSHD para. 71.538 (January 24, 1977). the work render monitoring infeasible. It con- that she purposes of she Ac: are better served by its pV:cy of using personal protective equipment and precautionary work practices *hen its employees work *;:h asbestos. In slew of our disposition, need not rew*v- this issue. Since the evidence fails to establish that Respondent's process of replacing asbestos insulation resulted in the release or as bestos fibers, a violation of Section 1910. 1001(t)(l) has not been established. Conse "^Complainant would have us conclude from the fact quently there is no violation of the record- th>: Krvponrtcnf required the use of revpirators and its w .-:k practices that Respondent recognised the possi ble:;.- of asbestos rt'ea*e. We will not draw such an In adidtinn to relying on his own opinion, the com inference. The fact that an employer, perhaps out of an abundance of caution, takes certain precautionary sr.p> does not establish that the employer believes pliance officer purported to rely on the opinion, of the area director and the industrial hygienist. Aside from the hearsay nature of that testimony, the record lh*>e precautions are required by Complainant's stan dard,. See R*y*Us Siends Co.. 76 OSAHRC JI/CI4. BNA 3 OSHC 2031, CCH OSHD para. 20.447 (1976). docs not reveal the qualifications, if any, of the area director and the industrial hygienist to form such an opinion. 013728' 5 OSHC 1476 Goodyear Tire < Rubber Company keeping requirements of Section 1910.1001 (i)(l). Accordingly, the decision of Judge Bren- ton to vacate the alleged violations of the asbestos standard is affirmed. Dissenting Opinion CLEARY, Commissioner, dissenting: Regardless of whether the asbestos stan dard requires monitoring when there is a "genuine possibility of asbestos release," as argued by the Secretary, or only when "it is more likely than not that fibers lare] released," as stated by the majority, the evidence adduced in this case shows a failure to comply with the standard pub lished at 29 CFR 51910.1001(f)(1). The majority, therefore, errs when it accepts the Judge's evaluation of the evidence and affirms his disposition. There was no dispute that respondent's pipefitters repaired leaks and replaced worn .or damaged insulation on pipes, some of which were insulated with asbestos. It was complainant's position at the hearing that the removal of asbestos insulation would release asbestos fibers into the air. Although not urged by complainant during the course of these proceedings, there is a strong indi cation within the provisions of 51910.1001 that the removal of asbestos insulation causes the release of asbestos fibers. Para graph (c)(2)(iii) of 51910.1001 requires the wearing of respirators and special clothing when employees are engaged . . in the removal or demolition of asbestos insula tion or coverings. . . The presence of such a requirement strongly suggests a find ing by the Secretary of Labor during rule making that the removal of asbestos insu lation releases asbestos fibers. Moreover, proof of complainant's posi tion was adduced through testimony of the compliance officer and two of respon dent's employees. Their testimony estab lishes a probability of asbestos release war ranting monitoring of the operations in volving the handling of asbestos insulation. Before working for the Department of Labor, the compliance officer had worked for 21 years in the petrochemical industry. During this time he had handled asbestos insulation on numerous occasions. He testi fied that, when replacing worn and often times crumbling asbestos insulation, fibers were released into the air. The majority notes, but fails to specify, equivocation in the compliance officer's testimony. My review of his testimony reveals nothing that could be considered equivocal. . In any event, the most persuasive testi mony on asbestos release during the re placement process came from the foreman of respondent's pipe department. Part of his testimony was that most but not all the asbestos insulation was saturated with water before removal. He opined that saturated insulation would not release asbestos fibers during removal and replacement. Both the majority and the Judge attach significance to the fact that most of the insulation was saturated before replacement. Apparently, they regard the saturation process as obviat ing the requirement for monitoring. I would not. Although saturation is a work practice which contributes to compliance under 51910.1G01(c)(2Xi), it does not necessarily follow that employers who use the method are relieved from the duty to monitor under 51910.1001(tXl). 1 submit that, by its terms, 51910.1001(f)(1) requires an employer to monitor exposure levels before instituting specific compliance methods. This is evi denced by the last sentence of 51910.1001 (0(1). which reads as follows: If the (permissible exposure] limits are exceeded, the employer shall immediately undertake a compliance program in ac cordance with paragraph (c) of this section. Respondent did not monitor the vicinity of damaged asbestos insulation before satu rating it. Moreover, even if 1 were to dis regard the standard's mandate for pre abatement monitoring, 1 submit that an employer who implements a compliance program must conduct personal monitoring under 51910.1001(0(2) to determine the efficacy of the methods in use. This was not done by respondent. As noted, respondent's foreman .stiFied that some of the asbestos insulation was replaced without first being saturated. He also testified that dry, damaged insulation would release asbestos fibers into the air during replacement. Nevertheless, the Judge rejected this evidence of asbestos release because "iiie quantity iof asbestos dust^ released] would be so small and in frequent that exposure to asbestos fibers would be nil. . . .'' In addition, he stressed the fact that the insulation was enclosed in a jacketing that was "pretty hard." Both bases for ignoring the foreman's explicit statement that asbestos dust is re leased are incorrect. It is plain error to attach any significance to estimates of low concentrations in determining whether the duty to monitor attaches. Monitoring stan dards are intended to supplant such esti mates, no matter how reliable they may be. Wheeling-Pittsburgh Steel Corporation 5 OSHC 1477 See Western Electric, Inc., 4 BNA OSHC Full Text of Decision 2021, 1976-77 CCH OSHD para. 21.538 (No, 8902, 1977) (Cleary, Commissioner, MORAN, Commissioner; dissenting), petition for review withdrawn. A January 26, 1976, decision of Review No. 77-1252. 8th Cir., April 8. 1977. Under Commission Judge Ben D. Worcester, at the facts of this case it is also error to re tached hereto as Appendix A {omitted].1 gard the fact that the insulation was jacketed is before this Commission for review pur as negating a duty to monitor. The reason suant to 29 U.S.C. 661(i). That decision for replacing the insulation was that it was vacated a citation which alleged that re damaged. Such damage, according to both spondent had violated 29 U.S.C. $654(a) respondent's pipefitter and foreman, some (2) by failing to comply with the occupa times involved breaks or cracks in the jac tional safety standard codified at 29 C.F.R. keting. Thus, the Judge erred in ruling that $1910.95(b).1 The Judge's vacation of the respondent had no duty to monitor asbestos citation was based on complainant's failure release during the handling of dry insulation. to establish the existt- : of feasible engi Similarly, the majority errs when, in neering and administc e controls for re addition to accepting the Judge's erroneous ducing employee exposure to noise. For analysis, it regards as probative the fre reasons that follow, the Judge's decision is quency and duration of exposure and the affirmed. precautions taken when dry asbestos insu Review of the Judge's decision in this lation is replaced. The monitoring mdard matter was requested by Local $1190, does not permit these qualifications. Rather, United Steelworkers of America, the $1910.1001(0(1) requires that . . every 'authorized employee representative. The employer shall cause every place of employ union contends that (1) respondent did ment where asbestos fibers are released to use feasible controls to reduce empk be monitored.. . ." exposure to noise and (2) the Judge er: -i Accordingly, I dissent from the majority's in placing the burden of proof on complain disposition of the citations at issue in this ant to establish the feasibility of engineering case. and administrative controls. It is a well-settled principle that the bur den of proving all elements of an alleged violation rests with complainant. Brennan WHEELING-PITTSBURGH STEEL v. OSAHRC and Raymond Hendrix d/b/a CORPORATION Review Commission Decision Alsea Lumber Company, 511 F.2d 1139 [2 OSHC 1646] (9th Cir'. 1975); 29 C.F.R. f2200.73(a). The standard of proof to be SECRETARY OF LABOR, Complain applied in these proceedings is the pre ant v. WHEELING-PITTSBURGH STEEL ponderance of the evidence rule. Olin Con CORPORATION, Respondent, OSAHRC struction Co. v. OSAHRC, 525 F.2d 464 Docket No. 13949, May 13, 1977. ]3 OSHC 1526] (2d Cir. 1975); Secretary v. Dennis Dowdell, Jr., Cleveland, Ohio, Armor Elevator Co.. Lite., 5 OSAHRC 260 for complainant. (1 OSHC 1409] (1973). The burden of George Raynovich, Jr., Pittsburgh, Pa., proving that engineering or administrative for respondent. controls are feasible was therefore properly Review Commission Judge Ben D. Wor assigned to complainant. Also see Secretary cester. v. Continental Can Co., htc., OSAHRC Before Bamako, Chairman; Moran and Docket No. 3973 {4 OSHC 1541], August Cleary, Commissioners. 24,1976. NOISE The record before us is totally devoid of any probative evidence regarding the Feasibility of Controls >-210.1155 > 110.03! feasibility of administrative or engineering noise controls for respondent's worksite. Complainant's only witness on this subject Secretary s failure to present evidence 'was the industrial hygienist who sondiicied regarding feasibility of administrative or the inspection at respondent's mill. This engineering noise controls for employer's witness had no particular expertise in the worksite, other than testimony of industrial hygienist with no particular expertise in area of noise abatement and control, war rants affirmance of judge's decision vacat ing citation for violation of 29 CFR 1910. 95(b). 'Chairman Bamako dors not a^rrr to this attach ment. JThaI standard provides in pertinent part as follows: "When employees are subjected In sound levels escveding those listed in Tahle C I6. feasible adminbtrative or engineering controls shall be utiiseed." 013730 October 4, 1977 w+Mr. Ken Carlson Basin Mud Service P. 0. Box 1075 Vernal, Utah 84078 v*/z Dear Ken: Enclosed is a copy of Carbide's report on Blair's field monitoring at the well near Vernal. As you can see, the counts are all far below the ceiling limit of 10 fibers per cc. Any assumption that they could exceed 10 times that ceiling (as specified in the citation) is just simply ridiculous. We are standing by for information from you on the following points: 1. Whether the November 14th hearing can be set back to Friday morning, November 11th. (This would enable Dr. Rhodes to be there.) 2. The name of your attorney, so Dr. Rhodes can talk with him in advance by phone. Before this, it would be useful if your man could look over the reports we have sent you. 3. Any indication you can get from Gulf and Manning that they would go back to Super Visbestos, if we can succeed in getting the citation rescinded. 4. A description of the type of hearing that has been set in Salt Lake. Who will preside? Is it with 0SHA only, or is a Review Commission involved? Who will argue for OSHA's side on the citation? etc. etc. Ken, please let us know if you need any further back up information from here. As soon as we hear from you, we will get Dr. Rhodes wired in for the trip. Best regards, M0NTELL0, INC. Kenneth N. Campbell KC/mt Enc: (1) monteUo P.O. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 From The Desk Of DOROTHY LEPIANO 013731 September 29, 1977 Dear Mr. Wyatt, At the request of Mr. Ingalls, kindly forward three copies of the Cactus Drilling Rig #5 report to Basin Mud. Any questions may be forwarded to Dr. Rhodes or Ms. Spencer. Thank you. (: . Rhodes) CALIDRIA" ASBESTOS w 013732 AIRBORNE ASBESTOS COUNTS for Cactus Drilling Rig #5 ~20 Miles Southwest of Vernal, Utah Date Sampled: September 23, 1977 Date Reported: September 28, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: G. J. Spencer Union Carbide Corporation Reported By: G. J. Spencer Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York *> OBJECTIVE 013733 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #5) during the use of five bags of Super Visbestos. DESCRIPTION OF OPERATION Operation involved the addition of five bags Super Visbestos, bentonite, limestone and zinc chromate to a vent-type hopper in a drilling application. , SAMPLE EQUIPMENT AND TEST PROCEDURES 013734 Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Several photographs obtained in the work zone during monitoring are included. The OSHA regulations permit a maximum limit of 2 fibers greater than 5 microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-jT^ + CgT2 + CnTn describes the TWA ZT where C = fiber count in fibers/cc and T = time. In the present application the worker handled asbestos for 14 minutes and left the area. Asbestos was not used again. Presumably his exposure for the other parts of the shift was zero or at most at the level of the natural background. For a zero exposure, for the time not handling asbestos, his 8-hour, time-weighted average exposure can be estimated as: 8-hour TWA = (0-*)0-I(4.66j. i 0>01 fibers/cc >5y In the vicinity of the hopper, the levels before and after handling ranged from 0.0 to 0.04 fibers/cc >5y. If the worker had stayed in the vicinity of the hopper throughout the shift his maximum TWA exposure is estimated as: . 8-hour TWA = W) . 0.05 The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. The ceiling exposure for this operation was 0.3 fibers/cc greater than 5 microns. Sample Air Sample No. Time Minutes -------~ ----------- :-------- - M-39 on: 1:00P Off: 1:39P 39 M-48 on: 1:01P off: 1:41P 40 M-52 on: 1:01P off: 1:41P 40 M-19 M-49 N-95 M-44 M-46 B-9 on: 1:47P off: 2:01P on: 1:48P off: 1:59P on:. 1:48P off: 2: OOP on: 2:05P off: 3.14P on: 2:07P off: 3:16P on: 2:09P off: 3:13P 14 11 12 69 69 64 013735 ^ n . .. Operation Description_________ Airborne Fiber Coi (fibers/cc >5) r, Chrysotile Asbestos Area - prior to the use of asbestos. Located -20 feet south of hopper and 3-1/2 feet above ground. Area - prior to the use of asbestos. Located -4 feet west of hopper-6 feet above ground, and-2 feet above hopper. Area - prior to the use of asbestos. Located -5 feet east of hopper- 3-1/2 feet above hopper and~6-1/2 feet above ground. Rig #5. Personal - (Chuck Ireland) During 12 min. dump of five bags SVB, and during bag disposal. Area - during the dump of five bags SVB. Located same as M-52. Area - during the use of asbestos. Located same as M-48. Area - after the use of asbestos. Located same as M-52. Area - after the use of asbestos. Located same as M-48. Area - after the use of asbestos. Located --3 feet from hopper, ~2 feet above hopper and -5 feet above ground. 0.04 0.02 0.04 0.3 0.1 0.3 0 0.01 0.01 V 013736 FIGURE 1 - Rig #5 FIGURE 2 - Hopper and dry materials storage area. FIGURE 3 - Hopper and dry materials storage area. 013737 FIGURE 4 - Addition of SVB to hopper. FIGURE 5 - Addition of SVB to hopper. 013738 AIRBORNE ASBESTOS COUNTS for Cactus Drilling Rig #5 ~2Q Miles Southwest of Vernal, Utah Date Sampled: September 23, 1977 Date Reported: September 28, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: 6. J. Spencer Union Carbide Corporation Reported By: 6. J. Spencer Union Carbide Corporation Union Carbide Corporatton Metals Division Niagara Falls, New York OBJECTIVE 013739 To monitor airborne asbestos emissions at the subject company's drilling facilities (Rig #5) during the use of five bags of Super Visbestos. DESCRIPTION OF OPERATION Operation involved the addition of five bags Super Visbestos, bentonite, limestone and zinc chromate to a vent-type hopper in a drilling application. 013740 SAMPLE EQUIPMENT AND TEST PROCEDURES Sampling and dust counting were carried out in accordance with OSHA Regulation 1910.1001, using the Bayer, Zumwalde and Brown method for counting asbestos fibers by phase contrast microscopy (Bureau of Occupational Safety and Health, Feb. 1969). Battery-powered air pumps (M.S.A. type), calibrated to 2 liters per minute, were used to collect personal breathing zone and environmental samples on Millipore membrane filters of 0.8 micron porosity. Fiber counting was performed on a Nikon phase contrast microscope at 400X utilizing a Porton reticle for sizing and field definition. TEST RESULTS The details of sample collection and resultant fiber counts are listed in the attached table(s). Several photographs obtained in the work zone during monitoring are included. The OSHA regulations permit a maximum limit of 2 fibers greater than 5.microns in length per cubic centimeter of air sampled on an 8-hour, timeweighted average (TWA). The formula C-jT-j + C2T2 + CnTn describes the TWA ._ where C = fiber count in fibers/cc and T = time. In the present application the worker handled asbestos for 14 minutes and left the area. Asbestos was not used again. Presumably his exposure for the other parts of the shift was zero or at most at the level of the natural background. For a zero exposure, for the time not handling asbestos, his 8-hour, time-weighted average exposure can be estimated as: 8-hour twa . .(-3J,a4l^_(PJ).U466J. j, ,,fibers/cc >5y . In the vicinity of the hopper, the levels before and after handling ranged from 0.0 to 0.04 fibers/cc >5p. If the worker had stayed in the vicinity of the hopper throughout the shift his maximum TWA exposure is estimated as: 8-hour TWA - (0-3)04) M0.04)(466) . The regulations also stipulate a ceiling concentration of 10 fibers/cc greater than 5 microns which is not to be exceeded at any time. The ceiling exposure for this operation was 0.3 fibers/cc greater than 5 microns. y 013741 T1r SamPleHinutes . . Operatjo" Descrjp.tign-------------- Airborne Fiber Col (fibers/cc >5u) M-39 M-48 M-52 on: 1:00P off: 1:39P on: 1:01P off: 1:41P on: 1:01P off: 1:41P H-19 M-49 N-95 M-44 M-46 B-9 on: 1:47P off: 2:01 P on: 1:48P off: 1:59P on:. 1:48P off: 2: OOP on: 2:05P off: 3:14P on: 2:07P off: 3:16P on: 2:09P off: 3:13P 39 Area - prior to the use.of asbestos. Located ~20 feet south of hopper and 3-1/2 feet above ground. 0.04 40 Area - prior to the use of asbestos. Located ~4 feet west of hopper o'6 feet above ground, and *2 feet above hopper. 0.02 40 Area - prior to the use of asbestos. Located ~5 feet east of hopper~ 3-1/2 feet above hopper and~6-l/2 feet above ground. Rig #5. 0.04 14 Personal - (Chuck Ireland) During 12 min. dump of five bags SVB, and during bag disposal. 0.3 11 Area - during the dump of five bags SVB. Located same as M-52. 0.1 12 Area - during the use of asbestos. Located same as M-48. 0.3 69 Area - after the use of asbestos. Located same as M-52. 0 69 Area - after the use of asbestos. Located same as M-48. 0.01 64 Area - after the use of asbestos. Located feet from hopper, ~2 feet above hopper and ^5 feet above ground. 0.01 0X3742 FIGURE 1 - Rig #5 FIGURE 2 - Hopper and dry materials storage area. FIGURE 3 - Hopper and dry materials storage area. FIGURE 4 - Addition of SVB to hopper. } FIGURE 5 - Addition of SVB to hopper. /tb 013744 September 28, 1977 Hr. Ken Carlson Basin Hud Service P. 0. Box 1075 Vernal, Utah 84078 Dear Ken: Enclosed you will find a complete file folder covering field moni toring on our Super Vlsbestos. Me will send you a copy of the re port on Blair's monitoring In Utah as soon as It Is completed. Please accept our thanks for your help In getting him to location for those tests. Best regards, HONTELLO, INC. Kenneth N. Campbell KC/mt Enc: (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-040-3007 Chapter G 93a ' Rules and Regulations Page 170 013745 by the method prescribed in 93a.5 of this Part. 93a.2.3 Ceiling concentration. No employee shall be exposed at any time to airborne concentrations asbestos fiber* s'inv exc-esss'of f '10 f*--ib' e' r* s- : ' longer than 5 micrometers^ per^ cublc^. ` centimeter of air, as determined byh^&iV ' ,>SK 93a.3.2L_ Engineering methodsrv -, ^ Part 93a ASBESTOS x-V - v. - ' *. ' f ri.r- 7 . .: . .' 93a. 1 ~ Definitions. For the purpose -Of this Part, 93a.1.1 "Asbestos" includes chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. - * 93a.1.2 "Asbestos fibers" means - asbestos fibers longer than 5 micrometers. ' 93a.2 Permissible exposure to airborne concentrations of asbestos : fibers. _ .. ,; J ' ; 93a.2.1 Standard effective, i: . July 7> 1972. The 8-hour time- weighted average airborne concen- trations'of asbestos fibers to which ' any employee may be exposed shall not exceed five fibers, longer than 5 _ micrometers, per cubic centimeter of . air, as determined by`the method pre scribed in 93a.5 of tills Part. ` ./ ' *' 93a.2.2 . Standard effective July I, 1976. The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air, as determined ^ 93a.3.1.1.t Engineering controls.**' Engineering controls, such as, but,; , not limited to ^isolation, enclosure, exhaust ventilation,' and dust i collection, shall'he'used to meet the'' exposure limits prescribed in 93a.2':r of this Part. - ',, .-.v 93a.3.1.2 Local exhaust ventilation. ` 93a.3.1.2.1 Local exhaust venti- _ lation and dust collection systems, shall be designed, constructed, In stalled, and maintained in accordance with the American National Standard Fundamentals Governing the'Design and Operation of Local Exhaust Systems, ANSI 29.2-1971, which is " incorporated by reference herein.. - - . . ` . ..< v-.".'.- 93a.3.1.2.2 Reference ANSI - 29.2-1971, and the maintenance of a historic file in connection there with. The address of the American National Standards Institute is given In Part 100., ~ . . 93a.3.1:3 Particular tools. All hand-operated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits prescribed in 93a.2 of this Part, such as, but not limited to, saws, scorers, abrasive wheels, and drills, shall be provided with local exhaust ventilations systems Utah Occupational Safety and Health Divisitm Chapter G 93a Rules and Regulations Page 171 013746 in accordance with 93a.3.1.2 of this Part. \ 93a.3.2 Work practices. 93a.3.2.1 Wet methods. ' Insofar' . as practicable, asbestos shall be handled, mixed, applied, removed,' / cut, scored, or otherwise worked, in . a wet state sufficienttopreventihe' emission of airborne fibers in'excess'/ of the exposure limits prescribed^^' . in 93a.2 of this Part,l unless the^^^. usefulness of the'product would be diminished thereby - *-* v . i. . 93a.3.2.2 ^ Particular products . and operations.' No asbestos cement,' mortar, coating^'srroiit, plaster,^ ^ r ; or similar material containing. ' asbestos shall be removed from , bags, cartons, or other containers in which they are shipped, without - being either wetted, or enclosed,. or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the_ Units prescribed in 93a.2 of this Part. . 93a.3.2.3 Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal, or demolition of asbestos insulation or coverings shall be provided with respiratory equipment in accordance with 93a.4.2.3 of this Part and with special clothing in accordance with 93a. 4.3 of this Part.. . 93a.4 Personal protect!ve ecuipment. 93a.4.1 Compliance with the exposure limits prescribed by 93a.2 of this Part may not be achieved by the use of respirators or shift rotation of employees, except: 93a.4.1.1 During the time period necessary to install the engineering controls and to institute the work practices required by 93a. 3 of this * Part. * '* ` ' - ^ - 93a.4.1.2 In work situation ,, which the~ methods ~prescribed 'in^' 93a.3 of this Part are either^^ technically not feasible or* feasible^* to an extent insufficient pofreduce*$&~ the airborne concentrations pier's1%i $' . asbestos fibers below the limits'\r 93a.4.1.4 . Where both respirators and personnel rotation'are, allowed by subdivisions 93a.4.1.1,' .2,``-or i of this Part, and both are. practicable, personnel rotation shall > be preferred and used. ' " *J 93a.4.2 , Where a respirator is> permitted by 93a.4.2.1, it shall be selected from among those approved ; v by the Bureau of Mines, Department of' the Interior, or the National In- . stitute for Occupational Safety arid - Beal th, and shall be used in accord ance with 93a.4.2.1, .2, .3, and/ .4 of this Chapter.' ", ' !<:*' 93a. 4.2.1 Air purifying respi-r rators. A reusable or single use '/ . air purifying respirator, or a" ` 'v respirator described in 93a.4.2.2 or 93a.4.2.3 of this Chapter, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator Jbelow the exposure ~ilmits prescribed in 93a.2 of this Part,/" when the ceiling or the 8-hour time-, weighted average airlx>rne concen- ` trations of asbestos fibers are ; reasonably expected to exceed no more than 10 times those limits. ' V'/ 93a.4.2.2 Powered air purifying respirators. A full facepiece * Utah Occupational Safety and Health Division nines ana Regulations Page 172 013747 powered air purifying respirator, or a powered air purifying respirator, or a respirator described in 93a.4.2.3 of this Chapter, shall be used to reduce the concentrations of airborne asbestos fibers in the ' respirator below the exposure limits prescribed in 93a. 2 of this Partwhen the ceiling or the 8-hour time-weighted average concentrations of asbestos'V^' filters are reasonably expected to >>?*?, . exceed ` ' ' "*'' "* those ,; T93^4^7.^ffyj^}Ts^Ti^ai'r^' respirators/ continuous flow or&fst-qt^- pressure-demand^class.- .A type J'C"- ' continuous flow^ orpressure-demand, . . supplied air respirator'shall 2>e' ... used to reduce the' concentrations of ' airbonre asbestos fibers In the,' ' respirator below the exposure limits prescribed in 93a.2 of this Part, v when the ceiling or the 8-hour time- weighted average airborne concen trations of asbestos fil>ers are ' reasonably expected to exceed 100 ' times those limits. /"' employee will be unable to function normally wearing a respirator, or\ that the safety or health of the \ ' employee or other employees will be ; impaired by his use of a respirator. . Such employee shall be rotated toj>;i another Job or given the opportunity^' 'to transfer to a different position whose, duties he is able to perform; with the same employer, in the same&Ji'- ,,geographical area and with the sanely seniority', status, .and rate of pay*- he had Just prior to such transfer> is' such a different position availabie^*^:^:^.}-..'y :.$/. 93a.'4.3 Special clothings The ' employer shall provide, and require the use of, special clothing, such, ; as coveralls or similar whole body^l*' clothing, head coverings,' gloves, and foot coverings for any employee' ^ exposed to airborne concentrations- of asbestos fibers, which exceed /r\ the ceiling level prescribed in - 93a.2 of this Part. * ; 93a.4.4 Change rooms: '' 93a.4.2.4 Establishment of a respirator ^program. "v. .: ` .' - ' 93a.4.2.4.1 The employer shall establish a respirator program in accordance with the. requirements of the American National Standards Practices for Respiratory Protection, ANSI Z88.2-1969, which Is incorporated by reference herein. ' y ' 93a.4.2.4.2 Reference ANSI Z88.2-1969 and the maintenance of an historic file in connection therewith. 'The address of the ' American National Standards Institute is given in Part 100. ^ ' ' 93a.4.2.4.3 No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examination, an examining physician determines that the 93a.4.4.1 At any fixed place' of employment exposed/ to airborne concentrations of asbestos fibers in excess of the exposure limits pre- : ~ scribed in 93a.2 of this Part, the~- employer shall provide change rooms ' for employess working regularly ' at the place. ` ' 5~': 93a.4.4.2 Clothes lockers: -.The' employer shall provide two separate ; lockers or containers for each em- ployee, so separated or isolated as" to prevent contamination of the ' employee's street clothes from his work clothes. . - : 93a. 4.4.3 Laundering: 93a.4.4.3.1 Laundering of asbestos contaminated clothing shall be done so as to prevent the release of airborne asbestos fibers Utah Occupational Safety, and Health Division Chapter G 93a Rules end Regulations Page 373 013748 in excess of the exposure limits prescribed in 93a.2 of this Part. 93a.4.4.3.2 Any employer who gives asbestos-contaminated clothing' to another person for laundering, 1 " shall inform such person of the re quirement in 93a.4.4.3.1 to effectively prevent the release of airbornerl 1, asbestos fibers in excess of the'^'~ 93a.4.4.3.3^ Contamijiaied. clothing shall be trraannssnpoortretdefIln ^ssealeedda impermeable bags f or other'closed? ,, impermeable containers, .and labeled ' in accordance 'with93a.7 of thisl ~ '``j Samples shall be taken for the determination of the' 8-hour time- ' weighted average airborne concen- . .. .trations and of the ceiling concen-^r trations of asbestos fibers 93a.6.2.2 Sampling frequency_and?C' patterns. - Afterthe^ initial determi-4* nations.required by 93a. 6:1, '*samples\_ jshall beofsuch frequency and pattern as' to represent with reasonable. ` ". . accuracy' the levels of exposure employees In no case shall jthe ... : sampling [be done at "intervals greater. than,.6 months for employees whose exposure,.~to asbestos may,,^\ reasonably .'he foreseen to exceed ^ ] .vrV^ir ,; ? - : 93a.5 Method of measurement. All determinations of airborne concen trations of asbestos fibers shall be made by the membrane filter method . at 400-450 X (magnification) (4 millimeter objective) with phase - contrast illumination. . 93a.6 Monitoring. 93a.6.1 Initial determinations? - Within 6 months; of the publication.: of this Part, every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to, , determine whether every employee's exposure to asbestos fibers is below the limits prescribed in 93a.2 of this Part. If the limits are ex ceeded, the employer shall immedi ately undertake a compliance program in accordance with 93a.3 of this Part. ' - 93a.6.2 Personal monitoring. ; * " ' ~ ` . ' "V, ' . ' ` ' ` ' r . 93a.6.2.1 Samples shall be ..... collected.from within the breathing zone of the employees, on membrane filters of 0.8 micrometer porosity mounted in an open-face filter holder. 93a.6.3_ Environmental monitoring. . 93a.6.3.1 Samples shall be . - collected from'areas of a work en- .S'~ vironment which are representative of the aizborne concentrations of * asbestos fibers which may reach the.' breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer..porosity mounted in.an open-face filter holder. Samples shall be taken for the^' ^^r ' determination of the 3-hour time- weighted average airborne concen-1,7 ` trations and of the ceiling concen- . . trations ofasbestos fibers. ^ . -u.7-' ' 93a.6.3.2 Sampling frequency --l'r - and patterns. After the initial < determinations required by 93a.6.1, ^ samples shall be of such frequency. and pattern as to represent with reasonable accuracy the'levels / exposure of the employees. .In- . no case shall samplinq be at inter- ' vals greater than .6 months for x employees whose exposures to asbestos may reasonably-be foreseen to exceed the exposure limits prescribed in 93a.2 of this Part. 93a.6.4 Employee observation of Utah Occupational Safety and Health Division - * > - Chapter G 93a Rales and Regulations Page 174 013749 monitoring. Affected employees, or debris, and other products containing their representatives, shall he given asbestos fibers, or to their con- '. a reasonable opportunity to observe' tainers, except that no label is r -- any monitoring required by this para required where asbestos fibers have'; - graph and shall have access to the "" ,: been modified by `a ^bonding agent^V^f^ v records' thereof.. coating', binder, ^or qtheriaaterial \'.m v so that during any'reasonably^fore-^X'-. 93a.7 Caution signs and labels.'' seeable^ use/ handling/storage disposal/processing^ or' trans-^/T^r 93a.7.1 Caution signs. "r-V ; portation,'no'airborne'concentrations ; of^asbestos fibers in excessof the \ , . 93a~7iiil* Posting. Caution signs exposure limits prescribed ih"93a.2 `shall be 'jpf<wid(f^and_disjpla^edf of ' this. Part will be released. each location?where airborne Jc6hcehrz:~ trations.of asbestos fibers may beyE*? 93a.7.2:2 .Label specifications'. an excess .of the exposure limits - - y The 'caution ihbles'required by >r\.' ` prescribed^ in 93a'%2^qf this^Part/^^- 93a.7.2*1' of this'subparagraph shall* Signs shali-be jposied'ai sucha * " distance from such a' location so that be printed In letters of sufficient1? size and contrast as to be readily ah employee may read the signs and . visible and legible. The label shall take necessary protective steps before entering the area marked by the signs. Signs shall be posted state:--tJ- 'i.v - . A *l r -* CAUTION : ' * v r Z-Z at all approaches to areas containing 'Contains Asbestos Fibers/ excessive concentrations of airborne Avoid Creating Dust -- asbestos fibers. J Breathing Asbestos Dust May Cause Serious Bodily Harm ' 93a.7.1.2 Sigh specifications^ . The warning signs required by ~r 93a.8 Housekeeping.1^1 -if-- y* 93a.7.1.1 shall conform to the re quirements of :'20" jc~14" vertical format signs'specified in 145.4.4, ~ 93a.8.1*Cleaning'. All external' surfaces,in any place of employment"^ and'of this subdivision'. The signs shall be maintained free'of accumula shall d'isply the following legend in tions of asbestos fibers if; with,their the lower panel, with letter sizes ; dispersion, there would be ah excessive and. styles -of a visibility at least1 concentration."f--- ' --r-~ . equal to that specified this subdivision. " ` . LEGEND Asbestos............... i. Z ... i .. .1. '. Dust Hazard........... .v'.......... Avoid Breathing Dust'.-.^ Wear Assigned Protective Equipment.. Do Not Remain in Area Unless Your Work Requires It . Breathing Asbestos Dust May Be Hazardous to Your Health......... 93a.7.2 Catuion Labels. NOTATION *- ; .1" Sans Serif; Gothic or Block v'\ 3/4" San Serif; Gothic or Block ': 1/4" Gothic > 1/4" Gothic 1/4" Gothic. . ' * * ' _ ' ' > ' * ' ' 14 point Gothic . > Spacing between lines shall be at least equal to the height of the upper of any two lines. - 93a.7.2.1 Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste/ 93a.8.2 Waste Disposal. Asbestos waste, scrap, debris, bags. Utah Occupational Safety and Health Division r.M f i-.k**. . Chapter 6 93a Rules and Regulations page 175 containers, equipment, and asbestos- contaminated clothing, consigned for disposal, which may produce in any. reasonably foreseeable use,, handling, storage, processing, *>-~ disposal, or transportation airborneVconcentrations of asbestos fibers in excess of the exposure limits pre- " t " scribed,in 93a.2 of this Part shall be collected and disposed of in sealed impermeable bags,-or other closed,-. impermeable 013750 93a.10.2 Preplacement. The employer shall 'provide or make available to each of his employees,- within 30 calendar days following' '*:-.* . his first employment in an occupation 3, - exposed to airborne-concentrations +* ; of asbestos fibers, a comprehensive'.^is. medical examination,' which shall f \ include, as' a mlnimum',^'a 'chest'~-s?~* V- roentgenogram (posterior-anteriorv ;* 14. x, I7_inches) history to. elicit 93a. 9 93a employer, any personal '"or environmental monitoring required by this. PartRecords shall be maintained Kfor a . period of at 'least 3 years"and shall be made available ' upon request to the Administrator of the Utah Occupational Safety and Health Act. > 93a.'9.2 Employee access. Every employee and former employee shall have reasonable access to any record required to'be maintained by 93a.9.1, which indicates the employee's own exposure to asbestos fibers.- 93a. 9.3 "Employee notification. . Any employee found to have been ex- posed at any time to "airborne concen trations of asbestos fibers in excess of the limits prescribed in 93a.2 of this Part shall be notified in 1 writing of the exposure as soon as practicable but not later than 5 days of the finding.- "The employee shall also be timely notified of the corrective action being taken. 93a.10 Medical examinations. 93a.10.1 General. The employer shall provide or make available at his cost, medical examinations relative to exposure to asbestos required by this paragraph. 93a.10-3 Annual exmaina tions. On or^beforp January 31, 1973, and. at least annually thereafter^ every^ employer shall provide, or make.,. . available, comprehensive medical ' j. .. examinations to each of his employees, engaged in occupations exposed to , airborne concentrations of asbestos ../ , fibers.. Such annual examination shall include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches), a history to elicit. v . symptomatology of respiratory disease,t and pulmonary function .tests \to,. include forced vital capacity. (fVC).,i: and forced expiratory volume-at 1 * j. _ second (FEVi.x)) >s* ' T ` " I-: . 93a.10.4 Termination of employ- . ment. . the employer shall provide 'or make availableTwithin.30, calendar days before or after the" termination of employment of any employee engaged in an occupation exposed to airborne. concentrations of asbestos fibers, a comprehensive medical examination, which shall include, as a minimum, a chest roentgengogram (posterioranterior 14 x 17 inches) a history to elicit symptomatology of respiratory'disease, and pulmonary function tests to include forced vital capacity ~(FVC) and forced expiratory volume at 1 second (FEV^ q) . Utah Occupational Safety and Health Division c/idpcer u 93a 93b 93c Rules and Regulations 93a.10.5 Recent examinations. No medical examination is required of any employee, if adequate records show that the employee has been .... examined in accordance with this^r paragraph within the past 1-year,: - ; period. . ....... - .- .a 93a.10.6 Medical records* r, V - I w - . . Ji--: I * <7Vt-iv;.* 93a.10.6.2- Maintenance'! ^ Employers of employees' examined pursuant' to this paragraph' shair[cause. to'be maintained complete arid'accurate;^^?^ . records 'of all such" medical* examlna-- * tions. 'r Records^shall he 93a.10.6.2 Recess. The contents of the' records -of the medical' examina tions required by this paragraph shall be made available, for in- ' spection and copying, to the VOSH - ' Administrator, to authorized physicians and medical consultants, and, ' upon ' - the reguest of an'employee or former employee, to his physician. ~ Any. physician who conducts'a medical ~examination required by this paragraph shall furnish to the employer of the examined employee'all the information specifically required by this paragraph, and any other medical information. ~ - 5 related to t>ccupational exposure to-- ' asbestos fibers. - .t . 4 -1 .u J: ' ' ' Part 93Jn COAL TAR PITCH VOLATILES INTERPRETATION OF..~ Page 17.6 ,. ... . 013751 - Utah Occupational Safety SUMMARY OF FIELD MONITORING TESTS Super Visbestos (Crushed Pellets) 013752 (Current OSHA Regs: 10.0 Fiber Ceiling; 2.0 Fiber TWA) Location Explanation Maximum Count (10.0 Allowed) TWA Calculation (2.0 Allowed) Rig - Central Oklahoma -- - Breathing Zone - Dumper Upwind Location--------- *- Downwind Location -------- 1.9 .1 .5 Rig - Texas Panhandle Breathing Zone - Dumper 4 Feet From Hopper -----20 Feet Downwind --------- 1.0 .4 .2 3 Rigs - Upper Michigan First Rig ----------------- Second Rig Third Rig Breathing Zone - Dumper A Id v UUIlip TM _______a 7 9nrl Himn____________ _ _______ o o -Ave. Breathing Zone - Dumper B I# UvJlli^s _______ 1 A .. ? a -Ave. 7 Feet Downwind uU I lily UUllip 7T X .. .. 1K _______ 1 Q -4 .. 1 o ............ o Breathing Zone - Dumper A 1iLOc4l>* HUUitImlipn______ _ _ _______c 7 Humn .............. 91 ------Ave. Breathing Zone - Dumper B .. Pnrl Hiimn ............... QO o q ------Ave. 3 Feet From Hopper .......... A .... 0 Hurlnn Humn MO ......... 1 fi - ... 0 Breathing Zone Dumper A ----- ............... 1.9 Breathing Zone Dumper B ----- ............. .7 Directly Over Hopper --------- ............. .4 .27 .31 .45 .49 .45 .41 Rig - Canadian, Texas Breathing Zone - Dumper 3 Feet From Hopper During Dump ----------After Dump ------------- 1.8 .38 .7 .3 Warehouse - Woodward, OK - Breathing Zone - Loading - Breathing Zone - Unloading Worker on Truck ---------------- Storage Area --------------------Loading Dock --------------------Sweep Up Background ---------- .3 .6 -Ave. .3 .2 .3 .5 Page 1 of 3 SUMMARY OF FIELD MONITORING TESTS (cont'd.) V -i- 4 r V* Date Location Explanation Maximum TWA Count Calculation (10.0 Allowed) (2.0 Allowed) 4/75 6/76 6/76 6/76 6/76 Rig - Wichita Falls, TX -- Breathing Zone - Worker During Dump -----------Bag Disposal------- -- 4 Feet From Hopper Before Dump -----------During Dump -----------Bag Disposal ---------After Disposal ------- .6 .5 -Ave. .22 .1 .5 .2 .0 Warehouse A - Gillette, WY- Breathing Zone - Loader 4 Feet From Storage Before Loading ------During Loading ------Loading Dock Before Loading ------During Loading ------- 2.5 ,24 .1 .5 .2 1.6 Rig A - Gillette, WY Breathing Zone - Dump A During Dump --------------- Bag Disposal ------------Breathing Zone - Dumper B During Dump --------------Bag Disposal ------------- 4 Feet Downwind, Hopper Before Dump --------------During Dump --------------- 1.2 4.7 Ave. .30 .6 3.3 Ave. .33 .4 .8 Warehouse - Yellowstone, WY Breathing Zone - Loader Before Loading ------During Loading ------- 2 Feet From Storage Before Loading ------During Loading ------After Loading --------- Loading Dock Before Loading ------During Loading ------After Loading --------- Warehouse - Casper, WY ----- Breathing Zone - Loader Storage Area During Loading ------After Loading --------Loading Dock During Loading ------After Loading --------- .1 .1 -Ave. .19 .1 .1 .2 .1 .2 .2 ----- 1.5 -.4.-------------- .15 ......... 1.6 .......... .1 .2 .1 Page 2 of 3  SUMMARY OF FIELD MONITORING TESTS (cont'd.) 013754 Date Location Explanation 6/76 6/76 6/76 Rig B - Gillette, WY Breathing Zone - Dumper 4 Feet Upwind, Hopper Before Dump ----------During Dump ----------- 5 Feet Downwind, Hopper Before Dump ----------During Dump ----------- Warehouse B - Gillette, WY- Breathing Zones Loader A --------Loader B --------- 5 Feet From Storage Before Loading During Loading Loading Dock Before Loading During Loading Rig C - Gillette, WY Breathing Zone - Dumper 5 Feet Upwind, Hopper Before Dump ----------During Dump ----------- 7 Feet Downwind, Hopper Before Dump ----------During Dump ----------- Maximum TWA Count Calculation (10.0 Allowed) (2.0 Allowed) .9 .28 .1 .6 .3 .5 1.7 .11 .7 .12 .1 1.1 .1 .2 .2 .1 .1 .2 & Page 3 of 3 Product Bulletin 1/77 013755 The purpose of this bulletin is to provide certain background in formation on the use of Super Visbestos in the drilling industry. Existing OSHA regulations cover all commercial applications of asbestos. A reading of these regulations makes it appear that the total range of workplace environments was intended. A more careful study, however, enables us to characterize the concept of "workplace" in some detail. Implicit are the assumptions of fixed places of employment; of regular, day-to-day exposure; of exposure on essentially a full shift basis; of comparatively large asbestos tonnages being involved; of specific individuals being exposed with little relief; of enclosed or nearly enclosed work spaces. Even in those references to irregular workplaces, such as in construction, the inference is of specific workers, exposed for nearly a full shift, on a day-to-day basis, in at least partially enclosed surroundings. Exposure to asbestos in the drilling industry is of a substantially different type. Asbestos is added to the drilling fluid through a mud hopper. Venturi action of the fluid rushing through the bottom of this hopper creates a suction, which pulls the dry product into the liquid stream. Additions to the system are made only occasionally, typically occuring no more often than once per shift. The amounts added are small, rarely exceeding 500 pounds at a time. With three eight hour shifts per day and eight to ten men per shift, assignments are exchanged frequently, with the same worker rarely performing the job of adding materials for more than a few shifts and then only for a small part of the sjaift. Dumping rates are slow, averaging an hour or so for 500 pounds. In dumping, the worker cuts the end of^the 50 pound bag and allows the asbestos to fall into the suction end of the hop per, where the material becomes part of the liquid drilling fluid monteloseconds later. The hopper itself is typically located in the open. (Continued on other side --) P.0. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 A totally enclosed mixing area is a rare exception. 013756 With enactment of the regulations in 1972, Union Carbide Corpo ration and Montello, Inc. began a series of drillsite monitoring tests, in accordance with the procedures established by OSHA. A substantial body of data has been accumulated from all parts of the U.S. Many different locations (including rigs and warehouses) have been evaluated, and we believe the widely varying conditions inherent in the drilling industry have been fairly included. The results show a consistent pattern of readings which are sub stantially below both the maximum ceiling limit (10 fibers/cc >5p and the time weighted average (2 fibers/cc >5p) prescribed in the regulations. In more than 4 years since the asbestos regulations became law, we have no knowledge of any OSHA citation having been issued, based on corroborating monitoring data to establish the existence of excess air-borne fiber concentrations. In fact, where such tests have been run by compliance officers, no basis has been found for citation. (In September of 1974, a compliance office for the State of Utah carried on field monitoring tests at one of our cus tomer's locations. After analysis, a ruling of "In Compliance" was handed down.) . In addition to the continuing program of field monitoring. Union Carbide and Montello are carrying on basic research with the aim of improving both the cleanliness and the field performance of Super Visbestos. Outgrowths of this research are the high density, crushed pellet form of the product; and the introduction of indi vidually shrink filmed bags to minimize handling and storage prob lems. With Union Carbide, we will continue to work toward the highest possible standards of quality and safety. 013757 January 5, 1977 Hr. Robert Hailey Texland Drilling Corporation P. 0. Box 3037 Abilene, Texas 79604 Dear Mr. Hailey: Please refer to our recent phone conversation about the field moni toring tests on Super Visbestos. After"the individual'reports, we felt it might be useful to collect all the scattered data into a single recap format. We also prepared an updated bulletin giving general background on the use of Super Visbestos in the drilling industry. We hope you will find the contents of this updated pre sentation both helpful and informational. A second folder is enclosed for your lawyer, as requested. Under separate cover we have also sent a copy to Mr. Don Dyer of Safety Consultants in Odessa. We have spoken with our Union Carbide people in Niagara Falls about the possibility of initiating a field monitor ing series in your area of activity, as soon as practical. As al ways, they are pleased to cooperate and we plan to coordinate the "whens and wheres" with Mr. Dyer. Will keep you advised as the program develops. Thanks for your continuing interest in Super Visbestos. Please let us know whenever we can be of service in any way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (2) &y P.S. We have received the citation copy you mailed, and appreci ate having it. montelo P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013758 January 5, 1977 Mr. Don Dyer Safety Consultants, Inc. P. 0. Box 6564 Odessa, Texas 79762 Dear Mr. Dyer: We spoke to Mr. Robert Hailey of Texland Drilling recently, about the OSHA regulations on asbestos. He suggested that we send you a duplicate of information which we furnished him. The presentation is enclosed. We hope you will find it both informational and help ful. We have spoken to our people with Union Carbide in Niagara Falls about the possibility of initiating a series of monitoring tests in West Texas, as a part of our ongoing program. Mr. Hailey had in dicated his interest and willingness to cooperate in such a series, assuming a convenient time frame could be established. Is it poss ible that you might have other clients who would be similarly in terested? Depending upon the distance between locations, it is generally poss ible to run two or three monitoring tests per day. The series are generally designed to last about three days. Union Carbide furnishes the professional person and equipment to perform the tests. They also do the phase contrast counting on the resulting samples. Re ports are prepared for each location, and copies forwarded to all participants. We will take the liberty of contacting you shortly, in the hope that some one with your company might be willing to assist in working out the logistics for such a series. In the meantime, please let us know whenever we can be of any help. Sincerely, MONTELLO, INC. * Mi Kenneth N. Campbell KNC/jd monteloEnc. (1) P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /{918)-245-6661/TWX 910-840-3007 013759 January 5, 1977 Mr. Van Harry Loffland Brothers Company P. 0. Box 459 New Iberia, Louisiana 70560 Dear Mr. Harry: Please refer to our recent phone conversation about the OSHA regulations on asbestos, and our product Super Visbestos. After gathering the individual reports, we felt it might be useful to collect all the scattered data into a single recap format. We also prepared an updated bulletin giving what we hope will be a useful "overall" view of Super Visbestos in the drilling industry. All this is in the enclosed file folder. As requested, we have also included a half dozen extra business cards, along with the disposable respirator information dis cussed. We will be happy to supply extra copies of any or all of the enclosures. Many thanks for your interest in our pro ducts, and please let us know whenever we can be of further service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd cc: Mr. Charlie Reeves Enc. (3) montelo P.O. BOX 130, SAND SPRINGS, OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 013760 January 5, 1977 Hr. Leo Dean Sharp Drilling Company First National Bank Building Midland, Texas 79701 Dear Mr. Dean: Mr. Bud Tucker called us recently and asked that we send you information on Super Visbestos, in the context of the OSHA regulations which cover asbestos. The enclosed file folder contains an updated presentation of this data. We hope you will find it useful and informative. At Bud's request, we've sent a duplicate to Mr. Leroy Cargile. Many thanks for your interest in our products. Please let us know whenever we can be of service. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) IDonteflo 013761 January 5, 1977 Mr. Leroy Cargile Sharp Drilling Company P. 0. Box 182 Stanton, Texas 79782 Dear Mr. Cargile: Mr. Bud Tucker phoned us recently and asked that we send infor mation to you on Super Visbestos in the context of the OSHA regulations covering the use of asbestos. This information is enclosed. We hope you'll find it helpful. At Bud's re quest, we've sent the same presentation to Mr. Leo Dean in Midland. We appreciate your interest in our products, and hope you will contact us whenever we can be of service. Sincerely, MONTELLO, INC Kenneth N. Campbell KNC/jd Enc. (1) montelo P.O. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /{918)-245-6661/TWX 910-840-3007 013762 January 5, 1977 Hr. Taylor Davis American Mud Company P. 0. Box 555 Abilene, Texas 79604 Dear Taylor: We spoke to Bob Hailey earlier about the OSHA/Super Visbestos matter. Our form of presentation has been brought up to date, and we've sent him copies. At his request, we've also copied Don Dyer of Safety Consultants in Odessa with the same presen tation. Enclosed is a similar copy for your files. We're working out a program to carry on a series of field monitoring tests in West Texas soon. Will keep you advised as the plans take shape. Best regards, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) monteHo .0. BOX 130, SAND SPRINGS. OKLAHOMA 74063 /(918)-245-6661/TWX 910-840-3007 January 5, 1977 Mr. Bud Tucker 3710 Stanolind St. Midland, Texas 79701 Dear Bud: Many thanks for your call the other day. We've updated our presentation on the OSHA matter, and have sent copies to Mr. Leo Dean and Mr. Leroy Cargile of Sharp Drilling. As requested, we're enclosing two copies for your use. We appreciate your help on this one. Please let us know when ever we can help. Best regards, MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (2) t? montelo our letter , pns on shipmer ^"`Vfai* to the last j ^Pfehf,r|>tition file ffl'phboth issues. 20th, the regulc fS*; Filial regulatic ` itltles in fiber! Eon, 4ie COT has r ' :rom the palletit talnly a we Icon loosed a copy of th Register. I^e the regs . 8. ` 'As stated ` 'pSPOof bags before P simpler. Pleas "whenever we can bell Eno. ftp- If 013764 "9 ng the new "ticular, ;age, which <ey have been dipped prior 1 December hipment of s requested. of private rements. files, we e August 16, burden on ing in dust uld make : e any ques- monteiio 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013765 August 7, 1979 Mr. Taylor Davis American Mud Company P. 0. Box 555 Abilene, Texas 79604 Dear Taylor: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) Rigid, airtight packagings such as metal or fiber drums, portable tanks; (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or (3) Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. Taylor Davis August 7, 1979 Page 2: 013766 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd 0*3*67Federal Register / Vol. 44. No. 160 / Thursday, August 16, 1979 / Rules and Regulations Materials Transportation Bureau 49 CFR Part 173 [Docket Noi HM-160; Arndt Nos. 172-47, 173-123,174-33,175-7,176-6,177-44] Transportation of Asbestos; Additional . Revisions of Amendment No. 173-123 agency: Materials Transportation Bureau (MTB), Research and Special Programs Administration, DOT. ACTION: Additional Revisions of Previous Amendment No. 173-123. SUMMARY: These revisions to Amendment No. 173-123 (44 FR18673, March 29,1979) will permit carriage of ' asbestos: (1) by private carrier in dust and sift-proof bags and other non-rigid packaging without palletizing and ' unitizing; (2) in dust and sift-proof bags and other non-rigid packagings within fiberboard or wooden boxes when shipped in less than pallet load quantities. This revision also clarifies : the authority to ship ieaktight hopper cars and Ieaktight hopper motor vehicles, and provides a grandfather clause for shipments initially shipped and transported prior to August 20,1979. EFFECTIVE DATE: August 20,1979. . ' FOR FURTHER INFORMATION CONTACT: Delmer F. Billings, Standards Division, Materials Transportation Bureau, Research and Special Programs Administration, DOT, Washington, D.C. 20590, phone 202-426-2075. SUPPLEMENTARY INFORMATION: On March 29,1979, the MTB published an amendment to the final rule under docket HM-160 in the Federal Register (44 FR 18673). Since this publication, the MTB has received two petitions for reconsideration in accordance with the provisions of 49 CFR 100.35. One petitioner requested that the MTB clarify the meaning of the word `airtight" as it is used in f 173.1090(d)(1). and he questioned whether hopper cars would be authorized by the provisions of this same section. For the purposes of this section, the word "airtight" means that there can be no transfer of either air or particles between the packaging and the surrounding atmosphere under ambient conditions. Packaging specified in this section need not be pressure tight packaging. In an effort to eliminate any confusion, the word "airtight" has been deleted from this section, and the word "Ieaktight" has been substituted. Also, this section has been amended to include a specific reference allowing the use of Ieaktight hopper cars or hopper motor vehicles for the shipment of asbestos. A petitioner stated that difficulties arise due to the lock of a provision allowing the shipment of dust and siftproof bags or other non-rigid packagings in less than pallet load quantities. The petitioner stated that the use of an exclusive use vehicle for shipments of only a few bags of asbestos is extremely uneconomical and that it is also not feasible to maintain supplies to unitize and palletize small quantity shipments of bags of asbestos. This petitioner requested that fiber boxes be allowed as an alternative to the palletizing and unitizing method: The MTB is in basic agreement with this petitioner concerning small quantity shipments of asbestos in bags, therefore, this amendment provides for the shipment of dust and sift-proof bags or other nonrigid packagings when in rigid outside fiberboard or wooden boxes. This option will continue to provide for public safety by providing for equal . protection of the bags during shipment but will allow shipment of less than pallet load quantities. A petitioner objected that the amendment to the final rule as published on March 29,1979, did not include the provision allowing private highway carriers to transport dust and sift-proof packagings without palletizing and unitizing which appeared in the final rule published on December 4.1978 (43 FR 56664). The MTB agrees that the provision should be reinstated in view of the closer control exercised by private carriers over shipments. This provision will allow for private carriage by highway of dust and sift-proof bags and other non-rigid packagings which are not palletized and unitized. Several questions have been raised concerning the meaning of the words "exclusive use" as used in 173.1090(d)(3). For the purposes of this section, "exclusive use" means that the consignor has complete use of the transport vehicle and that the loading is carried cut by the consignor and unloading is carried out by the consignee or consignees. A petitioner also cited a need for en " extended effective date for packages of asbestos initially entered into transportation prior to August 20.1979, but which would still be required to be shipped from distributors, warehouses, and the like, after that date. It was 'stated that many distributors, etc., do not have the ability or facilities to repackage such shipments und, therefore, such stocks would not be oble to be reshipped after the effective date of the final rule, thus causing severe hardships. The MTB is in agreement that this situation could pose a serious burden and. therefore, this amendment includes a provision allowing packages of asbestos initially shipped prior to August 20,1979. to continue to be shipped until December 31,1979. In consideration of the foregoing, 1173.1090 os it appeared In the Federal Register published on March 29,1979 (44 FR 18073) Is revised as follows: In 173.1090, paragraphs (d) (1). (2), and (3) ore revised; paragraphs (d) (4) and (5) are added to read as follows; $173.1090 Asbestos. * (d) * * * (1) Rigid, Ieaktight packagings, such as metal or fiber drums, portable tanks, hopper-type rail cars, or hopper-type motor vehicles; (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; (3) Bags or other non-rigid packagings which are dust and sift-proof. When transported by other than private carrier by highway, such packagings containing asbestos must be palletized and unitized by methods such as shrink-wrapping in plastic film or wrapping in fiberboard secured by strapping. Pallets need not be used during transportation by vessel for loads with slings that are unitized by methods such as shrink-wrapping, if the slings adequately and evenly support the loads and the unitizing method prevents shifting of the bags or other non-rigid packagings during conditions normally incident to transportation; or (4) Bags or other non-rigid packagings which are dust and sift-proof in strong outside fiberboard or wooden boxes. (5) Notwithstanding the requirements of this section, packages containing asbestos initially shipped and transported prior to August 20,1979, may continue to be shipped and transported until December 31.1979. (49 U.S.C. 1803.1804.1808; 49 CFR 1.53 and App. A to Part 1.1 Note.--'The Materials Transportation Bureau has determined that this final rule will not result in a major economic impact under the terms of Executive Order 12044 and DOT implementing procedures (44 FR 11034} ncr require an environmental impact statement under the National Environmental Policy Act (49 U.S.C. 4321 et aeq.). A regulatory evaluation is available in the dojket. Issued in Washington. D.C. On August 10. 1979. L. D. Santmsn, Director. Materials Transportation Bureau. |FK Due 7S-2SZ17 Filed S-IS-TV. kS era) BILUHQ CODE 4S10-CO-U , 'A."' Federal Register / Vol. 44, No. 160 / Thursday. August 16, 1979 / Rules and Regulations 013768 47937 Materials Transportation Bureau 49 CFR Part 173 . [Docket No& HM-160; Amdt Nos. 172-47, 173-123,174-33,175-7,176-6,177-44] Transportation of Asbestos; Additional . Revisions of Amendment No. 173-123 AGENCY: Materials Transportation Bureau (MTB), Research and Special Programs Administration, DOT. ' ACTION: Additional Revisions of Previous Amendment No. 173-123. SUMMARY: These revisions to Amendment No. 173-123 (44 FR18673, March 29,1979] will permit carriage of asbestos: (1) by private carrier in dust and stft-proof begs end other non-rigid packaging without palletizing and unitizing; (2) in dust and sift-proof bags and other non-rigid packagings within fiberboard or wooden boxes when shipped in less than pallet lead quantities. This revision also clarifies . : thr authority to 6hip leaktight hopper cars and leaktight hopper motor vehicles, and provides a grandfather clause for shipments initially shipped and transported prior to August 20,1979. EFFECTIVE DATE: August 2ft 1979. ` FOR FURTHER INFORMATION CONTACT: Delmer F. Billings, Standards Division, Materials Transportation Bureau, Research and Special Programs Administration, DOT, Washington, D.C. 20590, phone 202-426-2075. SUPPLEMENTARY INFORMATION: On March 29,1979, the MTB published an amendment to the final rule under docket HM-360 in the Federal Register (44 FR 18673). Since this publication, the MTB has received two petitions for reconsideration in accordance with the provisions of 49 CFR 106.35. One petitioner requested that the MTB clarify the meaning of the word "airtight" as it is used in S 173.1090(d)(1). and he questioned whether hopper cars would be ' authorized by the provisions of this same section. For the purposes of this section, the word "airtight" means that there can be no transfer of either air or particles between the packaging and the surrounding atmosphere under ambient conditions. Packaging specified in tins section need not be pressure tight packaging. In an effort to eliminate any confusion, the word "airtight" has been deleted from this section, and the word "leaktight" has been substituted. Also, this section has been amended to include a specific reference allowing the use of leaktight hopper cars or hopper motor vehicles for the shipment of asbestos. ' A petitioner stated that difficulties arise due to the lack of a provision allowing the shipment of dust and sift- proof bags or other non-rigid packagings in less than pallet load quantities. The petitioner stated that the use of an exclusive use vehicle for shipments of only a few bags of asbestos is extremely uneconomical and that it is also not feasible to maintain supplies to unitize and palletize small quantity shipments of bags of asbestos. This petitioner requested that fiber boxes be allowed as an alternative to the palletizing and unitizing method: The MTB is in basic agreement with this petitioner concerning small quantity shipments of asbestos in bags, therefore, this . amendment provides for the shipment of dust and sift-proof bags or other non- rigid packagings when in rigid outside fiberboard or wooden boxes. This option will continue to provide for public safety by providing for equal . protection of the bags during shipment but will allow shipment of less than pallet load quantities. A petitioner objected that the amendment to the final rule as published on March 29,1979, did not include the provision allowing private highway carriers to transport dust and sift-proof packagings without palletizing and unitizing which appeared in the final rule published on December 4,1978 (43 FR 56664). The MTB agrees that the provision should be reinstated in view of the closer control exercised by private carriers over shipments. This Erevision will allow for private carriage y highway of dust and sift-proof bags and other non-rigid packagings which are not palletized and unitized. Several questions have been raised concerning the meaning of the words "exclusive use" as used in 173.1090(d)(3). For the purposes of this section, "exclusive use" means that the consignor has complete use of the transport vehicle and that the loading is carried out by the consignor and unloading is carried out by the consignee or consignees. - A petitioner also cited a need for an extended effective date for packages of asbestos initially entered into . transportation prior to August 20.1979, but which would still be required to be shipped from distributors, warehouses, and the like, after that date. It was 'stated that many distributors, etc., do not have the ability or facilities to repackage such shipments and, therefore, such stocks would not be able to be reshipped after the effective date of the final rule, thus causing severe hardships. The MTB is in agreement that this situation could pose a serious burden and. therefore, this amendment includes a provision allowing packages of asbestos initially shipped prior to August 20,1979, to continue to be shipped until December 31,1979. In consideration of the foregoing. { 173.1090 as it appeared in the Federal Register published on March 29,1979 (44 FR 18673) is revised as follows: In 173.1090, paragraphs (d) (1), (2), and (3) ore revised; paragraphs (d) (4) and (5) are added to read as follows: ' $ 173.1090 Asbestos. *It . (d)V * . (1) Rigid, leaktight packagings, such as metal or fiber drums, portable tanks, . hopper-type rail cars, or hopper-type motor vehicles; (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; (3) Bags or other non-rigid packagings which are dust and sift-proof. When transported by other than private carrier by highway, such packagings containing asbestos must be palletized and unitized by methods such as shrink-wrapping in plastic film or wrapping in fiberboard secured by strapping. Pallets need not be used during transportation by vessel for loads with slings that are unitized by methods such as shrink-wrapping, if the slings adequately and evenly support the loads and the unitizing method prevents shifting of the bags or other non-rigid packagings during conditions normally incident to transportation; or (4) Bags or other non-rigid packagings which are dust and sift-proof in strong outside fiberboard or wooden boxes. (5) Notwithstanding the requirements of this section, packages containing asbestos initially shipped and transported prior to August 20.1979, may continue to be shipped and transported until December 31,1979. (49 U.S.C. 1803.1804.1808; 49 CFR 1.53 and App. A to Part 1.1 Note.--The Materials Transportation " Bureau has determined that this final rule will not result in a major economic impact under the terms of Executive Order 12044 and DOT implementing procedures (44 FR 11034) ncr require an environmental impact statement under the National Environmental Policy Act (49 U.S.C. 4321 et seq.J. A regulatory evaluation is available in the doScf ket. ' Issued in Washington. D.C. on August 10, 1979. L. D. Santmsn, Director, Materials Transportation Bureau. (Fit Doc. 7S-UZI7 nM S-lV7. fctt tre) BILUNO CODE 4S10-SO-M , -^ ' OU769Federal Register / Vol. 44, No. 160 / Thursday, August 16. 1979 / Rules and Regulations Materials Transportation Bureau 49CFR Part 173 {Docket Nos. HM-160; Arndt Nos. 172-47, 173-123,174-33,175-7,176-6,177-44] Transportation of Asbestos; Additional . Revisions of Amendment No. 173-123 AGENCY: Materials Transportation Bureau (MTB). Research and Special Programs Administration, DOT. ACTION: Additional Revisions of Previous Amendment No. 173-123. summary: These revisions to Amendment No. 173-123 (44 FR18873. March 29.1979) will permit carriage of asbestos: (1) by private carrier in dust and sift-proof bags and other non-rigid packaging without palletizing and unitizing: (2) in dust and sift-proof bags and other non-rigid packagings within fiberboard or wooden boxes when shipped in less than pallet load quantities. This revision also clarifies the authority to ship leaktight hopper cars and leaktight hopper motor vehicles, and provides a grandfather clause for shipments initially shipped and transported prior to August 20,1979. EFFECTIVE DATE: August 20.1979. FOR FURTHER INFORMATION CONTACT: Delmer F. Billings, Standards Division, Materials Transportation Bureau, Research and Special Programs Administration, DOT, Washington, D.C. 20590. phone 202-426-2075. SUPPLEMENTARY INFORMATION*. On March 29.1979. the MTB published an amendment to the final rule under docket HM-160 in the Federal Register (44 FR 18673). Since this publication, the MTB has received two petitions for reconsideration in accordance with the provisions of 49 CFR 106.35. One petitioner requested that the MTB clarify the meaning of the word "airtight" as it is used in 1173.1090(d)(1), and he questioned whethefhopper cars would be authorized by the provisions of this tame section. For the purposes of this section, the word "airtight" means that there can be no transfer of either air or particles between the packaging and the surrounding atmosphere under ambient conditions. Packaging specified in this section need not be pressure tight packaging. In an effort to eliminate any confusion, the word "airtight'* has been deleted from this section, and the word leaktight" has been substituted. Also, this section has been amended to include a specific reference allowing the use of leaktight hopper cars or hopper motor vehicles for the shipment of asbestos. A petitioner stated that difficulties arise due to the lack of a provision allowing the shipment of dust and siftproof bags or other non-rigid packagings in less than pallet load quantities. The petitioner stated that the use of an exclusive use vehicle for shipments of only a few bags of asbestos is extremely uneconomical and that it is also not feasible to maintain supplies to unitize and palletize small quantity shipments of bags of asbestos. This petitioner requested that fiber boxes be allowed as an alternative to the palletizing and unitizing method: The MTB is in basic agreement with this petitioner concerning small quantity shipments of asbestos in bags, therefore, this amendment provides for the shipment of dust and sift-proof bags or other nonrigid packagings when in rigid outside fiberboard or wooden boxes. This option will continue to provide for public safety by providing for equal protection of the bags during shipment but will allow shipment of less than pallet load quantities. A petitioner objected that the amendment to the final rule as published on March 29,1979, did not include the provision allowing private highway carriers to transport dust and sift-proof packagings without palletizing and unitizing which appeared in the final rule published on December 4,1978 (43 FR 56664). The MTB agrees that the provision should be reinstated in view of the closer control exercised by private carriers over shipments. This provision will allow for private carriage by highway of dust and sift-proof bags and other non-rigid packagings which are not palletized and unitized. Several questions have been raised concerning the meaning of the words "exclusive use" as used in 173.1090(d)(3). For the purposes of this section, "exclusive use" means that the consignor has complete use of the transport vehicle and that the loading is carried out by the consignor and unloading is carried out by the consignee or consignees. A petitioner also cited a need for an extended effective date for packages of asbestos initially entered in-o transportation prior to August 20.1979, but which would still be required to be shipped from distributors, warehouses, and the like, after that date. It was' stated that many distributors, etc., do not have the ability or facilities to repackage such shipments and, therefore, such stocks would not be able to be reshipped after the effective date of lire final rule, thus causing severe hardships. The MTB is in agreement that this situation could pose a serious burden and, therefore, this amendment includes a provision allowing packages of asbestos initially shipped prior to August 20,1979. to continue to be shipped until December 31,1979. In consideration of the foregoing, $ 173.1090 as it appeared in the Federal Register published on March 29,1979 (44 FR 18673) is revised as follows: In 173.1090, paragraphs (d) (1). (2), and (3) are revised: paragraphs (d) (4) and (5] are added to read as follows: 173.1060 Asbestos. * * Cd)* * * (1) Rigid, leaktight packagings, such as metal or fiber drums, portable tanks, hopper-type rail cars, or hopper-type motor vehicles: (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; (3) Bags or other non-rigid packagings which are dust and sift-proof. When transported by other than private carrier by highway, such packagings containing asbestos must be palletized and unitized by methods such as shrink-wrapping in plastic film or wrapping in fiberboard secured by strapping. Pallets need not be used during transportation by vessel for loads with slings that are unitized by methods such as shrink-wrapping, if the slings adequately and evenly support the loads and the unitizing method prevents shifting of the bags or other non-rigid packagings during conditions normally incident to transportation; or (4) Bags or other non-rigid packagings which are dust and sift-proof in strong outside fiberboard or wooden boxes. (5) Notwithstanding the requirements of this section, packages containing asbestos initially shipped and transported prior to August 20,1979, may continue to be shipped and transported until December 31,1979. (49 U.S.C. 1603.1804.1808; 49 CFR 1.53 and App. A to Part 1.) Note.--The Materials Transportation Bureau has determined that this final rule will not result in a major economic impact under the terms of Executive Order 12044 and DOT implementing procedures (44 FR 11034) nor require an environmental impact atatement under the National Environmental Policy Act (49 U.S.C 4321 et seq.). A regulatory evaluation is available in the docket. Issued in Washington. D.C on August 10. 1979. L D. Sautman, Director. Materials Transportation Bureau. (FR Doc. 7S-JJ23> Filed S-1S-7V. IU *m| BILUNQ CODE 4S10-4O-M ' /ft, Rer/is/o/us 3/2.9/77 DEPARTMENT OF TRANSPORTATION MATERIALS TRANSPORTATION BUREAU WASHINGTON, D.C 20590 18673 013770 [Docket No. HM-160: Arndt. No. 173-M. 173-123.174-33.175-7,176-6,177-44J PART 173--SHIPPERS--GENERAL RE* QUIREMENTS FOR SHIPMENTS AND P A..CKAGINGS Vr- ' Transportation of Asbostos; Rovision of Anondmont No- 173-123; Effno* V thro Dato Extension- AGENCY: Materials Transportation Bureau (MTB), Research and Special Procrams Administration. DOT. ACTION: Revision of previous Amend ment No. 173-123 and extension of the effective date for all amendments. SUMMARY: This revision of Amend ment No. 173-123 regarding the trans portation of asbestos as published on December 4.1978, in the Federal Reg ister (43 FR 58664) will allow ship ments of asbestos when packaged In bags or other non-rigid packagings to be transported in closed freight con tainers. motor vehicles, or rail cars when loaded by the consignor and un loaded by the consignee; or in bags and other non-rigid packagings that are dust and sift proof which are palle tized and unitized. Unitized loads in slings need not be palletized during transportation by vessel. The effective date of the entire Docket HM-160 is revised from April 30, 1979 to August 20.1979. EFFECTIVE DATE: August 20,1979. ADDRESS: All written comments re ceived in this rulemaking action are available for examination during regu lar business hours in the Docket Branch, Room 6500, TransPoint Build ing, 2100 Second Street, S.W., Wash ington. D.C. FOR FURTHER INFORMATION CONTACT. Delmer F. Billings, Standards Divi sion, Materials Transportation Bureau, Research and Special Pro grams Administration, 2100 Second Street, S.W., Washington, D.C. 20590, phone 202-755-4902. SUPPLEMENTARY INFORMATION: On December 4, 1978, the MTB pub lished a final rule under Docket HM160 In the Federal Register (43 FR 56684). Since this publication, the MTB has received several petitions for reconsideration in accordance with the provisions of 49 CFR 106.35. The peti tions requested reconsideration of the provisions and/or extension of the ef- fective date of the final rule. This doc ument will incorporate methods of shipment which were identified in the notice of proposed rulemaking (43 FR 8562, March 2, 1978) and also those which were Included in the final rule. These amendments represent mini mum safety requirements and are in tended to reduce the risks to public health associated with the generation of unacceptable airborne concentra tions of asbestos that my result from * .packaging and handling of asbestos shipments in commercial transporta . tion. . -> Two petitioners based their petitions on the fact that the final rule con tained a provision requiring bags and other non-rigid containers of asbestos to be palletized and unitized by some method such as shrink-wrapping in plastic film or wrapping in fiberboard secured by strapping. It was noted that this requirement was not lnclud- ed in the notice of proposed rulemak ing (43 FR 8562), thus making com ments on this requirement impossible during the normal comment period for the proposed rulemaking. Petitioners also posed the question of whether or not freight containers, rail cars, etc., constituted rigid, airtight packagings as required in 9173.1090(d)(1). It was stated that if such containers were not included In this provision, all ship ments of bags or non-rigid containers would be required to be palletized and unitized according to the provisions of 9173.1090(d)(2), and that this require ment would impose great hardship on the asbestos industry and on shippers of large volumes of asbestos who nor mally ship using exclusive use vehicles and rail cars. It was also indicated that neither the equipment nor faculties exist at the present time to achieve compliance with the palletizing and unitizing requirement of the final rule by the published effective date. The MTB has determined that freight con tainers and, probably, motor vehicles and raU cars would not satisfy the re quirements of 9173.1090X1X1). By allowing the use of unitized paUet loads as identified In the final rule, the MTB intended to recognized less restrictive handling requirements for bagged asbestos than those that would have been required by the "loading by consignor/unloading by consignee" approach. However, it was not the intent of the MTB to elimi nate the more restrictive consignor/ consignee approach. Therefore, 9173.1090(d) is being revised to allow the option of either the consignor/ consignee approach as identified in the original proposed rulemaking with inclusion of an exclusive use provision or the unitized paUet approach using bags or other non-rigid packagings as required by the final rule. One petitioner noted that a method of shipment of asbestos via water was the use of slings which are shrinkwrapped or stretch-wrapped and trans ported in the hold of a vessel without the use of pallets. It was the petition er's contention that the use of pallets would Increase the incidents of unin tentional release of asbestos due to the interaction of the pallets against the bags which are unitized by the slings. It was noted that pallets were used In all instances 7 except when placed in the hold of the transport vessel. Given the lack of detailed data on the amount of asbestos fibers re leased in transportation and the cir cumstances and cause for such release, the MTB is in general agreement that increased unintentional releases may be likely if pallets were used under the method identified in the petition. Therefore, 9173.1090(d) is being re vised to allow slings in loads that are shrink-wrapped or stretch-wrapped to be transported by water without the use of pallets. Future monitoring of hazardous materials incident reports will assist the MTB In determining the safety and efficiency of this and other methods for shipment of asbestos. One petitioner suggested that the terms "pallet" and "palletized" be de fined in the rulemaking. The MTB does not intend to publish a definition of pallet or palletized. It 1s the MTB's opinion that any rigid platform or board upon which goods may be placed for transportation would meet the requirements when unitizing a load of bags or other non-rigid packaginss. Several petitioners cited a need for the MTB to define the term "dust and sift proof". For the purposes of this amendment, the MTB considers dust and sift proof to mean packagings which are constructed so as to prevent the release of their contents either through materials of construction, seams, or closures during conditions normally Incident to transportation. One petitioner requested that the use of gluing of bags into a unit be al lowed as an alternative to the unitiz ing methods identified in the final rule. It is the MTB's opinion that the use of shrink-wrapping or other simi lar methods of enclosure assist not only in unitizing a pallet load of bags or other non-rigid packagings, but also assist in the prevention of airborne as- u ................ -- ... > ' 1 ...... !--. ---- 1 f:&% 2- - 137-71 bestos contamination of individuals in volved in the transportation of asbes tos. Simply gluing these packaging* to gether to form a unit would not pro vide this added measure of safety to which the final rule addresses itself. Therefore, gluing of bags into a unit is not being included as an alternative unitizing method. Ohe petitioner requested that quan tities of less than 2,000 pounds, net weight, per vehicle be excepted from the palletizing and unitizing require ment. It is MTB's opinion that the pal letising and unitizing requirement does^notr unreasonably,, restrict the shipment of asbestos in any 'quantity. This requirement is necessary to pro vides minimum level of safety.1; . . ' Several petitioners requested; an ex tension" of the effective date/of the final rule. The effective date has been extended'to allow five months for compliance as originally Intended by the December 4.1978 publication. Primary drafters of this document are Delmer F. Billings. Standards Divi- sion,1,-Office of Hazardous Materials Regulation, and Douglas A. Crockett, Standards Division, Office of Hazard ous--M---ateri-als Regulations. " In consideration of the foregoing, the effective date and paragraph (d) of $ 173.1090 as they appeared in the Federal Register published on De cember 4, 1978 (43 FR 56664) are re vised to read as follows: 1. The effective date of the final rule as it appeared in HM-160 on Decem ber 4, 1978, is revised to read as fol lows: EFFECTIVE DATE: August 20.1979. 2. In 173.1090 paragraph (d) as it appeared at 43 FR 56669 is revised to read as follows: . .. , . .. . . *.>' ^ . . ? Al 1173.1090 Asbeatoa JA <d) Commercial asbestos must be of fered for - transportation and trans ported ln--v,< ,v w. .. (1) Rigid, airtight packagings such as metal or fiber drums, portable tanks; (2) Bags or other non-rigid packag ings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or - .. . (3) Bags or other non-rigid packag ings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrapping in plastic film or wrapping in ftberboard secured by strapping. Pallets need not be used during transportation by vessel for loads with slings that are unitized by methods such as shrink wrapping, if the slings adequately and evenly support the loads and the unit izing method prevents shifting of the bags or other non-rigid packagings during conditions normally incident to transportation.,,.-^ ^ <49 DS.C. 1803,1804,1808; 49 CFR U3). ^ - Nora--The Materials - Ttansportation Bureau has determined that these amend ments do not require a regulatory analysis under the items of Executive Order 13044 and DOT Implementing procedures (43 FR 9582). A regulatory evaluation is available for review in the Docket. , Issued in Washington, D.C. on March 22,1979. UD. SAMTKAir. Director, - Materials Transportation Bureau. [FR Doc. 79-9325 Field 3-28-79: 8:45 ami RHIAl UOiSTfX, VOL 44, NO. 82--IHUUOAY, MARCH 29, 1979 { 172.316 Packaging* containing material classed as ORM. (a) Except as provided in i 73. SOS ol this subchapler. each package containing a material c'assed as ORM-A. B. C. or 0 must be plainly and durably marked on a; least one side or end with the appropriate ORM designation immediate!/ following or below the proper shipping name.of the material. The appropriate ORM designation must be placed within a rectangle that is approximately '/inch (6.3 mm ) larger Va 0 each side than the designation The appropriate designation for each ORM must be: i (1) ORM-A for and ORM -A. ' (2) ORM-B-KEEP DRV for an ORM-B that is a solid and is corrosive i '-w only to aluminum when wet. j <3) ORM-B for an ORM-B olher tnan that described in paragraph I (a)(2) of this section. j (4) ORM-C for an ORM-C. I (5) ORM-D-AIR for an ORM-D that is prepared tor air shipment and ' packaged in accordance with the provisions of 173.6 of this subchap- J ler. i (6) ORM-D for an ORM-D other than that described in paragraph (a)(5) of this section. .J? (b) When the ORM-D marking, including the proper shipping name, can not be affixed on the package surface, it may be on an attached tag. I ,, (c) The marking ORM -A. B. C or D is the certification by the person i rj offering the package for transportation that the material is properly classed, packaged, marked, and labeled (when appropriate) and in , proper condition for transportation according to the applicable reguta- 4 - lion of the Department. This form of certification does not preclude the : 4 requirement for a certificate on a shipping paper when required by a 172.204. _ -- : i 5G6S4 H910-60-MJ . Title 49--Transportation CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DE PARTMENT OF TRANSPORTATION (Docket No. HM-160: Arndt. Nos. 172-47. 173 123. 174-33, 175-7. 176-6. 177-441 TRANSPORTATION OF ASBESTOS Miscellaneous Amendment AGENCY: Materials Transportation Bureau. Research and Special Pro grams Administration. DOT. ACTION: Final Rule. SUMMARY: These amendments re quire shipments of commercial asbes tos fibers to be packaged in rigid, air tight or dust and sift proof packagings. Except when the shipment is by private carrier, non-rigid packages, such as bags, must be palletized and unitized using shrink-wrapping or strapped fiberboard wrapping. These amendments represent minimum safety requirements and are intended to reduce the risks to the public health associated with the generation of airborne concentrations of asbestos that may result from the packaging and handling of asbestos fiber ship ments in commercial transportation. EFFECTIVE DATE: These regula tions are effective April 30.1979. ADDRESS: All written comments re ceived in this rulemaking action are available for examination during regu lar business hours in the Dockets Branch. Room 6500, Trans Point Building. 2100 Second Street SW., Washington, D.C. FOR FURTHER INFORMATION CONTACT: Douglas A. Crockett. Standards Divi sion. Materials Transportation Bureau, Research and Special Pro grams Administration, 2100 Second Street SW.. Washington, D.C. 20590, phone 202-426-2075. SUPPLEMENTARY INFORMATION: On March 2. 1973. a r.ouce of proposed rulemaking (HM-160: Notice 78-3) was published in the Federal Register (43 FR 8562) stating that the MTB was planning to exercise regulatory con trol over the transportation of asbes tos. Specific regulatory requirements were proposed for the control of cer tain forms of asbestos (e.g., milled or crude asbestos fibers). No require ments were proposed for asbestos fibers which are Immersed or fixed in a natural or artificial binder material, or for manufactured products contain ing asbestos. Interested persons were Invited to participate in the rulemak ing proceeding through submission of written comments on the proposal to RULES AND RE4 GULATI'ONS the MTB. All submissions, including late submissions, that were received on the proposal were fully considered by the MTB in the development of this final rule. Need To Regulate the Transportation op Asbestos Several commenters felt that the MTB had failed to establish a need to regulate the transportation of asbes tos. One of the commenters suggested that there was no need for the pro posed regulatory control of asbestos In transportation because the "methods and procedures now in use for the packaging and transport of asbestos meet the requirements of Part 173. 24(A)(sic) of the Transportation Act, that is `under conditions normally in cident to transportation there will be no significant release of the hazardous materials to the environment' and `the effectiveness of the packaging will not be substantially reduced (t)he proposal contains no documentation to justify additional regulation." This commenter, while apparently believing that asbestos is a hazardous material, was incorrect in suggesting that asbes tos is currently regulated oy the MTB; or in suggesting that the purpose of Notice 78-3 was to justify the addition al regulation by the MTB of asbestos In transportation. The transportation of asbestos is not now regulated by the MTB. It was precisely the purpose of Notice 78-3 that It should be. If. as the commenter suggests, the transporta tion of asbestos is now ` in compliance with pertinent provisions of the Trans portation Act," this rulemaking action will formalize and insure in a uniform and systematic manner that this is the case. Another commenter stated that Notice 73-8 did "not establish a foun dation for regulation, in that it does not document, or even allege for that matter, the actual release of fiber during the transportation of asbestos." As was pointed out In Notice 78-3. the MTB has "no detailed information on the amount of asbestos fibers released during transportation." The MTB does not now regulate asbestos, and has not therefore systematically collected acci dent data on the amounts of asbestos released In transportation or data on the frequency of such accidents. Most asbestos fiber, however, is currently shipped in bags, and it is undeniable that these bags can and do break, or can be and are being torn or punc tured. with a consequent release of some or all of the bag contents. It can be speculated, moreover, that If all of the 750,000 tons of asbestos annually shipped in the United States were packaged in. as one commenter states, the "standard package" of a 100-pound bag; and if as iittle as one-tenth of one percent of these bags were damaged in 013772 transportation during the year (one out of a thousand) and if on tjie aver age 1 percent of the contents of the bags so damaged were released, the total amount of asbestos released per year would equal about 7.5 tons. These calculations give a genera! idea of the magnitude of asbestos fiber that would be released, given a 99.5 percent efficiency factor for "bag integrity" in transportation, and a 99.0 percent effi ciency factor in minimizing the amount of asbestos released given a tear in the bag. The rather evident fact that asbestos has been accidental ly released during transportation has not been contradicted by anything submitted to the public docket on this rulemaking action. One commenter. for example, in discussing the use of open-bed trailers with side racks and tarpaulins to transport asbestos stated that there is no evidence that the use of such trailers "has contributed to bag breakage and the release of air borne concentrations of asbestos fiber." The Asbestos Information As sociation, an incorporated nonprofit organization representing 51 firms in the United States and Canada engaged in the manufacture or processing of asbestos-containing products and the mining/milling of asbestos fibers, stated that with "the very large volume cf asbestos shipped, occasional container damage may occur." Although several commenters who discussed this matter do not contend that asbestos has not been released in transportation, they generally are of the view that the amounts that are being released are not significant or of a sufficient amount to pose an unrea sonable risk to public health. The MTB does not agree; it believes that the amounts' of asbestos fibers that are being released now. or would be re leased in the future, in the absence of these amendments, may pose an un reasonable risk to health. Several commenters were concerned with the statement appearing in Notice 78-3 that "asbestos in its sever al commercial forms, poses serious health hazards to individuals subject to leng term exposure to airborne as bestos concentrations." One comtnenter stated that "not all long-term exposures to airborne concentrations pose any health hazards * * V' An other commenter suggested that the statement needed "more explicit defi nition" and that "reference should have been made to unanswered ques tions within the scientific community concerning mineral type, fiber size and smoking in the asbestos-canccr rela tionship." One commenter stated that there is a dose-response relationship between exposure to asbestos and dis ease causation, and that this conclu sion is supported by an OSHA state ment from its June 7. 1972 preamble FEDERAL REGISTER, VOL 43, NO. 233--MONDAY, DECEMBER 4. 1978 RUIES AND REGULATIONS viJ^*56S5 to Us standard for exposure to asbes tos dust (31 FR 11318). The OSHA statement is that: "No one has disput ed that exposure to asbestos of high enough intensity and long enough du ration is causally related to asbestosis and cancers" (empharis added). Al though the MTB had also quoted this statement in Notice 78-3, the words underlined for emphasis had been in advertently omitted. Under these cir cumstances, some commenters appar ently fell that the MTB was asserting the view that because, according to some commenters, asbestos is ubiqui tous, long term exposure to ambient levels of asbestos fibers poses serious health hazards to all people, without regard to their occupational or paraoccupational status. It was not the In tention of the MTB to assert this view. That there are or can be "undisputed grave consequences from exposure to asbestos" (37 FR 11318) does not depend on the questioned conclusive ness of the evidence reported by OSHA (40 FR 47652) regarding the po tential health hazards posed by lowlevel, brief or intermittent exposure to asbestos. The MTB relies on the fore going Fedebal Register references for the general view that exposure to as bestos may pose an unreasonable risk to the public. Section 173.1090(a) and (b) Several commenters stated that there are certain mineral ores, ore con centrates and milled mineral products which may have trace amounts of as bestos, or minor amounts of asbestos occurring as contaminants. They sug gested that these materials presented no risk to property and little, if any. risk to public'health and safety in transportation. Moreover, since the packaging requirements proposed in Notice 78-3 applied to only certain kinds of asbestos, namely milled or crude asbestos fibers produced by an asbestos mill, they further suggested that only "commercial asbestos fibers" be defined as a hazardous material. The MTB recognizes that there are certain mineral ores, ore concentrates and milled mineral products, as well as other products, that contain certain amounts of asbestos, and that the commercial value of these minerals or products is not dependent on their as bestos content. The specific require ments in these amendments for the control of asbestos fibers in transpor tation do not apply to such materials or products, nor do they apply to as bestos as a waste product1 or as a con- Under Docket HM-145A 143 FR 22626. May 25. 1978). new standards and proce dures were proposed for the transportation of hazardous waste materials. That proposal would include waste asbestos if so identified by EPA under Section 3001 of the Solid Waste Disposal Act as amended by the Re- taminating trace element. The amend ments apply only to asbestos in its *ciH!ral commercial forms since it is those forms of asbestos that have been firmly established as posing serious health hazards to individuals. A new paragraph has been added which would define commercial asbestos as any material or product containing as bestos that has commercial value be cause of its asbestos content, and ap propriate modifications have been made in the amendments to reflect this clarification. This new paragraph is identified in this amendment as paragraph (b) (paragraphs (b) and (c) in the notice are now paragraphs (c) and (d), respectively). One commenter recommended that the scope of Notice 78-3 be amended to include, in addition to asbestos fibers, "all mineral and man-made (fibers) which have been identified by U.S. Government agencies as being carcinogenic and which may pose seri ous health risk." On December 9.1976, the MTB published an Advance Notice of Proposed Rulemaking (41 FR 53824) in Docket No. HM-145 entitled "Environmental and Health Effects Materials." In that Notice, the MTB announced that it was considering whether new or additional transporta tion controls are necessary for certain classes of materials which are not gen erally subject to the existing Hazard ous Materials Regulations. The ques tion of whether all mineral and man made fibers, which have been identi fied by U.S. Government agencies as being carcinogenic and which pose an unreasonable risk to public health, should be controlled in transportation will be considered in terms of the fur ther development and resolution of the issues associated with Docket HM145. Notice 78-3 however, pointed out that a large number of comments were received in Docket HM-145, and that a considerable amount of staff evalua tion of these comments was still re quired before it would be possible to Issue a notice or notices of proposed rulemaking for environmental and health effects materials, either on a comprehensive or on a selective basis. Section 173.1090(c)(1) Several commenters objected to the reference made to metal or fiber drums to illustrate the rigid packaging alternative for asbestos fibers. These commenters stated that the asbestos industry has not developed the tech nology to use this-type of packaging alternative: that available technology is not transferable to the use of metal or fiber drums: and that, among other things, the use of this alternative could generate far greater airborne concentrations of asbestos than pack- source Conservation and Recovery Act (Pub. L. 94-580). aging and shipping practices currently in effect. As one commenter pointed out: < Commercial asbestos b fluffy. It is diffi cult to pack this material in a rigid contain er. and. because the fiber would gradually compact during shipment, it would be diffi cult to remove it for introduction into the manufacturing process. It would also be ex tremely cumbersome, if not Impossible, to empty rigid containers effectively and rapid ly Into hoods designed for bags. Spillage would no doubt occur and workers would be unnecessarily exposed to fibers. Another commenter recommended that a DOT Specification 56 portable tank be tncluded in the amended rule as an acceptable package "for the transportation of asbestos-type prod ucts." This commenter stated that "with the use of equipment designed for the purpose, the D.O.T. 56 package can be readily filled or emptied with out release of any product dust to the atmosphere or contact with the prod uct by the operator." Another com menter Insisted that only metal drums and not fiber drums were acceptable for the transportation of asbestos fibers. TheSfe commenters apparently lost sight of the fact that .proposed f 173.1090(cXl) does not "mandate." as one commenter suggested, or even en courage the use of rigid, airtight pack aging such as metal or fiber drums or even portable tanks. It provides an al ternative method of shipping commer cial asbestos fibers. As was indicated in Notice 78-3, the MTB believes that its proposed non-specification packaging standards as applied to the transporta tion of commercial asbestos is an ef fective and efficient means of preclud ing potential problems associated with asbestos airborne emissions occurring during transportation: and that they are consistent with the standards of the EPA and the OSHA. Some ef the commenters however were also appar ently unaware that the transportation standards for the control of asbestos are designed to be comprehensive in nature such that, once the standards are promulgated, commercial asbestos cannot be packaged and transported in any matter not specified in the amend ments. If under more advanced tech nology the use of rigid, airtight pack aging would lessen the likelihood of airborne asbestos emissions associated with bag breakages under current in dustry wide non-uniform non-standardized packaging practices, then it is necessary that alternative transporta tion standards be available so as not to preclude the development and utiliza tion of such technology. Although the pubyc record on Notice 78-3 contains statements that the asbestos industry is seeking to improve the technology Involved in the shipment and handling of commercial nsbestos so as to mini mize the possibility for the accidental release of such asbestos incident to FEDERAL REGISTER. VOL 43, NO. 233--MONDAY, DECEMBER 4, 1978 56666 RULES AND REGULATIONS 013774 transportation. It is by no means cer stances and causes for such release, tain that the pace of such technologi the MTB is in general agreement with cal improvements is rapid enough or the thrust of these ccrr.mcnhs: accord that the best, economically feasible ingly. a newr paragraph (d)<2) recog technology is being considered. How nizes less res:r:ctivs handling of ever. the classification of asbestos as bagged asbestos than was proposed. an ORM-C will, for the first time, re quire the submission of incident re ports to the MTB by carriers of any Sections 174.810. 175.840, 176.906. 177.844 unintentional release of asbestos -In these Sections, Notice 78-3 had during transportation, and enable the proposed that, incident to its transpor MTB to monitor the safety perform tation. asbestos must be loaded, han ance record associated not only with dled, and any asbestos contamination the transportation alternatives availa removed, in a manner that will prevent ble under current tecluiology as pro occupational exposure to airborne as vided for by these amendments, but bestos particles (emphasis added). also with any improvements in that Some commenters objected to the technology. word "prevent," believing that this For these reasons, the substance of word was intended to mean completely proposed $173.1090(0(1) is being re precluding the possibility of an acci tained but modified to reflect an even dent occurring in which asbestos fibers broader range of permissible rigid, air would be released; or completely iso tight packaging alternatives. This sec lating people involved in the transpor tion now is identified in this amend tation. loading and unloading of asbes ment as 173.1090(d)(1) because of the tos from exposure to asbestos fibers addition of new paragraph (b). . from whatever source such fibers were generated. One commenter pointed Section 173.1090(c)(2) out that with "the very large volume of asbestos shipped, occasional con tainer damage may occur." Another Proposed paragraph (c)(2) of Notice commenter pointed out. although in a 78-3 covered the transportation alter somewhat contradictory fashion, that native of shipping commercial asbestos since "asbestos Ls ubiquitous," there in bags when in closed freight contain fore "airborne levels of asbestos fibers ers. motor vehicles, or rail cars that can be present in any place of employ were loaded by the consignor and un ment. regardless of whether or not as loaded by the consignee. Several com bestos or products containing known menters noted that, unless reliance quantities of asbestos are handled" was placed on using the rigid, airtight (emphasis added). The Asbestos Infor packaging alternative provided in the mation Association in its comments proposal, this alternative would pre stated that "asbestos is ubiquitous, clude the shipment of asbestos fibers and there are no workplaces where by open-bed trailers. One commenter there is zero occupational exposure to noted that there is "no evidence to in asbestos" (original emphasis). If dicate that the use of open-bed trailers Notice 78-3 was not as clear as it with side racks and tarpaulins has con might have been on this point, it is tributed to bag breakage and the re only necessary to say that the basic lease of airborne concentrations of as purpose of these amendments is to bestos fiber." Another commenter minimize the exposure to airborne as noted that the type of bag permitted bestos particles accidentally released .by proposed paragraph (c)(2) was not during or incident to transportation; specified, and that the shipper could and appropriate changes to Parts 174, package asbestos In burlap bags, or 175, 176, and 177 have been made to .-very thin paper or polyethylene bags reilect this purpose. - which could permit asbestos fibers to - be easily released into the air during ORM-C Classification transit. Another commenter was con Notice 78-3 proposed that the classi ; cemed with "small volume users of as fication for "asbestos" would be as an bestos and customers who, from time ORM-C. (Other Regulated Material, -to time, require sample shipments for Group C). Several commenters were : trial production runs of a few hundred uncertain and concerned about the : pounds." and who-- under . marking requirements associated with $ L73.l090(cX2> would be forced to ac ORM-C classifications. One com quire the exclusive use of a railcar or menter noted that the designation highway trailer, or rely on the alterna .ORM-C would "carry no meaningful tive provided by $ 173.1090(c)(1). .warning to the`person handling or V. Given' the lack of detailed data on . opening the package." Another noted t the amount of asbestos fibers released ` that.the present regulations of the Oc c ln - transportation and .thercircum- cupational Safety and Health Admin- b: F.:'A un- - i- ' .- .; *' >- r _ S-g-WTl Lstration (OSHA) on labeling require ments for asbestos convey much more Information than an ORM-C marking requirement. These commenters were apparently not completely familiar with the marking requirements associ ated with ORM-C designated materi als. The ORM-C marking not only warns when a package contains haz ardous material, but it is also a certifi cation by the person offering the package for transportation that the material is properly described, classed, packaged, marked, and labeled (when appropriate) and in proper condition for transportation according to- appli cable regulations- of the Department. Neither function precludes or pre empts OSHA labeling requirements or creates "contradictory regulatory re quirements for labeling" as one com menter suggested. For these reasons, no changes have been made with re spect to any marking requirements for. asbestos packages. Economic/Inflationary Impact In reviewing the potential economic and inflationary impacts associated with the final rule, the MTB has de termined that such impacts will be minimal. Based on the comments re ceived, and the consequent modifica tion of Notice 78-3. the only economic costs associated with final amendment pertain to the reporting requirements to be submitted to MTB on the acci dental releases of commercial asbestos fibers during or incident to transporta tion. The absolute annual magnitude of these costs will be* of course, a func tion of the total number of incident reports that are submitted on acciden tal releases of asbestos fibers; but In view of the undisputed grave conse quences from exposure to asbestos fibers, these reporting requirements will not impose an unnecessary burden on the economy, on individuals, or on public and private organizations. In consideration of the foregoing. Title 49, Code of Federal Regulations. Parts 172, 173, 174. 175. 176. and 177 are amended as follows: PART 172--HAZARDOUS MATERIALS TABLE AND HAZARDOUS MATERI ALS COMMUNICATIONS REGULA TIONS - - 1. In 172.101 the Hazardous Materi als Table ls amended by adding a new entry. Immediately following "Arsine," to read as follows: -v c v T - * DS CEV; "; FEDERAL REGISTER. VOL 43. NO. 233--MONDAY, DECEMBER 4, 1978 [4910--60--Cl J 172.101 Hazardous materials table. (1) <i> */ Hazardous aatarlals descriptions U/ and proper ahlppln( aease A. (Add) Aabaatoa i i. i< i. i (3> Hazard class ORM-C (*) Labels(s) required (If not excepted) (5> Packaging (a) . (b) Specific Exception raqulre- aente Kaxlnua net quantity In one package (a) Passenger carry ing aircraft or railcar (bj Cargo only aircraft m Hater ehlpaents (a) (b) (c) Cargo veecal Pasrnger vessel Other raqulraaent \ ' None 173.1090 173.1090 (c) (d) Mo Llalt No Llalt 1. 2 , x, 2 Stow and * handle to avoid air borne particles. JO c > zo mO c r>- oz a i t , O H- CO rtOEiAl REOISTEI, VOL 43, NO. 233--MONDAY, DECEMBER 4, Iff! -aj 55668 RULES AND REGULATIONS PART 173--SHIPPERS--GENERAL RE QUIREMENTS FOR SHIPMENTS AND PACKAGINGS 2. Section 173.1090 is added preced ing Subpart I? to read as follows: 173.1090 Asbestos. (a) Asbestos includes any of the fol lowing hydrated mineral silicates: chrysotile, crocidolite. amosite, anthophyllite asbestos, tremolite asbestos, actinolite asbestos, and every product containing any of these minerals. (b) Commercial asbestos is any mate rial or product containing asbestos that has commercial'value because of its asbestos content. Cc) Asbestos which is immersed or fixed in a natural or artificial binder material (such as cement, plastic, as phalt. resins or mineral ore) and man ufactured products containing asbes tos or any materials or products whose commercial value is not dependent on their asbestos content, are not subject to the requirements of this sub chapter. (d) Commercial asbestos must be of fered for transportation and trans ported in-- CD Rigid, airtight packagings such as metal or fiber drums, portable tanks, or (2) Bags and other non-rigid packag ings that are dust and sift proof. When transported by other than a pri vate carrier by highway, bags and other non-rigid packagings containing asbestos must be palletized and unitited by methods such as shrink-wrap ping in plastic film or wrapping in fiberboard secured by strapping. PART 174--CARRIAGE BY RAIL 3. A Subpart M Heading is added im mediately following 174.812 to read as follows: Subpart M--Detailed Requirements for Other Regulated Materiois 4. Section 174.840 is added to read as follows: 174.840 Special loading and handling re quirements for asbestos. Asbestos must be loaded, handled, and unloaded, and any asbestos con tamination of rail cars removed, in a manner that will minimize occupation al exposure to airborne asbestos parti cles released incident to transporta tion. (See 173.1090 of this sub chapter.) - PART 175--CARRIAGE BY AIRCRAFT 5. Section 175.6-10 is added to read as follows: 175.640 Special requirement* for other regulated materials. Asbestos must be loaded, handled. and unloaded, and any asbestos con tamination of aircraft removed, in a manner that will minimize occupation al exposure to airborne asbestos parti cles released incident to transporta tion. (See 173.1090 of this sub chapter.) PART 176--CARRIAGE BY VESSEL 6. Section 176.906 is added to read as follows: 176.306 Stowage and handling of asbes tos. Asbestos must be stowed, handled, and unloaded, and any asbestos con tamination of vessels removed. In a manner that will minimize occupation al exposure to airborne asbestos parti cles released Incident to transporta tion. (See 173.1090 of this sub chapter.) PART 177--CARRIAGE BY PUBLIC HIGHWAY 7. Section 177.844 is added to read as follows: 177.841 Other regulated materials. Asbestos must be loaded, handled, and unloaded, and any asbestos con tamination of transport vehicles re moved, in a manner that will minimize occupational exposure to airborne as bestos particles released Incident to transportation. (See 173.1090 of this subchapter.) . (49 U.S.C. 1803,1804, 1808: 49 CFR 1.53(c).) Note.--The Materials Transportation Bureau has determined that these amend ments do not require a regulatory analysis under the items ol Executive Order 12044 and DOT implementing procedures (43 FR 9582). A regulatory evaluation Is available for review In the docket. Issued in Washington, O.C., on No vember 27,1978. L. D. Santman, Director, Materials Transportation Bureau. IFR Doc. 78-33771 Filed 12-1-78: 8:45 am] I \\ \ 6) FEDERAL REGISTER. VOL 43, NO. 233-MON0AY, DECEMBER 4, 1978 013776 (JrilON CARBIDE CORPORA. ION COft:vOnAn distribution .i v * s;.:c, VO*(K., N. t . 20Q17 July 23* 1979 013777 Materials Transportation Bureau US Department of Transportation 21D0 Second Street* SW Washingtont DC 20590 SUBJECT: Docket Ko. 1M-160 Transportation of Asbestos QSntl^en: Dr? March 29* 1979* the Materials Transportation Bureau published In the federal Register {44 F.R. 18573) a revision of fosndsent No. 173-23 Veqarding the transportation of asbestos* as published on Dece^sr * iyA7/ofi , {43 F.R, 6664). . Union Carbide Corporation Is engaged, among other things* in the production, sale and distribution of chrysotlle asbestos and ships an aggregate of over 30,000 tons per year of such material for use in various applications. Although a substantial portion of Union Carbides shipments of asbestos is made in bulk* an equally substantial portion requires packaging In bags. As revised* 1173.1090 {d} (2) and (3) content!ate the use of bags or other . * non-rigid patfcaqings. In each case* however, the revised section appears to assume tfcat shipments in bags can always be made In fairly large quantities. Thus, subparagraph (2) permits the use of bags in closed vehicles which are assigned for the "exclusive use" of the consignor. Obviously it would In most cirCtEistances be exceedingly unetongesicai for gny consignor to operate* or contract for the exclusive use of, a vehicle to transport a shipment of only a few bags of asbestos. Similarly, subparagraph (3) requires that bags be palletized and unitized. Ordinarily, in cccEnercial sales of asbestos, shipment quantities are sufficient to economically and practically accaws&date that r*quiresent. In many cases, however, distributors ir?jst ship quantities of only a few bags to meet customer requirements or limitations. Additionally*; in the case of sample shipments, only a single bag nay be involved. "*' 013778 It is normally impractical, however, for distributors to Taaintain supplies of pallets of various sites to acccaoodate s hi plants of varying numbers of bags. It is also impractical for distributors qr manufacturers to acquire and maintain equipment capable of unitizing pellet loads of widely divergent dimensions- In the oil drilling industry, for example, customers tend to order asbestos in relatively small quantities. It Is also cusiasary, for reasons explained In the enclosed letter frm Pie of Union Carbide's distributors, for such customers to return one or more bags (as "overages'*) for credit. It would not be realistic to expect Oil drillers, frequently at remote locations, to have available either the required pallets or unitizing' equipment. It Is respectfully suggested, therefore, that tbs regulations be further re vised to permit shipments of asbestos in dust and sift proof bags which are protected in transit by enclosure in a sufficiently strong outside packaging. Such a revision would make possible the shipment of one or xsre bags with protection against leakage of asbestos during transportation at least equal to that afforded by palletising and unitizing. If the Bureau agrees with the foregoing suggestion, it would appear to be most simply accomplished by revising the initial portion of S173.lOSO(<i} (3) to read as follows: ' {3} Bags or other non-rigid packsgings which are dust and sift proof end which are (i) enclosed in s rigid outside fiber-board or wooden packaging, or (il) palletized and unitized.... In order to assure continuity of movement without excessive inesrruption, it Is requested that the foregoing revision be published to bscssa effective or? 'August 20,'"1979. simultaneously with the previously revised sl73.K*uS, or as soon thereafter as possible. In connection with the currently scheduled effective date of August 20, 1979* Union Carbide Is concerned with certain packages of asbestos presently in the possession of distributors located primarily in the eastern portion of the United States- Although such isaterlals are palletized, they do not entirely conform with the new requirements of 8173.1050(d) (3) and, therefore, could not lawfully be shipped after August 20, 1979. Since it Is unlikely that all such Inventory could be finally disposed of before August 20, 1979*-it would be necessary prior to that dote, to return at least a portion thereof to Union Carbide's facility at King City, California for repackaging In accordance with the new regulations. Aside frm the additional costs which such e movcs&tt would generate, it appears incongruous to require the transcontinental transportation of asbestos In non-conforming packaging, ever, though such transportation would fee lawful prior to August 20. T-r 4. I KAi rfche~ __ 4 such materials were allowed sufficient time to be shipped tbs relatively short distances frts eastern dis tributors to fine! destinations, such unnecessary transcontinental evssnefifc could be avoided. 013779 Page 3 Accord-;ngly* it Is respectful!y requested that the effective date of the new regulations be further extended to 'October"!, 19/9^ but solely Kith resbect to asbestos p__a_c_k_a_g_e_d___a_n_d__i_nitlal 1 v_shippgd_ pr1or to August 20?~_Tj7?_T_ ^t 'hrni ;t bi reccypnirad, however* that a prompt response to this request is imperative since, 1 * r' *ytension is to hoe* grancea, rnvovv.c-*a?r:/rfa>nrt>c * "t f.'*i rk.?<'J(>i1? CW ;WSr)***i * *_ Shortly in order to he completed on or before August 20 T&jt courtesy and cooperation in considering tha setters discussed herein are greatly appreciated. Respectfully submitted, UNICri CARBIDE CORPORATION f&hjnr ~fA/y/\ .s/c .. -yts* fs /? H D'/Hichalid Assistant Acfeinistrator Hazardous Materials Transportation Regulations / -- n>,H KLVVUMlWni . 013780 [4910-60-M] Tills 49--TronsporloHon . the MTB. All submissions, including transportation during the year (o late submissions, that were received on out of a thousand) and if on the av the proposal were fully considered by age 1 percent of the contents of t CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DE PARTMENT OF TRANSPORTATION {Docket No. BM-160; Arndt. Nos. 112-47. the MTB in the development of this bags so damaged were released, t final rule. total amount of asbestos released p Need To Regulate tide Transportation or Asbestos year would equal about 7.5 tons. The ' calculations magnitude give a general of asbestos Idea of t fiber th 173-123.174-33. 175-7. 175-8. 177-44J . Several commenters felt that the would be released, given a 99.9 perce TRANSPORTATION OF ASBESTOS MTB had failed to establish a need to efficiency factor for "bag integrity" regulate the transportation of asbes transportation, and a 99.0 percent ei Miscellaneous Amendment tos. One of the commenters suggested ciency factor in minimizing t that there was no need for the pro amount of asbestos released given AGENCY: Materials Transportation Bureau. Research and Special Pro- (rams Administration.-DOT. . ACTION: Pinal Rule. - posed regulatory control of asbestos in transportation because the "methods and procedures now in use for the packaging and transport of asbestos meet the requirements of Part 173. tear in the bag. The rather evide fact that asbestos has been accident, ly released during transportation h not been contradicted by anyth! submitted to the public docket on t! SUMMARY: These amendments re-' 24(AMsic) of the Transportation Act. rulemaking action. One comment quire shipments of commercial asbes that is `under conditions normally In for example, in discussing the use tos fibers to be packaged in rigid, air cident to transportation there will be open-bed trailers with side racks a: tight or dust and sift proof p&ckag- no significant release of the hazardous tarpaulins to transport asbestos stat ings. Except when the shipment is by materials to the environment' and 'the that there is no evidence that the t: private carrier, non-rigid packages, effectiveness of the packaging will not of such trailers "has contributed such as bags, must be palletized and be substantially reduced (t)he bag breakage and the release of a - unitized using shrink-wrapping or - proposal contains no documentation to borne concentrations of asbest strapped fiberboard wrapping. These Justify -aririlrinnal regulation." This' fiber." The Asbestos Information i amendments represent minimum commenter, while apparently believing sociatlon. an incorporated nonpro safety requirements and are intended that asbestos is a hazardous material, organization representing 51 firms to reduce the risks to the public was incorrect in suggesting that asbes the United States and Canada engag health associated with the generation tos is currently regulated by the MTB: in the manufacture or processing of airborne concentrations of asbestos - or in suggesting that the purpose of asbestos-containing products and t. that may result from the packaging ' Notice 78-3 was to Justify the addition mlning/milling of asbestos fibe. and handling of asbestos fiber ship al regulation by the MTB of asbestos stated that with "the very lar ments in commercial transportation. in transportation. The transportation volume of asbestos shipped, occasion 1 EFFECTIVE DATE: These regula \ tions are effective April 30,1979. of asbestos is not now regulated by the MTB. It was precisely the purpose of Notice 78-3 that It should be. If. as the container damage may occur." Although several commenters wl discussed this matter do not conter ADDRESS: All written comments re-' commenter suggests, the transporta that asbestos has not been released J . ceived In this rulemaking action are tion of asbestos is now "in compliance transportation, they generally are i L available lor examination during regu with pertinent provisions of the Trans- the view that the amounts that a lar business hours in the Dockets poriation Act," this rulemaking action being released are not significant or i<i Branch. Room 6500. Trans Point will formalize and insure in a uniform a sufficient amount to pose an unre Building. 2100 Second Street SW,, and systematic manner that this is the sonable risk to public health. T. i Washington. D.C. . . case. MTB does not agree: it believes th i i ! FOR FURTHER INFORMATION CONTACT: ' Douglas A. CrockettsStandards Divi sion. Materials Transportation Bureau. Research and Special Pro grams Administration. 2100 Second Street SW.. Washington. D.C. 20590. phone 202-426-2075. Another commenter -stated that Notice 73-8 did "not establish a foun dation for regulation, in that it does not document, or even allege for that' matter, the actual release of fiber the amounts, of asbestos fibers th are being released now, or would be r leased in the future, in the absence these amendments, may pose an u reasonable risk to health. during the transportation of asbestos." Several commenters were concernf As was pointed out in Notice 78-3. the with the statement appearing i MTB has "no detailed information on Notice 78-3 that "asbestos in its seve the amount of asbestos fibers released * al commercial forms, poses serioi SUPPLEMENTARY" INFORMATION: during transportation." The MTB does health hazards to Individuals subje< ' On March 2.1978, a notice of proposed not now.regu'z's asbestos, and has not to long term exposure to airborne a rulemaking.(HM-160; Notice 78-3) was therefore.iystematicaUy collected acci bestos concentrations.". One coc published in the Federal Register (43 dent data on the amounts of asbestos menter stated that "not all Ioniter. FR 8562) stating that the MTB was' released inv transportation or data on - exposures' to airbony concentrattor planning to exercise regulatory con - the frequency of such accidents. Most pose any health hazards V* An trol over the transportation of asbes asbestos fiber, however, is currently other commenter suggested that th tos. Specific regulatory requirements shipped in bags, and It is undeniable statement needed "more explicit def were proposed for the control of cer that these bags can and do break, or nltion" and that "reference shoul tain forms of asbestos (e.g., milled or can be and axe being tom or punc have been made to unanswered que .crude asbestos fibers). No requlre- tured. with a consequent release of tlons within the scientific communit . meats were, proposed for asbestos some or all of the bag contents. It can ., concerning mineral type, fiber size ar. fibers which are Immersed-or fixed in be speculated, moreover, that if all of smoking in the asbestos-cancer rek a natural or artificial binder material, the 750.000 tons of asbestos annually tionship." One commenter stated thr or for manufactured products contain- shipped In the United States were there is a dose-response relationshi in* asbestos. Interested persons were packaged In. as one commenter states, between exposure to asbestos and di invited to participate in the rulemak the "standard package" of a 100-pound ease causation, and that this conch ing proceeding through submission of bags and if as Uttle as one-tenth of one sion is supported by an OSHA stat< written comments on the proposal to percent of these bags were damaged in ment from Its June 7, 1972 preamb! - . '.*'** # FEDERAL REGISTER* VOC 43, NO. 233---MONDAY, DECEMBER 4, 197 m  lYaWbAIIVil^ w j. v i v/s. 56665J to its standard for exposure to asbes- laminating trace element. The amend aging and shipping practices currently . tos dust (37 FR 11318). The OSHA ments apply only to asbestos in its in effect. As one commenter pointed ' statement is that; "No one has dispute several commercial forms since it U out: ed that exposure to asbestos of high those forms of asbestos that have been enough intensity and tony enough du firmly established as posing serious ration Is causally related to asbestosis health hazards to Individuals. A new and cancers" (emphasis added). Al paragraph has been added which though the MTB had also quoted this . would define commercial asbestos as Commercial asbestoa la Dully. It la difflculuto pack this material In a rigid contain er. and. because the liber would gradually compact during shipment. It would be diffi cult to remove It for Introduction into the statement in Notice 78-3. the words any material or product containing as manufacturing process. It would also be ex . underlined for emphasis had been In bestos that has commercial value be tremely cumbersome. If not Impossible, to advertently omitted. Under these cir cumstances. some commenters appar ently. felt that the MTB was asserting the view that because, according to cause of its asbestos content, and ap propriate modifications have been made in the amendments to reflect this clarification. This new paragraph empty rigid containers effectively and rapid ly Into hoods designed lor ban- Spillage would no doubt occur and workers would be unnecessarily exposed to libers. ' - some commenters. asbestos is ubiqul- is identified in this amendment as Another commenter recommended tous. long term exposure to ambient paragraph (b) (paragraphs (b) and> (c) that a DOT Specification 56 portable .. levels of asbestos fibers poses serious in the notice are now paragraphs (c) tank be included in the amended rule , health hazards to all people, without and (d). respectively). as an acceptable package "for the ; regard to their occupational or para ' One commenter recommended that transportation of asbestos-type prod : occupational status. It was not the'in- the scope of Notice 78-3 be amended ucts." This commenter stated that ; tentlon of the MTB to assert this view. to include, in addition to asbestos "with the use of equipment designed 1 That there are or can be "undisputed fibers, "all mineral and man-made for the purpose, the D.O.T. 56 package ' - grave consequence? from exposure to (fibers) which have been identified by can be readily filled or emptied with asbestos" (37 FR 11318) does not U.S. Government agencies as being out release of any product dust to the depend on the questioned conclusive carcinogenic and which may pose seri atmosphere or contact with the prod ness of the evidence reported by ous health risk." On December 9. 1976, uct by the operator." Another com OSHA (40 FR 47652) regarding the po- the MTB pufahshedan Advance Notice menter Insisted that only metal drums i tential health hazards posed by low : level, brief or intermittent exposure to of Proposed Rulemaking (41 FR 53824) inOocfcet No. HM-145 entitled and not fiber drums were acceptable for the transportation of asbestos asbestos. The MTB relies on the fore : going Federal Register references for . the general view that exposure to as -. bestosjnay pose an unreasonable risk . i to thelmblic. . . -I i Section 173.1090(a) aits (6) "Environmental and Health Effects Materials." In that Notice, the MTB announced that it was considering whether new or additional transporta tion controls are necessary for certain classes of materials which are not gen erally subject to the existing Hazard-. >j ` !. i { 1 : j Several commenters s.tated' that tbere are certain mineral ores, ore con centrates and milled mineral products which may have trace amounts of as1 bestos. or minor amounts of asbestos' occurring as contaminants. They suggested that these materials presented ous Materials Regulations. The ques tion of whether all mineral and man made fibers, which have been Identic fled by U.S. Government agencies as being carcinogenic and which pose an unreasonable risk to public health, should be controlled in transportation will be considered.in terms of the fur 1 no-risk to property and little, if any. risk to public health and safety in ther development and resolution of the issues associated with Docket HM- | transportation. Moreover, since the 145. Notice 78-3 however, pointed out packaging requirements proposed in that a large number of comments were y Notice 78-3 applied to only certain received in Docket HM-145. and that a : kinds of asbestos, namely milled or considerable amount of staff evalua crude asbestos fibers produced by an tion of these comments was still re asbestos mill, they further suggested quired before it would be possible to / that only "commercial asbestos fibers" issue a notice or notices of proposed : - be defined as a hazardous material, rulemaking for environmental and i - The MTB recognizes that there,are health effects materials, either on a ; certain mineral ores, ore concentrates comprehensive or on a selective basis. and milled mineral products, as well as fibers. These commenters apparently lost sight of the fact that proposed i 173.1090(e)(1) does not "mandate." as one commenter suggested, or even en courage the use of rigid, airtight pack aging such as metal or fiber drums or even portable tanks, it provides an al ternative method of shipping commer cial asbestos fibers. As was indicated in Notice 78-3, the MTB believes that its proposed non-specification packaging standards as applied to the transporta tion of commercial asbestos is an ef fective and efficient means of preclud ing potential problems associated with asbestos airborne- emissions occurring during transportation: and that they are consistent with the standards of the EPA and the OSHA. Some of the commenters however were also appar ently unaware that the transportation standards for the control of asbestos are designed to be comprehensive in nature such that, once the standards are promulgated, commercial asbestos cannot be packaged and transported in any matter not specified in the amend ! other products, that contain certain BectionTT3.1090(c)(1) ments. If under more advanced tech ; amounts of asbestos;' and that the j commercial value of these minerals or ; products is hot dependent on their as : bestos content. The specific require - ments in these amendments for the : control of asbestos fibers in transpor tatlon do not apply to such materials - or products, nor do they apply to as ; . bestos as a waste product * or as a con Several commenters objected to the reference made tp metal or fiber drums to illustrate the rigid packaging alternative for asbestos fibers. These commenters stated that the asbestos Industry has not developed the tech nology to use this type of packaging alternative; that available technology is not transferable to the use of metaJ nology the use of rigid, airtight pack aging would lessen the likelihood of airborne asbestos emissions associated with bag breakages under current in dustry wide non-uniform non-standardized packaging practices, then it Is necessary that alternative transporta tion standards be available so as not to preclude the development and utiliza tion of such technology. Although the i .................................. -..... - - -1 Under Docket HM-14SA (43 FR 22636. May 33. 1978). new standards and proce dures were proposed (or the transportation of hazardous waste materials. That proposal or fiber drums; and that, among other things, the use of this alternative could generate far greater airborne concentrations of asbestos than pack* public record on Notice 78-3 contains statements that the asbestos industry is seeking to Improve the technology involved in the shipment and handling would Include waste asbestos If so Identified of commercial asbestos so as to mini by EPA under Section 3001 of the Solid source ConsemUon and Recovery Act (Pub. mize the possibility for the accidental Waste Disposal Act aa amended by the Re- L94^580>. - release of such asbestos incident to EEDUAl ItGISTT*. VOL 43, NO. 233--MONDAY. DECXMSEX 4. 1*78 56666 . RULES AND REGULATIONS 013732 transportation. It Is by no means cer stances and causes for such release, lstratlon (OSHA) on labeling requir tain that the pace of such technologi the MTB Is in general agreement with ments for asbestos convey much mo cal improvements is rapid enough or the thrust of these comments; accord information than an ORM-C markir that the best, economically feasible ingly, a new paragraph (d)(2) recog requirement. These commenters we: echnology is being considered. How- nizes less restrictive handling of apparently not completely famili. ver. the classification of asbestos as bagged asbestos than was proposed. with the marking requirements assoc an ORM-C will, for the first time, re- ulre the submission of incident re ports to the MTB by carriers of any Sections 174.840. 175.640. 176.906. . 177.844 * ated with ORM-C designated maie: als. The ORM-C marking not on warns when a package contains ha unintentional release of asbestos In these Sections, Notice 78-3 had ardous material, but It is also a certL during transportation, and enable the proposed that, incident to its transpor cation by the person offering t) MTB to monitor the safety perform tation. asbestos must be-loaded, han package for transportation that t.1 ance record associated not only with dled. and any asbestos contamination material is properly described, classe. the transportation alternatives availa removed. In a manner that will prevent packaged, marked, and labeled (whe ble under current technology as pro occupational exposure to airborne as appropriate) and In proper conditic vided for by these amendments, but bestos particles (emphasis added). - for transportation according to app also with any Improvements in that ' -Some commenters objected to the cable regulations of the Departmer. technology. ' word "prevent," believing that this Neither function precludes or pr For these reasons, the substance of word was intended to mean completely empts OSHA labeling requirements c proposed g173.1090<cKl) is being re precluding the possibility of an' acci creates "contradictory regulatory r tained but modified to reflect an even dent occurring in which asbestos fibers quirements for labeling" as one cor. broader range of permissible rigid, air would be released; or completely iso menter suggested. For these reason tight packaging alternatives. This sec lating people involved in the transpor no changes have been made wiUir. tion now is identified in this amend tation. loading and unloading of asbes- spect to any marking requirements ic ment as $ 173.1090<dXl) because of the tea hrom mcposurnio asbestos libers asbestos packages. addition of new paragraph <b). .' from wisaleversuhrce .such fibers were Section 173.1090(c)(2) generated. ~^>ne commenter pointed out that with "the very large volume `of asbestos shipped, occasional con EcONOSnC/lNIXATIOKAltT IMVACT tainer damage may occur." Another Proposed paragraph (cX2) of Notice commenter pointed out. although in a 78-3 covered the transportation alter somewhat contradictory fashion. - that native of shipping commercial asbestos . since "asbestos Is ubiquitous." there in bags when in closed freight contain fore "airborne levels of asbestos fibers ers, motor vehicles,- or rail cars that can be present In any place of employ were loaded by the consignor and un ment, regardless of whether or not as loaded by the consignee. Several com- bestos or products-containing known menters noted that, unless reliance quantities of asbestos are handled" was placed on using the rigid, airtight (emphasis added). The Asbestos Infor packaging alternative provided in the mation Association in its comments proposal, this alternative would pre stated that "asbestos is ubiquitous, clude the shipment of asbestos fibers . and there are no workplaces when by open-bed trailers. One commenter there is zero occupational exposure to noted that there is "no evidence to- in asbestos" (original emphasis). If In reviewing the potential econotn. and inflationary Impacts associate with the final rule, the MTB has di termined that such Impacts will t minimal. Based on the comments rt ceived, and-the consequent modifier Uon of Notice 78-3. the only economi costs associated with final amendmer. pertain to the reporting requirement to be submitted to MTB on the acc: dental releases of commercial asbestc fibers during or Incident to transport; Uon. The absolute annual magnitudof these costs will be, of course, a func Uon of the total number of inciden dicate that the use of open-bed traders Notice 78-3 was not as dear as it reports that are submitted on accider with side racks and tarpaulins has con might have been on this point, it is tal releases of asbestos fibers; but L tributed to bag breakage and the re only necessary to say that the basic - view of the undisputed grave const lease of airborne concentrations of as purpose of these amendments is to quences from exposure to asbesto bestos fiber." Another commenter minimize the exposure to airborne as fibers, - these reporting requirement noted that the type-of bag permitted bestos particles accidentally released will not impose an unnecessary burde: by proposed paragraph (cX2) was not during or Incident to transportation; on the ecoftomy, on Individuals, or or specified, and that the shipper could and appropriate changes to Parts 174, public and private organizaUons. ' package asbestos in burlap bags, or~ -175. 176, and 177 have been made to In consideration of the foregoing very thin paper or polyethylene bags reflect this purpose. Title 49, Code of Federal Regulations which could permit asbestos fibers to be easily released into the air during ORM-C Classification . Parts 172. 173. 174, 175. 176. and 17'. are amended as follows: transit. Another commenter was con Notice 78-3 proposed that the classi cerned wrlth "small volume users of as fication for "asbestos" would be as an bestos and customers who, from time to time, require sample shipments for trial production runs of a few hundred ORM-C, (Other Regulated Material. Group O. Several commenters were uncertain and concerned about the PART 172--HAZARDOUS MATERIALS TABLE ANO HAZARDOUS MATERI pounds," and who under marking requirements associated with ALS COMMUNICATIONS REGULA 1173.109(XcX2) would be forced to ac ORM-C classifications. One com TIONS quire the exclusive use of a railcar or menter noted that the designation & * highway trailer,' or rely oh the alterna ORM-C would "carry no meaningful tive provided by } 173.1090(cXl>. warning to the person handling or 1. In $ 172.101 the Hazardous Materi Given the lack of detailed data on opening the package." Another noted als Table Is amended by adding a new the amount of asbestos fibers released that the present regulations of the Oc entry. Immediately following "Arsine.' In transportation and the circum cupational Safety and Health Admin- to read as follows: fCDCKAl fctesns. VOL <3, NO. 233--MONDAY, OEttMK* 4, mg [4910-60-C] . 1 172.101 Hm i H m n materUU Uhl*. notRAl IIOISTIR, VOL 43, NO. 233-M(4nDAY, DICIMBIR4 ,1971 . VWWW 0 y A i A 9 A* . A wA K A .A 4S >* O w C s <4 Mi V A A. A A A . * w A M A ^ r<* XS A ASA ft* A 9 V If w *4 5 -k w AA s: 5: . `Li A OA it AA . AA < A * * "A A *. 83o28 * A > O A W X i Ob ` A " m* " #4 .4 ' -v ' .. . # * ^ *. _ ` . - . * 013783 '. . . # ' . . * .* . * ' * ** #. - * ' A %4 8 *4 -4 tf , C II a 9M or o v a y A. *S i: * SZZ 3S a u S* AA V % WS d 4 AA .M 2 Mi tf N I* A C Ml A v8u A a-4 A Moo ABA Ik 4 h A '# v* A Ml %4 U ' I A v .a a a A or B ' MS. A 8 1 C *8 s A ~ i_ ' - *. .' 44 . ^ .. * . . . a .. .-. -. J , * . z ' . "w l . *# * ....................` . . ' - . . - a * .. . . o o 1* Ml M r AS -4>M . . * . - ` ._ .. ' . * * \ . ** . " - . - --. ,k A* . r - . mo - - ... . - 4*7 Mb 4> <1 . MV .4 . . . .. * . ' * - . * *. . -- ** * - . * . * * _' - . - -. ,. .' * MRU Mk - At At V* A 4* A 4% N Q W -a -4 a e o. 9 * dO V J3 S 3 5 . . . - - ^ i' & ` . . . .... . -" . . ' . ' '. . ' ' - . _ _ * . . . 5 *> A* AC -5 2 s " j5 . .. - ^ -- . x 'O i 'i1 . \ *' . . O . * * * -f fl OJ > 5 s o c.d-k. . IS A Aad-* V. o . . .. . Al 8 i * .. w A, - . * IS s'. ; " __ 1assJu-Z. W8 8At S? < % 56668 RULES AND. REGULATIONS 013734 PART 173--SHIPPERS--GENERAL RE- and unloaded, and any asbestos con QUIREMSNTS FOR SHIPMENTS AND PACKAGINGS 2. Section 173.1090 Is added preced ing: Subpart N to read as follows; tamination of aircraft removed, in a manner that will minimize occupation al exposure to airborne asbestos parti cles released incident to transporta 1 173.1090 Asbestos. tion. (See } 173.1090 of this sub chapter.) (a) Asbestos includes any of the fol lowing hydrated . mineral silicates: chrysotlle, crocidolite. amosite. anthophyilite asbestos, tremolite asbestos, PART 176--CARRIAGE BY VESSEL'. actinollte asbestos, and every product containing any of these minerals. Cb> Commercial asbestos is any mate 6. Section 176.906 is added to read as follows: rial or product containing asbestos that has commercial value because of its asbestos content. , $ 176.906 tos. Stowage and handling of asbes (c) Asbestos which b Immersed or Asbestos must be stowed, handled, fixed in a natural or artificial binder and unloaded, and any asbestos con material (such as cement, plastic, as phalt, resins or mineral ore) and man ufactured products containing asbes tos or any materials or products whose tamination of vessels removed. In a manner that will minimize occupation al-exposure to airborne asbestos parti commercial value is not dependent on cles released incident to transporta their asbestos content, are not subject tion. (See f 173.1090 of this sub to the requirements of this sub chapter.) chapter. (d) Commercial asbestos must be of fered for transportation and trans ported in PART 177--CARRIAGE BY PUBLIC ti) Rigid, airtight packaging* such HIGHWAY as metal or fiber drums, portable tanks, or 7. Section 177.8J4 is.added to read as (2) Bags and other non-rigid packag- follows: ings that are .dust and sift proof.- When transported by other than a prl* - i 177.844 Other regulated materials. vatc carrtelf W tUgMWW, bags ana other non-rigid pacaaginis containing*. Asbestos must be loaded, handled, issatoa must B6 palletized and unlt- and unloaded, and any asbestos con Md pymetnocB such as shrmic-wrarv tamination of transport vehicles re ping in plastic film or wrapping in fl- moved, is a manner that will minimize oerooara secured py strapping. occupational exposure to airborne as bestos particles released incident to PART 174--CARRIAGE BY RAIL 3. A Subpart M Heading is added im mediately following 174.812 to read as follows: Subpart M--Detailed Requirements for Other Regulated Materials 4. Section 174.340 is added to read as follows:. transportation. (See 173.1090 of this subchapter.) (49 U.S.C. 1803, 1804. 1808; 49 CFR 1.53(e).) Note.--The Material* Transportation Bureau has determined that these amend ments do not require a regulatory analysis under the items of Executive Order 12044 and DOT Implementing procedures (43 FR 9682)i A regulatory evaluation is available for review In the docket. 174.840 Special loading and handling re quirement* for asbelt*. Issued in Washington. D.C.. on No Asbestos must be loaded, handled, vember 27.1978. and unloaded, and any asbestos con tamination of rail cars removed. In a anner that will minimize occupation al exposure to airborne asbestos parti cles released Incident to transporta L. D. Sutmax, Director, Material* - Transportation.Bureau. (FR Doc. 78-33771 Filed 15-1-78; 8:45 am) tion. (See i 173.1090. of this sub chapter.) ^[4910-59-M] PAR I I75r--CARRIAGE BY AIRCRAFT 3. Section 175.640 is added to read as follows: CHAPTER V--NATIONAL HIGHWAY 1173.S40 Special requirements for other regulated materials. -Asbestos must be loaded, handled. TRAFFIC SAFETY ADMINISTRA TION, DEPARTMENT OF TRANS PORTATION (Docket No. 78-17: Notice 1) PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS New Pneumatic Tires--Passengc Cars AGENCY: National Highway Tra Safety Administration (NHTSA). p&rtment of Transportation. ACTION: Pinal rule. SUMMARY: Pursuant to petitions the Mlcheiln Tire Corporation (Mic lln) and by the Rubber Manufactur Association (RMA). this notice ame: Federal Motor Vehicle Safety Sta: ard No. 109, New Pneumatic Tire Passenger Cars, by adding four r tire size designations to Table I of c. pendix A of the standard. The ame: ment permits the introduction into terstate commerce of the new t sizes. EFFECTIVE DATES January 3. 19' if objections are not received prior that date. ADDRESS: Comments should refer the docket number and be submitt to- Room 5108, Nassif Building, 4 Seventh Street SW.. Washington, D. 20590. ' . FOR FURTHER INFORMATIO CONTACT: John Diehl. Office of Vehicle Safe Standards, National Highway Tra fie Safety Administration. 400 Se enth Street SW., Washington, Da 20590 (202-426-1714). SUPPLEMENTARY INFORMATIO: According to agency practice, the N tional Highway Traffic Safety Admi. Istration responds to petitions fc adding new tire sizes to Table I of A; pendix A of Standard No. 109 by qua. terly issuing final rules under an at breviated rulemaking procedure fc expediting such routine amendments. On July 13. 1978. Michelin pet tioned for the addition of two new tir size designations requested to be loca: ed in a new table, I-QQ within Apper dix A of Standard No. 109. On July U 1978, and August 3. 1978. the RMA pe titloned for the addition of two ne; tire size designations to existing table within Table I of Appendix A of th standard. The bases for accepting o denying requests to add new tire siz, designations are set forth in Introduc tory guidelines to the appendix (Octo ber 5. 1963, 33 FR 149S4, as amendeMay 4. 1971. 36 FR 8298: July 22. 197: 38 FR 13601; and August 13. 1974, 3: FR 23980). The four new tire size dec lgnations requested to be added tc r--^"---~ i ~ fCDEKAU etGlSTt.(vOt_|434 NOi 23^1-WUnOaVI PtC^Biai e.ilVTat^ monteiio 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 March 29, 1979 013735 Mr. Robert Moseley Safety and Environmental Control Petroleum & Minerals Group Dresser Industries, Inc. P. 0. Box 6504 Houston, Texas 77005 Dear Rob: We have received an updated report from Union Carbide on the proposed DOT asbestos regulations. Copies of relevant information are enclosed for your use. Union Carbide will be keeping us informed as the issue develops, and of course we'll be doing the same with you. Best personal regards, M0NTELL0, INC. Kenneth N. Campbell KNC:kb Enclosure monteBo 6106 EAST 32N0 PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-645-2396 March 29, 1979 013786 Mr. W. B. Kirkland Baroid Petroleum Services Div. NL Industries, Inc. P. 0. Box 1675 Houston, Texas 77001 Dear Mr. Kirkland: We have received an updated report from Union Carbide on the proposed DOT asbestos regulations. Copies of relevant information are enclosed for your use. Union Carbide will be keeping us informed as the issue develops, and of course we'll be doing the same with you. Best personal regards, MONTELLO, INC. Kenneth N. Campbell KNC:kb Enclosure Baroid _ . Petroleum Services January 10, 1979 013787 Montello, Inc. Attn: Mr. Kenneth Campbell 6101 E. 32nd Place Tulsa, Oklahoma 74135 Re: Transportation of Asbestos- Visbestos Dear Ken, Beginning May 1st 1979 Asbestos Fiber in the form we sell as Visbestos will be classified as a hazardous material for transportation purposes. Because of this, extreme measures must be taken in both the packaging and shipping of Visbestos to be in compliance with the Federal Regulations. Please furnish us information including photographs of packaging, both individual bags and palletized or unitized units to be shipped to us, indicating the required markings of proper shipping name and hazardous classification as required in the regulations. Also furnish us in your letter a statement to indicate that you comply with the regulations as stated. Your prompt reply will be appreciated. Yours very truly. Director of Purchases WBK:sa Baroid Petroleum Services Divlsion/NL Industries, Inc. P.O. Box 1675, Houston, Texas 77001 Tel. (713) 527-1100 Cable Address: Baroid-Houston Iflontello 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-645-2396 013788 August 24, 1979 Ms. Arlene Schaefer Milchem, Inc. P. 0. Box 22111 Houston, Texas 77027 Dear Arlene: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards, MONTELLO, INC. ' Kenneth N. Campbell KNC/jd Enc. (1) monteHo 6106 EAST 32NO PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013789 August 24, 1979 Mr. Howard Sutter Baroid Division N. L. Industries P. 0. Box 1675 Houston, Texas 77001 Dear Howard: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make ' compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards, M0NTELL0, INC. ` Kenneth N. Campbell KNC/jd Enc. (1) montello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 August 24, 1979 013790 Mr. Tom Stacy IMCO Services P. 0. Box 22605 Houston, Texas 77027 Dear Tom: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards. MONTELLO, INC. Kenneth N. Campbell KNC/jd Enc. (1) 4" montello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013791 August 24, 1979 Mr. A1 Pinkerton GH-Gufco 5005 Riverway Suite 100 Houston, Texas 77056 Dear Al: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of . small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make ' compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards, MONTELLO, INC. ' Kenneth N. Campbell KNC/jd Enc. (1) & montello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013792 August 24, 1979 Mr. Robert Moseley Petroleum S Minerals Group Dresser Industries, Inc. P. 0. Box 6504 Houston, Texas 77005 Dear Rob: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of . small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make ' compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards, MONTELLO, INC. ' Kenneth N. Campbell KNC/jd Enc. (1) monteiio 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013793 August 24, 1979 Mr. John Bracken Oil Base Incorporated 3625 S. W. Freeway Houston, Texas 77027 Dear John: Please refer to our letter of August 7th concerning the new DOT regulations on shipments of asbestos. In particular, please refer to the last paragraph on the first page, which mentions the petition filed by Union Carbide. They have been successful on both issues. On Super Visbestos shipped prior to August 20th, the regulations do not apply until December 31, 1979. Final regulations also allow for the shipment of . small quantities in fiberboard or wooden boxes, as requested. In addition, the DOT has reinstated the exemption of private carriers from the palletizing and unitizing requirements. This is certainly a welcome inclusion. For your files, we have enclosed a copy of the regs as printed in the August 16, 1979 Federal Register. We sincerely hope the regs won't impose any undue burden on our customers. As stated earlier, we began shipping in dust and sift proof bags before August 20th. This should make compliance simpler. Please contact us if you have any ques tions, or whenever we can be of further service. Best regards, MONTELL0, INC. ' Kenneth N. Campbell KNC/jd Enc. (1) fllontello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013794 August 7, 1979 Mr. John Bracken Oil Base Incorporated 3625 S. W. Freeway Houston, Texas 77027 Dear John; New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) Rigid, airtight packagings such as metal or fiber drums, portable tanks; (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or (3) Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. John Bracken August 7, 1979 Page 2: 013795 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 arid 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC, Kenneth N. Campbell KNC/jd montello 6106 EAST 32ND PLACE TULSA. OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013796 August 7, 1979 Mr. Robert Moseley Petroleum S Minerals Group Dresser Industries, Inc. P. 0. Box 6504 Houston, Texas 77005 Dear Rob: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) Rigid, airtight packagings such as metal or fiber drums, portable tanks; (2) Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or (3) Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. Robert Moseley August 7, 1979 Page 2: 013797 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd montello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013798 August 7, 1979 Hr. A1 Pinkerton GH-Gufco 5005 Riverway Suite 100 Houston, Texas 77056 Dear Al: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) (2) (3) Rigid, airtight packagings such as metal or fiber drums, portable tanks; Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS . ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. A1 Pinkerton August 7, 1979 Page 2: 013799 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (.transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd ITlontello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013800 August 7, 1979 Hr. Tom Stacy IMCO Services P. 0. Box 22605 Houston, Texas 77027 Dear Tom: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) (2) (3) Rigid, airtight packagings such as metal or fiber drums, portable tanks; Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. Tom Stacy August 7, 1979 Page 2: 013801 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd Ifiontello..... 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74136 (918) 665-1170 / TWX 910-845-2396 ^ August 7, 1979 Mr. Howard Sutter Baroid Division N L Industries P. 0. Box 1675 Houston, Texas 77001 Dear Howard: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) (2) (3) Rigid, airtight packagings such as metal or fiber drums, portable tanks; Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Mr. Howard Sutter August 7, 1979 Page 2: 013803 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd montello 6106 EAST 32ND PLACE TULSA, OKLAHOMA 74135 (918) 665-1170 / TWX 910-845-2396 013804 August 7, 1979 Ms. Arlene Schaefer Milchem, Inc. P. 0. Box 22111 Houston, Texas 77027 Dear Arlene: New DOT regulations affecting the packaging and transportation of asbestos in the U.S. will become effective August 20, 1979. The Super Visbestos which we supply you will be subject to these regulations. We suggest that you become familiar with the regula tions, and especially with the following provision: 173.1090(d) Commercial asbestos must be offered for transpor tation and transported in - (1) (2) (3) Rigid, airtight packagings such as metal or fiber drums, portable tanks; Bags or other non-rigid packagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or Bags or other non-rigid packagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrap ping in plastic film or wrapping in fiberboard secured by strapping. Beginning immediately all Super Visbestos shipped to you will be in dust and sift proof bags. This is being accomplished by double shrink filming each bag, at no additional cost to you. In addi tion, palletizing and unitizing with shrink wrap will be available at our cost of $15.00 per ton. All bags will be marked "ASBESTOS ORM-C", as provided in the regulations. Realizing that field inventories of previously purchased Super Visbestos may be on hand August 20th, our manufacturer Union Carbide has petitioned the DOT for an extension of the effective date to October 1, 1979, on all such previously purchased mater ial. Included in that petition is a request for DOT approval on the use of cardboard boxes as an alternate to palletizing and Ms. Arlene Schaefer August 7, 1979 Page 2: 013805 unitizing. (It is felt that the latter can offer somewhat greater flexibility in the handling of small lots between field locations.) We are informed that there is good reason to expect DOT approval of the petition, and we will contact you as soon as we are noti fied. Finally, we will call your attention to paragraphs 174.840 and 177.844, which read essentially the same, as follows: Asbestos must be loaded, handled, and unloaded, and any asbestos contamination of rail cars (transport vehicles) removed, in a manner that will minimize oc cupational exposure to airborne asbestos particles released incident to transportation. Please let us know if you have need of any further information on this subject. We will do our best to cooperate in every pos sible way. Sincerely, MONTELLO, INC. Kenneth N. Campbell KNC/jd 56664 ......... RULES AND REGULATIONS 013806 Q [4910-60-M] the MTB. All submissions, including transportation during the year (or Title 49--Tramportafion late submissions, that were received on out of a thousand) and If on the ave the proposal were fully considered by age 1 percent of the contents of th CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DE PARTMENT OF TRANSPORTATION tDocket No. HIM-160; Arndt. Nos. 172-47. the MTB in the development of this final rule. Need To Regulate the Transportation op Asbestos bags so damaged were released, tl total amount of asbestos released pyear would equal about 7.5 tons. The calculations give a general idea of tl magnitude of asbestos fiber th 173-123. 174-33. 175-7.176-6. 177-44] Several commenters felt that the would be released, given a 99.9 percer TRANSPORTATION OF ASBESTOS Miscellaneous Amendment AGENCY: Materials Transportation Bureau. Research and Special Pro grams Administration,'DOT. ACTION: Pinal Rule. MTB had failed to establish a need to regulate the transportation of asbes tos. One of the commenters suggested that there was no need for the pro posed regulatory control of asbestos in transportation because the 'methods and procedures now in use for the packaging and transport of asbestos meet the requirements of Part 173. efficiency factor for "bag integrity" transportation, and a 99.0 percent ef: ciency factor in minimizing tl amount of asbestos released given tear in the bag. The rather evide: fact that asbestos has been accidents ly released during transportation hi not been contradicted by anythir submitted to the public docket on th SUMMARY: These amendments re 24(A)(sic) of the Transportation Act, rulemaking action. One commence quire shipments of commercial asbes that is under conditions normally in for example, in discussing the use < tos fibers to be packaged in rigid, air cident to transportation there will be open-bed trailers with side racks ar. tight or dust and sift proof packag- no significant release of the hazardous tarpaulins to transport asbestos state ings. Except when the shipment is by materials to the environment' and 'the that there is no evidence that the vu private carrier, non-rigid packages, effectiveness of the packaging will not of such trailers "has contributed t such as bags, must be palletized and be substantially reduced <t)he bag breakage and the release of ai unitized using shrink-wrapping or proposal contains no documentation to borne concentrations of asbestc strapped fiberboard wrapping. These justify additional regulation." This fiber." The Asbestos Information A. amendments represent minimum commenter, while apparently believing sociation. an incorporated nonprof safety requirements and are intended that asbestos is a hazardous material, organization representing 51 firms i to reduce the risks to the public was incorrect in suggesting that asbes the United States and Canada engage health associated with the generation tos is currently regulated by the MTB: in the manufacture or processing c of airborne concentrations of asbestos or in suggesting that the purpose of asbestos-containing products and th that may result from the packaging Notice 78-3 was to justify the addition mining/milling of asbestos fiber- and handling of asbestos fiber ship al regulation by the MTB of asbestos stated that with "the very larg ments in commercial transportation. In transportation. The transportation volume of asbestos shipped, occasions EFFECTIVE DATE: These regula- Mmsare^ffectiveA^ of asbestos is not now regulated by the MTB. It was precisely the purpose of Notice 78-3 that it should be. If, as the container damage may occur." Although several commenters win discussed this matter do not content ADDRESS: All written comments re commenter suggests, the transporta that asbestos has not been released ii ceived in this rulemaking action are tion of asbestos is now "in compliance transportation, they generally are o available for examination during regu with pertinent provisions of the Trans the view that the amounts that ar lar business hours in the Dockets portation Act." this rulemaking action being released are not significant or o Branch. Room 6500. Trans Point will formalize and insure in a uniform a sufficient amount to pose an unrea Building, 2100 Second Street SW., and systematic manner that this is the sonable risk to public health. Th Washington, D.C. case. MTB does not agree: it believes tha FOR FURTHER INFORMATION CONTACT: Douglas A. Crockett, Standards Divi sion. Materials Transportation Bureau, Research and Special Pro grams Administration. 2100 Second Street SW.. Washington. D.C. 20590, phone 202-426-2075. Another commenter stated that Notice 73-8 did "not establish a foun dation for regulation, in that it does not document, or even allege for that matter, the actual release of fiber during the transportation of asbestos." As was pointed out in Notice 78-3, the MTB has "no detailed information on the amount of asbestos fibers released the amounts of asbestos fibers tha are being released now, or would be re leased in the future, in the absence o these amendments, may pose an un reasonable risk to health. Several commenters were concerned with the statement appearing ir Notice 78-3 that "asbestos in its sever al commercial forms, poses serious SUPPLEMENTARY INFORMATION: during transportation." The MTB does health hazards to individuals subject On March 2, 1978, a notice of proposed not now regulate asbestos, and has not to long term exposure to airborne as rulemaking .(HM-I60; Notice 78-3) was therefore systematically collected acci bestos concentrations.". One com published in the Federal Register (43 dent data on the amounts of asbestos ' menter stated that "not all long-term FR 8562) stating that the MTB was released in transportation or data on exposures to airborne concentrations planning to exercise regulatory con the frequency of such accidents. Most pose any health hazards * * An trol over the transportation of asbes asbestos fiber, however, is currently other commenter suggested that the tos. Specific regulatory requirements shipped in bags, and it is undeniable statement needed "more explicit defi were proposed for the control of cer that these bags can and do break, or nition" and that "reference should tain forms of asbestos (e.g.. milled or can be and are being torn or punc have been made to unanswered ques crude asbestos fibers). No require tured, with a consequent release of tions within the scientific community ments were proposed for asbestos some or all of the bag contents. It can concerning mineral type, fiber size and fibers which are immersed or fixed in be speculated, moreover, that if all of smoking in the asbestos-cancer rela a natural or artificial binder material, the 750,000 tons of asbestos annually tionship." One commenter stated that or for manufactured products contain shipped in the United States were there is a dose-response relationship ing asbestos. Interested persons were packaged in. as one commenter states, between exposure to asbestos and dis invited to participate in the rulemak the "standard package" of a 100-pound ease causation, and that this conclu ing proceeding through submission of bag*, and if as little as one-tenth of one sion is supported by an OSHA state written comments on the proposal to percent of these bags were damaged in ment from its June 7, 1972 preamble FEDERAL REGISTER, VOL 43, NO. 233--MONOAY, DECEMBER 4, 197$ 013807 (P tytfS AND REGULATIONS to Its standard for exposure to asbes tos dust (37 FR 11318). The OSHA statement Is that: "No one has disput ed that exposure to asbestos of high enough intensity and long enough du ration is causally related to asbestosis and cancers" (emphasis added). Al though the MTB had also quoted this statement in Notice 78-3, the words underlined for emphasis had been in advertently omitted. Under these cir cumstances. some commenters appar ently felt that the MTB was asserting the view that because, according to some commenters. asbestos is ubiqui tous, long term exposure to ambient levels of asbestos fibers poses serious health hazards to all people, without regard to their occupational or paraoccupational status. It was not the in tention of the MTB to assert this view. That there are or can be "undisputed grave consequence? from exposure to asbestos" (37 FR 11318) does not depend on the questioned conclusive ness of the evidence reported by OSHA (40 FR 476S2) regarding the po tential health hazards posed by lowlevel, brief or intermittent exposure to asbestos. The MTB relies on the fore going Federal Register references for the general view that exposure to as bestos may pose an unreasonable risk to the public. Section 173.1090(a) and (b) Several commenters stated that there are certain mineral ores, ore con centrates and milled mineral products which may have trace amounts of as bestos, or minor amounts of asbestos occurring as contaminants. They sug gested that these materials presented no-risk to property and little, if any, risk to public health and safety in transportation. Moreover, since the packaging requirements proposed in Notice 78-3 applied to only certain kinds of asbestos, namely milled or crude asbestos fibers produced by an asbestos mill, they further suggested that only "commercial asbestos fibers" be defined as a hazardous material. The MTB recognizes that there are certain mineral ores, ore concentrates and milled mineral products, as well as other products, that contain certain amounts of asbestos, and that the commercial value of these minerals or products is not dependent on their as bestos content. The specific require ments in these amendments for the control of asbestos fibers in transpor tation do not apply to such materials or products, nor do they apply to as bestos as a waste product' or as a con- Under Docket HM-145A (43 FR 22626. May 25. 1978). new standards and proce dures were proposed for the transportation of hazardous waste materials. That proposal would Include waste asbestos if so identified by EFA under Section 3001 of the Solid Waste Disposal Act as amended by the Re- taminatlng trace element. The amend ments apply only to asbestos in its several commercial forms since it is those forms of asbestos that have been firmly established as posing serious health hazards to individuals. A new paragraph has been added which would define commercial asbestos as any material or product containing as bestos that has commercial value be cause of its asbestos content, and ap propriate modifications have been made in the amendments to reflect this clarification. This new paragraph is identified in this amendment as paragraph (b) (paragraphs (b) and (c) in the notice are now paragraphs (c) and (d), respectively). One commenter recommended that the scope of Notice 78-3 be amended to include, in addition to asbestos fibers, "all mineral and man-made (fibers) which have been identified by U.S. Government agencies as being carcinogenic and which may pose seri ous health risk." On December 9, 1976, the MTB published an Advance Notice of Proposed Rulemaking (41 FR 53824) in Docket No. HM-145 entitled "Environmental and Health Effects Materials." In that Notice, the MTB announced that it was considering whether new or additional transporta tion controls are necessary for certain classes of materials which are not gen erally subject to the existing Hazard ous Materials Regulations. The ques tion of whether all mineral and man made fibers, which have been identic fied by U.S. Government agencies as -being carcinogenic and which pose an unreasonable risk to public health, should be controlled in transportation will be considered.in terms of the fur ther development and resolution of the issues associated with Docket HM145. Notice 78-3 however, pointed out that a large number of comments were received in Docket HM-145, and that a considerable amount of staff evalua tion of these comments was still re quired before it would be possible to issue a notice or notices of proposed rulemaking for environmental and health effects materials, either on a comprehensive or on a selective basis. Section 173.1090(c)(1) Several commenters objected to the reference made to metal or fiber drums to illustrate the rigid packaging alternative for asbestos fibers. These commenters stated that the asbestos industry has not developed the tech nology to use this type of packaging alternative; that available technology is not transferable to the use of metal or fiber drums; and that, among other things, the use of this alternative could generate far greater airborne concentrations of asbestos than pack- source ConservaUon and Recovery Act (Pub. L.JM-580). aging and shipping practices currently in effect. As one commenter pointed out: Commercial asbestos ia fluffy. It is diffl- culLto pack this material in a rigid contain er. and. because the fiber would gradually compact during shipment, it would be diffi cult to remove it for Introduction into the manufacturing process, it would also be ex tremely cumbersome, if not Impossible, to empty rigid containers effectively and rapid ly into hoods designed for bags. Spillage would no doubt occur and workers would be unnecessarily exposed to fibers. ' Another commenter recommended that a DOT Specification 56 portable tank be included in the amended rule as an acceptable package "for the transportation of asbestos-type prod ucts." This commenter stated that "with the use of equipment designed for the purpose, the D.O.T. 56 package can be readily filled or emptied with out release of any product dust to the atmosphere or contact with the prod uct by the operator." Another com menter insisted that only metal drums and not fiber drums were acceptable for the transportation of asbestos fibers. These commenters apparently lost sight of the fact that proposed 173.1090(cXl) does not "mandate," as one commenter suggested, or even en courage the use of rigid, airtight pack aging such as metal or fiber drums or even portable tanks. It provides an al ternative method of shipping commer cial asbestos fibers. As was indicated in Notice 78-3, the MTB believes that its proposed non-specification packaging standards as applied to the transporta tion of commercial asbestos is an ef fective and efficient means of preclud ing potential problems associated with asbestos airborne emissions occurring during transportation; and that they are consistent with the standards of the EPA and the OSHA. Some of the commenters however were also appar ently unaware that the transportation standards for the control of asbestos are designed to be comprehensive in nature such that, once the standards are promulgated, commercial asbestos cannot be packaged and transported in any matter not specified in the amend ments. If under more advanced tech nology the use of rigid, airtight pack aging would lessen the likelihood of airborne asbestos emissions associated with bag breakages under current in dustry wide non-uniform non-standardized packaging practices, then it is necessary that alternative transporta tion standards be available so as not to preclude the development and utiliza tion of such technology. Although the public record on Notice 78-3 contains statements that the asbestos industry is seeking to improve the technology involved in the shipment and handling of commercial asbestos so as to mini mize the possibility for the accidental release of such asbestos Incident to FEDERAl REGISTER, VOL 43, NO. 233-MONDAY, DECEMSER 4, 197* / 013808 @ 56666 RUIES AND REGULATIONS transportation, it is by no means cer tain that the pace of such technologi cal improvements is rapid enough or that the best, economically feasible technology is being considered. How ever. the classification of asbestos as an ORM-C will, for the first time, re 'quire the submission of incident re ports to the MTB by carriers of any unintentional release of asbestos during transportation, and enable the MTB to monitor the safety perform ance record associated not only with the transportation alternatives availa ble under current technology as pro vided for by these amendments, but also with any improvements in that technology. For these reasons, the substance of proposed 173.1090(c)(1) is being re tained but modified to reflect an even broader range of permissible rigid, air tight packaging alternatives. This sec tion now is identified in this amend ment as $ 173.1090(d)(1) because of the addition of new paragraph (b). Section 173.1090(c)(2) Proposed paragraph (cX2) of Notice 78-3 covered the transportation alter native of shipping commercial asbestos in bags when in closed freight contain ers, motor vehicles,- or rail cars that were loaded by the consignor and un loaded by the consignee/ Several com mented noted that, unless reliance was placed on using the rigid, airtight packaging alternative provided in the proposal, this alternative would pre clude the shipment of asbestos fibers by open-bed trailers. One commenter noted that there is "no evidence ta in dicate that the use of open-bed traders with side racks and tarpaulins has con tributed to bag breakage and the re lease of airborne concentrations of as bestos fiber." Another commenter noted that the type of bag permitted by proposed paragraph (c)(2) was not specified, and that the shipper could package asbestos in burlap bags, or very thin paper or polyethylene bags which could permit asbestos fibers to be easily released into the air during transit. Another commenter was con cerned with "small volume users of as bestos and customers who, from time to time, require sample shipments for trial production runs of a few hundred pounds," and who under } 173.1090(c)(2) would be forced to ac quire the exclusive use of a railcar or highway trailer; or rely on the alterna tive provided by 5 173.1090(c)(1). Given the lack of detailed data on the amount of asbestos fibers released In transportation and the circum stances and causes for such release, the MTB is in general agreement with the thrust of these comments; accord ingly, a new paragraph (d)(2) recog nizes less restrictive handling of bagged asbestos than was proposed. Sections 174.840.175.640,176.906. 177.844 in these Sections, Notice 78-3 had proposed that, incident to its transpor tation, asbestos must be- loaded, han dled. and any asbestos contamination removed, in a manner that will prevent occupational exposure to airborne as bestos particles (emphasis added). Some commenters objected to the word "prevent," believing that this word was intended to mean completely precluding the possibility of an acci dent occurring in which asbestos fibers would be released; or completely iso lating people involved in the transpor tation. loading and unloading of asbes tos from exposure to asbestos fibers from whatever source such fibers were generated. One commenter pointed out that with "the very large volume 'of asbestos shipped, occasional con tainer damage may occur." Another commenter pointed out, although in a somewhat contradictory fashion, that since "asbestos is ubiquitous," there fore "airborne levels of asbestos fibers can be present in any place of employ ment. regardless of whether or not as bestos or products-containing known quantities of asbestos are handled" (emphasis added). The Asbestos Infor mation Association in its comments stated that "asbestos is ubiquitous, and there are no workplaces where there is zero occupational expotvre to asbestos ~ (original emphasis). If Notice 78-3 was not as clear as it might have been on this point, it is only necessary to say that the basic purpose of these amendments is to minimize the exposure to airborne as bestos particles accidentally released during or Incident to transportation; and appropriate changes to Parts 174, 175, 176, and 177 have been made to reflect this purpose. ORM-C Classification Notice 78-3 proposed that the classi fication for "asbestos" would be as an ORM-C. (Other Regulated Material, Group C). Several commenters were uncertain and concerned about the marking requirements associated with ORM-C classifications. One com menter noted that the designation ORM-C would "carry no meaningful warning to the person handling or opening the package." Another noted that the present regulations of the Oc cupational Safety and Health Admin istration (OSHA) on labeling require ments for asbestos convey much more information than an ORM-C marking requirement. These commenters were apparently not completely familiar with the marking requirements associ ated with ORM-C designated materi als. The ORM-C marking not only warns when a package contains haz ardous material, but it is also a certifi cation by the person offering the package for transportation that the material is properly described, classed, packaged, marked, and labeled (when appropriate) and in proper condition for transportation according to appli cable regulations of the Department. Neither function precludes or pre empts OSHA labeling requirements or creates "contradictory regulatory re quirements for labeling" as one com menter suggested. For these reasons, no changes have been made with re spect to any marking requirements for asbestos packages. Economic/Inflationary Impact In reviewing the potential economic and inflationary impacts associated with the final rule, the MTB has de termined that such impacts will be minimal. Based on the comments re ceived, and-the consequent modifica tion of Notice 78-3, the only economic costs associated with final amendment pertain to the reporting requirements to be submitted to MTB on the acci dental releases of commercial asbestos fibers during or incident to transporta tion. The absolute annual magnitude of these costs will be. of course, a func tion of the total number of incident reports that are submitted on acciden tal releases of asbestos fibers; but in view of the undisputed grave conse quences from exposure to asbestos fibers, these reporting requirements will not impose an unnecessary burden on the economy, on individuals, or on public and private organizations. In consideration of the foregoing. Title 49. Code of Federal Regulations. Parts 172, 173, 174, 175, 176, and 177 are amended as follows: PART 172--HAZARDOUS MATERIALS TABLE AND HAZARDOUS MATERI ALS COMMUNICATIONS REGULA TIONS 1. In { 172.101 the Hazardous Materi als Table is amended by adding a new entry, immediately following "Arsine." to read as follows: FHMHtAL kfOISTCR, VOC 43, NO. 233--MONDAY, DECEMBER 4, 1971 [49KM0-C] S 172.101 Hazardous materials table. (!) (2) / */ Hazardous materials descriptions U/ and proper shipping naaas a O) Hazard class I (Add) Aabcacoa ORM-C I I (*> Labcls(s) required (If not excepted) (5) Packaging. (a) <b> Specific Exception requlre- aenta Maximum net quantity In one package (a) Passenger carry ing aircraft or railcar (b) Cargo only aircraft (7) Water shlpaenta (a) (b) (c) Cargo vassal Pasanger vassal Other requirement None 173.1090 173.1090 (c) (d) No Limit No Limit 1. 2 .1 2 Stow and ' handle to avoid air borne particles. >oz o cr-- > -4 5 z FCOCHAl MOISTIg, VOL. 43, NO. 333--MONDAY, DCCtMMH 4, 1971 V o CO OO CO a-o3>> 013810 Department of Transportation final rule on the transportation of asbestos. Federal Register, Vol. 43, No. 233, p. 56664, Dec. 4, Kear (one the averits of the ased. the eased per ins. These lea of the ber that .9 percent egrtty" in rcerit effizing - the \ 1 given a ir evident ccldentalation has anything et on this'' unmenter. . he use of. racks and tos stated: U the useibuted to ' se of air- : asbestos; tation As-i nonprofit. I firms in.: a engaged jessing of and the' a fibers. ' try large Occasional .. .- Y iters who 0 contend blessed in (ly are of | that are cant or of \ an. unrea- - \ kith. -The '.1 (eves that! 1 ibers that ` juld be re- ' ibsence of ? te an un- toncemed | taring in i its severa serious Is subject ! 'borne as- ' be comlong-term (ntrations \" An i that the (licit defi le should (red ques- i immunity J tr size and j ncer rela- i :ated that iationship ! ;'i and dis- ! s conclu- : HA state- ! preamble r 56664 [4910-60-M] Title 49--Trantporfotion j~T. CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DE PARTMENT OF TRANSPORTATION (Docket No. HM-160: Arndt. Nos. 172-47. 173-123. 174-33. 175-7.175-5,177-441 TRANSPORTATION OF ASBESTOS Miscellaneous Amendment AGENCY: Materials Transportation Bureau. .Research and Special Pro grams Administration. DOT.. ACTION: Final Kule. SUMMARY: These amendments re quire shipments of commercial asbes tos fibers to be packaged in rigid, air tight or dust and sift proof packag ing. Except when the shipment is by private carrier, non-rigid packages, such as bags, must be palletized and unitized using shrink-wrapping, or strapped fiberboard wrapping.-These amendments represent minimum safety requirements and are intended to reduce the risks to the public health associated with the generation of airborne concentrations of asbestos that may result from the packaging and hand!Lag of asbestos fiber ship ments in commercial transportation. EFFECTIVE DATE: These regula tions are effective April 30.1979. ADDRESS: All written comments re ceived in this rulemaking action are available for examination during regu lar business hours in the Dockets Branch. Room 6500, .Trans Point Building. 2100 Second Street SW., Washington. D.C. FOR FURTHER INFORMATION CONTACT: Douglas A Crockett, Standards Divi sion, Materials Transportation Bureau. Research and Special Pro grams Administration, 2100 Second Street SW.. Washington, D.C. 20590. phone 202-426-2075. SUPPLEMENTARY INFORMATION: On March 2,'1978, a notice of proposed rulemaking (HM-160; Notice 78-3) was published in the Federal Register (43 FR 8562) stating that the MTB was planning to exercise regulatory con trol over the transportation of asbes tos. Specific regulatory requirements were proposed for the control of cer tain forms of asbestos (e.g.. milled or crude asbestos fibers). No require ments were proposed for asbestos fibers which are immersed or fixed in a natural or artificial binder material, or for manufactured products contaLning asbestos. Interested persons were invited to participate in the rulemak ing proceeding through submission of written comments on the proposal to RULES AND -REGULATIONS 013811 S . ' .4 . \r.:, the-MTB: All submissions, including transportation during: the year (one late submissions, that were received on out of a thousand) and if on the aver the proposal were fully considered by age 1 percent of the contents of the- the MTB in the development of this bags so damaged were released, the final rule. _ __ total amount of asbestos released per Need To Recgiate thz > --Transportation or Asbestos year would equal about 7.5 tons. The^e calculations give a general idea of the magnitude of asbestos fiber that Several commentera felt that the MTB had failed to establish a need to regulate the transportation of asbes tos. One of the commentera suggested that there- was no need for the pro posed regulatory control of asbestos in transportation because the "methods and procedures - now in use for the packaging,and transport of asbestos meet the requirements of Part 173. 24(AXsic) of the Transportation Act, that is 'under conditions normally in cident to transportation there will be no significant release of the hazardous materials to the environment' and `the effectiveness of the packaging will, not be substantially reduced * (t)he proposal contains no documentation to justify additional regulation." This commenter, while apparently believing that asbestos is a hazardous material, was incorrect in suggesting that asbes tos is currently regulated by the MTB: or in suggesting that the purpose of Notice 78-3 was to Justify the addition al regulation: by the MTB of asbestos in transportation: The transportation of asbestos is notnow regulated by the- would be released, given a 99.9 percent efficiency factor for "bag integrity" in transportation, and a 99.0 percent effi ciency factor la minimizing - the amount of asbestos released given a tear in. the bag. The rather evident fact that asbestos has been accidental ly released during transportation has not been contradicted .by anything submitted to the public docket on this'' rulemaking action. One commenter.. for example, in discussing the use oL. open-bed trailers with side tacks and. tarpaulins to transport asbestos stated:' that there is no evidence that the use- of such trailers "has contributed to: bag breakage ancT the release of air- borne concentrations of asbestos; fiber." The Asbestos Information As-i sociatlon. an incorporated nonprofit organization representing 51 firms in the United States and Canada engaged in the manufacture or processing of asbestos-containing products and the.' mirung/milling oL . asbestos fibers.: stated that with "the very large volume of asbestos shipped, occasional-, container damage may occur." - .-.> j MTB. It was precisely the purpose of Although'several commentera who Notice 78-3 that it should be. If, as the discussed this matter do not contend commenter suggests, the transporta that asbestos has not been released in tion of asbestos is now "in compliance transportation, they generally are of with pertinent provisions of the Trans the view that the amounts that are portation Act," this rulemaking action being released are not significant or of ] will formalize and insure in a uniform a sufficient amount'to pose an unrea- - i and systematic manner that this is the sonable risk to public health.-The-Yj case. . MTB does not agree; It believes thatl 1 Another commenter stated that Notice 73-8 did "not establish a foun dation for regulation, in that it does not document, or even allege for that matter, the actual release of fiber the amounts of asbestos fibers that < are being released now, or would be re- ` leased in the future, in the absence of j these amendments, may pose an tm- y* reasonable risk to health.. . j during the transportation of asbestos." Several commentera were concerned | As was pointed out in Notice 78-3, the MTB has "no detailed information on the amount of asbestos fibers released during transportation." The MTB does with the statement appearing in ; Notice 78-3 that "asbestos in its sever al commercial forms, poses serious ; health hazards to individuals subject i not now regulate asbestos, and has not to long term exposure to airborne as- ! therefore systematically collected acci bestos concentrations." One com- ; dent data on the amounts of asbestos menter stated that "not all long-term released in transportation or data on exposures to airborne concentrations ; the frequency of such accidents. Most pose any health hazards An asbestos fiber, however, is currently other commenter suggested that the shipped in bags, and it is undeniable statement needed "more explicit defi that these bags can and do break, or nition" and that "reference should can be and are being tom or punc have been made to unanswered ques- tured, with a consequent release of ' tions within the scientific community 1 some or all of the bag contents. It can concerning mineral type, fiber size and be speculated, moreover, that if all of smoking in the asbestos-cancer rela the 750,000 tons of asbestos annually tionship." One commenter stated that shipped in the United States were there is a dose-response relationship packaged in, as one commenter states, between exposure to asbestos and dis- ! the "standard package" of a 100-pound ease causation, and that this conclu- : bag; and if as little as one-tenth of one sion is supported by an OSHA state- 1 percent of these bags were damaged in ment from its June 7. 1972 preamble j FEDERAL REGISTER VOL 43, NO. 233--MONDAY, DECEMBER 4, 1978 RULES AND REGULATIONS 013812 56665 to its standard for exposure to asbes tos dust (37 FR 11318). The OSHA statement Is that: "No one has disput ed that exposure to asbestos of high enough intensity and long enough du ration is causally related to asbestosis and cancers" (emphasis added). Al though the MTB had also Quoted this statement in Notice 78-3, the words underlined for emphasis had been in advertently omitted. Under these cir cumstances, some commenters appar ently felt that the MTB was asserting the view that because, according to some commenters, asbestos is ubiqui tous. long term exposure to ambient levels of asbestos fibers poses serious health hazards to all people, without regard to their occupational or paraoccupational status. It was not the in tention of the MTB to assert this view. That there are or can be "undisputed grave consequences from exposure to asbestos" (37 FR 11318) does not depend on the questioned conclusive ness of the evidence reported by OSHA (40 FR 47652) regarding the po tential health hazards posed by lowlevel, brief or intermittent exposure to' asbestos. The MTB relies on the fore going Federal Register references for the general view that exposure to as bestos may pose an unreasonable risk to the public. Section 173.1080(a) and (b) Several commenters stated that there are certain mineral ores, ore con centrates and milled mineral products which may have trace amounts of as bestos. or minor amounts of asbestos occurring as contaminants. They sug gested that these materials presented no risk to property and little, if any. risk to public health and safety In transportation. Moreover, since the packaging requirements proposed in Notice 78-3 applied to only certain kinds of asbestos, namely milled or crude asbestos fibers produced by an asbestos mill, they further suggested that only "commercial asbestos fibers" be defined as a hazardous material. The MTB recognizes that there are certain mineral ores, ore concentrates and milled mineral products, as well as other products, that contain certain amounts of asbestos, and that the commercial value of these minerals or products Is not dependent on their asb.ios content. The specific require ments in these amendments for the control of asbestos fibers in transpor tation do not apply to such materials or products, nor do they apply to as bestos as a waste product * or as a con Older Docket ITM-145A <43 FR 22525. M?.y 25. 197S), new standards and proce dures were proposed for the transportation of hazardous waste materials. That proposal would Include waste asbestos if sc identified by EPA under Section 3C-9I of the Solid V/aste Disposal Act as amended by the Re- taminating trace element. The amend aging and shipping practices currently ments apply only to asbestos in its In effect. As one commenter pointed several commercial forms since It is out: those forms of asbestos that have been firmly established as posing serious health hazards to individuals. A new paragraph has been added which would define commercial asbestos as Commercial asbestos is huffy. It is diffi cult to pack this material in a rigid contain er. and. because the fiber would, gradually compact during shipment. It would be diffi cult to remove it for introduction into the any material or product containing as manufacturing process. It would also be ex bestos that has commercial value be tremely cumbersome, if r.ot impossible, to cause of its asbestos content, and ap propriate modifications have been made in the amendments to reflect this clarification. This new paragraph empty rigid containers effectively and rapid ly into hoods designed for bags. Spillage would no doubt occur and workers would be ' unnecessarily exposed to fibers. is identified in this amendment as Another commenter recommended paragraph (b) (paragraphs (b) and (c) that a DOT Specification 56 portable in the notice are now paragraphs (c) tank be included in the amended rule and (d). respectively). as an acceptable package "for the One commenter recommended that transportation of asbestos-type prod the scope of Notice 78-3 be amended ucts." This commenter stated that to include. In addition to asbestos "with the use of equipment designed fibers, "all mineral and man-made for the purpose, the D.O.T. 56 package (fibers) which have been identified by can be readily filled or emptied with U.S. Government agencies as being out release of any product dust to the carcinogenic and which may pose seri atmosphere or contact with the prod ous health risk." On December 9,1976, uct by the operator." Another com the MTB published an Advance Notice menter insisted that only metal drums of .Proposed Rulemaking (41 FR and not fiber drums were acceptable 53824) in Docket No. HM-145 entitled for the transportation of asbestos "Environmental and Health Effects fibers. These commenters apparently Materials." In that Notice, the MTB lost sight of the fact that proposed announced that it was considering 5 173.1090(c)(1) does not "mandate." as whether new or additional transporta one commenter suggested, or even en tion controls are necessary for certain courage the use of rigid, airtight pack classes of materials which are not gen aging such as metal or fiber drums or erally subject to the existing Hazard even portable tanks. It provides an al ous Materials Regulations. The ques ternative method of shipping commer tion of whether all mineral and man cial asbestos fibers. As was indicated in made fibers, which have been identi fied by US. Government agencies as Notice 78-3, the MTB believes that its proposed non-specification packaging being carcinogenic and which pose an unreasonable risk to public health, should be controlled in transportation will be considered in terms of the fur ther development and resolution of the issues associated with Docket HM145. Notice 78-3 however, pointed out thai a large number of comments were received in Docket HM-145. and that a considerable amount of staff evalua tion of these comments was still re quired before it would be possible to issue a notice or notices of proposed rulemaking for environmental and health effects materials, either on a comprehensive or on a selective basis. . standards as applied :o the transporta tion of commercial asbestos is an ef fective and efficient means of preclud ing potential problems associated with asbestos airborne emissions occurring during transportation; and that they are consistent with the standards of the EPA and the OSHA. Some of the commenters however were also appar ently unaware that the transportation standards for the control of asbestos are designed to be comprehensive in nature such that, once the standards are promulgated, commercial asbestos cannot be packaged and transported in any matter not specified in the amend Section 173.1090(c)(1) Several commenters objected to the reference made to metal or fiber drums to illustrate the rigid packaging alternative for asbestos fibers. These commenters stated that the asbestos industry has not developed the tech nology to use this type of packaging alternative; that available technology is not transferable to the use of metal or fiber drums; and that, among other things, the use of this alternative could generate far greater airborne concentrations of asbestos than pack- ments. If under more advanced tech nology the use of rigid, airtight pack aging would lessen the likelihood of airborne asbestos emissions associated with bag breakages under current in dustry wide pon-uniform non-standardized packaging practices, then it is necessary that alternative transporta tion standards be available so as not to preclude the development arid utiliza tion qf such .technology. Although the public record on Notice 78-3 contains statements that the asbestos industry is seeking to improve the technology involved in the shipment and handling of commercial asbestos so as to mini source Conservation and Recovery Act (Pub. mize the possibility for the accidental L. 94-580). release of such asbestos incident to FEDERAL REGISTER, VOL 43, NO. 233--MONDAY, DECEMBER 4, 1978 56666 transportation. It is by no means cer tain that the pace of such technologi cal improvements is rapid enough or that the best, economically feasible technology is being considered. How ever. the classification of asbestos as an ORM-C will, for the first time, re quire the submission of incident re ports to the MTB by carriers of any unintentional release of asbestos during transportation, and enable the MTB to monitor the safety perform ance record associated not only with the transportation alternatives availa ble under current technology as pro vided for by these amendments, but also with any Improvements in that technology. For these reasons, the substance of proposed 173.1090(0(1) is- being re tained but modified to reflect an even broader range of permissible rigid, air tight packaging alternatives. This sec tion now Is identified in this amend ment as 173.1090(d)(1) because of the addition of new paragraph (b). Section 173.1090(c)(2) Proposed paragraph (c)(2) of Notice 78-3 covered the transportation alter native of shipping commercial asbestos in bags when in closed freight contain ers. motor vehicles, or rail cars that were loaded by the consignor and un loaded by the consignee. Several commenters noted that, unless reliance was placed on using the rigid, airtight packaging alternative provided in the proposal, this alternative would pre clude the shipment of asbestos fibers by open-bed trailers. One commenter noted that there is "no evidence to in dicate that the use of open-bed trailers with side racks and tarpaulins has con tributed to bag breakage and the re lease of airborne concentrations of as bestos fiber." Another commenter noted that thd type of bag permitted by proposed paragraph (c)(2) was not specified, and that the shipper could package asbestos in burlap bags, or very thin paper or polyethylene bags which could permit asbestos fibers to be easily released into the air during transit. Another commenter was con cerned with "small volume users of as bestos and customers who, from time to time, require sample shipments for trial production runs of a few hundred pounds." and who under 173.1090(c)(2) would be forced to ac quire the exclusive use of a railcar or highway trailer, or rely on the alterna tive provided by 173.1090(c)(1). Given the lack of detailed data on the amount of asbestos fibers released in transportation and the circum RULES AND REGULATIONS stances and causes for such release, the MTB is In general agreement with the thrust of these comments; accord ingly. a new paragraph (d)(2) recog nizes less restrictive handling of bagged asbestos than was proposed. Sections 174.840, 175.640.176.906. 177.844 In these Sections. Notice 78-3 had proposed that, incident to its transpor tation, asbestos must be loaded, han dled, and any asbestos contamination removed. In a manner that will prevent occupational exposure to airborne as bestos particles (emphasis added). Some commenters objected to the word/prevent," believing that this word w as intended to mean completely precluding the possibility of an acci dent occurring in which asbestos fibers would be released; or completely iso lating people involved in the transpor tation. loading and unloading of asbes tos from exposure to asbestos fibers from whatever source such fibers were generated. One commenter pointed out that with "the very large volume of asbestos shipped, occasional con tainer damage may occur." Another commenter pointed out. although in a somewhat contradictory fashion, that since "asbestos is ubiquitous," there fore "airborne levels of asbestos fibers can be present in any place of employ ment, regardless of whether or not as bestos or products containing known quantities of asbestos are handled" (emphasis added). The Asbestos Infor mation Association In its commentsstated that "asbestos is ubiquitous, and there' are no workplaces where there is zero occupational exposure to asbestos" (original emphasis). If Notice 78-3 was not as clear as It might have been on this point, it is only necessary to say that the basic purpose of these amendments is to minimize the exposure to airborne as bestos particles accidentally released during or incident to transportation; and appropriate changes to Parts 174. 175, 176, and 177 have been made to reflect this purpose. ORM-C Classification Notice 78-3 proposed that the classi fication for "asbestos" would be as an ORM-C, (Other Regulated Material. Group C). Several commenters were uncertain and concerned about the marking requirements associated with ORM-C classifications. One commenter noted that the designation ORM-C would "carry no meaningful warning to the person handling or opening the package." Another noted that the present regulations of the Oc cupational Safety and Health Admin- lt -I 013813 1 istration (OSHA) on labeling require- ; ments for asbestos convey much more 1 information than an ORM-C marking j requirement. These commenters were apparently not completely familiar with the marking requirements associ ated with ORM-C designated materi als. The ORM-C marking not only warns when a package contains haz ardous material, but It is also a certiftcation by the person offering the package for transportation that the material is properly described, classed, packaged, marked, and labeled (when appropriate) and in proper condition for transportation according to appli cable regulations of the Department. Neither function precludes or pre erupts OSHA labeling requirements or . creates "contradictory' regulatory re- . quirements for labeling" as one commenter suggested. For these reasons, no changes have been made with re spect to any marking requirements for asbestos packages. Economic/Intl-mtonart Imfact . # \ <4 In reviewing the potential economic ; and inflationary impacts associated ! with the final rule, the MTB has de termined that such impacts will be minimal. Based on the comments re ceived, and the consequent modifica tion of Notice 78-3. the only economic costs associated with final amendment pertain to the reporting requirements to be submitted to MTB on the acci dental releases of commercial asbestos- fibers during or Incident to transporta tion. The absolute annual magnitude .; of these costs will be. of course, a func- j tion of the total number of incident reports that are submitted on acciden- . tal releases of asbestos fibers; but in view of the undisputed grave conse- > quences from exposure to asbestos fibers, these reporting requirements will not impose an unnecessary burden on the economy, on individuals, or on public and private organizations. ~ In consideration of the foregoing. Title 49. Code of Federal Regulations. Parts 172, 173. 174. 175. 176. and 177 are amended as follows; PART 172--HAZARDOUS MATERIALS TABLE AND HAZARDOUS MATSSUALS COMMUNICATIONS REGULATIONS j I j | l.tn 172.101 the Hazardous Materi als Table is amended by adding a new entry, immediately following "Arsine." to read as follows: EEDERAl REGISTER, VOL 43, NO. 233--MONDAY, DECEMBER 4, I97S S 172.I&1 Hazardous materials table. (1) (2) (3) / Hazardous satorlals descriptions U/ and proper shipping nance A Hazard elaoo (Add) Asbestos ORM-C (*) Lsbuls(s) required (If not axeoptad) (S) Packaging (a) <b) Specific Reception roqulro- acnts Kaxlatn net quantity In one package (a) Passenger carry ing aircraft or railcar <b> Cargo only aircraft (7) Water shlpnents (a) (b) (e) ' Cargo vessel Pti* engtr veuil Other requirement Nono 173.1090 173.1090 (c) (d) No Lllt No Unit 1. 2 1. 2 * Stow and ' handle to avoid air borne particles. , a \ c r* (ft oz ocr-- > oz * CO CO FEDERAL REGISTER, VOL. 43, NO. 333--MONDAY, DECEMBER 4, 197# W oC>D 0-45 56668 RULES AND REGULATIONS PART 173--SHIPPERS--GENERAL RE and unloaded, and any asbestos con QUIREMENTS FOR SHIPMENTS AND tamination of aircraft removed. In a PACSCAGINGS manner that will minimize occupation 2. Section 173.1090 Is added preced al exposure to airborne asbestos parti ing Subpan N to read as follows; . cles released Incident to transporta 3 173.1090 Ajbtitoi tion. (See 3173.1090 of this sub chapter.) (a) Asbestos includes any of the fol lowing * hydrated mineral silicates: chrysotile. crocidolite. amosite. anthophyllite asbestos, tremolite asbestos, PART 176--CARRIAGE BY VESSEL actinotite asbestos, and every product containing any of these minerals. 6.Section 175.906 is added to read as (b) Commercial asbestos is any mate follows: rial or product containing asbestos that has commercial value because of its asbestos content. 3 176.906 Stowage and handling of asbes tos. . ' (c) Asbestos which is immersed-of - - - Asbestos roust be stowed, handled, fixed in a natural or artificial binder and unloaded, and any asbestos con material (such as cement, plastic, as phalt. resins or mineral ore) and man ufactured products containing asbes tos or any materials, or products whose tamination of vessels removed, in a . manner that will minimize occupatlon. al exposure to airborne asbestos parti commercial value is not dependent on-r- cles * released1 incident * t<r transports- their asbestos content, are not subject- tion. (See 5173.1090 of this sub to the requirements of this sub* chapter.) chapter. - (d) Commercial asbestos must be of fered for transportation and trans ported in-- PART 177--CARRIAGE BY PUBLIC (1) Rigid, airtight packagtngs such as metal or fiber drums, portable tanks, or (2) Bags and other non-rigid packag HIGHWAY 7. Section 177.844 is added to read as follows: ' ings that are dust and sift proof. When transported by other than a pri vate carrier by highway, bags and other non-rigid packagings containing asbestos must be palletized and unitned by methods such as shrlrtk-wTap- 177.344 Other regulated materials. Asbestos must be loaded, handled, and unloaded, and any asbestos con tamination 'of transport vehicles re pir.g in plastic film or wrapping in- fl- moved. in a manner that will minimize berboard secured by strapping. occupational exposure to airborne as bestos particles released incident to PART 174--CARRIAGE BY RAIL 3. A Subpart M Heading is added im mediately following 3 174.812 to read as follows: transportation. (See 173.1090 of this subchapter.) (49 U.S.C. 1803. 1804. 1803; 49 CTR 1.53(e).) Note.--The Materials Transportation Suboart M--Detailed Requirements - Bureau has determined that these amend- for Other Regulated Materials meats do not require a regulatory analysis under the items of Executive Order 12044 4. Section 174.S40 is added to read as folls-vs: and DOT Implementing procedures (43 FR 8532). A regulatory evaluatioa Is available for review in the docket. 3 171.3*> Special Soaring and handling re quirements for asbestos. Issued in Washington, DC., on No Asbestos must be loaded, handled, vember 27. 1978. . and unloaded, and any asbestos con tamination of rail cars removed, in a manner that will minimize occupation al exposure to airborne asbestos parti cles released incident to transporta L. D. Santman, Director, Materials Transportation Bureau. (FR Doc.-73-33771 Filed 12-1-78; 8:45 am) tion. (See 3 173.1090 of this sub chapter.) PART 175--CARRIAGE BY AIRCRAFT 5. Section 175.540 is added to read as follows: 175.640 Special requirements for other regulated materials. Asbestos must be loaded, handled. 013816 Pertinent sections of the Department of Transportation's Hazardous Materials Regulations, Title 49, Code of Federal Regulations, Parts 171- _ _^ ....... . ' " ...............I immMmmmmi --i i-ii ! niwai 172. s a a >S. ;) ra a. a- ed in "ha la&V or tba aba ied up- dne s ta ratbi* RULES AND REGULATIONS 013817 12::K9 * ' chapter, the letters "ICC" may contlnue to be placed on any packaging requlring specification markings until Jan uary 1.1910. . (b) pack&giags with the specification lng in duplicate on DOT Form F 5803.1 * to tbe Department within 15 days of the date of discovery, each incident that oc curs during the course of transportation (Including loading, unloading, or tempo Sec. 172.446 172.448 172.450 MAGNETIZED MATERIAL label. CARGO AIRCRAFT ONLY labrl. EMPTY label. Subpart F--Placarding markings "ICC" placed thereon before - , ..January 1, 1970. may be continued In " service as marked. [Aset. 171-a, S3 PJR. 17818. Dec. 3, 18881 g 171.15 Immediate notice of certain . . huardooi material* incident*. rary storage) In which, as a direct result of the hazardous materials, any of the circumstances set forth in 1171.15(a) occurs or there has been an uninten tional release of hazardous materials from a package (including a tank). 172.500 172.502 172.504 172 506 172.508 Applicability of placarding require ments. . Prohibited placarding. General placarding requlren.enu ' Providing and affixing placard.-: highway. Providing and affixing placards: rT '(a) At the- earliest practicable moment, each carrier who transports (b) Each carrier making a report . ' ' rail. ' ' . under this section shall send that report 172.510 Special placarding provisions: rail. 172.512 . Freight container. hazardous materials shall give notice In to the Secretary, Hazardous Materials 172.514 Cargo tanks and portable tanks. . accordance with paragraph (b) of this Regulations Board. Department of 172.516 Visibility and display of placards section after each Incident that occurs during the course of transportation <ln- Transportation, Washington, D.C. 2C59C. 172.519 Genera! specifications for placards. 172.521 DANGEROUS placard. - .. eluding loading, unloading and temporary storage) In which as a direct result of hazardous materials-- 1 Arndt. 171-7. 85 FJR. 16837. Oct. 3. 18701 PART 172--HAZARDOUS MATERIALS 172.522 172.624 172.525 EXPLOSIVES A placard. EXPLOSIVES 3 placard. Standard requirements EMPTY placard. lor ti.e (1) A person is killed; TABLE AND HAZARDOUS MATERIALS 172.527 Background requirements for cer .. (2) A person receives Injuries requir- COMMUNICATIONS REGULATIONS tain placards on rail ccrs. . . lug his hospitalization; . ' (3) Estimated carrier or other prop ". " erty .damage exceeds $50,000; i'-* Fire, breakage, spillage, or sus pected radioactive contamination occurs ' involving shinment of radioactive mate.rial. (See also J5 174.588(c)U). 175.655 ! - . r.CJ) (3), and 177.861(a) of this chapter.); - :.v .--^-1(5) Fire, "breakage, spillage, or sus . *' : i pected contamination occurs Involving ^shipment of etiologic agents; or . 2 (6) A situation exists of such a nature . rthat, in the Judgment of the carrier, it 'should be reported in accordance with v paragraph (b) of this section even ^-though it does not meet the criteria of . paragraph (a) (1>',.(2). or (3) of this sec -tlon; e.g., a continuing danger cf life Sec. 172.1 Subpart A--General Purpose and scope. -. 172.528 NON-FLAMMABLE GAS placard 172.530 OXYGEN placard. 172.532 FLAMMA3LE GAS placard. 172.3 Applicability., Subpart B--Table of Hazardous Materials, Their Description. Proper Shipping Name. Claes, Label, Packaging, and Other Requirements 172.100 Purpose and use of tbe table. 172.101 Hazardous materials teble. 172.536 172.540 172.542 172.544 172.546 CHLORINE placard. POISON GAS placard. FLAMMABLE placard and modi','..- tlon. . ' * COMBUSTIBLE placard and modifi cation. - FLAMMABLE SOLID placard. Subpart C--Shipping Papers ' , 172.548 FLAMMABLE SOLID W placard. 172 ZOO 17JL201 172.202 172203 Applicability. - General entries. . Description of hazardous, material on shipping papers. Additional description require - 172.550 172.552 173.554 172.556 172.558 OXIDIZER placard. ORGANIC PEROXIDE placard. POISON placard. - RADIOACTIVE placard. CORROSIVE placard. ments.' Apfzkdix A--Specifications lor colors 172.204 Shipper's certification. "- AppEh-rcc B--Dimensional speciflcatlon for ' ' - Subpart D--Marking' placards. Appendix' C--Dimensional specifications for 172200' General martins requirements. - recommended placard holder. ,, .` exists at the scene of the incident. ` ' (b) Each notice required by paragraph ' (a) of this section shall be giver, the De- ' Apartment b~ telephone at Area Code --... ^.7,(202) 426-1830. Notice involving etiologic ' . ^agents may be given the Director, Center L ' t* for Disease Control. DA Public Health 172202 172.304 172 208 172208 172210 172212 172216 Export shipments by water. ~ . . Marking specifications. - . v AuTHoairr: 18 DSC. 834. 46 US.C. 170(7) Consignee's name and address. - ; ' 148 U.S.C. 1471, 1472(h)(1). 1807). 49 CFE Authorized abbreviations: - 1.53(e)-(h). , Radioactive materials. Acthoutt : 49 US C. 1803. 1804; -49 CFR Liquid hazardous materials. 1.53(e). Facksglngs containing material Effective Date Note: Jan. S, 1977. for elassed as ORM. - above ewebocicy eitaUon. -jt Service. Atlanta. Ga., Area Code (404) 172226 ;T: 833-5313, in place of the notice to the., 172228 . '.Department. Each notice must include 172230 ~ '. -\the following information: . Portable tanks. , Cargo tanks. '.' Tank cars. Subpsrt E--Labeling ' Source: AieiK. 172-29,41 PR 15996. Apr 55. - 1976, un>as otherwise noted. ~ Eptecitve .Date Note: . (1) Except as pic- vided la paragraphs (2) through (4), com . ' .Vv'ta (1) Name of reporter. ' r- 172.400 General labeling requirement*. pliance wish tb* pcovieions of this amend (2) Neme and address of. carrier rep-. 172.401 Prohibited labeling. - ment is sot mandatory until January 1. 1977. -- l-.xesentcd by reporter. ' 172.402 Additional labeling requirements. . (2) Compliance with the provisions of this .. v"I3) Phone number where reporter can 172.403 Radioactive material.' V \-~be contacted. - - * 172.404 Labels for mixed arid, consolidated V- b^r(4) Date, time, and location of lacl- v;d.enfc, ` - -- ' " , - packaging. 172.405 Authorized label modifications. 172.406 .Placement of labels. >v^.<5) The cxter.t of Injuries, if any. -' 172.407-.. label specifications. amendment pertaining to the Information required to appear esc a shipping paper or the format of a shipping paper. Is not mandatory until Jclr 1, :?77. (See note to 4S CIR 172.204(a) regarding delayed compliance with that section's required use of a netrly vn.-tfed (6) Classification, name, and quantity 172.411 EXPLOSIVE A. EXPLOSIVE B, AND shipper's certification.) .t- 'c~of hazardous materials involved, if such : EXPLOSIVE C labels. _ ' (3) A package filled, marked or labeled be L.- ^Information is available. .' - ^i-(7) Type of incident end nature of ; 5 hazardous material involvement and 172.415 '.-KON-FLAMMABLE GAS label. 172.416 POISON GAS label. 172.417 FLAMMABLE GAS label. 172.419 FLAMMABLE LIQUID label. fore July l, 1976. in accordance with regula tions in efiect on June *0.1976, may be ofiered for transportation and transported, even though it does not comply with the package, whether a continuing danger to life 172.420 FLAMMABLE SOLID label. marking and labeling ' provisions of . this r.. -exists at the scene. . 172.422 SPONTANEOUSLY OOUBUS7T3LS ^amendment, if it (I) fc; efiered for transporta r 7 . W-- (c) Each carrier making a report `.n under this section shall also make the iireport required by { 171.16. . ' 172.423 172.426 -172.427 label. . DANGEROUS WHEN WTT label. OXIDIZERlabel. ORGANIC PEROXIDE label. tion before July 1, 1977, and (11) compiles with the package, marking and labeling reg ulations in efiect on June SO, 197C. - Arndt. 171-7. 85 FJSL 16837,-Oct. 8. 1870. as 172.430- POISON label. (4) Compliance with the provisions ol this T. --.-ameaded by tod:. 171-13, 86 FR. 21201, 172.432 IRRITANT label. amendment appearing in Subpart F of Part ' ` i .'Nov. 4. 1871; toad-w 171-18, 88 PR 81C2, 172:436 RADIOACTIVE WHUTE-I label. .. 172 (Placarding) Is not mandatory until July w `. .. -`Mar.2*,OTSJ . . . v 172.438. RADIOACTIVE YELLOW-H label. - 1. 1977. , - : '? 171.16 Detailed hazardous materiali J; incident reports. . 172.440 RADIOACTIVE YELLOW-Ht label. . (5) Under the authority of any cf the pre 172.442 . CORROSIVE label. - ceding four numbered paragraphs: - 172.444' ETIOLOGIC AGENT label. ' (1) When a provision of this amendment (a) Each carrier who transports' -X- !e not complied with, the oompejvbie pro "hazardous materials shall report In writ- 1 Filed as part of the original document. vision (If any) of the regulations In effect t: FE3ERAI REGISTER, VOl. 41, NO. 168--MONDAY, SEPTEMBER 27, 1976 013818 RULES AND REGULATIONS 42419 , . must be entered either betp 'the awe of the class of the mate --ski or fonowiag the basic-description of Nor*.--Preprinted oertiScates complying with 49 era 173.430(a) In effect on June SO, 1078. may be used through Juno 30, 1979. After June 30, 1979, use of the cer be re-marked. This section does not apply to portable tanks, cargo tanks and tank cars. 'ta material In the car. tificate required by this section Is manda (Arndt. 173-29. 41 PH 15998. Apr. 13. 1978, m < j The shipping paper for each specl- tory. ' amended by Arndt. 173-29A. 41 PH 40678, Antuoa DOT 112A or 114A tank car rrttbost head shields) containing a Asmmable compressed gas must contain lnt notation. -DOT 112A- or "DOT jHA.- n* appropriate, and either "Must be handled in accordance with FRA E.O. Ka 5" or "Shore to rest per E.O. No. 5."-- <h> Transportation bp highway. Fol lowing the basic description for a haz ardous material In a specification MC 339 or MC 331 cargo tank made of cuenchod and tempered steel, there must be entered for-- .. (1) Anhdyrous ammonia. (1) The srords "0.2 per cent water" to Indicate the suitability for shipping anhydrous ammonia In the cargo tank as author ised by 1173.817 of this subchapter, or 1 The words "NOT FOR Q.AND T TAKES" when the anhydrous ammonia does not contain 0.2 per cent or more water-tar weight (b) Exceptions. No certification Is re Sept. 20.1976] quired for hazardous material offered for 172.302 Export shipments by water. transportation by highway that is trans ported--- . (1) In a cargo tank supplied by the carrier, or .. . (2) By the shipper as a private carrier except for a hazardous material that Is to be reshipped or transferred from one carrier to another. (c) Transportation by air--(1) Gen eral. Certification containing the follow ing language may be used in place of the certification required by paragraph (a) of this section: ' (a) Each package of hazardous mate rial offered for export by water and de scribed by a "n.o.s." entry in 1172.101 must have the technical name of the material added in parentheses iramedi- _ ately following the proper shipping name. For example: Corrosive liquid. n.ox. (Caprylyl chloride). . (b) For a mixture, only the technical name of any hazardous material giving a mixture its hazardous properties must be identified. ` 1 hereby certify that the contents of this consignment are fully and accurately de scribed above by proper-shipping name and [Arndt. 173-29. 41 FR 15998. Apr. 15. 1978. U mended by Arndt. 173-29A, 41 FH <0678, Sept. 20.1976] ' are classified, packed, marked end labeled, and in proper oondltlon for carriage by air according to applicable national govern mental regulations. 172.304 Marking specifications. (a) The marking"required in this subpart--(1) Must be durable, in English (2) liquefied petroleum gas. The word "Non-corrosive" or "Non-cor" to indicate the suitability for shipment of the "Kon- carroslre" liquefied petroleum gas of fered for transportation, by cargo tank as authorized by ) 173.315(a) (1) Note 15 of this subchapter. / (l)Transportation by water. (1) Each shipment by water must have the fol lowing additional shipping paper entries: * . ' ' (1)Identification of the typo of pack ages such as barrels, drums, cylinders, (2) Certificate in duplicate. Each per son who offers a hazardous material to an aircraft operator for transportation by air shall provide two copies of the cer tification required In this section. (See S 175.30 of this subchapter.) . (3) Passenger and cargo aircraft. Each person who offers for transportation by air a hazardous material authorized for air transportation shall add to the cer tification required in this section the fol lowing statement: .- and printed on or affixed to the surface of a package or on a label, tag, or sign. (2) Must be displayed on a background of sharply contrasting color; (3) Must be unobscured by labels or attachments; and (4) Must be located away from any other marking (such as advertising) that could substantially reduce Its effective ness. 172.306 Consignee** name and ad dress. .' and boxes,' This shipment Is within the Umltstlons (a) Each package containing a haz (ii) The number of each type of pack age Including those in a freight container prescribed for passenger slrcraft/csrgo-oaly aircraft (delete nonappllcable). ardous material offered for transporta tion must be marked with the name and or on a pallet, and - (4) Radioactive material. Each person address of the consignee or consignor (liD The gross weight of each type of who offers any radioactive material for except when the package is--(1) Trans package or the individual gross weight transportation aboard a passenger-car ported by highway and will not be trans of each package. . rying aircraft shall sign (mechanically ferred from one motor carrier to another; - (2) The shipping paper for a hazardous or manually) a printed certificate stating (2) Part of a carload lot, truckload lot, material offered for transportation by that the shipment contains radioactive or freight container loed, and the entire water to any country outside the United material Intended for use in. or Incident States must have In parenthesis the tech to, research, medical diagnosis or treat nical name of the material following the ment This requirement does not apply proper shipping name when the material to materials excepted under the provi is described by a "aos." entry In } 172. sions of S 175.10(a) (6) and (a) (8) of this 101. For Example: Corrosive liquid, n.oa. subchapter. . (caprylyl chloride). Corrosive material.* ' (d) Signature. The certifications re However, for a mixture, only the technl- ' quired by paragraph (a) or (c) of this cal name of any hazardous material giv section-- ing the mixture Its hazardous properties (1) Must be legibly signed by a prin must be identified. cipal, officer, partner, or employee of the contents of the rail car, truck or freight container ere tendered from one con signor to one consignee, or ** (3) A portable tank, cargo tank or tank car. (Arndt. 173-29, 41 FR 16998, Apr. 15. 1976, aa amended by Arndt. 173-29A, 41 FR 40878, Sept. 30,1978] .. 172.308 Authorized abbreviation*. (a) Abbreviations may not be used ex 172.204 Shipper's certification. (a)' General. Except as provided In paragraphs (b) and <c> of this section, each person who offers a hazardous ma terial for transportation shall certify that the material offered for transportation In accordance with this subchapter by printing (manually or mechanically) the following statement on the shipping paper containing the required shipping description: - Thia Is to certify that the above-named materials are properly classified. described, packaged, marked and labeled^ and are in proper condition for transportation accord ing to the applicable regulations of the De shipper or his agent; and (2) May be legibly signed manually, by typewriter, or by other mechanical means. ' Subpart D--Marking 172.300 General marking * require ' merits. Except as provided by this sub chapter, each person who offers a pack age containing a hazardous material for transportation shall mark the package with the proper shipping name required by 1172.101. However, when It has been determined by the shipper that,a package has been previously marked as required cept in the following instances--(1) For marking descriptions on ammunition, such as ammunition far cannon without projectiles, etc, the words "with" or "without" may be abbreviated as "W" or "W/O" for example: "ammunition for cannon W/O projectiles" (2) The abbreviation "ORM" may be used in place of the words "Other Regu- lated Materials." S 172.310 Radioactive materials. (a) In addition to any other markings required by this subpart, each package containing radioactive materials must be marked as follows: (1) Each package of partment of Transportation. . for the material It contains. It need not radioactive materials in excess of HO FEDERAL REGISTER, VOL 41, NO. 188--MONDAY, SEPTEMBER 27, 1976 I k*. 'r en-'^esenhsj,- V. - ^"^W-'". " ' ^v.K!^v,; .....;...."..'....-.r..c...S....?......'...... ,: Omi:9'K-5;^ : . .-;.?.* '^/'A i -"-vw-'' "'"iK* : ."'v' ^t^'~ 4122442200".:V":rV '-'? *UU$ AND. REGULATIONS "'V..'-. ?' *"o -.''*& * ': ! '', j pounds (50 kilograms)- must have Its aged In accordance with-the provisions These markings must be 2 inches (50.8 -- gross weight plainly and durably marked of 3173.6 of this subchapter. ^ ' mm.) or more In height and must be on the outside of the package. (6). ORM-D for an ORM-D otherthan placed near the specification identifies- - (2) Each package of radioactive mate that described in paragraph (a) (5) of tion plate. ... - . rials which conforms to the requirements this section. -- . - ... (d) A cargo- tank marked with the . for Type A or Type B packaging (1173. (b) When the ORM-D marking in name of .a. specific hazardous material. . 3S9(j) and (k) and 173.398(b) and <c> cluding the proper shipping name can may not be used to transport any other ' of this subchapter) must be plainly and not be affixed on the package surface, it material unless the marking Is removed. . durably marked on the outside of the may be on an attached tag. or changed to identify the hazardous ~ package in letters at least fe-inch (13 (c) The marking ORM-A. B. C. or D material.the cargo tank contains, which- i mm.) high, with the words "TYPE A" or is the certification by the person oCer- ever is appropriate. .. .-j . "TYPE B" as appropriate. A packaging which is . not is compliance, with these lng the package for transportation that the material is properly described, [Amdt. 173-29, 41 FR 15996. Apr. 15. 1978. as amended by Arndt. 172-29A. 41 FR 40678. 1 ~ requirements may not be so marked. - classed, packaged, marked, and labeled Sept. 20,1976] .. ' .. (3>- Each package of radioactive mate-' (when appropriate) and In proper con rial destined for export shipment must dition for transportation according to the 172.330 .Tankcars. also be marked "USA": in conjunction applicable regulations of the Department. (a) When-required to be marked, by i: with the specification marking, or other This form of certification does not pre Parts 173 or 179 of this subchapter, each -il package certificate identification. (See clude the requirement for .a certificate tank car used to transport a hazardous S3 173.393aand 173.393b of this subchap on a shipping paper when required by material most be marked as specified in .rsj ter.)-,. ' !,. ?y. . V~. 5 172.204. . ; ;.v- --- --..this subpart -with the--(1)-" Proper _ 9 172.312 -Liquid hazardons materials. [Arndt. 172-29. 41 FR 15996! Aprff5M97,'M ^"shipping name,or-.-. - ---rv.amended by Arndt. 172-29A. 41 FR 40678. (2X Common: name authorized .hi this (a) Except as provided in this section, Sept, 20.1976J .\ - . - . subchapter for the material such as "Re each package having artinside packag ing containing liquid hazardous mate 172.326 Portable tanks. '- ' : frigerantGas." . . (b) The letters in required -v markings-:,^ rials must be--(1) Packed with closures (a) A portable tank - containing a must be 4 inches (101.6 mm.) or more in Aij upward, and " hazardous material must be marked in height with at least a %-toch (15.9 s (2) Legibly marked `THIS SIDE UP^ lettering two Inches (50.8 mm.) or more mm.)-stroke." The separation between -s [ or "THIS END UP" as appropriate, to in height with the proper shipping name each letter must be at least **-incb <19 Q->4 f indicate the upward position of the in of the material. This marking must be mm.). .; - - - - -k:g | side packaging. - - : ' legibly displayed, as specified in this (c> The markings must be--(1> Af-r'4 I ' (b) Except as otherwise prescribed in part on two-opposing sides. ' fixed to both sides of the tank car; and' x j Part 173 of this subchapter cylinders of (b) A portable" tank marked with-the (2) Readily visible when viewed from"*? I ^liquefied compressed gas and specifica name of a specific hazardous material,. each side of the tank car. tion containers 6D, 37M, 37P, and 2 IP may not be used to transport any other <d) A tank car marked with the name ? ; are not required to be marked "THIS material unless the marking is removed, of a specific hazardous material may not SIDE UP" or `THIS END UP". (c> Arrows for purposes other than In dicating proper package orientation may . not be displayed on a package contain cr changed to identify th; hazardous material in the portable tank, whichever is appropriate. -. (c) The name of the owner, or when be used to transport any other material unless the marking is removed, or changed to identify the hazardous mi . teriai the tank car contains, whichever is 5 ing a hazardous material that is a liquid. appropriate, of the lessee, must be legi appropriate. - (1) An arrow symbol Indicating "This Way Up" as specified in ANSI MH8.1196g bly displayed on a portable'tank that contains a hazardous material. [Amdt. 173-29, 41 FR 15996, as amended by,g Amdt. 112-29A, 41 FR 40878, Sept. 20. 1976 entitled "Pictorial Marking for Handling [Arndt. 173-29, 41 FR 15996. Apr. 15, 1976. M of Goods" should be used In addition to amended by Amdt 172-29A. 41 FR 40578, . Subpart E--Labeling the marking required by this section and Sept. 20,19761 ^ -. . 172.400' Central Libeling i i require-*^ 1/ 3 173.25 of this subchapter. - [Arndt. 174-89. *1 PR 13995. Apr. 15. 1973. amended by Arndt. 172-29A. 41 FH 40675, Sept. 20,1978J ' 172.316 Packaging* containing ma terial classed as OiOL (a) Except as provided in 3 173.505 of this subchapter, each package contain ing a material classed as ORM-A, B, C, or D must be plainly and durably marked on at least one side or end with the ap propriate ORM designation immediately following or below the proper shipping name of the material. The appropriate ORM designation must be placed with in a rectangle that Is approximately V* Inch (6.3 mm.-) larger on each side than the designation. The appropriate desig nation for each ORM must be: (1) ORM-A for an ORM-A. 172.328 Cargo tanks. - - 'r - - (a) Required markings: Hazardous materials other than gases. When trans porting a hazardous material other than a compressed gas, a cargo tank required by Part 173 of this subchapter to be marked with the proper shipping name of the contents must be marked as speci fied in this part on each end and each side. (b) Required markings: gases. Each cargo tank transporting flammable or nonflammable compressed gas subject to this subchapter must be ' legibly -. ' menLit - . (a) Except as otherwise provided'jin? this subchapter. each person who offers a.? package, overpack, or freight containercontaining a hazardous material .for transportation shall label it, wherr-re^ quired, with labels prescribed for the ma-.terial as specified to } 172.101 and in acS cordance with this subpart. (b) A label is not required on a--' " . (1) Package for which labeling is not required under the conditions set forth in this subchapter and in this section;- -- (2) Cylinder containing a compressed gas classed as flammable or nonflamma marked In lettering two inches (50.8 ble that is--(i) Carried by a private.^ mm.) or more In height as specified in this Part on each end and each side contract motor carrier; r (ii) Not overpacked; and r-.SKjJ' -.r,, with-- ' (1) The Proper shipping name of the (iii) Durably and legibly marked. ^ accordance with CGA Pamphlet C~i- gas, or Appendix A. (2) ORM-B-KEEP DRY for an (2) An appropriate common name for (3) Military ammunition shipped by. ORM-B that Is a solid and Is corrosive the material such as "Refrigerant C-as." for, or to the U.S. Department of-~D^ only to aluminum when wet. <c) QT/NQT marking for XC 330 end tense (DOD) when to carload or true*' < 3) ORM-B for an ORM-B other than XC 331 cargo tanks. Each specification load shipments, if loaded and unleaded tiiat described In paragraph (a) (2) of MC 330 and MC 331 cargo tank must be by the shipper, or DOD. this section. appropriately marked "QT" or `NQT" to (4) Package containing a hazardo"' (4) ORM-C for an ORM-C. indicate it is constructed of quenched material other than ammunition .t^* (5) ORM-D-AIR for an ORM-D that and tempered steel (QT) or other than Is--(i) Loaded and unloaded undertce Is prepared for air shipment and pack quenched and tempered steel <N'QT>. super.ision of DOD personnel, and'.v FEDERAL SEGiSIER, VOl. 4i; NO. 16a--MONOAY, S5FTEM8E* 27, 1976 \.M .5 013820 DOT Form F 5800.1 Department of Transportation Incident Report Form 013821 DEPARTMENT OF TRANSPORTATION Form Approved OMB No. 04-5613 HAZARDOUS MATERIALS INCIDENT REPORT INSTRUCTIONS: Submit this report in duplicate to the Director, Office of Hazardous Materials Operations, Materials Transportation Bureau, Department of Transportation, Washington, D.C. 20590, (ATTN: Op. Div.). If space provided for any item is inadequate, complete that item under Section H, "Remarks1', keying to the entry number being completed. Copies of this form, in limited quantities, may be obtained from the Director, Office of Hazardous Materials Operations. Additional copies in this prescribed format may be reproduced and used, if on the same size and kind of paper. A INCIDENT 1. ty --pe of operation r.' i.1 ;___ ! AIR 2___j HIGHWAY 3[_JRAIL .------ , , ... rnciwn i ......... OTHER 4L_JwATER 5 [Z] FORWARDER 6____ (IdentHy)_ 2. DATE ANO TIME OF INCIDENT (Month - Day - Year) \ _a.m. p.m. 3. LOCATION OF INCIDENT REPORTING CARRIER, COMPANY OR INDIVIDUAL 4. FULL NAME S. ADDRESS (Number, Street, City, State end Zip Code) 6. TYPE OF VEHICLE OR FACILITY SHIPMENT INFORMATION 7. NAME ANO ADDRESS OF SHIPPER (Origin address) 8. NAME AND ADDRESS OF CONSIGNEE (Destinetion address) 9. SHIPPING PAPER IDENTIFICATION NO. 10. SHIPPING PAPERS ISSUED BY carrier .SHIPPER I I OTHER (I den ti fy) DEATHS, injuries, loss and damage DUE TO HAZARDOUS MATERIALS INVOLVED II. NUMBER PERSONS INJURED 12. NUMBER PERSONS KILLED 14. ESTIMATED TOTAL QUANTITY OF HAZARDOUS MATERIALS RELEASED 13. ESTIMATED AMOUNT OF LOSS ANO, OR PROPERTY DAMAGE INCLUDING COST OF DECONTAMINATION (Round oil in dollars) hazardous materials involved 15.HAZARO CLASS (`Sec. 172.101, Col. 3) 16. SHIPPING NAME (Sec. 172.101, Col. 2) 17. TRADE NAME nature of packaging failure10 10. (Check all applt cable boxes) ( I) DROPPED IN HANDLING (2) EXTERNAL PUNCTURE 13) DAMAGE BY OTHER FREIGHT (4' WATER DAMAGE (5) DAMAGE FROM OTHER LIQUID <6i FREEZING 171 EXTERNAL HEAT (8) INTERNAL PRESSURE 19: CORROSION OR RUST , 1n. DEFECTIVE FITTINGS, 1 VALVES. OR CLOSURES (HI LOOSE FITTINGS. VALVES OR CLOSURES (121 FAILURE OF INNER RECEPTACLES (13) BOTTOM FAILURE (14) BODY OR SIDE FAILURE ( 16) CHIME FAILURE (17) OTHER CONDITIONS (Identity) Form DOT F 5800.1 (10-70) (9/1/76) -Editorial change to incorporate redesignation per HM-112. I IS) WELD FAILURE 19. SPACE FOR DOT USE ONLY PACKAGING INFORMATION ft mote than one /* or type packaging / involved in loaa o( material show packafltnfl information aaparately tor each, If more apace ia needed, uae Section H "Remarka" below keying to the item number, " ITEM TYPE OF PACKAGING INCLUDING INNER 20 RECEPTACLES (Steal dtvma, wooden box, cylinder, etc.) CAPACITY OR WEIGHT PER UNIT 21 (SS tollono, SS lb,., ole.) *1 2 - Ufi X1 3822 NUMBER OF PACKAGES FROM WHICH 22 MATERIAL ESCAPED NUMBER OF PACKAGES OF SAME TYPE 23 IN SHIPMENT DOT SPECIFICATION NUMBER(S) ON 24 PACKAGES (21P. I7E. 3AA. etc., or none) SHOW ALL OTHER DOT PACKAGING 25 MARKINGS (Port 17,) 26 NAME. SYMBOL, OR REGISTRATION NUM BER OF PACKAGING MANUFACTURER SHOW SERIAL NUMBER OF CYLINDERS, 27 CARGO TANKS, TANK CARS. PORTABLE TANKS 28 TYPE DOT LABEL(S) APPLIED IF RECONDITIONED REGISTRATION A NO. OR SYMBOL 29 OR OATE OF LAST B TEST OF INSPEC REQUALIFIED, SHOW TION IF SHIPMENT IS UNDER DOT OR USCG 30 SPECIAL PERMIT OR EXEMPTION, ENTER PERMIT OR EXEMPTION NO. H REMARKS - Describe essential facts of incident including but not limited to defects, damage, probable cause, stowage, action taken at the time discovered, and action taken to prevent future incidents. Include any recommendations to improve packaging, handling, or transportation of hazardous materials. Photographs and diagrams should be submitted when necessary for clarification. 31. NAME OF PERSON PREPARING REPORT (Type or print) 33. TELEPHONE NO. fInclude Area Code) 32. SIGNATURE 34. DATE REPORT PREPARED Reverse of Form DOT F 5800.1 (10-70) ( NORTH AMERtCA ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway, Crystal Square 4, Suite 509 Arlington, Virginia 22202 (703) 979-1150 013823 Dockets Section Office of Hazardous Materials Department of Transportation Washington, D.C. 20590 Operations 1 May 1978 Gentlemen: Re: Notice of proposed rulemaking. Transportation of Asbestos; (Docket No. HM 160; Notice No. 78-3; FR Vol. 43, No. 42, March 2, 1978 " The Asbestos Information Association/North America (AIA/NA) invites the attention of the Department of Transportation to these comments submitted in accordance with the Federal Register notice of March 2, 1978. AIA/NA States ing of fiber. is an incorporated, nonprofit organization of 51 firms in the Unite and Canada (see attachment) engaged in the manufacture, or process asbestos-containing products and in the mining/milling of asbestos The AIA/NA was established in 1970 with the following objectives: - To provide industry-wide information on the asbestos- health relationship, and on industry efforts to eliminate problems associated with asbestos dust. . - To cooperate with government agencies in developing and implementing standards for worker protection from asbestc dust, and for the control of asbestos emissions into community air and water. - To exchange information on asbestos dust control methodol - To assist members in the solution of asbestos-health related problems. - To increase public knowledge of the benefits to be derive from and the importance of asbestos-containing products. INTRODUCTION Substantial changes in the packaging and shipping of asbestos fiber have been made over a period of more than ten years. Permeable bags such as those made of jute have been replaced with strong, multiwall kraft paper bags and film or woven plastic bags. Paper bags may be covered or lined with plastic as an added protective measure. Asbestos pellets and compres blocks which also control dust emission have been developed for certain ap plications. Both are enclosed in paper or plastic to further ensure that no dust emissions occur. Pellets may also be shipped in hopper cars. Page 2 013824 It is customary to package asbestos in bags containing 100 pounds of fiber. Manufacturers' formulae and handling procedures are generally based on incremental quantities of 100 pounds of fiber in bags. Paper bags are preferred in some manufacturing processes because the bag and its contents can be introduced into processing without adverse effect on the product and, by so doing, eliminate risk of fiber exposure. Bag opening machines have been designed to eliminate dust emissions during the introduction of fiber into the manufacturing process. In transportation of major asbestos shipments from mills, bags are stacked as unitized loads on pallets and the pallets are wrapped with plastic film. Glueing bag to bag and metal strapping may be used as a means to avoid shifting of pallet loads. Lumber and in flatable dunnage may be used between pallets in rail and truck transport. Bagged asbestos on pallets is transported in intermodal freight containers for marine shipment. Small-lot shipments of bags by truck from warehouses or other sources are common and may or may not be palletized depending on the number of bags trans ported. Tests have demonstrated both plastic and paper bags with stand transport and handling in this manner without unusual risk of breaking or tearing. The methods and procedures now in use for the packaging and trans port of asbestos meet the requirements of Part 173, 24 (A) of the Transportation Act, that is "under conditions normally incident to transportation there will be no significant release of the hazardous materials to the environment" and "the effectiveness of the packaging will not be substantially reduced." We submit there is no need for the proposed regulations on the basis that current practices and procedures for the transport of asbestos are in compliance with pertinent provisions Of the Transportation Act. The proposal contains no documentation to justify additional regulation. This is the position of this Association in response to the Department's proposal. j * We take this opportunity to offer a number of comments on specific areas of the proposal which we believe will be helpful to the Depart ment in its deliberations. A discussion follows: DISCUSSION I - Unreasonable Risk to the Public The Transportation Act of 1974 requires the finding of "an unreason able risk to the public" as the statutory basis for the promulgation of a regulation (49 U.S.C. 1803, 1804). The March 2, 1978, DOT Pro posal, addresses this issue in Part II startina with the following statement: ? "The MTB believes it to be firmly established that asbestos in its several commercial forms, poses ser ious health hazards to individuals subject to long term exposure to airborne asbestos concentrations. As noted in the 1972 preamble of the Occupational Page 3 013825 Safety and Health Administration (OSHA) standard on asbestos (37 FR 11318): "No one has disputed that exposure to asbestos of high enough duration is causally related to asbestosis and cancers."... Recent new evidence, however, as reported by OSHA, not only tends to confirm this finding but also suggests that serious potential health risks are involved with even relatively low-level, brief or intermittent exposure to airborne asbestosconcentrations." (Emphasis added) The claim that asbestos "...poses serious health hazards to indi viduals subject to long-term exposure to asbestos concentrations" requires more explicit definition Man has been exposed to nat urally occurring low concentrations of asbestos throughout his existence. Asbestos is common to the earth's crust. There are no known or identified health hazards from natural sources. DOT's statement, without identification of concentration, is not sub stantiated. The statement from the proposal discussed above was supported by an erroneous quotation from OSHA (37 FR 11318) "No one has disputed that exposure to asbestos of high enough duration is causally related to asbestosis and cancer." Key words relating to level exposure were omitted. should have read: The quotation "No one has disputed that exposure to asbestos of high enough intensity and long enough duration is causally related to asbestosis and cancers." (Underlined words were omitted) For more complete understanding of the problem, reference should have been made to unanswered questions within the scientific com munity concerning mineral type, fiber size, and smoking in the asbestos-cancer relationship. A reference is made to "recent new evidence" reported by OSHA which "also suggests" serious potential health risks from relatively low-level, brief, or intermittent exposure. AIA/NA provided comments to OSHA on this "new evidence" (copy attached) with the following conclusions: "Review of the literature indicated that no credible epidemiological studies have been published which would suggest an excess of malignant tumors among persons exposed to no more than 2 asbestos fibers per cc of air (TWA), using the prescribed membrane filter test method. This is a fact simply because there have yet been identified for study no populations the exposure experience of which consistently has been as low as 2 fibers. Page 4 013826 Since all populations studied to date have been exposed to substantially higher concen trations of airborne asbestos, we can conclude only that an excess of all types of asbestos disease is associated with levels of exposure significantly higher than the level currently mandated to become effective on July 1, 1976." That portion of the OSHA references cited in the proposal wherein worker exposure to asbestos dust is of sufficient duration and the cohort is of sufficient size to be valid for standards setting is based on the occupational situation where raw fiber is handled with regularity. In transportation, the fiber is contained in ' sealed bags. The only direct contact of a transport worker with free fiber would be in the event of an accident. The difference between these situations was not considered in the Department's proposal. This section of the preamble of the proposal concludes with the statement: "Although there is no detailed information available on the amount of asbestos fibers re leased in transportation, the MTB believes that, in consideration of the carcinogenic and other health hazards associated with asbestos, there is a sufficient basis for establishing regulatory control of asbestos in transportation.11 (Emphasis . added) From the statement that "..there is no detailed information available on the amount of asbestos fibers released in transportation.." and the fact that inaccurate and disputed information, as noted above, was used in the development of the proposal,we contend that sufficient evidence to meet the statutory requirement of the finding of "unrea sonable risk" needed to promulgate a regulation has not been present ed. > II - Rigid, Airtight Packages to Transport Asbestos Bagged asbestos is typically introduced into the manufacturing process by inserting bags under a hood or placing them adjacent to a suction duct. The bag is slit and the fiber is released into a hopper or process tank. Empty bags are placed in plastic containers for dis posal in accordance with OSHA regulations. Hoods and suction ducts are designed to accommodate the standardized bags. tv Commercial asbestos is fluffy. It is difficult to pack this material in a rigid container and, because the fiber would gradually compact during shipment, it would be difficult to remove it for introduction into the manufacturing process. It would also be extremely cumber some, if not impossible, to empty rigid containers effectively and rapidly into hoods designed for bags. Spillage would no doubt occur and workers would be unnecessarily exposed to fibers. In addition to these packaging and handling problems, cost and logis- Page 5 013827 tical factors in the use of rigid containers must be considered. The standard package for asbestos is a 100-pound bag and manu facturing formulations are based on this unit size. The equivalent rigid container to hold 100 pounds is a 15-gallon open-head drum that would be required to be fitted with a gasket and seal ring to make it dust tight. This type of container is available in fiberboard (leverpack) at a cost of about $3.00 each and in metal at about $5.75 each. The annual asbestos usage in the United States is about 750,000 tons. Fifteen million drums at a cost of $45,000,000 to $90,000,000, depending on choice of material, would be required. At these purchase costs, return and reuse of the container must be considered. Since shipment of asbestos has not been made in this manner, there are no specific data on the average number of round trips to be expected with such containers. Damage from repeated handling is expected to be substantial and only dust-tight drums could be reused. For calculation purposes an average of one and a half round trips for leverpack and three round trips for metal has been assumed. The cost of shipping a carload of 1680 empty drums at weights of 10,41 pounds for leverpack and 18,480 pounds for metal to Quebec from three representative locations in the United States are summarized in the table below: Shipping Cost per Drum Leverpack Metal New York City Houston Los Angeles 0.44 1.14 1.64 0.57 1.48 2.13 The materials cost for present packagings, i.e. multiwall paper bags on pallets with the pallet wrapped in plastic sheet, is about $15 per ton or $0.75 per ,100-pount unit. The incremental cost for materia only can be calculated as the original cost of the drum adjusted for the average service life,'plus the cost to return it to the origin, minus the saving from the elimination of the present packaging. For the case here, this ranges from $34 to $65 per ton depending on the. location. ` r - There is also a disposal cost to consider. With the service life assumed, 10 million leverpack or 5 million metal drums would be added to the present burden on the.solid waste disposal facilities of the country. These containers would each have to be vacuum clean ed or washed to remove the last trace of asbestos or be deposited in controlled hazardous waste facilities. The proposed use of rigid containers would require development of new filling and handling technology and new machinery, all at great expense. Present equipment, developed at high cost for bag usage would become needlessly obsolete. Rigid containers would greatly increase materials costs and add waste disposal problems. In short, for a variety of reasons, discussed above, rigid containers are not practicable for asbestos packaging. Ill - Shipment in Uncovered Vehicles 013828 Prohibition of transport of bagged asbestos in open vehicles would result in severe and costly disruption to the industry, particularly to small businesses. Two modes must be considered: (1) shipment of TL amounts of palletized bags on flatbed trucks and (2) shipment of LTL quantities either palletized or as individual bags from ware houses and other sources to small users. Flatbed truck shipments are the result of specific transportation needs and are handled by both contract and common carriers. Examples include, but are hot limited to, the movement of product from the mill to the rail shipping point, deliveries to larger users within a limited geographical area from an asbestos mill, and backhaul of asbestos from the supplier to the asbestos user's plant. In this type of shipment, the pallets generally are protected by one or more of the following procedures: - Pallets are shrink or stretch wrapped with plastic film . ' - Individual bags are enclosed in plastic film prior to palletizing. - The entire load is protected with a canvas or plastic cover. Shipments from warehouses are typically less than truckload, i.e. from a few bags to a few pallets. Although the total tonnage is a relatively modest percentage of the total U.S. usage, it is estimated that 500-1000 businesses, many of them small, are serviced in this manner. Examples include manufacturers of caulks, adhesives, sealants mastics, reinforced plastics and high-performance specialty industrial coatings. In these cases, asbestos is used to provide unique proper ties to a product. Although bagged asbestos may move in closed trucks in inter-city shipments, a substantial amount is transported in open vehicles. In this situation, the pallets normally are o.r should be . covered with plastic film. Similarly, where individual bags are handled, they are either covered or lined with plastic film. The DOT concern seems to be the need to avoid airborne emissions to the environment from the moving vehicle. is being achieved in open vehicles today. Prohibition is not needed nor justified. ; asbestos This can of their and use IV - Definition of Occupational Exposure to Asbestos A far-reaching impact of this proposal comes frpm a wording which occurs ,with variation to identify the type of carrier, in Parts 174, 175, 176, and 177. This is illustrated in paragraph 177.844: "Asbestos must be loaded, handled, and any asbestos contamination of transport vehicles removed, in a manner that will prevent occu pational exposure to airborne asbestos parti cles. " (Emphasis added) Page 7 013829 If it is assumed that "prevent occupational exposure" means what it implies, i.e. zero exposure, some fundamental problems result. Asbestos is ubiquitous in the environment and there are no work places where there is zero occupational exposure to asbestos. Zero or any other extremely low-level exposure requirement, as a practical matter would preclude the use of bag and compressed block packaging. With the very large volume of asbestos shipped, occasional container damage may occur. There is no provision for this in a Zero exposure standard and the problem cannot be elimi nated entirely regardless of the container used. ment would be incapable of compliance. Such a require The wording also does not define which workers are covered by a DOT standard. It is assumed that the DOT jurisdiction applies only to employees of the transportation employer who are engaged in specific tasks in proximity to the transport vehicle. Employees of the manufacturing, the warehouse facilities, and the end user of the asbestos would be under OSHA asbestos regulation. The wording in the proposal lacks: (1) clear and concise definition of the statutory authority under which the regulation would be pro mulgated and identification of workers to be covered, (2) definition of occupational exposure to include a specified numerical level, specification of fiber length and aspect ratio of fibers; and (3) an analytical method to measure airborne fiber concentration. V - Loading by Consignor, Unloading by Consignee* VI The meaning of the requirement that bags shipped in closed transport be loaded by the consignor and unloaded by the consignee is not clear. Does this mean that transport company employees cannot load, unload, or tranship? If so, such a restriction would seriously impact on the small user. Present asbestos packaging satisfies the statutory re quirement of "no unreasonable risk". An added restriction is unneces sary. VI - The Use of Package Markings The proposed regulation places asbestos in Class ORM-C, but labels are not required. ORM-C identification on shipping papers is neces sary only for air and water transport. The proposal does not define package marking requirements. It would appear, however, that para graph 172.316 of the Transportation Act would require a marking on each package, i.e. ASBESTOS ORM-C Under present OSHA regulations, every bag of asbestos must be labeled: . CAUTION Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm Page 8 813830 This is a more informative marking than that required under paragraph 172.316. The OSHA stipulation that this label must be on every bag of asbestos is fully responsive to the Department of Transportation marking requirements. The Association respectfully submits its views on this important rulemaking proposal affecting the asbestos industry. We will be happy to provide any additional information or clarification of these comments as might be desired. Very tuly yours. xecutive Director RHM:sra Enclosures 6562 PROPOSED RULES [4910-60] DEPARTMENT OF TRANSPORTATION Mattrioli Traoif^rtaltoA Svroou H* CFR Fort* 172, 173. 174, 175, 174, 177] CDocket No. HM-150; Notice No. 74-31 TRANSPORTATION OF ASSESTOS AGENCY: Materials Transportation Bureau. DOT. ACTION: Notice of proposed rulemak ing. . | SUMMARY: The amendments pro posed herein would require certain kinds of asbestos to be shipped by all inodes In non-specification, rigid, air tight packagings, such as metal or fiber drums; or In bags when shipped in closed freight containers. The pro posals are intended to reduce the risks to property and to the public health and safety associated with the genera tion of airborne concentrations of as bestos that may result from the pack aging and handling of asbestos fiber shipments. The available data clearly indicates that regular, long term expo sure to aribome concentrations of as bestos fibers poses a range of carcino- j genic and other serlqus health risks; and recent studies suggest that these dangers are also associated with expo- i sures that are low-level, brief or inter- f mittenc. r DATE: Comments must be received on or before May 2,1978. I ADDRESS COMMENTS TO: Dockets Section. Office of Hazardous Materials Operations, Department of Transpor-. tation, Washington, D.C. 20590. It is requested that five copies be submit ted. FOR FURTHER INFORMATION CONTACT: Alan I. Roberts. Director, Office of Hazardous Materials Operations, 2100 Second Streets SW,, Washing ton. D.C. 20590. 202-425-0656. SUPPLEMENTARY INFORMATION: I. BACKGROtrro--Proldoctiox/Consumrtion/Transportation Patterns Asbestos is a generic term used to describe a number of naturally occurir.g fibrous, hydrated mineral silicates. 1 It includes chrysolite, crocidolite, amositc. ar.mophyliite asbestos, trrmoiite asbestos, and actlnolite asbestos. These are all asbestiform minerals which, when crushed, produce asbes tos fibers with various chemical and , physical properties. 013831 Asbestos fibers are generally charac terized by high tensile strength and flexibility, and favorable chemical re sistance, heat and frictional proper ties. Certain grades of asbestos can be spun and woven, while others can be . laid and pressed to form paper, or used for structural reinforcement of materi als such as cement, plastic, asphalt and tile. The asbestos content of these latter products ranges from 5 to 15 percent by weight. Although asbestos is adaptable to more than 2,000 uses, the construction Industry accounts for nearly twothirds of the United States (U.S.) as bestos fiber consumption. The remain ing 33 percent is utilized in a myriad of industrial and consumer products. During the ten-year period ending 1976, the total amount of new asbestos Introduced Into the OS. transporta tion system averaged approximately 1.700.000 short tons annually. Slightly more than half this tonnage consists of crude or nulled asbestos fibers, with the remainder consisting of asbestos contained in products manufactured In whole or in part from asbestos. There is. of course, a lag between the time a shipment of asbestos fibers enters the transportation system and the time that shipment enters the transportation system as a manufac tured product. Growth in the utilization and trans portation of asbestos is expected to slowly increase at a rate of about 2 percent per year. During the entire history of the as bestos Industry In the United States, domestic sources have been able to meet only a small percentage of UB. requirements. Roughly 90 percent of ' the total U.S. industrial demand for all grades and types of asbestos fibers is thus dependent on foreign Imports-- with Canada being the major source of supply. In 1975, 93 percent of U.S. im ports came from Canada with the next largest suppliers being the Republic of South Africa (3 percent) and the U.S.S.R. (2 percent). Eight other coun tries shipped smaller amounts of as bestos to the U.S. in 1975. The transportation pattern for as bestos is characterized by three dis tinct stages: In the first stage, asbestos ore is transported from the mine site to a milling plant where the ore is crushed and processed Into fibers. Of the five mills operating in the U.S. as of late 1976. three are located at the mines. but the other two are 32 and 52 miles distant. Transportation is reported to be by open-hopper vehicles such as dump trucks. The second stage is characterized by the shipment of crude or milled asbes- asbestos IKEO^aTTON 1745 Jefferson Dtivis Hwy. Suite 509, Crystal Square 4 Arlington, Va. 22202 .fibtRAt REGISTER, VOL 43, NO. 42--THURSDAY MARCH 2, J975 PROPOSED RULES 013832 8563 tos fibers from the mm* (mostly for eign) to industries that use asbestos in ' the products they manufacture. The largest industry in this category (SIC 3292) as of 1972 consisted of 142 estab- "shments primarily engaged in the manufacture of asbestos textiles, as bestos building materials, asbestos in sulating materials for covering boilers and pipes, and other products com posed wholly or chiefly of asbestos fibers. Other Industries receiving as bestos fibers are mainly industries en gaged In the production of asphalt felts and coalings (SIC 2952), hard surface floor coverings (SIC 3996). gas kets (SIC 3293). and paper products (SIC 2261). These industries generally receive their shipments of asbestos fibers in pressure packed, five-ply paper* or woven vinyl bags weighing about 100 lbs. per bag. with the bags glue-locked to each other and shrink-wrapped to a pallet (wrapped with a film of plastic which is then shrunk). In the aggre gate. rail shipments handle about 80 percent of all milled asbestos fibers en tering the U.S. transportation system, with merchant vessel shipments ac counting for the remaining 20 percent. Packaging for ocean transportation, both for imported ar.d exported asbes tos fibers, is changing to containeriza tion. All shipments, for example, from the Union of South Africa have been reported to be containerized. Although rail shipments of asbestos fibers are not yet being containerized, the major ity of such shipments are made in sealed, railroad box cars which are routed for the most part direct to the asbestos products manufacturing in dustries. The third stage in the transporta tion of asbestos involves the shipment of manufactured products made wholly or in part from asbestos. Ap proximately 61 percent of the asbestos used in manufactured products is firmly Imbedded or "locked In'' such products as floor tiles, asbestos cement p;pes and sheets, floor products and plastics. These products generate less airborne fibers than asbestos manufac tured products that are friable or in powder form, although at the present time, it is not known whether the transportation of products In either category under current conditions pre sents an unreasonable risk to the public heaich and safety. As defined in the Department of Commerce's 1972 Census of . Transportation, approxi mately 92 percent of asbestos manu factured products are shipped by motor vehicle, with rail and all other modes accounting for about 7 percent and 1 percent, respectively. II. General Effects of Airborne As bestos Exposurz/Evioence of Acci dental Release of Asbestos Fibers The MTB believes it to be firmly es tablished that asbestos, in its several commercial forms, poses serious health hazards to individuals subject to long term exposure to airborne as bestos concentrations. As noted In the 1972 preamble of the Occupational Safety and Health Administration (OSHA) standard on asbestos (37 FR 11316): "No one has disputed that ex posure to asbestos of high enough du ration is causally related to asbestosis and cancers Recent new evi dence, however, as reported by OSHA. not only teads to confirm this finding but also suggests chat serious potential health risks are involved with even rel atively low-levei, brief or intermittent exposure to airborne asbestos concen trations. Although there is no detailed information available on the amount of asbestos fibers released in transpor tation, the MTB believes that, in con sideration of the carcinogenic and other health hazards associated with asbestos, there is a sufficient basis for establishing regulatory control of as bestos in transportation. III. Relationship to HM-145 On December 9. 1976, the MTB pub lished an Advanced Notice of Proposed Rulemaking (41 FR S3824) in Docket No. HM-145 entitled "Environmental and Health Effects Materials.'' In that Notice, the MTB announced that it was considering whether new or addi tional transportation controls are nec essary for certain classes of materials which are not generally subject to the existing Hazardous Materials Regula tions. A large number of comments were received in Docket HM-145. The MTB has concluded that a considerable amount of time and effort is still needed in staff evaluation of these comments before it will be in a posi tion to issue a notice or notices of pro posed rulemaking for environmental and health effects materials, either on a comprehensive or on a selective basis. Several comments on HM-145, how ever, were specifically directed to the idea that transportation regulatory controls for asbestos be established as soon as possible, with the suggestion that asbestos be addressed on an indi vidual basis, rather than writing until the eventual resolution of Docket HM145. The MTB agrees with the urgen cy of the views expressed on this matter, and therefore Asbestos is being treated separately under this proposed rulemaking. IV. Quantitative Versus Qualitative Standards In determining that there is a need for transportation controls on asbes tos, the MTB has considered the desir ability and practicality of utilizing quantitative or qualitative emission criteria or some combination of the two, either as developed by the MTB or as developed by other agencies. Currently, quantitative permissible exposure limits fer asbestos,' as pro mulgated by the Environmental Pro tection Agency (EPA) have not been established for environmental or non- occupational settings. The EPA's stan dard for airborne asbestos emissions falls under its "no visible emissions" criterion. This is in contrast to the quantitative criteria established by OSHA for airborne concentrations of asbestos fibers In occupational or worksite conditions. The criteria of OSHA consist of an 8-hour time weighted average standard, and a maximum "ceiling concentration" standard. Both standards are to soms extent based on the ability of current devices to measure asbestos airborne concentrations in a systematic, mean ingful manner, and are not directly based on any causal or threshold rela tionship between the standards and the probability of contracting an as bestos Induced disease. The MTB believes that Its proposed non-specification p*ckaging standards as applied to the transportation of as bestos fiber is an effective and effi cient means of precluding potential problems associated with asbestos air borne emissions occurring during transportation: and that they are con sistent with the standards of both EPA and OSHA. V. Score and Impact The standards as herein proposed would only apply to the transporta tion of what are generally regarded as milled or crude asbestos fibers, but would exclude asbestos contained in a natural or artificial binciing-ma'.erial and manufactured products containing asbestos. In light of the regulatory controls already In existence or under consider ation by other federal agencies, and until such time as the MTB has more specific and concrete information that the normal packaging and handling of these forms of asbestos is such as to create unreasonable asbestos exposure problems, the MTB does not believe their specific regulation in transporta tion is warranted. In reviewing the potential inflation ary and economic impacts associated with the proposed rule, the MTB has determined that such impacts will be minimal. Based on the foregoing dis cussion of the production and trans portation pattern for asbestos ship ments. It is clear that the only aspect of that pattern which might experi ence a cost impact pertains to import and export shipments by merchant vessel. This follows from the fact that the proposed rule would generally re quire all such shipments to be contain erized in contrast to packaging alter natives ' now available to shippers. However, the cost-differential between these alternative cargo handling meth ods is not only very small, but a sig nificant portion of such shipments are already containerized, or being con tainerized. As proposed herein, a new paper shipping name "Asbestos" would be added to the list of hazardous materi als in 49 CFR 172.101. The proposed FEDERAL REGISTER, ^OL 43, NO. 47--THURSDAY, MARCH 2, 1973 A r 8564 PROPOSED RULES classification for `'asbestos'- would be as an ORM-C (Other Regulated Mate rial. Croup C). Primary drafters of this document are A. W. Grella. Technology Division. Office of Hazardous Materials Oper ations: J. S. Nalevanko. Economist, Materials Transportation Bureau; and Douglas A. Crockett. Office of the Chief Council, Research and Special Programs Directorate. In consideration of the foregoing. Title 49, Code of Federal Regulations, Parts 172 through 177 would be amended as follows: PART 172--HAZARDOUS MATERIALS TABLE AND HAZARDOUS MATERI ALS COMMUNICATIONS REGULA TIONS 172.10 [Amended! 1. In 172.101. the Hazardous Mate rials Table would be amended by adding a new entry, immediately fol lowing "Arsine." to read as follows: 013833 k - S365 (2) O) taerlptlons and rop.r shipping nine* elaaa <*) . . .a a required . (if not excepted) () Except Iona (J) (b) Specific requirements (6k ' . ~ Haxleuirf "et quenlty in on* package .* (e) (b) Passenger carrying Cargo only aircraft or rail car aircraft U> Uare siUmfint.1 fa) (b) (e) Cargo Passenger Other vessel vassal requirements (Add) AlklltSI ' ORM-C Done 173.1090(b) 173.1090(e) Mo Halt Mo Halt 1. 2 1. 2 Stov rv4 haatrbo parcicla*. * ./ f it ' FcCcXAl RSGISTJ*, VOL 43, NO. 42--THURSDAY, MARCH 2, 1973 -8566 PROPOSED RULES PART 173--SHIPPERS--GENERAL RE QUIREMENTS FOR SHIPMENTS AND PACKAGINGS 2. 173.1090 would be added to read as follows: sels removed. In a manner that will prevent occupational exposure to air borne asbestos particles. (See i 173.1090 of this subchapter.) : 7. $ 177.844 would be added to read as follows: -- S 173.1090 'Aiboloa <&) Asbestos includes any of the fol lowing hydrated mineral silicates: chrysolite, crocidolite, amosite. antho- phyllite asbestos, tremolite asbestos, and actlnolite asbestos, and every product containing any of these min erals. . - (b) Asbestos which is immersed or fixed in a natural or artificial binder material (such as cement, plastic, as phalt, resins or mineral ore) and man ufactured products containing asbes tos are not subject to the require ments of this subchapter. (c) Asbestos must be offered for transportation and transported in-- (1) Rigid, airtight packagings such as metal or fiber drums, or (2) Bags when in closed freight con tainers, motor vehicles, or rail cars, that are loaded by the consignor and unloaded by the consignee. PART 174--CARRIAGE BY RAIL 3. Subpart Heading M would be added immediately following J 174.812 to read as follows: $ 177.844 Other regulated material*. .1 Asbestos must be loaded, handled, and any asbestos contamination of transport vehicles removed. In a manner that will prevent occupational exposure to airborne asbestos parti cles. (See $ 173.1090 of this sub chapter.)------ - - .Authority: (18 O.S.C. 1803. 1804. 1808: 49 CFR 1.53(e) and paragraph (aX4) of Appen dix A to Part 102). Nora--The Materials Transportation Bureau has determined that this document does not contain a major proposal requiring preparation of an Economic Impact State ment under Executive Order 11821 and OMB Circular A-107. . . Issued in Washington, D.C., on February 23,1978. , 1 i Alan I. Roberts, Director. Office ofHazardous Materials Operations. (FK Doc. 78-5277 Filed 3-1-78: 8:45 am) ! Subpart M--Oalailod Requirement* ter Other Regulated Material* 4. $ 174.840 would be added to read as follows: S 174.840 Special loading and handling re ' quirementa for asbestos. - Asbestos must be loaded, handled, and any-asbestos contamination of rail cars removed, in a manner that will prevent occupational exposure to air borne asbestos particles, (See 173.1060 of this subchapter.) PART 175--CARRIAGE BY AIRCRAFT 5. $ 175.640 would be added to read as follows: 175.640 Special requirements for other regulated materials. Asbestos must be loaded, bandied, and any asbestos contamination of air craft removed, in a manner that will prevent occupational exposure to air borne asbestos particles. (See 173.1090 of this subchapter.) PART 176--CARRIAGE BY VESSEL 6. 5 176.906 would be added to read as follows: $ 176.906 Stowage and handling of asbes tos. Asbestos must be stowed, handled and any asbestos contamination of ves FEDERAL REGISTER, VOL 43, NO. 42--THURSDAY, MARCH 2, 1978 %<\ Lp5'f I PO..M TITLE 49 -- TRANSPORTATION AJ.C CHAPTER I - RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION niQQQ* MATERIALS TRANSPORTATION BUREAU DEPARTMENT OF TRANSPORTATION PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS (Docket No. HM-160; Arndt. No. 172-47, 173-123, 174-33, 173-7, 176-6, 177-44> TRANSPORTATION OF ASBESTOS REVISION OF AMENDMENT NO. 173-123 EFFECTIVE DATE EXTENSION .AGENCY: Materials Transportation Bureau (MTB), Research and Soecial Programs Administration, DOT. 00 ACTION: Revision of previous Amendment No. 173-123 and extension of the effective date for all amendments. SUMMARY: This revision of Amendment No. 173-123 regarding the transportation of asbestos as published on December 4, 1978, in the Federal Register (43 FR 56664) will allow shipments of asbestos when packaged in bags or other ncn-rigid packagings to be transported in closed freight containers, motor vehicles, or rsil cars when loaded by the consignor and unloaded by the consignee; or in bags and other non-rigid packagings that are dust and sift proof which are palletized and unitized. Unitized loads in slings need not be palletized during transportation by vessel. The effective date of the entire Docket HM-160 is revised from April 30, 1979 to August 20, 1979. EFFECTIVE DATE: August 20, 1979. ADDRESS: Ail written comments received in this rulemaking action are available for examination during regular business hours in the Docket Brandi, Room 5300, s? TransPcint Building, 2100 Second Street, S.W., Washington, U.C. rsji k m Mi 3* l T-i FOR FURTHER INFORMATION CONTACT: . 013836 Delmer F. Billings, Standards Division, Materials Transportation Bureau, Research and Special Programs Administration, 2100 Second Street, S.W., Washington, D.C. 20590, phone 202-755-4902. SUPPLEMENTARY INFORMATION: On December 4, 1978, the MTB published a final rule under Docket HM-160 in the Federal Register (43 FR 56664). Since this publication, the MTB has received several petitions for reconsideration in accor dance with the provisions of 49 CFR 106.35. The petitions requested reconsid eration of the provisions and/or extension of the effective date of the final rule. This document will incorporate methods of shipment which were identified in the notice of proposed rulemaking (43 FR 8562, March 2, 1978) and also those which were included in the final rule. These amendments represent minimum safety ` requirements and are intended to reduce the risks to public health associated with the generation of unacceptable airborne concentrations of asbestos that may result from packaging and handling of asbestos shipments in commercial transportation. Two petitioners based their petitions on the fact that the final rule contained a provision requiring bags and other non-rigid containers of asbestos to be palletized and unitized by some method such as shrink-wrapping in plastic film or wrapping in fiberboard secured by strapping. It was noted that this requirement was not included in the notice of proposed rulemaking (43 FR 8362), thus making comments on this requirement impossible during the normal comment period for the proposed rulemaking. Petitioners also posed the question of whether or not freight containers, rail cars, etc., constituted rigid, airtight packagings as recuired S 173.1030(d)(1). It was stated that if such containers were not included in this t rd r. provision, nil shipments of bags of non-rigid cont.:iner> would be required to -c palletized and unitized according to the provisions of S 173.1090(d)(2), vnd that this requirement would impose grent hardship on the asbestos industry and on shipper? of large volumes of asbestos who normally ship using exclusive use vehicles and rail ears. It was also indicated that neither the equipment nor facilities exist at the present time to achieve compliance with the palletizing and unitizing requirement of the final rule bv the published effective date. The MTB has determined that freight containers and, probably, motor vehicles and rail cars would not satisfy the requirements of 173.1090(d)(1). . By allowing the use of unitized pallet loads as identified in the final rule, the MTB intended to recognize less restrictive handling requirements for bagged asbestos than those that would have been required by the ''loading by con signor/unloading by consignee" approach. However, it was not the intent of the MTB to eliminate the more restrictive consignor/consignee approach. Therefore, 173.1090(d) is being revised to allow the option of either the consignor /consignee approach as identified in the original proposed rulemaking with inclusion of an exclusive use provision or the unitized pallet approach using bags or other non-rigid packagings as required by the final rule. One petitioner noted thnt a method of shipment of asbestos via water was the use of slings which are shrink-wrapped or stretch-wrapped and transported in the hold of a vessel without the use'of pallets. H was the petitioner's contention that the u-,e of pullets would increase the incidents of unintentional release of a stoics due to the interaction of the pallets against the bags which ere unitzed by the slings. It was noted that pallets were used in all in;: i nee's :v. when place-: it; the hold of the transport vessel. Given the hick cf dew?:led t'v. on the amount cf 3 / asbestos fibers released in transportation and the circumstances end cause for such release, the MTB is in general agreement that increased unintentional releases may be likely if pallets were used under the method identified in the petition. Therefore, 173.109fifdt is being revised to allow slings in loads that are shrinkwrapped or stretch-wrapped to he transported by water without the use of pallets. Future monitoring of hazardous materials incident reports will assist the MTR in determining the safety and efficiency of this and other methods for shipment of asbestos. One petitioner suggested that the terms ''pallet" and ''palletized'" be defined in the rulemaking. The MTB does not intend to publish a definition of pallet or palletized. It is the MTB's opinion that any rigid platform or board upon which goods may be placed for transportation would meet the requirements when unitizing a load of bags or other non-rigid packagings. Several petitioners cited a need for the MTB to define the term "dust and sift proof". For the purposes o? this amendment, the MTB considers dust and sift proof to mean packagings which are constructed so as to prevent the release of their contents either through materials of construction, seams., or closures during conditions normally incident to transportation. One petitioner requested that the use of gluing of bags into a unit be allowed as an alternative to the unitizing methods identified in the final rule. It is the M J'B'.s opinion ttvl the use of $Sv ink-wrappin-r or other similisr metr.od* of enclosure assist not only in unitizing a pallet load of bags or other r.on-rigid packagings, but also assist in the m event ion of a rhorne st;-.stos contamination of individuals involved in the transportation of asbestos. 5:mpiy gluing these i tm ''t s\ Li L / 013839 .t L :. packaging? together to form a unit would not provide this added measure of safety to which the final rule addresses itself. Therefore, ghiin*: of bags into a unit is not being included as an alternative unitizing method. One petitioner requested that quantities of less than 2,000 pounds, net weight, per vehicle be excepted from the palletizing and unitizing requirement. It is MTB's opinion that the palletizing and unitizing requirement does not unreason ably restrict the shipment of asbestos in any quantity. This requirement is necessary to provide a minimum level of safety. Several petitioners requested an extension of the effective date of the final rule. The effective date has been extended to allow five months for compliance as originally intended by the December 4, 1978 publication. Primary drafters of this document are Delmer F. Billings, Standards Division, Office of Hazardous Materials Regulation, and Douglas A. Crockett, Standards Division, Office of Hazardous Materials Regulation. In consideration of the foregoing, the effective date and paragraph (d) of 173.1090 as they appeared in the Federal Register published on December 4, 1978 (43 FR 56664) are revised to read as follows: 1. The effective dale of the final rule es it appeared ir. HM-160 on December 4, 1978, is revised to read as follows: EFFECTIVE DATE: August 20, 1978. 2. In 173.1090 paragraph (d) as it appeared at 43 FR 56669.is revised to read as follows: 173.1090 Asbestos. # * * * 01J840 (d) Commercial asbestos must be offerer, for transportation and transported in-- (1) Rigid, airtight packaging such as ruetai or fiber drums, portable tanks; (2) Bags or other non-rigid paekagings in closed freight containers, motor vehicles, or rail cars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee; or (3) Bags or other non-rigid paekagings which are dust and sift proof and which are palletized and unitized by methods such as shrink wrapping in plastic film or wrapping in fiberboard secured by strapping. Pallets need not be used during transporta tion by vessel for loads with slings that sre unitized by methods such as shrink wrapping, if the slings adequately .and evenly support the loads and the unitizing method prevents shifting of the bags or other non-rigid paekagings during conditions normally incident to transportation. AUTHORITY: (49 U.S.C. 1303, 1804, 1808; 49 CFR 1.53). Note.-The Materials Transportation Bureau has determined that these amendments do not require a regulatory analysis under the items of Executive Order 12044 and i)%} 1' implementing procedures (43 FR 9382). A regulatory eval.:: tier* is svaiitibV Aror review in the Docket. ert ificd Issued in Washington, D.C., on March to he a true copy of the or iy.inal . >?; A:~ j t/7' ' ,i / ' Y ./ g -- > ( til / i rr i t'O.r S 1.. f). SantM'.a;:. Director Materials Transportation Burcd-j 013956 Material Safety Data September 1,1976 UNION CARBIDE CORPORATION 4625 ROYAL AVENUE NIAGARA FALLS, NEW YORK 14302 TELEPHONE: (716) 278-3376 PRODUCT: Chrysotile Asbestos TRADE NAMES: "Calidria" Asbestos CHEMICAL FORMULA: Mg6(0H)8Si4010 1 BOILING POINT AND MELTING POINT: Not Pertinent SPECIFIC GRAVITY (H20 = 1): 2.45 VOLATILE CONTENT: Absorbed Water 1 - 4% By Weight. Structural Water Approximately 13% by Weight. APPEARANCE: Pellets or Fine White Powder. No odor. Very Slight Solubility in Water. hTd*ittiuiK* I ? tel ;i q j i a * I r .jr-'S, Asbestos contains no hazardous ingredients. However, the material itself can be hazardous under certain conditions. (See V below.) ^REAND^X^LOSIONHAZAftpSATA'Ig NON-COMBUSTIBLE MATERIAL: No Fire or Explosion Hazard. INERT MATERIAL: No Decomposition or Polymerization Conditions. ^/^EACmHAZARD 'DATA/ < f * *- ' PERMISSIBLE EXPOSURE TO AIRBORNE CONCENTRATION: The current Occupational Safety and Health Standard (CFR 29, 1910.1001) contains the following exposure limits: "The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the membrane filter method at 400-450 X magnification (4 millimeter objective) phase contrast illumination. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method just noted." EFFECTS OF EXPOSURE: CAUTION: Breathing asbestos may cause serious bodily harm. EMERGENCY AND FIRST AID PROCEDURES: No acute toxicity. Use respirator if airborne asbestos fiber concentration exceeds OSHA limits. tVlJSPILLOR LEAK PROCEDURES`; - ::'d STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Avoid inhalation of dust. Remove spilled material by vacuum cleaner or by water wash. WASTE DISPOSAL: Bags and waste and scrap materials should be disposed of in a manner which will avoid airborne concentrations of asbestos, such as the use of dust-tight trash bags or containers. Ensure that disposal complies with all applicable federal, state or local regulations. Union Carbide Corporation assumes no responsibility and makes no warranty, expressed or implied, repre sentation, promise, or statement as to completeness, accuracy, or currency of any data provided. 013957 VENTILATION: Local exhaust for each operation is preferable. (See American National Standards Institute booklet, Z9.2 -- 1971.) General area exhaust is acceptable. No special considerations. PROTECTIVE GLOVES: None EYE PROTECTION: None RESPIRATORY PROTECTION The current Occupational Safety and Health Standard CFR 29, 1910.1001 contains the following require ments for respiratory protection. AIRBORNE CONCENTRATION*2* 8-HOUR EXPOSURE*3* CEILING CONCENTRATION 2 maximum 10 maximum 20 maximum 100 maximum 200 maximum 1000 maximum MINIMUM REQUIRED MASK TYPE*4* Not required when allowable limits are not exceeded. Reusable or single use air purifying respirator. Powered filter positive pressure. Over 200 -- Type C positive pressure, air supplied. (1) Allowed only during the time required for installation of engineering controls, when engineering controls are not technically feasible or adequate, and in emergencies. Current OSHA standards require that no em ployee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examina tion an examining physician determines that the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by the use of a respirator. (2) Fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. (3) 8-Hour time-weighted average. (4) Only masks certified by NIOSH as acceptable for the exposures encountered may be used. OTHER PROTECTIVE EQUIPMENT: If the ceiling concentration limit is exceeded, clothing providing whole body covering shall be supplied and its use required. Every place of employment where asbestos fibers are released must be monitored to determine exposure levels. If the permissible time-weighted average and ceiling concentration limits are not exceeded, no special pre cautions are required except: a) Bag damage and dusting should be minimized and dust inhalation avoided. r b) A comprehensive medical examination is required for any employee exposed to airborne fibers within 30 days of first such employment, annually thereafter and on termination of employment. c) Personal work clothing can become contaminated with asbestos and may constitute an exposure hazard. Such clothing should be handled and laundered in a manner to avoid airborne concentrations of asbestos. d) Substantial medical evidence indicates that smoking will increase the risk from asbestos exposure. Those working with asbestos should not smoke. Where exposure limits may be exceeded, reference should be made to the regulation CFR 29,1910.1001 for details on caution signs, monitoring, change rooms, protective clothing laundering and record keeping. 013958 MINERALOGY OF CHRYSOTII ASBESTOS F. A. Mumpton J3TTR0DUCTION - . All of the properties and reactions of a material, no matter how complex or sophisticated, are basically dependent upon the answers to just two questions about the material - what is there, and how is it put together? It is, therefore, .appropriate that any discussion of the Coalinga asbestos begin by a consideration of these two aspects of chrysotile asbestos - what is its chemical composition, and what is its crystal structure? As will be Seen; everything which follow's is fundament ally related to these two properties. To begin with, an understanding of what is usually meant by the term ' "asbestos" is in order. The word itself is derived from the Greek, crPeoToo, meaning incombustible, and was originally applied to a number of calcium and magnesium silicates when they occurred as fine, silky fibers. Today, asbestos is a commercial term for a group of fibrous silicate minerals which are not only fire proof, but which are capable of being processed into flexible fibers of various lengths and widths. Six different minerals have been classified as asbestos minerals, including chrysotile, anthopbyllite, actinolite, tremolite, crocidolite, and amosite, with chrysotile accounting for over 95^ of the world's production of asbestos. As shown in Table I, each of these minerals is different chemically and each possesses its own distinctive physical properties which make it useful in particular applications. Although both crocidolite and anthophyllite are used currently within the Corporation, the present discussion will be confined primarily to chrysotile asbestos, which, of course, is the main constituent of the Coalinga deposit, and is by far the most useful type of asbestos used today. OCCURRENCE Almost all chrysotile asbestos occurs in the form of slip or cross-fiber velnlets, varying from a few hundredths of an inch to several inches in thickness, within large bodies of serpentinite rock, and is accompanied by small amounts of magnetite, chromite, and other members of the serpentine group of minerals. Serpen tinite, by definition, is a rock composed primarily of minerals of the serpentinite group.and is generally found as (a) low-temperature alteration product of pre existing ultrabasic rocks, composed primarily of olivine (Mg^e^SiO^ and pyroxene (Mg, Fe)SiC>3, or (b) metamorphic replacement product of magnesium-rich limestones. The exact origin of the cross-fiber veinlets is not well understood. However, one theory maintains that fibrous chrysotile precipitated from hydrothermal solutions along cracks and fissures in the rock during the serpentinization process. Recent speculations, on the other hand, suggest that the chrysotile veinlets precipitated from solution some time after the initial serpentinization process, and may be considerably lower temperature in origin. In any case, the great bulk of the rock was formed by the low-temperature hydration of the olivine and pyroxene, according to the following reaction: Olivine Serpentine Brucite 2Mg2SiOl4 + H2O (introduced)------ > Mg3Si205(0H)l4 + Mg(0H)g -4- TABLE I. PHY3ICAL PROPCRTIES OF ASBESTOS MDTOtALS FROPorrr AN > CHKYSOTELE AOTHOPHYLLITE Composition / Crystal Habit / / / Color 1 Luster | Occurrence ! Vetoing Mg3Sl205(0l)4 Fine, tbln, easily sepa rable fibers White, gray, greenish Silky Altered ultra basics and Intruded lime stone Cross-fiber. Slip-fiber. Massive fiber Ms^SIqO^ (OH )2 \ Prismatic crys tals and fibers I i jGray-vhlte 1j Vitreous to pearly i. 'Crystalline schists and gneisses 11 i SMalisps-ivfiebefirber CROCIDOLITE HaaFejFegSlsO^tOHjg Long brittle fibers Blue Silky to dull Fe-rlch, argil laceous schists Cross-fiber ACTSfOLlTE Ca2Fe3Sl8022(OH)2 Prismatic crystals and fibers TRQfOLITB AMOSITE Mg50 ^SlgO^(OH )2 (Pe#HK)7Sl8022(OB)2 Prismatic crystals Prismatic crystals and fibers . and fibers . Green Silky Metamorphosed limestones and crystalline schists Slip-fiber Massive fiber White, gray-white, Ash gray or brown greenish Silky P Vitreous to pearly Metamorphosed limestones and Mg-rich rocks Crystalline schists Slip-fiber Massive fiber Cross*fiber Hardness Specific Gravity Refractive Index (mean) - 2-5-k 2.k-2.6 1.51-1-55 5-5-6 2.8-3.1 1.61 k 3.2-3.3 1.7 6 3.0-3.2 I.63 5-5 a.^-3.2 1.61 5-5-6 3.1-3.3 l.6t . Texture l Soft to harsh i also silky Tensile Strength (pl) Electric Charge 80,000-100,000 Jr Positive._ . larsh <k000 (egatlve Resistance to Acids and Alk alis Poor fery good Soft to harsh 100,000-300,000 lfegatlve Oood Harsh <1000 negative Pair Harsh 1000-8000 negative Good Harsh 16,000-90,000 negative Oood Flexibility Impurities Usually &vcountered Very good Magnetite, chromite, calclte : bor !ngnetlte Good Magnetite Poor Calclte Poor Calclte Good . Magnetite . 013959 V VUV/V Current studies indicate that this reaction took place probably below 300* C., under several thousand pounds of water pressure. Most serpentinite bodies throughout the world contain small quantities of cross-fiber chrysotile, but mineable deposits are those which contain about 5-10^ recoverable fiber in veinlets varying from about l/l6" to l" thick. Although the Coalinga deposit was also formed by the serpentinization of a parent magnesium silicate rock, it bears little resemblance to most of the world's asbestos deposits. Cross-fiber veinlets are essentially absent from the body... Instead, nearly 75^ of the entire mountain consists of soft, powdery chrysotile, in the form of fr-tabi*" agglomerates and leathery sheets. " ^. - PRODUCTION The asbestos production of the United States is quite small compared with that of Canada and Russia, each of which produces about 1.5 x 10 tons a year, but it has increased from about Uo, 000 tons a year in i960 to over 100,000 tons in 1965* primarily due to the development of the Coalinga asbestos deposit, by three major companies - Johns Manville, Atlas Corporation, and Union Carbide. In contrast to the large-scale production of chrysotile asbestos, only about 2000-3000 tons of anthophyllite asbestos are sold each year, principally as filler materials in plastics. Crocidolite is produced mainly in South Africa, Australia, and in the Transvaal at about 100,000 tons a year. Its high strength (see Table I) and long fiber length command slightly higher prices than other asbestos ($250 to $600/ton), although the brittleness of the fiber restricts its usage in most applications. CRYSTAL STRUCTURE As can be seen in Table. I, the structural formula for chrysotile is some what different from those of the other asbestos minerals. This is because the basic crystal structure of chrysotile is different from that of the others; it belongs to a group of structures called layer lattice silicates, while anthophyllite, crocido lite, and the others are all chain structure silicates. Chrysotile itself is a member of the serpentine group of minerals. As seen in Figure 1, the serpentine minerals are divided into three main varieties, chrysotile, which occurs as tubular fibers, and lizardite and antigorite, both of which occur as platy or lath-like particles. The word chrysotile is derived from the Greek y&vooa = golden + TtXoa = fiber. Lizardite and antigorite derive their names from their type localities in Cornwall, England, and Val Antigorio, Italy, respectively. All serpentines have essentially the same chemical composition and are hydrous magnesium silicates? with small amounts of iron, aluminum, and nickel substituting for magnesium in the structure. The fundamental crystal structure of the serpentine minerals is similar to that of most clay minerals in that it is a layer lattice silicate, in which three of the four corners of the silicate tetrahedra are shared by adjacent tetrahedra. As shown in Figure 2, the fundamental units are a brucite-like layer, in which the cations are in octahedral coordination, coupled to a tridymite-like layer of silicate tetrahedra. This structure is analagous to the basic crystal structure of kaolinite clay; however, the serpentine structure contains three divalent cations, per two silicons, while the kaolinite structure is composed of two trivalent cations per" Ewb silicons. The basic brucite layer has unit dimensions of 5*^ x 9*3 k, while the silicate layer has unit dimensions of 5*0 x 8.7 k. Differences in these unit dimensions produce what is called a structural "misfit" between the two layers, which is alleviated in the serpentine minerals in the following manners. -6- FIGURE 1 CLASSIFICATION OF SERPENTINE GROUP MINERALS CHRYSOTILE LIZARDITE ANTIGORITE Hand Spictmen Morphology Electron Microscope Morphology Fibrous, platy Tubes Massive, platy Massive, fibrous Plates, laths Plates, laths Clino- Ortho- Para- o o o o o bc(X) c0(A) ' i beta Layers/unit cell 5.34 5.34 5.3 9.25 9.2 9.24 14.65 14.63 14.7 9316' 90 2 22 5.31 9.20 7.31 1 43.3 9.23 7.27 91.6* 1 C ry s ta l S tru ctu re o f C h ry s o tile Asbestos UJ o >X o >- oX oc o > X & . 0139-3 1. The combined sheet may be curved with the smaller silicate layer on the inside of the curve. 2. Ions of different sizes may substitute in either the octahedral or tetrahedral layers, thereby changing the basic unit dimensions. . 3. Vacancies may exist in the octahedral layer, with simultaneous removal of hydroxyl ions to balance the change, also changing the dimension of this layer. Ip chrysotile, the structural misfit is apparently alleviated by a curvature of the structure as illustrated in Figure 2, with the brucite layer on the outside of the curve, and a radius of curvature close to 88 JL In practice, the curved sheet goes all the way around, forming an elongated, hollow cylinder. The tubular structure of chrysotile can be seen in the electron micrograph shown in Figure 3. Measured internal and external diameters of 110 k and 260 k, respectively, suggest that each fiber consists of about ten concentric cylinders, each about 7*3 k thick. In general, the tubes are fairly uniform in diameter. However, length/width ratios of from 2-3 to several hundred have been observed. Commonly, the tubes appear to be partially filled with foreign material at periodic intervals. The filling material is thought to be amorphous, or poorly crystalline material having essentially the same composition as the chrysotile itself._ Since it cannot be removed from the tubes by heating or evacuationJ~Tt Ts" probably not water, per se. The pore spaces between the tubes also commonly contain similar material, but electron microscope studies have indicated that the Coalinga chrysotile is remarkedly free of such ad hering particles between the tubes. ' Although there was considerable controversy a few years ago as to whether or not ohrysotile was actually tubular in nature and did not just roll up under the electron beam, the recent structural analyses of Whittaker and the electron micro scopic work of Maser, Bice, and Klug have shown beyond any reasonable doubt that chrysotile is definitely tubular, both in and out of the electron microscope. This latter work was carried out on microtomed sections of chrysotile bundle s and showed the "doughnut"-shaped end sections of the natural tubes quite clearly. While all three varieties of chrysotile, clino, ortho, and para are tubular, particles of lizardite and antigorite appear platy to lath-like under the electron microscope with no evidence of a rolled or tubular structure. In these phases, the structural "misfit" is alleviated by ionic substitutions within the octahedral and tetrahedral positions of the lattice, combined with small amounts of vacancies in the brucite layer of antigorite. Substitutions of this sort give rise to unit dimensions much closer to one another, thereby eliminating any need for a curved structure. *. SURFACE AREA . The unique shape of chrysotile asbestos gives rise to one of its most important physical properties - that of its surface area. From strictly geometrical considerations, an assemblage of closely packed hollow cylinders having the dimen sions of chrysotile should have the following surface area: Internal Surface Area 35 M^/g. External Surface Area 70 M2/g. Total Surface Area 105 M2/g. -9- -oi- -xh STTJqM soqsaqsy STiqosAxqo paqB-isqn - aanOI& /'#! H '*-*>' '> Wr II. : i ' X,'? ts^Slr j| iI 0139P5 Most natural chrysotiles, however, have surface areas only of about 20-30 M^/g., suggesting that all of their internal area and parts of the external area are blocked by the foreign material mentioned on preceding page. Dispersion and/or defibrillation of many such chrysotiles results in an increase in the surface area by a removal of the inter-tubular material, but the intra-tubular, material appears to be unaffected by such treatment. Fortunately, the Coalinga chrysotile appears to have a surface area of 70-80 M^/g.', in line with the electron microscopic observations that little or no foreign material is present between the tubes. High surface area chrysotile of this type is found in only one other asbestos deposit in the world, the Stragari deposit in southern Yugoslavia. The material from this deposit, by the same token, closely resembles the Coalinga asbestos in physical appearance and in fiber content. THERMAL REACTIONS A second physical property of chrysotile and the serpentine minerals of considerable interest is their thermal stability. The dehydration reactions of chrysotile can easily be explained with reference to the differential thermal analysis pattern shown in Figure 1*. The small endotherm at about 600C. corresponds to the loss of water from just the surface layer of hydroxyls in the structure. The major endotherm at 700*0., however, is related to the removal of the remaining water from the lattice. At this temperature, the structure collapses and appears amorphous until recrystallization takes place. At 800C., recrystallization to forsterite (Mg2Si04) takes place, but neither silica nor enstatite (MgSiO^) appears in the X-ray diffraction patterns of these materials until well above 1000*0. In the past, dehydration of such materials was thought to take place by a simple reaction of two hydroxyl ions, forming a water molecule and an oxygen ion. Such a mechanism would, however, tend to disrupt considerably the internal structure oF"a~~serpentine particle, which apparently, from single crystal X-ray studies, does notToccuf. Instead, the dehydration appears to proceed in an extremely well ordered manner, and the final anhydrous products are highly oriented with respect to the crystallographic axes of the starting serpentine. .As shown in Figure 5> dehydra tion probably takes place by an initial migration of protons from the interior of the particle toward the edge, with a simultaneous migration of all of the magnesium and some of the silicon from the edge toward the center. This leaves a forsterite- rich interior, with a silica-rich exterior, both of which appear to be amorphous to X-rays. During recrystallization, the forsterite interior crystallizes, but the silica shell does not. Above 1000C., however, the forsterite reacts with the silica, producing the equilibrium assemblage-forsterite + enstatite. It is inter esting to note that the tubular morphology of chrysotile persist* nPr>n ng, "even after the crystal structure itself has disappeared during dehydration. Simi larly, the gross fibrous nature of the material is retained even after the sample has been heated to 1000 C., although the initial strength of the material is con siderably reduced. If chrysotile is leached completely in dilute acid, a silica residue is left which retains the original tubular structure of the starting material. The tubular silica product, however, is considerably shorter than the original chryso tile and much more brittle. Skeletal silica produced by leaching cations from silicate structures is not unique with chrysotile, and several other minerals, such as mica, wollastonite, zeolites, etc. also yield silica pseudomorphs in this manner. -11- FIGURE h Tempvratur* (C) 3j 6EI0 THERMAL REACTIONS OF CHRYSOTILE 2M g2 S i0 4 (X'llin e ) + 2 M g S i0 3 (X'lline) IT > i Oo 0 ' -V 3 \* > ot " >cx 3 <4 NS JaC . ft. o E c0 M : m X OX 'in o t . KooOU oCM in + > a hm cm o (s0ACO> CM E o O* in cm 0> s CO -13- 0l3fT7 u o o oo oi3<n BASIC FIBER PROPERTIES CF ASBESTOS S. Chwastiak My function today is to tell you about the properties of chrysotile asbestos, not only its intrinsic properties, but how they can be altered. Much data are available, so I will try to get them all in by presenting these pictorially - sketches and graphs, about 20,000 words worth. Initially, our mineralogical expert in the asbestos project was Fred Mumpton, who spoke to you just preceding me. Bill Dresher and Wayne Naumann studied the basic properties when we were located at the Tuxedo Research Center, and recently I .have become heir to this job. The data that I will present will be from all of these sources and from the published literature on chrysotile asbestos, which is primarily about asbestos from the Johns-Manville deposits in Quebec, Canada. . < As Fred Mumpton has told you, there are a number of minerals which are called asbestos. When I refer to asbestos, I will mean chrysotile asbestos and, unless I state otherwise, I will mean chrysotile from our Coalinga deposit in California. Asbestos occurs commonly as flakes, as seen in this first picture (Figure l). There are some veins of material composed of aligned fibrils, there are lots of disordered regions, and the whole structure is surprisingly porous. In this form, the flake material is not fibrous, but fortunately it can be separated into its component fibers readily. In the laboratory this is no problem; a blade spinning at high speed, such as in a Waring Blendor, will perform this task readily. One possible intermediate stage in the opening process is shown in the second picture (Figure 2). After the final stage of opening, ideally there would be only individual fibrils as shown in Figure 3* The magnification in this picture, as seen on the screen, is more than 300,000. The particles are semicolloidal in nature. Let me explain - colloids are normally defined as ranging from a top size of 10,000 A, or 1 micron, to the finer sizes. The chrysotile fibers are about 250 A in diameter, which is definitely colloidal, but the lengths are generally substantially greater than 1 micron and so are not colloidal. Opti cally, it is only possible to resolve dimensions as low as about 1 micron. Thus, we have the interesting phenomenon that the fibers are long enough to see but are not wide enough to see, so these fibers have to be studied with the aid of an electron microscope. _ In the next slide. Figure 4, the diameter size distribution of Coaljnga fibers is compared to that of Canadian fibers. Our fibers average about 260 A in diameter, while the Canadian fibers are somewhat larger in diameter. The lengths of the fibers are just about impossible to determine, but the range of fiber length is large. Unfortunately, the magnitude of the length of the fibers determines theeffectiveness of the product in some of its uses, so it is necessary to characterize the fibers some way according to their length. When a fiber is present in a fluid, it spins and turns freely as it is buffeted by thermal forces. In the presence of other fibers, however, it may collide and interact with them. There are always Van der Waals-type forces which -l4- 1 I FIGURE 1 - Replica of Asbestos Flake Magnification 9,OOOX - Photo No. 2550 -15- HT-1566 FIGURE 2 Aggregated Asbestos Fibrils Magnification 8,50OX - Photo No. 1996-H -16- HT-1567 FIGURE 3 - Liberated Asbestos Fibrils Magnification 75fOOOX - Rioto No. 23^0 -17- HT-1568 013972 013973 cause fibers to attract each other and form agglomerates. The simplest possible model relating the concentration of fibers and their probability of collision is shown in Figure 5 When the spheres of influence of the fibers start to over lap, their chances for collision go up rapidly. The volume of influence is a sphere defined using the length of the fiber as the diameter of the sphere. In the next slide, Figure 6, I have plotted this critical concentration of fibers as the function of a hypothetical average length. We have made a guess that most of the weight of our product has a length-to-diameter ratio between 100 and 1000. I have arbitrarily chosen 200 as the average l/d ratio. This corresponds to a length of about 5 microns, and the critical concentration is 0.06 gram per liter, or 60 mg. per liter, which is 60 ppm. Or to put it another way, one gram of fibers should start to interact in 17 liters of fluid. The line on the graph, by the way, has an l/d ratio of approximately 200.. That is the shape that I am proposing as the average for our asbestos fibers. Using the dimensions of 260 k for the diameter and 5 microns for the average length, I have calculated that there are about lOl1* fibrils in one gram Of asbestos. This is the ideal number, but the product that we sell probably has a hundred times of particles less per gram. In other words, all of the fibers are not liberated. This is a processing problem yet to be solved. However, first we have to solve another problem, and this is - how to determine quantitatively what the degree of liberation is. We have only begun to study this aspect of the problem. A fundamental bulk property of a solid is its solubility in water. It has been stated that asbestos has a brucite, or magnesium hydroxide, surface, so'.one might expect it to be as soluble as brucite. It is, at pH 11. At lower pH values, the influence of a silica layer below the brucite layer must become important. The solubility of asbestos is shown as a function of pH in Figure 7. Specific data points collected have been erratic, but the trend is definite. The magnesia is much more firmly bound to its structure than is the magnesia in brucite, at least down to pH 5* At very low pH values, below 1, all of the magnesia in the structure is leached irreversibly, leaving a fiber skeleton composed of silica. As noted in Figure 7, the silica has a low but finite solubility also. The pH of 11 has a special significance for asbestos, as will be seen shortly. However, the most important properties of our system are the fibrous shape of the particles and the positive surface charge of the fiber. ' Before I discuss the charge properties of chrysotile asbestos, let me introduce you in general to that important concept in the surface chemistry of colloids, the double layer. A schematic view of a double layer is shown in Figure 8. A charged particle, suspended in a solution, has an equal number of oppositely charged species in the liquid adjacent to its surface. The net charge on the particle and in its adjacent solution is zero, but there is a difference in character between the charges on the surface and those in the liquid. The surface charges occur at.fixed sites, while many of those in the diffuse layer around the particle, the double layer, are relatively mobxle~ami~iTee to' exchange with Mother ions in solution. Their distribution can be distorted bv mechanical forces, leaving the particle with an apparent net charge temporarily. In this figure, I have also shown that--the potential due to the surface charge drops off exponentisilly with distance beyond the first layer of absorbed ions. It is the form of this potential decrease which is responsible for the Boltzraan-type distribution of ions in the double layer. In Figure % two similarly charged particles are depicted as repelling each other when their double layers start to overlap. The lower sketch shows a > -19- 013974 MGUPE 5 AN APPROXIMATION OF CRITICAL FIBER CONCENTRATION FOR STRUCTURE FORMATION -20- 10-5 10'2 10-1 1 CONCENTRATION, S/1 10 100 013975 0139^ F,GURE 7 ASBESTOS SOLUBILITY IN WATER AT ROOM TEMPERATURE -22- \+ \+ \+ o1 L H*- V 3 '+ M\+ \+ Double Laver I 01397/ Solution FIGURE 8 DOUBLE LAYER AT A CHARGED SURFACE FIGURE 9 013973 CHARGED PARTICLES MOVEMENT OF A CHARGED PARTICLE IN AN ELECTRICAL FIELD ......Ol.)979' typical way in which charged properties are measured. This particular technique is known as electrophoresis. The velocity of a particle in an electric field of known strength is measured, and~potentials at the particle surface can be calculated rrom this information. The results of experimental measurements on chrysotile are given in Figure 10. Surface properties of a mineral are generally characterized by its zero point of charge. The latter..is the solution concentration of potential determining ions when .the surface has no net charge. For oxides, hydrogen and hydroxyl ions are the most important species affecting the basic surface properties. On the slide, the zero point of charge of chrysotile is shown as being at pH 11.8, 10.1, or 10.9, depending on the investigation. This is not an unusually large spread in the rather imprecise measurements common in colloidal systems. At t>H values below 10, the surface is quite positively charged, and at pH values below~b, the surface potentials increase very rapidly. ------ . At this point I will try to demonstrate the phenomenon known as dispersion as opposed to flocculation. The dispersed state is characterized by low viscosity suspensions, approaching that of water itself, while flocculated suspensions are quite viscous. The truly colloidal fibrils won't be visible as such when they are dispersed, although the aggregates of fibrils, the floes, will be visible. In the next slide. Figure 11, the zeta potentials of some other materials are shown for comparison with asbestos. The magnitudes of the potentials are lower than those shown in the previous graph because they have been calculated from data collected by different experimental techniques, but the behavior of the materials is correctly represented. The most prominent characteristic of these minerals is that they are, for the most part, negatively charged as compared with the more ppsitively charged chrysotile. * % Zeta P o te n tia l, 086110 FIGURE 11 ZETA POTENTIALS OF SOME MINERALS Zeta P o te n tia l, mv PH 0139'? Reprinted from TAPPI, Vol. 48, No. 8, August 1965 Copyright, 1965, by Technical Association of the Pulp and Paper Industry, and reprinted by permission of the copyright owner Properties of Asbestos Suitable for Use in Cellulosic Paper A. W. NAUMANN Asbestos is a class name for several naturally occurring fibrous minerals. The most common, and the one that is finding increasing use as a paper addi tive, is chrysotile, Mgt(OH)SiOut; The purpose of this paper is to compare chrysotile properties with those of other commonly used additives. CRYSTAL STRUCTURE AND PARTICLE MORPHOLOGY The structure of chrysotile is similar to that of the kaolinite minerals (/) in that it consists of an alternate series of layers of tetrahedrally coordinated silica and octahedrally coordinated magnesium joined into a composite sheet, with the tips of the silica tetrahedra and one of the surfaces of the octahedral layer lying in a common plane. The silica layer is in an oxide form. The magnesium layer is in a hydroxide form, giving this layer a resemblance to the mineral brucite |Mg(OH)j]. Figure 1 is a representa tion of the structure, the "a" dimension having been exaggerated to show the details of the structure. Pauling () predicted, before the layer structure of chrysotile was recog nized, that a magnesium analog of the kaolinite minerals would have to exist as curved sheets because of a mismatch in the repeat distances of the individual layers. The normal repeat distance for the silica layers (8.9A), as found in kaolin, is smaller than the corresponding repeat distance of an octahedral magne sia sheet (9.4A), as found in the mineral brucite (5). Pauling's prediction has been abundantly verified by X-ray dif fraction studies and by electron micro scopy (1,4, d). The layers of chrysotile curve and close to form cylinders of extreme length-to-diameter ratio. It is partially this filament-like form of chrysotile asbestos that makes it useful as an additive to a paper furnish. An electron micrograph of typical chrysotile fibrils is given in Fig. 2. As is shown by the calibration marks, the individual chrysotile fibrils are ex tremely small; many thousands being needed to make up the asbestos fila- A. W. Nacxiahh, Union Carbide Corp., Minin* and Metal* Division, Tuxedo, X. Y. Chrysotile asbestos is now available in a highly-purified, grit-free form, non abrasive to fourdrinier wire and printing plates. Its chemical and physical structure and properties are described relative to the geometry of cellulose pulp fibers. The electrostatic charge properties and surface chemistry of chrysotile in water systems are also discussed in relation to other materials found in paper furnishes. ments visible to the naked eye. Fibril lengths vary from a few microns to many tens of microns. Diameters vary much less and are usually in the range 250-350A. As the following data illus trate, this is a size considerably below that of many materials normally con sidered to be of small dimensions. Material Rock wool Synthetic organic fibers Human hair Paper pulp fibers Kaolin TiOt pigments Chrysotile Typical diaiiu<*r, y 1-20 10-40 Approx. 40 10-30 0.2-10 0.2-2 0.025-0.035 The usual mode of occurrence of chysotile is a "cross-fiber" configuration in which filaments of chrysotile (i.e., bundles of fibers) are closely packed together and set at right angles to the walls of cracks and fissures that extend through the host rock of the ore body (<>). Liberation of this materia] is accomplished by repeated crushing and classification operations (d). The re sultant products, particularly the less expensive grades, contain up to several per cent by weight of rock fragments and other abrasive constituents; and, for this reason, are not well suited to use on the high-speed machinery used in the paper industry. In 1959, an unusual deposit of chrysotile asbestos, with properties and mode of occurrence that differ from those of cross-fiber material, was dis covered in central California (7). The ore of this deposit, instead of occurring in veins, occurs in randomly-oriented, matte-like flakes and agglomerates that are not associated with the hard, con solidated rock masses characteristic of cross-fiber deposits. The ore is of high grade and is therefore amenable to different processing procedures than are usually used with conventional chrysotile ores. Specifically, wet^processing procedures have been developed that give rise to high-purity asbestos prod ucts, essentially gritrfree and of high brightness. ABRASIVENESS OF CHRYSOTILE PRODUCTS The measure of abrasiveness com monly used in the paper industry is the Valley Abrasion Test. Essentially, the method consists of rubbing a section of fourdrinier wire with a Micarta block in the presence of a slurry of the material under test. The slurry is introduced at the interface between block and wire. It then flows through the wire to a re ceiving vessel from which it is recir culated to the interface. The results of the test are reported as the "Valley Abrasion Value," corresponding to the weight lost by the wire in milligrams. Unfortunately the Valley Abrasion Test does not work well with fibrous materials, since fibers are retained on the fourdrinier wire and do not recirculate freely. A radiometric-tracer method HYDROXYL XYGEN O MAGNESIUM O SILICON 0.06A V> Fig. 1. Chrysolite structure (otter Whittaker) 2 Fig. 2. Electron mkrogroph of chryiotlU fibrils was developed to circumvent this prob lem. The details of this method have been given elsewhere (8); but, basically, it consists of measuring the amount of radioactivity transferred to the particles of a suspension, from an irradiated Waring Blendor impeller, during a pre scribed blending period. A comparison of the abrasiveness of wet-processed and conventional dryprocessed chrysotile products, along with data for bleached-sulfite paper stock, is given in Fig. 3. The data points of this figure, which establish the correlation between the Valley and the radiometric methods, are for a group of nonfibrous samples for which Valley abrasion values were available. Count-rate ranges observed for samples of the fibrous materials are superim posed on this correlation curve, and the Valley abrasion values inferred. The actual count-rate ranges for materials of the different types were: Wet-processed chrysotile products ' Bleached sulfite paper stock Dry-processed chrysotile products Count raw. count*/min . 500-1500 2000-2700 24,000-78,000 The wet-processed materials were clearly much less abrasive than the conventional products and, in fact, were less abrasive than paper pulp. The wet-processed materials, therefore, would not be expected to cause excessive wear to metal surfaces such as those of fourdrinier wires,, trimming knives, printing plates, etc. CHEMICAL AND PHYSICAL PROPERTIES It will be shown in the paper by Woolery (this issue, p. 92 A) that chrysotile is an unusually versatile paper additive. The properties that make this possible are:-1 1. Electropositive surface charge in the pH range where most paper making circuits operate 2. Highly anisodimensional particle shape 3. High surface area Chrysolite fibrils are of colloidal dimen sions and, when suspended in water, be have according to the classical electrokinetic rules of hydrophobic colloids. That is, the fibrils develop a surface charge when suspended in aqueous solu tions as a result of an adsorption of "po tential-determining" ions from the sus pending medium. With chrysotile and other oxygen-containing materials (metal silicates, oxides, hydroxides, etc.), the potential-determining ions are H + and OH ~. For a given material, adsorp tion favors hydrogen or hydroxide, de pending upon pH. Chrysotile, by virtue of the magnesium hydroxide layer ex posed at the surface, has a strong prefer ence for the adsorption of hydrogen ions. Chrysotile surfaces retain hydrogen and display a positive charge up to a pH of 10-12 (9, 10). Most materials (including cellulose and the mineral fillers commonly used in the paper in dustry) carry a negative charge in neu tral or acidic solutions. Typical values for the electrophoretic mobility of cel lulose and of representative fillers are given in Table I. The significance of the charge of chrysotile fibrils, from the standpoint of the retention of fillers and cellulose fines, is obvious. Having a mutually coagulating system of op positely charged particles is clearly desirable. Table I Electrophoretic Mobility Data for Mineral Fillers* Mat*rial Mob3ily. micron/irc pH JT/cm Kaolin (Hydrite UF) Talc (Mistron Frost) Titanium dioxide (Titanox AW'D) Bleached sulfite paper pulp Chrysotile 6.2 6.6 6.1 64 6.2 -1.4 -1.1 -1.1 -1.0 +3.1 * Data wer# obtained by the micro-electropbomia technique described by Riddick (.It)- varies as the longest dimension of the particle; while D (the diffusion con stant) varies as the mean particle di mension (11). The net result, for the rod-like particles of chrysotile, is a large effective collision radius and a large diffusion constant. It has also been established that coagulation in polydisperse systems (i.e., systems containing particles of differing sise) proceeds more rapidly than in monodisperse suspen sions (11). These factors combine to give a high probability for collisions, not only between chrysotile fibrils, but also between the fibrils and other particulate matter. Thus, in a paper furnish, chrysotile simultaneously acts as an ef fective "getter" for small particles such . as pigments or cellulose fines; and is collected itself, either by the fibers of the paper pulp or as tenuous asbestos floes. With either mode of collection, macroscopically uniform distribution of chrysotile, and of materials collected by the chrysotile, is obtained. The elec tron micrographs of Fig. 4, which are of surface replicas of handsheets prepared with and without fillers, show the distri bution of asbestos and TiOt on the sur face of a pulp fiber. The electron micrographs of Fig. 4 are of further interest with regard to the mechanical properties of paper. The strength of paper is attributable to the combined effects of four factors: (1) the strength of the pulp fibers, (2) the strength of fiber-to-fiber bonds, (3) the fraction of the fiber areas involved in bonding, and (4) the overall distribu tion of bonds as determined by sheet formation (18). The adsorption of chrysotile fibrils onto pulp fiber surfaces will have little influence on the strength of the fibers, but may have considerable influence on the bonding between fibers. It is now generally agreed that bonding in paper is due to the formation of . Electrostatic attraction, however, is only one of the factors that influence the effectiveness of chrysotile as a retention aid. The cylindrical shape of chrysotile particles is equally important. Colli sion and coagulation rate in suspensions of solids follow an expression of the form (11): ft " KDRn' where K -- proportionality constant D = particle diffusion constant R -- particle radius of influence n -- particle concentration To a first approximation, R (the collision radius of an anisodimensional particle), Fig. 3. Abrasion values for chrysolite products 3 Fig- 4. Surface repllcai of filled and unfilled paper hondiheeti hydrogen bonds at fiber-fiber contacts, and to secondary valence forces of the London-van der Waal's type. Both types of bonding are of short range nature. London-van der Waal's forces decrease as some multiple power of dis tance. Even for interactions between large particles, where the additivity of forces extend their operative range, the forces fall off rapidly in the first few angstroms and are practically nonexis tent beyond 100A 04)- Typical hy drogen bond distances are 1 to 2A 06). The diameters of chrysotile fibrils (approximately 300A) are long com pared to these bond distances. This is not to say that the fibrils act as inert spacers, separating pulp fibers by 300A; for chrysotile fibrils have OH outer surfaces that can enter into hydrogen bonding. Also, pulp fibers are pliable and deformable to a degree, and can expand to fill in the spaces between chrysotile fibrils. But the net effect is to reduce the total attraction between pulp fibers. It has been found, for example, that chrysotile additions to paper result in lower tensile and burst values, and correspondingly improved tear factor and softness. Practical applications of this effect--to improve the softness of tissue and towel prod ucts--will be discussed by Woolery. As would be expected from geometric considerations, chrysotile has a rela tively high surface area. BET nitrogen values for wet-processed asbestos suita ble for the paper industry fall in range 50 to 60 m*/g. As is evidenced by the rather extensive use of chrysotile as a reinforcing filler for plastic and resin systems, chrysotile surfaces have an affinity for organic materials. Use can be made of this property to adsorb solu ble organic matter. Adsorption occurs not only for negatively charged mole cules (anionic dyes, organic acids, etc.), where electrostatic attraction can be used to account for adsorption, but under favorable conditions can also occur with cationic species. The ad sorption of methylene blue from an aqueous solution is given in Fig. 5. Dye concentration in solution was ex tremely low until surface saturation was reached, indicating an extremely favora ble distribution between the surface and solution even though a positive'ion and a positive surface were involved. Wool en- will give examples of where the adsorption properties of chrysotile have been used for specific applications such as dye retention, improved printability, and pitch control. Another property of chrysotile that may be of interest for paper applications Fig. 5. Adsorption Iso therm for methylene blue on chrysotile is its chemical inherently a basic (alkaline) material because of the brucite-like layers that are exposed at fibril surfaces. It has been shown that the solubility and reac tivity of chrysotile suspensions are, to a first approximation, similar to those of magnesium hydroxide slurries (/0). It is also known that acid gases in the atmosphere and the acid nature of some of the constituents of paper (alum and chloride residues from bleaching) shorten the useful life of paper. It is reasonable to expect that chrysotile would provide a reserve of alkali that would adsorb and neutralise these acids, and thus would contribute to paper's permanence and durability. In summary, the shape and composi tion of chrysotile fibrils give rise to a unique combination of chemical and physical properties that should make chrysotile an unusually versatile paper additive. Nonabrasive chrysotile prod ucts are now available in quantity, per mitting their evaluation for specific applications. LITERATURE CITED 1. Whittaker, E. J. W., Acta Crytt. 9, 855(1956); 10:149(1957). 2. Pauling, L., Proc. Nat. Acad. Sci. U.S. 16:578(1930). 3. Wyckoff, R. W. G., "Crystal Struc tures," Sections IV c-1 and XII c-5, New York, Interscience, 1960. 4. Turkevich, J. and Hillier, J., Anal. Chem. 21: 475 (1949). 5. Maser, M., Rice, R. V., and Klug, H. P., Am. Mineralogist 45 : 680 (1960). 6. Sinclair, W. E., "Asbestos," Chapters 4 and 8, London, Mining Publica tions, Ltd., 1959. 7. Munro, R. C. and Reim, K. M., Can. Mining J. 83 (8): 45 (1962). 8. Hampton, W. J., Naumann, A. W., and Wahl, W. H., In "Nuclear Ap plications to the Wood, Paper, and Pulp Industry," TID-7704 U.S.A. E.C.. April 1964. 9. Pundsack, F. L., J. Phyt. Chem. 59:892(1955). 10. Martinez, E. and Zucker, G. L., J. Phyt. Chem. 64 : 924 (1960). 11. Kruyt, H. R., "Colloid Science," Vol. 1, "Irreversible Systems," Am sterdam, Elsevier, 1952, Ch. 7. 12. Riddick, T. M.,.CA*m. Eng. 68 (14): 141 (July 10, 1961). 13. Leech, H. J., Tappi 37 : 343 (1954). 14. Verwey, E. J. W. and Overbeek, J. Th. G., "Theory of the Stability of Lyophobic Colloids," Amsterdam, Elsevier, 1948, Ch. 6. 15. Pauling, L., "The Nature of the Chemical Bond and the Structure of Molecules and Crystals," 3rd ed., Ithaca, N. Y., Cornell University Press, 1960, Ch. 12. 16. Pundsack, F. L. and Reimschussel, G., J. Phyt. Chem. 60: 1218 (1956). Racztvxn Jan. 22, 1265. Presented at the 50th Annual Meeting of the Technical Association of the Pulp and Paper Industry held in New York. N. Y-, Feb. 21-25,1965. The author wishes to thank Mr. Wolbert Roettcers (or the preparation of the electron microcrapbs ot this communication. F-71-026 1M 2/71 Printed In U.S.A 01393 EQUIPMENT AND PROCEDURES FOR MOUNTING MILLIPORE FILTERS AND COUNTING ASBESTOS FIBRES BY PHASE CONTRAST MICROSCOPY Stephen G. Bayer Ralph D. Zummalde Thomas A. Brown Bureau of Occupational Safety and Health 1014 Broadway Cincinnati, Ohio 45202 February 1969 U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE Public Health Service Consumer Protection and Environmental Health Service Environmental Control Administration Lw 1 *1t . ^"s.. Sw 'l1 i/ j TABLE OF CONTENTS Page INTRODUCTION 1 EQUIPMENT LIST 1 LABORATORY SET-UP 2 PRELIMINARY MICROSCOPE SET-UP 2 MICROSCOPE SET-UP AND THE PROCEDURE FOR OBTAINING KOHLER ILLUMINATION 4 DETAILED INSTRUCTIONS FOR BAUSCH AND LOMB BINOCULAR MICROSCOPES 7 FILTER MOUNTING Set-up Prior to Mounting 8 8 Mounting Procedure 8 MICROSCOPE PRECAUTIONS AND MAINTENANCE 9 COUNTING PROCEDURE 10 FIELD MONITOR DISCUSSION 11 CALCULATION OF CONCENTRATION 12 ADDRESSES 15 013987 FOREWORD To determine concentrations of asbestos dust in air for comparis with established hygiene limits, a simple reproducible method is required. A simple and inexpensive sampling method uses disposable (reloadable if desired) plastic membrane filter holders, pre-loaded with membrane filters These membrane filters may be rendered transparent and the asbestos fibers counted with a phase-contrast microscope at 430X (or 400X). This method has been used by the Asbestosis Research Council in Great Britian and the U. S. Public Health Service in the United States of America. It is specified in the proposed change for asbestos in the 1968 threshold limit values of the American Conference of Governmental Industrial Hygienists. Uniform procedures must be used for carrying out these counts if reproducible results are to be achieved. Detailed equipment and procedures used by the U. S. Public Health Service are described here. -1- 013938 INTRODUCTION For several years, a set method for counting and sizing airborne particulate matter, which has been deposited upon membrane filters, has been used. The filters used in this technique are 37 mm diameter cellulose ester membrane filters manufactured by Millipore Corporation,(Cat. No. AAWP03700). The slide mounting technique refers only to these filters, and will not work for any others. The filters may be purchased premounted in convenient field monitor cases, and are ready for sampling. The filters are nearly 100% efficient for any asbestos dust, even for fibers with diameters much smaller than the 0.8 micron (-f) pore size. Sample preparation for electron and optical examination are both relatively simple. Slide mounts of the filters are semi-permanent. The following procedures and recommendations will produce accurate results, if each step is performed exactly as indicated. EQUIPMENT LIST1 11 1. Table 2. Adjustable chair 3. Phase contrast microscope 4. Ribbon filament illuminator or (built-in illuminator) 5. Eye piece reticle (Porton type) 6. Lens tissue 7. Small camels hair brush # 8. Slides 9. Cover slips 10. Spatula 11. Tweezers 12. Scalpel 13. Wheaton Balsam bottle 013989 LABORATORY SET-UP It is important to provide a suitable counting area, for the room in which the counting is to be done has a great bearing upon the microscopist. It should be out of the way of normal traffic, and be kept as free from dust and smoke as possible. The tables on which the microscopes are placed should be free from vibrations and shocks as possible. An adjustable chair will do much to add to the comfort of the counter. PRELIMINARY MICROSCOPE SET UP ' Before any dust sizing or counting can be done, proper equipment must be at hand. This section describes the required equipment. The illuminator should be small and reasonably compact. Ribbon filament illuminators are generally much easier to use. The illuminator must incorporate a condensing lens, so that the enlarged image of the lamp filament may be focused in the plane of the substage condenser diaphragm. The illuminator must also have an iris diaphragm located as near as possible to the condensing lens. The iris serves as a field diaphragm and is focused in the plane of the specimen. The microscope used must have a substage condenser fitted with an iris diaphragm. This iris serves as an aperture diaphragm. The microscope should have a calibrated reticle inside the non-adjustable eyepiece. The reticle should be small enough that all the counting field is in focus (if the flat field objective and eyepieces are used, essentially the entire field will be in focus). The microscope must be equipped with phase contrast accessories. Using phase contrast, even objects with almost the same refractive index as the mounting media can be seen. Light waves which travel through such a specimen are retarded by a fraction of a wave-length to produce a change in phase. The phase contrast optical system reveals these phase changes as light or dark contrast against the background. -3- 013990 This procedure was written by a user of Bausch and Lomb phase-equipped microscopes, so that microscope set-up procedures correspond with these. However, any good microscope with phase contrast accessories will be satisfactory. ^ For continual routine examination of filters, the binocular type microcope is much more comfortable. The use of .3 first surface mirror is recommended, but not necessary. By utilizing a second surface mirror, multiple images of the illuminator field iris are formed which will detract from the crispness of the final image. As mentioned previously, the microscope must contain a reticle. Any reticle, such as the Porton or Patterson Globe and Circle, which projects a constant counting area and has provision for sizing, will work. The Porton reticle which we use outlines a-rectangle that fits easily within the periphery of focus. The rectangle is divided into two squares. The left square is divided into six rectangles which constitutes the counting area. Above and below the large rectangle are a series of circles in which every other circle doubles in diameter. Hence the third is twice the diameter of the first; the fourth is twice the size of the second, etc. The right half of the rectangle contains a scale for extending the size above the number nine n circle. The formula D=L 2 describes the circles sizes. The diameter D is found from L which is the unit of length, and N which represents the number of the circle. L is determined by calibration with a stage micrometer. The entire length of the Tectangle is 200 L units. By measuring the length and dividing by 200, L is obtained and the circle sizes may be calculated. When ever a microcope is disassembled or cleaned, the reticle calibration should be checked. Another fact to take into consideration is that changing the interpupillary distance of the binocular will change the calibration, so the -4- microscopist may want to check the calibration at both extremes of adjustment. The counting area on the reticle should be kept as clean as possible, as dirt on the reticle is in focus and may be counted. MICROSCOPE SET-UP AND THE PROCEDURE FOR OBTAINING KOHLER ILLUMINATION* 1 By utilizing equipment that meets the requirements just mentioned, any counter may achieve comparable counts after some practice. This section will deal with setting the microscope up and obtaining Kohler illumination. It is extremely important that every step be followed exactly as indicated. 1. Place the microscope on a flat, level surface at a height such that the eyepieces may be observed without strain or discomfort. 2. Place a moderate dust sample upon the stage. 3. Place the illuminator directly in front of the microscope. Sight across the two and be sure they are aligned. For coil filament bulbs the illuminator iris should be ten inches from the center of the microscope mirror. For ribbon filament bulbs, the front of the filter holder should be seven inches from the center of the plane side of the mirror. Never use the curved side 4. Remove all diffusing filters from the system and insert a neutral density filter and a clear blue filter. Blue or green colored filters may be used at the discretion of the microscopist. NOTE: Where the microscope includes a built-in illuminator to give Kohler illumination, the above steps will not all be necessary. 013992 .-5- REVIEW A. Check microscope and illuminator alignment. B. Check the distance between the microscope and the illuminator. C. Be sure that you are using the flat side of the mirror. D. Make sure that there are only two filters in the system. 5. By means of the focusing knob on the side of the substage condenser assembly, raise it until the upper lens nearly touches the bottom of the slide. Remember that the free working distance of the condenser is in the order of 1.2 mm and that the slide is about 1 mm thick. 6. Turn on the illuminator. Using the tilt controls, direct the beam onto the center of the mirror. Then, by tilting the mirror direct the beam upward into the condenser. 7. Close the substage iris completely. Open the illuminator iris all the way. 8. By means of the focusing controls on the side of the illuminator, focus the image of the filament on the bottom of the substage iris. This may be done by leaning over the microscope and observing the substage iris in the microscope mirror. (On such models as the Bausch and Lomb PR-27, there is a fine focus knob at the rear of the illuminator. In that case, move the condensing lens all the way forward and trim the focus with the fine focus knob.) 9. Open the substage iris about half way. # REVIEW ' A. Check the distance between the slide and condenser. 013993 -6- B. Be sure that the beam is striking the center of the mirror, and that it is being deflected upward into the condenser. C. Please repeat step 7. D. Check step 8. If the image is not in focus now, correct it. Do not continue until the filament is correctly focused. E. Please repeat step 9. 10. Put the 10X objective in place and focus on the sample. This is done as follows: First, looking from the side of the microscope, lower the objective until it gets very near to the slide. Then, by looking through the eyepieces, focus up. Never focus down with coarse focus when looking through eyepieces. A word of caution: The objective lenses are very expensive, so be careful not to grind them through the slide. Always focus up. Now trim the focus with fine focus knob. Focus sharply on the sample. Secondly, close the field iris fully. If the consenser is nearly in focus, you should see a bright spot of light. By using the condenser focus knob, bring the field iris into sharp focus. Now, both the field iris and the objective are in focus on the sample. If there appear to be multiple images of the field iris, it is because of the second surface mirror. Some of the light waves are reflected from the first surface, resulting in secondary images. 12. If the image of the field iris is not centered, re-center it by tilting the mirror. If the color around the field iris is not uniform, recheck the tilting of the illuminator. REVIEW A. Check and be sure you are focused on the sample. 10X objectives have a relatively long focal length and it may be possible to focus on: (a) the top of the cover slip, (b) the sample, (c) the bottom of the filter, (d) the top of the slide, (e) the bottom of the slide, (f) the top of the condenser. So be sure of the focal plane. n ? *7 0 o * -7- B. Be sure that the field iris is focused in the sample plane. Check this often when examining samples. As the sample focus changes, so does the condenser focus. C. Recheck the centering and tilt of the illuminator. DETAILED INSTRUCTIONS FOR BAUSCH AND LOMB BINOCULAR MICROSCOPES1 1. Leave the microscope phase ring on C. Insert the telescope that is supplied with the kit into the right eyepiece tube. Focus on the dark phase ring. Open and close the substage iris to be sure that it is centered in relation to the objective phase ring. If it is not in the center, loosen the set screw on the condenser mount and properly seat the condenser. Then re tighten the set screw. This should very seldom be necessary. Do not force anything and be careful and patient. When you are satisfied that the condenser is aligned, open it all the way. 2. Turn the phase wheel to 10. This shows that the 10X phase ring is in place. Look through the telescope again. By using the adjustment screws on the side of the condenser, move the rings until they are perfectly concentric. When changing phase rings, move them carefully, so as not to knock the condenser out of alignment. 3. Turn to the 43X objective. Carefully turn the wheel to the 43 phase ring. Align the two rings in the same manner as performed in step 2. 4. Remove the telescope and replace the eyepieces. Again, check the condenser focus. You are now ready to examine the sample at 430X, assuming that you are using 10X eyepieces. 01392 8- - FILTER MOUNTING Set-up Prior to Mounting Have available at hand a quality scalpel and a supply of No. 10 curved blades, a pair of tweezers (fine pointed are preferred), a spatula or fire polished glass rod and a box of lens tissue. Slides (1" x 3" or 25 x 75 mm) with frosted ends are best because one may label the slide with the date, sample number, etc. It is advisable to use quality number 1-1/2 cover slips. Most dry objectives are corrected for this thickness cover glass. The mounting media should be kept in a Wheaton balsam bottle. The edge around the lid should be coated with stopcock grease to keep out the surrounding air. The mounting solution may now be prepared. A one to one solution by volume of dimethyl phthalate and diethyl oxalate is poured into the balsam bottle. Then add 0.05 gram of filter material for each milliliter of solution. The added filters increase the viscosity of the solution. Before using the solution, all of the filter material must be dissolved and the solution must be of uniform consistency. This may require a day or so with frequent stirring. Refrigeration may add to the shelf life of the solution. Mounting Procedure Keep in mind that cleanliness is important. First, lay down two pieces of lens tissue; one directly in front of you and the other to the left or right for the mounting tools. Next, wipe the scalpel, tweezers and glass rod or spatula with lens tissue. Holding a slide by the frosting, wipe it clean. Lay it down with the frosted end toward you. Even pre-cleaned slides must be cleaned this way. Hold a cover slip by the edges between the index finger and the thumb, and clean it in the same manner as the slide. Place the cover slip so that one edge rests on the unfrosted end of the slide and the other edge rests on the lens tissue. Be sure that the lower surface does not come into contact with the lens tissue. -9- 013996 Using the glass rod, or dropper, dispense a small drop of the mounting media onto the center of the slide. Replace the rod or dropper into the solution bottle and cover it. Using the spatula, spread the solution into a triangular shape. While the fluid is spreading, cut a wedge of corresponding size from the filter. Place it upon the mounting media, sample side up. Pick up the cover slip and place it on top of the filter. Press lightly on the cover slip to be sure the mounting media has made contact with it. Label the slide before completing any other slide. Sometimes, after an hour or so, the filter may not have cleared. Usually, this can be cured by pressing lightly on the cover slip with a pencil eraser that has been wrapped with lens tissue. If the filter has been used to filter liquids or is damp, it will require drying, for it will not clear unless completely dry. Use only enough solution to clear the filter. If too much solution is used the sample may spread and give an erroneous count per unit area. The filter should be counted as soon as possible because the solution may eventually form crystals that look like fibers and may be mistaken for part of the sample. After a little practice and experience, several samples may be mounted at the same time with excellent results. Remember to keep the area in which mounting is done as clean as possible to prevent contamination of the filter. MICROSCOPE PRECAUTIONS AND MAINTENANCE Quality lens tissue is a must. S' ' The microscopist should use it for any kind of lens cleaning. It should be as lint free as possible. It may be wrapped around the blunt end of a small camels hair brush and used to clean the eyepieces. Never wipe the inside of the microscope body. If it is necessary to remove dirt from the inside of the tubes, blow it out with -10- 01399V an aspirator bulb. Whenever you are using immersion oil, be sure that you wipe all surfaces that were in contact with the oil. Generally, solvents should not be used when cleaning lenses. Alcohol, like most solvents will dissolve the lens mounting cement, which may ruin the lens system. Xylene should be used sparingly to remove immersion oil. Use a camels hair brush to clean first-surface mirrors and noncritical lens surfaces. Never wipe first-surface mirrors with lens tissue. Avoid touching a lens surface with fingers as the fingerprint has a tendency to etch into the lens surface. COUNTING PROCEDURE Place the sample on the stage and focus on it. Since the sample is retained in the top ten to fifteen microns of the filter, be sure that you are focused in the proper plane. The reticle in the left eyepiece is used to define the counting area. The reticle should be calibrated prior to being used. The total fiber count (a fiber is anything three times as long as it is wide) should be at least 100 fibers, or twenty fields, which ever is less. It is advisable to make as large a count as practical to get an accurate average. If a fiber crosses the limits of the counting field, only those crossing either or both of two adjacent sides are counted. For example, a fiber crossing the top or right, or possibly both sides would be counted. The sides chosen are at the discretion of the counter, but any counter must always use the same sides. The fibers counted are estimated as to length, using the circles at the top of the reticle. Our practice has been to record all fibers seen, all fibers longer than five microns and all fibers longer than 10 microns. However, for comparison with the ACGYH TLV (1968), only the longer than 5^ fibers need be counted. -11- 013998 FIELD MONITOR DISCUSSION ' Membrane filters may be purchased pre-loaded in plastic holders (Aerosol Analysis Monitors). The Monitors consist of three sections. The filter is held between the middle and bottom sections. Between the membrane filter and the bottom section lies a support pad. The calibrated pump, designed to draw a known and constant supply of air, is always connected to the bottom of the field monitor case. When many loaded cases are taken into one particular area for sampling, a blank or control filter (meaning a loaded field monitor case) should be taken out to the area, brought back unused and counted. This will determine what degree of general contamination is present on the filters. We have found that banding the field monitor cases with cellulose bands greatly reduces the general contamination of the filters. The bands may be purchased from Walter H. Jelly and Company, Inc. They are white, opaque, size 41 x 25 and come packed' in solution S-132. Upon removal from the solution, the bands are slipped around the middle and bottom joints, or around all joints, depending upon whether the sample is going to be drawn through the top section plug hole, or the entire top section removed for "open" sampling. The latter procedure is recommended for asbestos dust sampling since it results in a more even sample distribution over the entire exposed filter surface. Convenient personal sampling pumps, such as those distributed by Mine Safety Applicances Co., Willson Products Division or Union Industrial are excellent for short term, low rate (around 2 1pm) sampling. A sampling pump is connected to a 3 foot length of non-collapsable, one quarter inch, rubber tubing with a male Leur slip adapter (stock number LH/L, available from Becton, Dickinson Co.) inserted into the other end. This enables one to connect the hose directly to the case by simply inserting the adapter into the plug hole at the bottom of the case. -12- 013999 Field monitor cases may easily be re-used. The plugs and all x sections are separated and placed in warm detergent water. The parts should be scrubbed thoroughly and rinsed in tap water. However, if the filters are to receive any chemical analysis, the cases should also be rinsed in distilled water. The cases should be allowed to dry in a clean area,(a clean room is preferable), to reduce contamination. The clean area is equally important when loading the filters into the cases. The filter pad (the thicker, fibrous disc) is placed in the bottom section. The filter is placed directly on the pad. The middle and top sections are added, the case is pressed tightly together, and the top plug is inserted. Replacement of the bottom plug is not necessary. A cellulose band is then placed around the case and after the band dries, the unit is ready for sampling. Sample code numbers, etc. may be written on the band or upon the filter case, first making sure the markings can be removed when and if it is necessary. Additional information concerning filters and field monitors may be obtained from Millipore Corporation. CALCULATION OF CONCENTRATION When a sample is taken, pertinent information about the sample should be recorded at the sampling site. First, the sample number should be written on the field monitor case and the sample ticket. Next, enter a description of his operation in the appropriate space. If the sample is a general air sample and does not pertain to any particular employee, write "general air sample" in the employee's name space. Information about the area may be written in the "description of operation" space. If you have several pumps which are identical in appearance, but have different flow rates, it would be a good idea to assign them instrument numbers. This enables you to keep accurate records of maintenance and calibration. When instrument SUPERVISBESTOS A REVIEW OF PRODUCT QUALITY, TEST METHODS AND END-USE PERFORMANCE CHARACTERISTICS B. L. Ingalls December 27, 1982 013841 Supervisor D. F. Kapral Project No. 530-10905 UNION CARBIDE CORPORATION METALS DIVISION PRODUCT DEVELOPMENT-TECHNOLOGY P.O. BOX 579-NIAGARA FALLS, NY 14302 SUMMARY 013842 Supervlsbestos was introduced as a drilling fluid vlscosifler and suspension aid In 1969. Product specifications were established based on Fann Viscometer Apparent Viscosity and Yield Point values of 15 cps and 25 lb/100 ft. 2 respectively. Originally, these specifications were high enough to exclude other competitive products from qualifying but lower than typical values for Supervlsbestos being manufactured at the time. In recent years, the plant has had difficulties meeting these specifications; and new competitive products, namely Flosal, have made significant Inroads both in quality and the marketplace. A review of product quality over the last several years was con ducted to determine the possibility of any trends. Some 60 monthly composite samples available from years 1970 through February 1982 were tested and analyzed statistically. The data support two Important conclusions. First, the average quality of production over the years borderlines the minimum Q. C. specifications, particularly with regards to Yield Point; and secondly, the extent of product variation has declined since the early seventies. No sign ificant trends were observed In mean production values based on regression analyses of the data. Variances In Supervlsbestos quality are dependent primarily on the Hartz jig and M-30 mill performance characteristics. Other factors can Influence product quality, however, particle size distribution* analyses suggest a strong correlation between quality and these production operations. Less than one percent of 1982 Supervlsbestos production was off spec as of the third quarter this year. This Is attributed to Improved efficiencies In the rock fiber circuit due to the new ore slurry feed system and Increased attention to the wet milling operations. The AEC #2 quality control test currently used in production demonstrated reasonable correlation with performance characteristics based on settling tests. However, the relationship is purely empirical and not Indicative of rheological Influences existing In application. Furthermore, this test cannot be used for comparison of asbestos materials having signi ficantly different fiber length distributions or other types of mineral thickening agents. The AEC test does not take into account the effects of shear and time-dependent properties which can vary significantly for different materials. Multi-point measurements over a broad range of shear rates with time studies are required to define the rheological properties of non-Newtonian time-dependent systems. A simplified test procedure consisting of a single point measurement without bentonite has been developed for production quality control. It's Implementation Is pending reveiw by the plant. A similar test is also being developed for the pelletized version of SVB. Flosal, a Canadian asbestos product, was found to exhibit somewhat higher viscosities and anti-settling characteristics when compared to Super vlsbestos at the low shear-rates Indicative of drilling operatings. Long fiber fractions (50-100 +y M) present in Flosal contribute to high rheopectic property which causes viscosity to increase at low shear rates. Flosal is also highly i 013843 pseudoplastic; 1e: viscosity decreases with increasing levels of shear. This could adversely affect its relative sweeping capabilities at high shear rates existing at the bottom of the hole. Both products, however, exhibit excellent viscosity building and suspension properties. In the author's opinion, the performance characteristics of the two products are in all probability indis tinguishable in application. The relationship between rheological properties and fiber length distribution is of academic importance. Supervisbestos has a finer particle size distribution and a surface areaH-1/2 times that of Flosal; and yet its performance characteristics are somewhat inferior at low shear rates. The principle mechanisms affected by fiber length are time and shear dependent properties. In effect, performance characteristics can be improved within limits by changing fiber length distribution. Although unsubstantiated, fiber aspect ratio may be a contributing factor as well. RECOMMENDATIONS 1. A minimum specification of 13 cps based on Apparent Viscosity as defined by the current AEC #2 test procedure is recommended. Results demon strated a significant drop off in both physical properties and settling characteristics of SVB products having Apparent Viscosities less than 11 cps. A minimum Av of 13 cps would insure product quality within predictable limits of test variability. 2. It is recommended that the Yield Point specification be discontinued. Yield Point offers no advantage as a secondary specification number. It has been shown that Yp has no real significance as related to end-use performance characteristics. 3. A simplified Q.C. test based on a single point Fann measurement with out bentonite is recommended for Supervisbestos. It has been shown that bentonite does not contribute to product quality or alter test results in any way. Furthermore, bentonite is a potential source of test variation. An asbestos suspension having a solids content of 12 to 15 grams per 400 ml distilled water is recommended for test purposes. The slurry should be mixed for 10 minutes with a Multi-mixer (3 discs) at 11 ,500 rpm. Measure ments are to be based on the Fann 600 rpm value taken at 15 seconds. The minimum product specification should equate to the 13 cps AEC test value stated earlier. . 4. Unlvis should have the same minimum 13 cps Av specifications as Super visbestos. A test similar to the SVB aqueous test described herein should be developed for Unlvis. Some modifications of the SVB test may be required in order to Insure proper opening of the pellets. Exact details of the test procedures will be worked out In cooperation with the plant. 5. Potentially new products and/or applications could be developed with a better understanding of the imp!icatons of fiber length distribution on rheological behavior In both aqueous and polymer suspensions. Further study is recommended in this area. ii TABLE OF CONTENTS SUMMARY RECOMMENDATIONS LIST OF TABLES LIST OF FIGURES INTRODUCTION ACKNOWLEDGMENTS EXPERIMENTAL DISCUSSION 1.0 AEC #2 QUALITY CONTROL TEST 2.0 PRODUCTION QUALITY CONTROL HISTORY 3.0 SIGNIFICANCE OF PARTICLE SIZE DISTRIBUTION ON PRODUCT QUALITY 4.0 IMPLICATIONS OF RHEOLOGICAL PROPERTIES ON RELATIVE PERFORMANCE CHARACTERISTICS 4.1 Background Theory 4.2 Effects of Mixing Energy 4.3 Relative Performance Characteristics-Anti Settling Properties 4.4 Comparison of Rheological Properties and Settling Characteristics 4.5 Supervisbestos Production Specifications 5.0 FLOSAL COMPETITIVE PRODUCT EVALUATION REFERENCES APPENDIX I - Production Data & Statistical Computations APPENDIX II - Tabulated Fann Viscosity & Settling Data 013844 Page i ii 1 1 2 3 4 6 11' 13 20 26 31 32 50 51 60 LIST OF TABLES TABLE I * Particle Size Distribution of Several Supervisbestos Products TABLE II Comparison of Supervisbestos Properties TABLE III Typical Physical Properties of Flosal & Supervisbestos TABLE IV * AEC #2 Fann Test Results on King City Supervisbestos Monthly Composites for Years 1970 - 1982 TABLE V Statistical Data Reference for Figure 2 TABLE VI Statistical Data Reference for Figure 3 TABLE VII Statistical Data Reference for Figure 4 TABLE VIII * Statistical Data Reference for Figure 5 TABLE IX Fann Viscosity and Settling Test Results TABLE X Settling Tests 10 Lb/bbl Asbestos Aqueous Suspensions TABLE XI Settling Tests 3 Lb/bbl Asbestos Aqueous Suspensions TABLE XII * Fann Rheological Properties of (1:1) Ratio Supervisbestos Feb.-76/Bentonite Aqueous Suspensions ..................... TABLE XIII * Fann Rheological Properties of (1:1) Ratio Supervisbestos Nov,-76/Bentonite Aqueous Suspensions ................ TABLE XIV Fann Rheological Properties of (1:1) Ratio Supervisbestos June-74/Bentonite Aqueous Suspensions ........... TABLE XV Fann Rheological Properties of (1:1) Ratio Supervisbestos Sept.-73/Bentonite Aqueous Suspensions ......................... s TABLE XVI * Fann Rheological Properties of (1:1) Ratio Supervisbestos March 73/Bentonite Aqueous Suspensions TABLE XVII Fann Rheological Properties of Supervisbestos Feb.-76/Aqueous Suspensions 013845 Page 10 31 33 52 54 55 56 57 61 62 63 64 66 68 70 71 73 013846 LIST OF TABLES (Contd.) TABLE XVIII .... Fann Rheological Properties of Supervisbestos Nov.-76 Aqueous Suspensions TABLE XIX .... Fann Rheological Properties of Supervisbestos June-74 Aqueous Suspensions TABLE XX .... Fann Rheological Properties of Supervisbestos March-73 Aqueous Suspensions TABLE XXI .... Fann Rheological Properties of (1:1) Ratio Flosal Feb.-82 TABLE XXII .... Rheological Properties of Flosal Feb.-82 Aqueous Suspensions TABLE XXIII .... Fann Instant Reading Test Results (1:1) Asbestos/Bentonite 10 Lb/Bbl Suspensions Page 75 77 79 81 83 85 013847 LIST OF FIGURES Figure 1 .... Graphical Representation of Yield Point Figure 2 ----- Supervisbestos Production Quality Control Values for Apparent Viscosity Figure 3 .... Least Squares Fit of Av Values for Supervisbestos vs. Production Year Figure 4 .... Supervisbestos Production Quality Control Values for Yield Point Figure 5 .... Least Squares Fit of Yp Values for Supervisbestos vs. Production Year Figure 6 .... Typical Flow Curves for Time-Independent Non-Newtonian Fluids Figure 7 .... Affect of Mixing Time on Shear Stress Response of 10 lb./bbl. (1:1) Ratio Asbestos/Bentonite Suspensions Figure 8 ----- Shear Stress-Shear Rate Curves for (1:1) Supervisbestos/Bentonite Suspension ; - Figure 9 .... Shear Stress-Shear Rate Properties of Supervisbestos Suspensions Figure 10---- Time Dependent Properties at 170.4 sec"1 of 10 l)b/bbl (1:1) Supervisbestos (2-76)/Bentonite Suspensions Prepared with the Multi-Mixer for 5 to 20 Minutes Figure 11 ---- Time Dependent Properties at 170.4 sec"1 of 10 Ib/bbl (1:1) Supervisbestos (2-76)/Bentonite Suspensions Prepared with the Multi-Mixer for 25 to 50 Minutes Figure 12 .... Settling Characteristics of Supervisbestos/Bentonite Suspensions Mixed in Multi-Mixer for 10 Minutes (5 lb. Asbestos, 5 lb. Bentonite and 44 lb. W03 per Barrel) Figure 13 .... Settling Characteristics of Supervisbestos/Bentonite Suspensions Mixed in Multi-Mixer 40 Minutes (5 lb. Asbestos, 5 lb. Bentonite and 44 lb. W03 per Barrel) Figure 14 .... Settling Characteristics of Supervisbestos/Bentonite Suspensions (1.5 lb. Asbestos, 1.5 lb. Bentonite and 13 ib. WO3 per Barrel) Figure 15 .... Comparison of the Settling Characteristics of Supervisbestos and Supervisbestos/Bentonite Aqueous Suspensions Figure 16 ----- Settling Properties vs. Apparent Viscosity Values 3 5 7 8 9 11 14 16 17 18 19 22 23 24 25 27 LIST OF FIGURES (Contd.) Figure 17 .... Settling Properties vs. Fann Yield Point Values Figure 18 .... Time Dependent Properties @ 170.4 sec"1 of 10 Ib/bbl Asbestos Suspensions Figure 19 .... Relationship Between Supervisbestos and Supervisbestos/ Bentonite Suspensions Figure 20 .... SEM Photomicrograph of Flosal as is @ 500 X Figure 21 .... SEMPhotomicrograph of Supervisbestos as is @ 500 X Figure 22 .... SEM Photomicrograph of Flosal as is & 2000 X Figure 23------SEM Photomicrograph of Supervisbestos as is @ 2000 X Figure 24 .... SEM Photomicrograph of Flosal @ 100 X Prepared from Dilute Aqueous Suspension Figure 24a.... EDAX Full Field Scan of Area in Figure 24 Figure 25 .... SEM Photograph of Supervisbestos @ 100 X Prepared from Dilute Aqueous Suspension Figure 25a.... EDAX Full Field Scan of Area in Figure 25 Figure 26 .... SEM Photomicrograph of Supervisbestos @ 20,000 X Prepared from Dilute Aqueous Suspension Figure 27 ----- SEM Photomicrograph of Flosal @ 20,000 X Prepared from Dilute Aqueous Suspension Figure 28 .... SEM Photomicrograph ofSupervisbestos @ 50,000 X Prepared from Dilute Aqueous Suspension Figure 29 .... SEM Photomicrograph of Flosal @ 50,000 X Prepared from Dilute Aqueous Suspension Figure 30 .... Flosal and Supervisbestos Comparisons-Settling Tests (1:1) Asbestos/Bentonite Suspensions (10 Minute mix in Multi-mixer) Figure 31 ____ Flosal and Supervisbestos Comparisons-Settling Tests . 1:1 Asbestos/Bentonite Suspensions (40 Minute Mixing in Multi-Mixer) Figure 32 ____ Flosal and Supervisbestos Comparisons-Settling Tests Asbestos Suspensions 013848 Page 28 29 30 34 34 34 34 35 35 35 35 36 36 37 37 39 40 41 LIST OF FIGURES (Contd.) 4. Figure 33 .... Time Dependent Properties at 170.4 sec"! of 10 Ib/bbl (1:1) Flosal/Bentonite Suspensions Prepared with Multi-Mixer for 5 to 20 minutes Figure 34 .... Time Dependent Properties at 170.4 sec"1 of 10 lb/bbl (1:1) FIosal/Bentonite Suspensions Prepared with Multi-Mixer for 30-50 Minutes Figure 35 .... Time Dependent Shear-Stress Response of 1:1 Asbestos/ Bentonite Suspensions Figure 36 .... Pseudoplastic (Shear Dependent) Properties of Supervisbestos and Flosal Bentonite Suspensions 013849 Page 42 43 44 45 Figure 37 .... Pseudoplastic (Shear Dependent) Properties of Supervisbestos and Flosal Bentonite Suspensions After Shearing 0 170.4 sec-1 for 5 Minutes 46 Figure 38 .... Relationship Between Settling Characteristics and the Rheological Properties of Asbestos Aqueous Suspensions (a) Apparent Viscosity 0 1022 sec"1 (b) Yield Point 9 1022 & 511 sec"1 Figure 39 .... Relationship Between Settling Characteristics and the Rheological Properties of Asbestos Aqueous Suspensions (a) K (based on 10.2 - 5.1 sec"1) (b) K (based on 1022- 170.4 sec'1) Figure 40 ___ Normal Probability Plot for ApparentViscosity Figure 41 __ Histogram of Apparent Viscosity Figure 42 .... Normal ProbabilityPlot for YieldPoint Figure 43 __ Histogram of Yield Point 47 48 58 55 59 59 INTRODUCTION 013850 Calldrla Supervisbestos products were developed for oil and gas well drilling fluid applications and are sold by Montello, Inc. Originally, product specifications were selected which were high enough to exclude other asbestos products from qualifying, namely Flosal, but were lower than typical values for Supervisbestos being manufactured at the time. In 1978, specifications were reduced by roughly 10%. This has led to some concern on the part of Montello, Inc. and speculation of a downward trend in SVB quality. In 1973, Drilling Specialities Introduced a new version of Flosal based on Canadian chrysotlle that was alleged to be equal to Supervisbestos. Prior to this, Flosal was produced from California Coallnga chrysotlle. Sub sequent studies In 1974 by Or. H. B. Rhodes, et. al. confirmed that the new Flosal had In fact been Improved substantially ('). Since then questions have been raised regarding the relative merits of Flosal and Supervisbestos In actual application. The present study was undertaken with the following objectives: 1. Determine the significance of production trends pertaining to Supervisbestos quality over the last ten years. 2. Review current test methods and establish quality control guide lines Indicative of end-use performance characteristics. 3. Determine comparative rheological characteristics of Supervisbestos and Flosal. Results reported herein are based on the definition of asbestos physical properties as related to rheological behavior in aqueous suspensions. The Influences of particle size, fiber length distribution and electroklnetlc phenomena on performance characteristics are discussed. ACKNOWLEDGMENTS Acknowledgments and my thanks are due Messrs. Fred Smith and Bob Robazza for their many contributions to this work. Fred assisted with computer compilations of the data and statistical analyses. The major body of data reported herein were collected by Bob with unerring patience and precision making It possible to present this work with confidence. , -1 - EXPERIMENTAL 013851 A Multi-mixer Model 9B with 3 discs was used for preparation of the asbestos slurries. Total solids content of the suspensions was 2.86% by weight equating to 10 lb/barrel, unless specifically stated otherwise. Bentonite, where used, was added on a one to one basis to asbestos. Tap water was used with exception of distilled water in the case of the standard Q.C. AEC #2 test. Rheological data were measured with a Model 35 Fann V.G. Meter at 600, 300, 200, 100, 6 & 3 rpm at 15 second intervals except as stated otherwise. Equivalent shear-rates in reciprocal seconds may be obtained by multiplying Fann rpm times 1.704. All Fann readings were obtained at ambient temperatures ranging between 21-25C. In order to eliminate variations due to time required for cooling after prolonged mixing, all the samples were allowed to stand over night. The suspensions were then re-dispersed for 2 minutes with the Multimixer prior to Fann tests to negate any settling or syneresis effects. Relative performance characteristics analogous to conditions existing in the annulus of the well were based on quiescent settling tests with tungsten oxide weighting agent. WO3 has a specific gravity of 7.2 which is equal to a density of 60 lbs/gal. Typical drilling formations have a density of 20 to 23 Ibs/gal. Settling was observed at high and low solids concentrations. Tungsten oxide was added at a concentration of 12.5% by weight (*v44 lb/bbl)during the last two minutes of the mix cycle. 250 ml of the resultant slurry was trans ferred to a 250 ml graduate cylinder. The remaining 150 ml of slurry was added to a 500 ml cylinder and diluted to the 500 ml mark. The cylinder was then Inverted 25 times to achieve a hqrriogeneous suspension. Settling was recorded by measuring the height of the interface in milliliters between clear water and sinks. Percent settling was reported as the height of the column minus the height of the Interface divided by the height of the column times 100. Flocced and dispersed wet screen analyses were performed as outlined in the "Calidria" asbestos Physical Tests and Procedures Manual - B. L. Ingalls, October, 1979. DISCUSSION 013852 1.0 AEC #2 QUALITY CONTROL TEST The AEC quality control test currently used by King City for Supervlsbestos Is based on Fann Viscometer Apparent Viscosity (Av) and Yield Point (Y ) at 600 and 300 rpm of a 1:1 Supervlsbestos & Bentonite aqueous suspension. Total solids are 10 grams per 350 ml distilled water (10 Ib/barrel system). Slurries are mixed In a Multi-mixer with 3 discs for 4 minutes at 11,500 rpm prior to Fann measurements. The Fann Is so designed that Av (centlpolse) may be calculated directly by dividing the 600 rpm reading by 2. Yield Point (lbs/100 ft.2) is determined by multiplying the 300 rpm reading by 2 and subtracting the 600 rpm reading. In theory, Av and Yp represent the following: Av* shear stress (/T) m lb/100 ft.^ shear rate T'jTT sec -1 |; X 478.8 ; centipoise Yp is the point where the asymptote of the shear stress-shear rate curve between 600 and 300 rpm Intersects the shear stress axis as shown In Figure 1 and Is expressed In lb/100 ft.2 or dynes/cm2, (lb/100 ft. 2 x 4.788 * dynes/cm2.) Fann rpm can be converted to sec by multiplying by 1.7034; l.e., 600 rpm Is equal to 1022 sec "'. FIgure 1 shear rat: () FIGURE I GRAPHICAL REPRESERTATIOR OF YIELD POINT -3- 013813 Although the coefficient of variance of the AEC test has been demonstrated to be within acceptable limits, (1) the test has some draw backs. The extent to which the test reflects actual product end performance characteristics has never been established. As such, product specifications are not definitive with regard to "down the hole" performance. Properties are measured at 1022 and 511 sec. by the AEC test procedure. Shear rates In the well annulus are much lower, 5 to 170 sec. -1. The rheological properties of SVB suspensions can vary considerably depending upon shear rate. Furthermore, the use of bentonite as required by the AEC test. Is a potential source of variation due to manufacturing fluctuations (2). 2.0 PRODUCTION QUALITY CONTROL HISTORY Moisture content has a significant Impact on values for Yield Point and Apparent Viscosity. Manufacturing Q.C. tests are run on product samples Immediately and moisture content is normally 5 12. Asbestos Is hydrophilic and, depending on temperature and humidity, can adsorb as much as 62 moisture. The composite samples tested during this Investigation contained between 2.0 to 4.52 moisture. As a result, Yp and Av values stated herein will be lower compared to their corresponding "as-manufactured" test values since they contained less asbestos on a bone dry basis. The effect of solids concentration on the AEC test Is not linear. Higher quality product tends to show a greater change in Yn and Av with a change In concentration than do lower quality materials. An Increase from 1 to 5 percent adsorbed free water can reduce Av and Yp by-vl-3 points. There is no easy method to standardize for free water content. Asbestos is so hydrophilic that several hours are required at evaluated temperatures to effectively drive off the moisture. Rapid moisture adsorption by the "bone dry" material necessitates "swing readings" during weighing. At ambient conditions approximating 250C and 702 RH, dry SVB can adsorb upwards of one percent moisture In a matter of seconds. Originally, Supervisbestos product specifications for Yp and Av were 25 lb/100 ft.* and 15 cps respectively. In 1978, Yp and Av were "temporarily" reduced to 23 lb/100 ft.2 and 13 cps and have remained In effect since. This has been of some concern to Montello and questions have been raised regarding the possibilities of a downward trend in SVB quality. A review of product quality over the last 12 years was conducted to determine the possibility of any trends and their potential significance. Sixty monthly composite samples from years 1970 through February 1982 were tested by the current AEC test procedure and the data analyzed statistically. Figure 2 shows a plot of apparent viscosity for monthly composites versus the year In which they were manufactured. The dash line*is the minimum specification for Av, 15 cps. The solid lines represent the upper and lower 992 confidence limits for the true but unknown mean of the population from which the samples were obtained. The actual mean and median of Av were 15.05 and 15.25 respectively. The data support two important conclusions; first, that the average quality of production for the last 12 years border lines the minimum specification of 15 for Av and second, the degree of product variation has declined since the early seventies. -4- 0i8'4 Apparent V isco sity (cps.) FIGURE 2 SUPERVISBESTOS PRODUCTION QUALITY CONTROL VALUES FOR APPARENT VISCOSITY 24. O** 20. <> Upper S Lower 16. 0+ *" 12. 0+ 8. 0+ 4. 70.0 72.0 74.0 76.0 78.0 80.0 82 Production Years 1970 - 1982 * Production alnliwai specification for Av, 15.0 cps. Solid lines represent the upper and lower 99X confidence Halts for the true but unknown eean (MU) of the population free which the saaples were obtained. The actual can of the Av values was 15.05. The eedlan-of Av was 15.25. BLI 12/7/82 -5- 0*79-5 A regression analysis of the same data Is shown In Figure 3. At first glance, the solid least squares line suggests a slight downward trend In Av from 1970 to present. However, the correlation coefficient (r) of the paired data was determined as 0.0837 which refutes any significance of the regression line. In order to show statistical significance, (r) would have to be at least 0.2 for 58 degrees of freedom. Statistically, there is no evidence to support a downward trend In quality as defined by the production Av data. A similar treatment of the data for (Yp) Is shown In Figures 4 & 5. The actual mean and median for Yp were 23.49 and 23.0 respectively. Based on the 99% confidence limits, the true mean value of YD for production years 1970-1982 could be as low as 21.5. As stated earlier, the monthly composite samples tested herein contained a higher amount of free water than production Q.C. test samples. The average for Yield Point based on "as-manufactured" test values having 'vlX free water is estimated to be in the order of 24 to 26 lbs/100 ft.2. The production norm for Apparent Viscosity is estimated to be between 16 and 18 cps. On the basis of the trends Illustrated, the margin between typical production mean capabilities and product specifications Is too narrow, particularly In the case of Yield Point. The lower 99% confidence limit of the production mean should not fall below product specifications. Yield Point Is at best border line In this respect. Off spec production of Supervlsbestos has decreased appreciably in recent months, due In part to the new ore slurry feed system and increased attention to the wet milling operations. The slurried ore Is a more liberated feed stock than "dry" ore and has improved the efficiencies of the rock fiber circuit; l.e., upgraded the attrition and classification stages. Rotation or changing of the hammers In the M-30 mill prior to Supervlsbestos production is now standard procedure. Supporting data and statistical calculations for these data including probability plots and histograms are appended. Appendix I. 3.0 SIGNIFICANCE OF PARTICLE SIZE DISTRIBUTION ON PRODUCT QUALITY Several SVB samples of varying quality (as determined by the AEC #2 test) were wet screened in the flocculated and chemically dispersed state. Results are shown in Table I. Flocculated wet screen particle size distributions and Fann test properties were Inversely related, l.e. the coarser the size distribution, the lower the values of Yp and Av. Variation among samples was greatest in the coarser screen fractions. The difference between the + 65 mesh fractions of high and low quality materials was as much as 250% whereas their + 325 mesh values varied by only-v20%. Dispersed screen results showed no significant differences between products. This suggests that the difference in quality observed with these materials Is not a function of variances in their wet classification during processing. If the differences In particle size distributions observed with -6- . ons^G Apparent V iscosity (cps.) FIGURE 3 LEAST SQUARES FIT OF AV VALUES FOR SUPEXVISBESTOS VS. PRODUCTION YEAR 23.0* 20.0* 22 13.0* 10.0* 3.0* .......................... .... .. 69.0 72.0 73.0 78.0 , 81.0 Production Years 1970 - 1982 . 8*. 0 The correlation coefficient (r) with 56 degrees of freedoa 0.0837. The dash lines denote the standard deviation of Av about the regression line (i 3.08). 8LI 12/7/82 -7- 013857 Yield Point ( lb ./100 f t . 2 FIGURE 4 SUPERVISBESTOS PRODUCTION QUALITY CONTROL VALUES FOR YIELD POINT C3 42* O* 35. 0* 28. 0* 2 * 2 Upper & Lower 99* Confidence Llnlts * (25.4) 21.0* 14. 0* \ 4 (21.5) * 2 Quality Control Levei for Y,, P 7.0** 0. 0* ?0.0 72.0 74.0 78.0 78.0 80.0 82. Production Years 1970 - 1982 BLI 12/7/82 * Production nlnleua specification for Yp, 25.0 Ib./lOO f.2. Solid lines represent the upper and lower 99* confidence Holts for the true but unknown seen (Ml) of the population froo which the saaples were obtained. The actual aean of the Yp values was 23.49 the aedlan of Yp was 23.0. -8- FIGURE 5 LEAST SQUARES FIT OF Yp VALUES SUPERVISBESTOS VS. PRODUCTION YEAR 40. 0-- 32. 0* CM (V oc>rS Y ie ld P oint (1 b .) 100 f t . 8. 0- 0. O* -- 69.0 72.0 75.0 78.0 81.0 Production Years 1970 - 1982 84. 0 Tho correlation coefficient (r) with 58 degrees of freedom * 0.0316. The dash lines denote the standard deviation of Yp about the regression line ( 5.85). 3LI 12/7/82 -9- TABLE 1 PARTICLE SIZE DISTRIBUTION Of SEVERAL SUPERV1S8ESTQS PRODUCTS Production Oate AEC K Fanntost Yield Point (lb/100 ft.2) Apparent Viscosity (Cps) March 1973 S.S 5.3 Seotaaiber 1973 June 1974 10 16 8 11 February 1976 27 16.5 Nov .1976 20 13 Wet Screen Test t Retained Flocced Screen Mesh * 65 4 100 + 200 325 % Dispersed Screen Mesh 4 65 4 100 4 200 4 325 9.5 14.6 28.7 34.5 2.8 5.5 13.1 22.3 8.1 13.8 31.2 39.1 5.6 8.7 19.2 25.9 5.8 11.1 28.0 38.9 4.1 6.8 16.8 26.0 3.8 7.2 21.8 33.6 3.9 6.7 20.5 28.3 3.0 5.1 12.7 18.1 3.2 4.7 12.1 22.8 BLI 12/7/G2 013859 0138*50 the flocced screenings were due to varying amounts of ganaue , then the dispersed screen results should demonstrate similar trends because rock and magnetite are not affected by the chemical dispersant. The possibility of over-drying can also be eliminated since sintered material produced by excessive drying temperatures will not disperse chemically. The differences in quality can be attributed to two potential areas of production, the Hartz jig and M-30 mill. If the jig is not operating properly, excessive green bladed material can be introduced which is more difficult to mechanically open, and has a coarser fiber size distribution. The importance of M-30 mill efficiency on SVB quality has been recognized by the plant for some time. Current operating procedures require rotation or replacement of the hammers prior to every SVB production run. This has been in effect the last several months this year. Super standard Grade off spec production as a whole decreased from a 1981 average of 10.61 to 5.4% for the same period. 4.0 IMPLICATIONS OF RHEOLOGICAL PROPERTIES ON RELATIVE PERFORMANCE CHARACTER!STI 4.1 Background Theory The principle mechanisms governing the rheological properties of asbestos aqueous suspensions are; particle size and shape, the state of floc culation and concentration. Asbestos fibers flocculate In water due to attractive Van der Waal's forces. If sufficient shear is applied to the suspension, these forces are overcome and the particles orientate with their lengths parallel to the direction of flow. When this occurs, viscosity of the suspension decreases. This phenomenon Is referred to as plastic (Bingham) or pseudoplastic behavior and demonstrates flow curves typical of those shown In figure 6. FlgM* $. Typical Flow Curves for TlM.lndapendant Noa-awtoa1aa Fluids -11- 013881 Bingham fluids exhibit a yield point where as pseudoplastic systems do not. Yield Point is the stress which must be exceeded before flow will start. Asbestos suspensions can be pseudoplastic or plastic depending on the state of flocculation. Flocculation contributes to pseudo plastic behavior. Dispersed (deflocculated) suspensions act more Binghamlike. Asbestos suspensions are also time-dependent, that is, viscosity changes with time at a constant rate of shear. The rheology of asbestos suspensions is further complicated by the fact that they exhibit both thixo tropic and rheopectic behavior depending on the state of flocculation and shear-rate. Tn the case of thixotropy, viscosity decreases with time. Thixo tropy is rather like pseadoplastlefty in which the time required for the alignment of particles is not negligible. Rheopectic property is attributed to the liquid acting as a lubricant for the particles when voidage is at a minimum. As shear is applied, the dense packing of the particles is broken up and consequently the voidage increases. As a result, there is insufficient liquid in the new structure to lubricate the flow of particles as they pass each other and the applied stresses have to be much greater to maintain flow. (3) Flocculated suspensions tend to exhibit rheo pectic property only at,low shear rates. These systews can arso behave tfitxo-. tropically at high shear ratesi JDeflocculatetf suspensions demonstrate greater thixotropic property. f4). State of flocculation is the major factor influencing rheological properties of asbestos aqueous suspensions. This depends on the net effect of the electrokinetics of the system. When the electrical repulsion forces of the particles predominate over Van der Waal's attractive forces, the particles remain separated and the suspension is deflocculated. This occurs with asbestos sus pensions below a pH of 5. At pH values greater than 8, flocculation is achieved. Aside from pH, chemical treatment and the presence of other materials can also affect the state of flocculation(5). State of the art pertaining to the fluid dynamics of non-Newtonian systems Is at best empirical. The rheometric quantitive characterization of non-Newtonian time-dependent fluids Is complicated and there is no mathematical model that totally defines the behavior of these suspensions. Two models comnonly used in drilling fluid technology are the Bingham (Plastic) model having a linear function on rectangular coordinates and; the Power Law, a linear model on logarith mic coordinates.(6). -12- 013862 (Bingham)'T + Up (y) (Power Law) T * K )* Where ^ * Yield point or yield stress (dyne-cm ) 'y. shear rate (sec "^) Up * Plastic Viscosity (cps) K Constant, a measure of fluid consistency; the higher K, the more viscous the fluid. n * Constant, slope of the shear stress-shear rate plot and a measure of the degree of non-Newtonian properties. It should be emphasized that neither of these models properly character ize time-dependent pseudoplastic systems. The Bingham model Is based on the premise of a yield point, when in fact, pseudoplastic systems do not exhibit yield stress values. In the case of the Power Law, K and n are considered constants. However, n is not a true constant for real fluids over all, possible ranges of shear; and K is dependent on the index n.(7) Furthermore, neither model takes into account the effects of time-dependency. Since yield stress Is dependent not only on the slope of the shear stress-shear rate curve but also the duration of shear rate, multi-point measurements must be obtained as function of time over a broad range of shear rates(5 to 1000 sec*') to effectively define the rheology of the total system. Within limits, these models do provide an empirical method by which the data can be analyzed quantitatively. However,,care must be taken with inter pretation of the data. 4.2 Effects of Mixing Energy The affect of mixing intensity on the rheological properties of supervisbestos/bentonite suspensions is illustrated in Figure 7. Shear stress at 1022 sec-1 is plotted against mixing time. All the SVB products exhibited a marked Increase in viscosity with mixing time.U) The higher the viscosity build ing properties of the product, the more pronounced the effects of mixing. This is best illustrated by the slope of the curves as shown below: Sloped Supervisbestos March-73 1.1 June-74 3.5 November-76 7.4 February-76 7.2 Performance characteristics of the competitive Canadian asbestos product, Flosal, will be discussed later in the report. ^ The shear stress values ('T') were all measured at the same shear-rate (1022 sec*') and as such are directly proportional to viscosity,'^ poise. ^ The slope was based on the linear region of curves between 5 and 30 minutes. -13- 013863 FIGURE 7 AFFECT OF MIXING TIME ON SHEAR STRESS RESPONSE OF 10 lb/bbl (1:1 ratio) AS3EST0S/3ENT0NITE SUSPENSIONS oo C*4 8 SHEAR STRESS - (d y n e s MULTI-MIXER TIME (MINUTES) -14- 3LI 12/7/S2 0138G4 The effects of mixing on the shear stress-shear rate flow curve for the Feb.-76 products is shown in Figure 8. The fallacy of applying the Bingham model to pseudoplastic suspensions is immediately evident. The suspension mixed for 50 minutes is considerably more Bingham-like than the 10 minute suspension. However, neither exhibits a yield point over the range of shear-rates tested. By the AEC test, Yp for the 10 and 50 minute curves would approximate 33 and 62 lb/100 ft. * respectively, as demonstrated by the dash asymptotic lines based on shear rates of 1022 and 511 sec "1. The same data are shown in Figure 9 as represented by the Power Law. K is a measure of consistency and n is indicative of the degree of non-Newtonaian properties. The greater n deviates from 1.0 (Newtonian), the more pronounced is the non-Newtonian property. At low conditions of mixing, the suspensions exhibit high pseudo plastic property and are time-independent except at very low rates of shear. As the suspensions are mechanically worked, the state of flocculation decreases and they become more plastic and thixotropic in property. It appears that as the available fiber content in suspension Increases, the electrical charge on the particles predominate over Van der Waal's attractive forces reducing the state of flocculation. Although this would tend to lower viscosity, the Increase in available fiber content from attritioning with additional mixing Is sufficient to affect a net Increase in viscosity. The time-independent property of SVB suspensions is also influenced by energy of mixing. Changes in shear stress at a constant shear-rate of 170 sec -1 (100 rpm Fann) were monitored over a period of * 6 minutes for samples pre-mixed 5 to 50 minutes with the Multi-mixer. Mechanical opening by the ftilti-mlxer for the mixing times indicated should emcompass those conditions existing in actual drilling operations. As shown in Figure 10, asbestos suspensions mixed 5 to 15 minutes were relatively time-independent. Viscosity of the 20 minute sample decreased under constant shear with time. Thixotropic property was more pronounced as mixing time increased from 20 to 50 minutes as shown in Figure 11. In terms of viscosity, the 50 minute suspension decreased from 118 to 72 centipoise (cps) when sheared 8 170 sec"* for 5.75 minutes (* * 5.75). By conparison, viscosity of the 10 minute sample only decreased from 79 to 73 cps under similar conditions of shear. The significance of time-dependency and Importance of multi-point measurements can be best Illustrated by comparison of the June 74 and February 76 SVB products. As shown earlier in Table 1, the February 76 sample has vastly superior Yp and Av properties by the AEC test. However, these values are representative of Instantaneous readings (t * o) at high shear rates. Conditions existing in the annulus of the well are in the order of 5 to 170 sec **. If we compare the Power Law K constants of the suspensions over this range, their properties are quite different as shown below: K Constant basod an S to 170 se -1 Junt 74 Product for 5 win, arlx for 50 min. nix Fob. 76 Product for 5 win, nix. for SO nln. nix t o 3.7 n.4 6.9 13.1 t- 5.75 In. 3.0 8.2 6.4 6.8 -15- 013865 FIGURE 8 Shear Stress - Shear Rate Curves for (1:1) Supervlsbestos (Feb.-76)/Benton1te ^Suspensions OO lb/bbl) N )i ' f SHEAR STRESS (lb/100 f t "Uo ! SoT 800 Tom ) SHEAR RATE ( sec -1) 12/7/c: -16 ( / ) SHEAR SJRZSS (d y n e s -T Figure 9 SHEAR STRESS - SHEAR RATE PROPERTIES OF SUPERVISBESTOS SUSPENSION DLI 11/19/C2 013867 FIGURE 10 TIME DEPENDENT PROPERTIES AT 170.4 sec -1 OF 10 lb/bbl (1:1) SUPERVISBESTOS (2-76)/BENT0NITE SUSPENSIONS PREPARED WITH THE MULTI-MIXER FOR 5 to 20 MINUTES 1.0 2.0 3.0 4.0 5.0 6.0 TIME (MIHUTES) 0 170.4 sec -1 3LI 12/7/S2 -18- 013868 FIGURE 11 TIME DEPENDENT PROPERTIES AT 170.4 sec -1 OF 10 Ib/bbl (1:1) SUPERVISBESTOS (2-76)/BENT0NITE SUSPENSIONS PREPARED WITH THE NULTI-MIXER FOR 25 TO 50 MINUTES Of TC>J> SHEAR STRESS -19- BU 12/7/82 0.l'?8r'9 The February 76 product exhibits superior viscosity building characteristics at low mixing conditions. However, when the products are compared after being mixed for 50 minutes, the June 74 sample has a higher K factor In the low shear rate range under conditions of prolonged shear. In effect, with sufficient mechanical opening, the June 74 product would have superior performance properties in actual application. By comparison. Its viscosity building properties at low shear rates are higher; and at high shear rates (500 to 1022 sec -1), Its viscosity Is lower than the February 76 product. Pressure loss Inside the drill string and drilling rate are a function of fluid viscosities in the range of 150 to 10,000 sec'1. As such, low viscosity Is desirable In this region of shear-rates. The relationship between mixing parameters for laboratory test procedures and condltons existing In drilling applications has been a subject of conjecture for some time. Energy shear-rate intensities are greatest at the drilling bit and estimated to be in the order of 10,000 to 100,000 + sec *1. There is no information presently available for determining the Intrinsic energy of mixing for the Multi-mixer. Currently, the rule of thumb for laboratory testing in the drilling Industry is to mix 10 to 30 minutes with a Multi-mixer. The 4 minute mix now used for the SVB AEC quality control test certainly Imparts considerably less energy than that existing In actual application. 4.3 Relative performance Characteristics - Anti-settling Properties Quantifying the performance characteristics of drilling fluid additives Is difficult due to the complexities and numerous variables Involved In drilling operations. Asbestos Is used primarily to remove cuttings generated at the drill bit and as a suspension aid. Asbestos assists particle suspension In two ways, by reducing particle slip velocities in the annulus under conditions of flow and when the system Is at rest. In the event of shut downs, suspension of the cuttings is critical in order to prevent settling which can result in freezing of the bit. The problem is not uncomnon and besides being costly, it occasionally can result in loss of the bit; or worse, the necessity of drilling a new hole. It has been demonstrated theoretically that particle slip velocity (settling rate) under conditions of flow in a column is the same for a quiescent stream. Therefore, static settling tests should relate to normal conditions of laminar flow in the well annulus. In an effort to relate rheological properties with end use performance characteristics, a settling test was developed using tungsten oxide (WO3 minus 80 mesh) as a weighting agent. A test was required that would effectively demonstrate over a broad range of conditions the rheologi cal Influences of SVB as related to settling properties. High density tungsten oxide was found to exaggerate settling effects. Lower density weighting materials (3- 4.5 SG) settled very slowly and tended to demonstrate*greater variability of the test results. WO3 has a specific gravity of-`V 7.2 which equates to 60 lb/gal density. Formation particles in general have densities in the range of 20 to23 Ib/gal. As such, the settling rate data herein reflect the extreme rather than the norm. Ten Ib/bbl one to one asbestos/bentonite suspensions were prepared with the multi-mixer. WO3 (44 ib/bbl) was added during the last two minutes of mixing. A 250 ml aliquot of the suspension was then transferred to a graduated cylinder. Another 150 ml of slurry was diluted to 500 ml and the cylinder inverted 25 times to obtain a homogenous suspension. Concentration after dilution was 3 and 13 1b/ bbl of asbestos/bentonite and WO3, respectively. -20- 013870 Settling rate data for the high solids prepared 10 and 40 minutes In the multi-mixer are shown in Figures 12 and 13. The relative order of perfor mance for the various products shown was not the same for different mixing conditions, the most obvious being the SVB 6-74 sample. This sample settled more rapidly than all but the SVB 3-73 product when mixed 10 minutes. However, the same sample mixed 40 minutes demonstrated the best suspension properties. This may be explained, in part, by comparing the K and n constants of some of the products at low shear rates (5-10 sec -), K & n Constants 9 Low Shear (5-10 sec'1) Multi -mixer 10 minutes Multi-mixer 40 minutes Nov. 76 June 74 Feb. 76 Nov. 76 June 74 Feb. 76 8.5 6.4 9.9 12.4 11.4 11.5 0.1312 0.0931 0.1155 0.2928 0.1031 0.3067 The June 74 product has a lower K value compared to the other suspensions when mixed for 10 minutes. The 40 minute suspensions, however, exhibited approxi mately the same K constants. The principle difference in the 40 minute suspensions was their n constants. The value of n for June 74 was approximately one third that of the other products. This Indicates a greater degree of non-Newtonian property, i.e., pseudoplastic behavior. As mentioned earlier, pseudoplastic systems tend to exhibit a higher state-of flocculation and rheopectlc property at very low shear rates. The June 74 product demonstrated only marginal decreases in viscosity at a constant shear rate of 170 sec"1 (data reference Table XIV - Appendix II, page 68] As such, at the lower shear-rates evident with the quiescent settling test its viscosity increased with time. This may also occur with the other suspensions, but to a much lesser degree. Similar plots of the diluted suspensions are shown in Figure 14. As would be expected, settling was much more pronounced with these suspensions. In general, the SVB 3-73 & 9-73 materials were again the worst performers. Comparisons were also conducted of settling properties without bentonite (refer Figure 15). Straight asbestos suspensions were highly flocculated and it was often difficult to obtain accurate Fann readings. Low shear-rate (5 - 10 sec"1) K constants for the asbestos and asbestos/bentonite suspensions were 12.9 and 9.9, respectively. The asbestos suspension exhibited rapid settling over the first six hours with minimum settling thereafter. Conversely, asbestos/bentonite systems settled slowly but, ultimately to a greater degree. The*difference in settling properties between the two systems is attributed to their state of flocculation. Flocculation of the asbestos suspensions may alter the "effective" particle size distribution of the suspension resulting in heavy dense floes that affect rapid settling. Bentonite tends to decrease flocculation, but contributes to Bingham property and exhibits a real yield point. The complexities of the co-flocculated system can at best be guessed at. -21- 013871 FIGURE 12 SETTLING CHARACTERISTICS OF SUPERVISBESTOS/BENTONITE SUSPENSIONS MIXED IN MULTI-MIXER FOR 10 MINUTES (5 lb. AS8EST0S, 5 lb. BENTONITE & 44 lb. W03 PER BARREL) 10 TIME (HOURS) ...... * TOO SLI 12/7/82 013872 FIGURE 13 SETTlIftG CHARACTERISTICS OF SUPERVISSESTOS/S :;tohite suspension sli 12/7/32 MIXED IN KULIT-MIXER 40 MINUTES (5 lbs ASBESTOS, 5 lbs BENTONITE 1 44 lbs '..'03 PER BARREL) PERCENT SETTLE -23- 3LI 12/7/82 W--^ FIGURE 14 SETTLING CHARACTERISTICS OF SUPERVISBESTOS/BENTONITE SUSPENSIONS (1.5 lbs. ASBESTOS, 1.5 lbs. BENTONITE & 13 lbs. WOj PER BARREL) PERCENT SETTLE S_ PERCENT SETTLE TIME (HOURS) -24- BLI 12/7/82 FI SURE 15 COMPARISON OF THE SETTLING CHARACTERISTICS OF SUPEP.VISBESTOS & SUPERVISSEST0S/3ENT0NITE AQUEOUS SUSPENSIONS PERCENT SETTLE TIKE (HOURS) -25- 3LI 12/7/32 013875 4.4 Comparison of Rheological Properties and Settling Characteristics The relationship between Av and Yp and settling effects are demonstrated in Figures 16 and 17, respectively. Although Av and Yp are based on high shearrate determinations, they demonstrated a reasonable correlation with the corres ponding settling values. The reason this occurs is that the only difference between the various suspensions tested is the amount of available fiber in suspension. Particle size and fiber length distribution is relatively the same for all the suspensions. A change in available fiber will result in a direct change in viscosity proportionally over the entire range of shear-rates. Yield Point at these high shear-rates, though indicative of product performance characteristics. Is purely empirical. Apparent Viscosity is indicative of real rheological property. The use of bentonite in the AEC test is not necessary for determining quality of Supervisbestos. Since product variance is predominately a function of available fiber content, product viscosity will change in direct proportion to the rate of shear. As fiber content increases, viscosity will increase accordingly with or without bentonite present. Figure 18 shows the relative time-response properties of asbestos and asbestos/bentonite suspensions para llel each other in properties when compared at comparable levels of mixing. The AEC test can be further simplified by a single point reading at a standard shear-rate and a fixed mixing time. The higher shear-rates tend to be less subject to fluctuation and therefore best suited for a quality control test. A comparison of Fann readings at 600 rpm (1022 sec ) and Av and Yp values for SVB suspensions of varying quality is shown in Figure 19. The relationships are close to linear over the major portion of the curve on semi-log coordinates. -26- 013876 FIGURE 16 SETTLING PROPERTIES VERSUS APPARENT VISCOSITY VALVES PERCENT SETTLE 0 48 HOURS 26 36............... 4b ............ 50 Av-APPARENT VISCOSITY (Cps) 9 1022 sec -1) 60...... SLI 12/7/82 -27- 013877 FIGURE 17 SETTLING PROPERTIES VERSUS FANN YIELD POINT VALVES PERCENT SETTLE 0 4 8 HOURS VO 20 ' 36 40 51T Yp- YIELD POINT (lbs/100 ft.2)(8 1022 & 511 sec -1) BLI 12/7/82 -28- 013878 FIGURE 18 TIME DEPENDENT PROPERTIES 8 170.4 sec -1 of 10 Ib/bbl ASBESTOS SUSPENSIONS ) SHEAR STRESS (d y n e s -c m " (nr -29- BLI 12/7/82 FIGURE 19 7. RELATIONSHIP BETWEEN SUPERVISDESTOS AND SUPERVISBESTOS/BENTONITE SUSPENSIONS S ta n d a rd AECI2 APPARENT VISCOSITY (C p s ) A YIELD POINT Ib s /IO O f t . 600 Fann Reading (10 1b/bb1 Supervlsbestos Suspension -1C Bin mix) 3LI 12/7/32 -30- 013870 4.5 Supervisbestos Production Specifications Of the five products evaluated, the March 73 and September 73 samples exhibited by far the lowest properties ie, settling, viscosity, particle size distribution and with regards to ease of mechanical opening as shown below: AEC #2 Test Yp Av TABLE II Comparison of Supervisbestos Properties March 73 ' Sept. 73 June 74 Nov. 76 5.5 10 16 20 5.3 8 11 13 Asbestos-only (10 min-mix) 600 e value 34 37 42 45.5 Relative ease of opening (multi-mixer) poor Flocced Particle Size 65 mesh 9.5 + 100 mesh 14.6 Percent Settle 10 lb/bbl Asbestos/Bentonite (44 lb/bbl W03) (10 min. mix) 1 hr. 15.2 48 hr. 48.8 poor fair 8.1 13.8 5.8 11.1 good 3.9 6.7 3.2 4 33 30.4 0 14.4 Feb. 76 27 16.5 51.5 good 3.8 7.2 0 14.4 -31- 073g3i The density of tungsten oxide is roughly three times that of typical formation materials and should be considered when Interpreting the settling data. All the products showed good suspension properties for up wards of an hour, with exception of the March 73 sample. Suspension properties with low density muds should be considerably better than that indicative with WO3. Furthermore, asbestos is used a majority of the time to create temporary plug flow for cleaning of the hole and prolonged suspension properties are not Important. In the author's opinion, a reasonable cut off point for product quality control Is an Apparent Viscosity of 13 cps as measured by the current AEC #2 test procedure. This Is based on an asbestos free water content of one to two percent which approximates manufactruing test conditions. Results reported herein show a significant drop off in both the physical properties and settling characteristics of SV8 products having Apparent Viscosities less than 11 cps. The coefficient of variance for the AEC test procedure is with in + 10 to 15% which represents a swing of one to two centipoise. A minimum Av spec of 13 cps would insure product quality within predictable limits of test variability, a yield point specification is at best redundant.. Yield Point is subject to greater variation than Av and has been shown to have no real significance regarding end-use performance characteristics. As mentioned earlier, a simplified test procedure based on a single point Fann measurement has been developed without bentonite. It is based on an asbestos suspension having a solids content of 12 to 15 grams per 400 ml distilled water. The slurry is mixed for 10 minutes with the Multi-mixer (3 discs) at 11,500 rpm. Measurements are to be based on the Fann 600 rpm value taken at 15 seconds. Details of its implementation will have to be worked out with the plant. 5.0 FLOSAL COMPETITIVE PRODUCT EVALUATION Flosal Is a chrysotile asbestos produced by Johns-Manville Corp. and sold exclusively to the drilling industry by Drilling Specialties Company, Inc. The original product was based on Coalinga California chrysotile. A new product was Introduced in 1973 based on Quebec Canadian chrysotile. The material contains both very fine and long fiber length distributions and sells for approximately the same price as Supervisbestos. Typical physical properties of Supervisbestos and Flosal are shown in Table III. Supervisbestos has a finer particle size distribution and higher surface area than Flosal. However, Flosal exhibits better suspension characteristics and viscosity building properties as demonstrated by Apparent viscosity and wet bulk values. The physical differences between the two products can be best appreciated by visual observations^under the microscope. Figures 20 4 23 show scanning electron photomicrographs (SEM) of the materials. Photomicrographs of dilute aqueous suspensions that were ultrasonically opened are shown in Figures 24-29. The longer fiber length distribution of Flosal is clearly evident in Figures 24 4 25. The EDAX scans shown represent full field EnergyDefractioa Analysis of X-rays of the areas referenced. The specimens were gold coated, giving the characteristic Au peak. At high magnifications, the short fiber fractions of the products appear very similar as shown in Figures 26-29. -32- TABLE 111 TYPICAL PHYSICAL PROPERTIES Of FLOSAL I SUPERVISBESTOS (Reflectance (Total Iron (HaQ (510. BET Surface Area (nZ/am) AECf2Fann 2q/1 Met Bulk Av CP Settle Vol.(cc) (Retained Flocced Met Screen 65H +100M +200H +325M Supervlsbestos 70 2.0 40 40 58 15 25 865 4 7 22 34 Flosal 54 4.5 36 36 34 22 20 1000 3 9 34 48 I CO 12/7/82 % 013832 Figure 20 SEM Photo micrograph of Flosal as is 0 500 X. Figure 21 photo micrograph of Supervisbestos as is @ 500 X, 013833 Figure 22 SEM Photomicrograph of Flosal as is 0 2000 X. Figure 23 SEM Photomicrograph of Supervisbestos as is 0 2000 X. .J .. Figure 24 $EM Photograph of Flosal @1 00 X Prepared from dilute Aqueous Suspension. Figure 24a EDAX Full Field Scan nf arna in Finnr 1 Figure 25 SEM Photograph of Supervisbestos (MOO X Prepared from dilute Aqueous Suspension. Figure 25aEOAX Full Field Scan p f * ' s -V f 013834 Figure 26 SEM Photomicrograph of Supervisbestos @ 20,000 X prepared from dilute aqueous suspension. SS88T0 Figure 27 SEM Photomicrograph of Flosal 0 20,000 X prepared from dilute aqueous suspension. -36- Figure 28 SEM Photomicrograph of Supervisbestos @ 50,000 X prepared from dilute aqueous suspension. Figure 29 SEM Photomicrograph of Flosal @ 50,000 X prepared from dilute aqueous suspension. -37- 013S37 The suspension characteristics of Flosal and Supervlsbestos are demonstrated in Figure 30. Tungsten oxide was used as a weighting agent. The suspension capabilities of Flosal exceeded that of Supervlsbestos, both at the high and low solids concentrations for slurries mixed 10 minutes in the multi-mixer. Settling characteristics of the two products were relatively the same when mixed for 40 minutes as shown In Figure 31. The properties of asbestos suspensions prepared without bentonite are shown In Figure 32. Again, Flosal demonstrated a marked advantage at high solids con centrations. Settling was approximately the same for the two products in dilute suspensions. The superior performance characteristics of Flosal are surprising considering that Supervisbestos has a finer particle size distribution and a surface area~l -1/2 times that of Flosal. Flosal is mechanically liberated much easier than Supervlsbestos (reference Figure 7). Although this may be an advantage in some instances, it is not the major reason for performance differences. Flosal aqueous suspensions tend to exhibit a much higher degree of flocculation than supervisbestos. This may be due in part to the slightly higher pH of Flosal. This is most likely due to a higher Brucite (Mg OH) content. Much of the naturally occuring Brucite in Calidria ore is removed during aqeuous processing. The principle mechanism, however; appears to be related to the fiber length distribution of Flosal. The long fiber fraction (20-100+/AM) enhances the cohesion of flberous structure physically, and appears to extenuate the effect of particle electrical forces. This contri butes to pseudoplastic and strong rheopectic properties. The rheopectic property of Flosal is evident at shear-rates as high as 170 sec as demonstrated in Figures 33 & 34. Viscosity increased with time at constant shear for Flosal/bentonite suspensions mixed for periods up to 20 minutes. Suspensions mixed longer than 20 minutes began to behave thixotropically at 170 sec -1. However, at low shear rates 5-10 sec -1, all Flosal suspensions exhibited rheopectic property. The significance of rheopectic property is further demonstrated in Figure 35. The Supervisbestos (2-76) suspensions were mixed for 40 minutes in the multi-mixer. Flosal was mixed 20 minutes. Each set of instantaneous (t*o) and steady state readings ( *5 minutes) were obtained on individual slurries over the entire range of shear-rates. For example, the initial Fann reading at 1022 sec was obtained first; and then the sample was sheared at 170 ser -1 for 5 minutes and the stress again recorded at 1022 sec-1. The shear stress values for the Flosal suspensions increased dramatically where as the Supervlsbestos suspensions decreased by approximately the same order of magnitude. The time-dependent effects, on Apparent Viscosity over the range of shear-rates is further illustrated in Figures 36 and 37. The relationship between Av & Yp and settling`characteristics is shown in Figure 38. The correlation between Av and Yp and settling property is poor when comparing Flosal and Supervisbestos beaause of the differences in their time-dependent properties at low shear rates. This is supported by observation of K values at high and low shear-rates, refer to Figure 39. K constants developed at shear rates in the region of 1022 -170 sec*1 show little correlation with settling properties when comparing the Flosal and Supervlsbestos suspensions. On the other hand, K values based on 10 -5 sec demonstrated excellent correlation with settling property for both Supervisbestos and Flosal suspensions. -38- FIGURE 30 FLOSAL AND SUPERVISBESTOS COMPARISONS SETTLING TEST (1:1) AS3EST0S/BENTQNITE SUSPENSIONS (10 minute six In Multi-mixer) 013888 SETTLE - PERCENT TIME (Hours) -39- 8LI 12/7/82 FIGURE 31 FLOSAL AND SUPERVISBESTOS COMPARISONS SETTLING TESTS 1:1 ASBESTOS/BENTONITE SUSPENSIONS (40 MINUTE MIXING IN MULTI-MIXER) 013839 PERCENT SETTLE TIKE (HOURS) -40- BLI 12/7/82 FIGURE 32 F10SAL AND SUPERVIS8EST0S COMPARISONS SETTLING TESTS ASSESTOS SUSPENSIONS 013890 PERCENT SETTLE TIME (HOURS) -41- SLI 12/7/82 013891 FIGURE 33 TIME DEPENDENT PROPERTIES AT 170.4 sec -1 of 10 lb/bbl (1:1) FLOSAL/OENTOfilTc SUSPENSIONS PREPARED WITH MULTI-MIXER FOR 5 TO 20 MINUTES SHEAR STRESS (dynes-as-2) 9 170.4 sec TIME (MINUTES) 8 170.4 sec-1 BLI 12/7/82 42- 013892 FIGURE 34 TIKE DEPENOEi.T PROPERTIES AT 170.4 sec -1 of 10 lb./bbl (1:1) F10SAL/3ENT0NITE SUSPENSIONS PREPARED WITH MULTI - MIXER FOR 30 - 50 MINUTES ( ) Shear Stress (dynes-cift?)T TIME (MINUTES) 170.4 sec -1 SLI 12/7/82 -43 013893 (z. uo-sau/p) SS3N1S W3HS 44 FIGURE 35 TIME DEPENDENT SHEAR-STRESS RESPONSE OF 1 :1 ASBESTOS/BENTONITE SUSPENSIONS SHEAR RATE (sec 013894 FIGURE 33 PSE'JuCPi-ASTIC (SHEAR DEPENDED) PROPERTIES OF SUPER'.'IS3EST0S FLOSAL 3EMT0NITE SUSPENSIONS (5 lbs AS3EST0S S 5 1bs/SENTONITE PER DARREL) INSTANTANEOUS READINGS {'f ) SHEAR RATE (sec -1) BU 12/7/82 -45- FIGURE 37 PSEUOOPLASTIC (SHEAR DEPENDENT) PROPERTIES OF SUPERVISBESTOS i FLOSAL 3ENT0NITE SUSPENSIONS AFTER SHEARING 0 170.4 sec-1 FOR 5 MINUTES (5 lbs. ASBESTOS, 5 lbs. BENTONITE PER BARREL) STEADY STATE" READINGS 013895 (Cps)_ (AV) APPARENT VISCOSITY (-?) SHEAR RATE (sec -1) 3LI 12/7/C2 -46- , .. ,, Figure (a) Apparent V isco sity 9 1022 sec -1 FIGURE 38 RELATIONSHIP BETWEEN SETTLING CHARACTERISTICS AMD THE RHEOLOGICAL PROPERTIES OF ASBESTOS AQUEOUS SUSPEHSIONS Figure (b) Field Point 9 1022 * 511 sec -1 ______________ 013896 47 PERCENT SETTLE PERCENT SETTLE FIGURE 39 RELATIONSHIP BETWEEN SETTLING CHARACTERISTICS AND THE RHEOLOGICAL PROPERTIES OF ASBESTOS AQUEOUS SUSPENSIONS Figure (a) K (based on 10.2 - 5.1 sec -1) 100. 1t .n:< niron i nn.4111.>:\+umi utwi +444 l-MHD mmrmi 144- ++4 4fj 10 lb/bbl (1:1} Asbestos/Bentonite Suspensions with 44 lb/bbl of WO3 LL;t1tTHfl Weighting Agent. Hlxlng was _U performed with a Multi-mixer for 1U periods of 10 *40 minutes. m jT(*) represents Flosal/Bentonite systems J (#) represents Supervlsbestos/ Figure (b) K (based on 1022 - 170.4 sec -1) .1^1j fllTTpTTT)1P3TTP3WW'WTlfl LEGEND ( 10 lb/bbl (1:1) Asbestos/Bentonite I Suspensions with 44 lb/bbl of WO3 ' Weighting Agent. Mixing was performed with a Multi-mixer for periods of 10 * 40 minutes,_______ (4) represents Flosal/Bentonite ~ systems - tt (e) represents Supervlsbestos/ " Bentonite systems u o 0If0a* c 013897 PERCENT SETTLE 20 30 40 PERCENT SETTLE OLI 12/7/P2 013898 The performance characteristics of Supervisbestos and Flosal demon strated herein are based on the most stringent of conditions and do not reflect conditions typical of most drilling operations. Both products exhibit excellent viscosity building and suspension properties. Although Flosal exhibits some advantages at low shear rates. It's high pseudoplastic property could adversely affect its relative sweeping capabilities at high shear rates existing at the bottom of the hole. Flosal Is also more sensitive to pH conditions compared to Supervisbestos (daga not shown). The relationships between rheological properties and fiber length distribution is of academic significance. Within limits of proper fiber length distributions,viscosity and time-dependent property could be improved. Although unsubstantiated, fiber aspect ratio may be a contributing factor as well. Dimensional properties Influencing rheological behavior In aqueous systems may also relate In some Instances to polymer suspensions. These factors should be given serious consideration in future developmental programs. BLI:jl * -49- REFERENCES 01389D 1. Rhodes, H. B., "Supervisbestos - A Review of Product Quality Trends and Competitive Market Position",union Carbide Corp. October 23, 1974. Ingalls, B. L., "Supervisbestos AEC Test" letter to R. J. Kronkhyte, March 11, 1980. Ingalls, B. L. "Interlaboratory AEC Test Variance for CSV", letter to J. L. Myers, July 23, 1982. 2. Goyer, D. Montello, Inc., letter to B. L. Ingalls, June 17, 1982. 3. Wazer, Lyons, Kim and Colwell, "Viscosity and Flow Measurement" Interscience, New York, 12-22, 156-161 (1963). 4. Park, K. et. al. "Properties of Union Carbides Chrysotile Asbestos", Union Carbide Corp. 45 (1967). 5. Chastlak, S. "Properties of Collordal Chrysotile Asbestos from the Coalinga Region of California Union Carbide Corp. 35-39, 89-95 (1968). 6. Walker, R. E. "Mud Hydraulics, Oil and Gas Journal, 59 August 9, 1976. 7. Wilkinson, W. H. "Non-Newtonian Fluids-Fluid Mechanics, Mixing and Heat Transfer", Pergamon Press, New York, 1-9 (I960). -50- APPENDIX I Production Data & Statistical Computations 013900 S' -51- ..... 013901 Manth F4b. March Juna AUf. Sp. Oct. Jan. Fab. March April May Sap. Nov. Oac. March April Juno July Auf. Sap. Oct. Nov. Oac. Jan. Fab. March April Juna July Sap. NoV. TABLE IV AEC #2 FANN TEST RESULTS OH KINS CITY SUPER YISBESTOS MONTHLY COMPOSITE3 FOR TEARS 1970 - 1982** lisn 70 71 71 71 71 71 72 72 72 72 72 72 72 72 73 73 73 73 73 73 73 73 73 74 7* 74 74 74 74 74 74 Av 17.5 20 17 18.S 19.S 16.2 21.5 17 16 18 16.S 11 10 18.S 6.3 20 23 20 13.S 8 13 10 13.S 12 14 14 11.5 11 16.S 12 13 .72... a&jssm 27 BU Juno 82 33 Ml Auf. 71 26 31 mm oct. 74 33 5 18.5 - 9 5 37 m 28 m 26 - 30 - 27 mm 24 m 5 IS BLJ Jum 82 31 5 5.5 HON Oct. 74 31 5 37 m m 9 34 m 9 9 21 BUI Juna 82 10 aa 9 9 20 m 9 , 13 HB1R Bet. 74 21 1 18 * 22 t 9 9 23 m 9 9 17 BLIJUna 82 16 m- 9 9 25.5 HBK Oct. 74 18 BLI Juna 82 20 ' 9 9 52- 013902 Month March July Sep. Nov. 0oc. Feb. July Nov. May Aug. Dec. Jan. July Oct. Feb. Mar. April Ooc. Jan. Mar. my Jono July Aug. Up. Ooc. Ooc. Jan. Feb. 13SL 75 75 75 75 75 75 . 75 77 77 77 78 78 78 75 75 75 75 80 80 80 80 80 80 80 80 81 82 82 TABU IV (cont'd) Av Yp 13.5 21 13 18 13.5 21 14.5 21 13.5 21 15.5 27 15.5 25 13 20 15.5 23 17 28 18 28 15.5 25 IS 22 15.8 23.5 15.5 25 17.3 27.5 IS 26 15.5 23 14.5 23 15.5 23 15.5 25 15 ' 24 14.5 23 15.5 25 14 22 12.5 19 13 20 14.5 23 13 21 Oita Source BLI Mar. 79 00 BLI June 82 BLI Mar. 79 BLI June 82 m 000 000 1U Mar. 79 0 00 000 000 000 BU June 82 000 000 000 000 000 000 000 000 0 00 000 000 000 0 00 000 *AEC #2 Test: S g*s. asbestos t 5 ges. bentonite olxed 4 alnutas In 350 nl. distill ad Mtv 25*C with nultlolxer (3 discs). Meesur tnts were obtained with a Model 35 FANN Vlscoaeter I 500 I 300 rp. Apparent viscosity (A*) cps. ` Plastic Viscosity (Pv) 600e - 300e cps. Yield Point (Yp) 3006 - Pv lb./lOO ft.2 -53- TABLE V STATISTICAL DATA REFERENCE FOR Figure 2 013903 MEDIAN OF COLUMN C2 MEDIAN 13.250 AVERAGE OF COLUMN C2 AVERAGE - 13.052 STANDARD DEVIATION OF COLUMN C2 ST.DEV. 3.094? MAXIMUM QF THE VALUES IN COLUMN C2 MAXIMUM 23.000 MINIMUM OF THE VALUES IN COLUMN C2 MINIMUM 5.3000 "INTERVAL SO PERCENT CONFIDENCE* SIGMA-3.094?, DATA IN C2 C2 N - GO MEAN - 13.052 ST. DEV. THE ASSUMED SIGMA 3.094? A 30.00 PERCENT C.I. FOR MU IS < 14.7822* 13.321D 3.09 SINTERVAL 95 PERCENT CONFIDENCE* SIGMA-3.094?, DATA IN C2 C2 N - GO MEAN 13.052 ST. DEV. - THE ASSUMED SIGMA - 3.094? A 95.00 PERCENT C.I. FOR MU IS < 14.2675* 13.8358) 3.09 ^INTERVAL 99 PERCENT CONFIDENCE* SIGMA-3.094?, DATA IN C2 C2 N 60 MEAN - 15.052 ST.DEV. - THE ASSUMED SIGMA - 3.0947 A 99.00 PERCENT C.I. FOR MU IS < 14.0204. 16.0829> 3.0? BLI 12/7/82 -54- TABLE VI STATISTICAL DATA REFERENCE FOR Figure 3 013904 REGRESS C2 OH 1 PREDICTOR IN COL Cl ' THE RE6RE?SI0H EQUATION IS Y 26. 0 - 0.145 XI COLUMN COEFFICIENT -- 25.951 XI Cl -0.145 ST. DEV. OF COEF. 9.082 0.120 THE ST. DEV. OF Y ABOUT REGRESSION LINE IS 5 3. 083 WITH < 60- 2> 58 DEGREES OF FREEDOM R-SOUARED * 2.4 PERCENT P-SPURRED 0.7 PERCENT* ADJUSTED FOR D.F. ANALYSIS OF VARIANCE DUE TO REGRESSION RESIDUAL TOTAL DF 1 58 59 SS 13.716 551.334 565.049 MS-SS'DF 13.716 9.506 T-RATIO COEF^S.D. 2.86 -1.20 BLI 12/7/82 -55- TABLE VII STATISTICAL DATA REFERENCE FOR Figure 4 MEDIUM OP COLUMN C3 MEDIAN 23.000 AVERAGE OF COLUMN C3 AVERAGE 23.492 STANDARD DEVIATION OF COLUMN C3 ST.DEV. - 5.8581 MAXIMUM OF VALUES IN COLUMN C3 MAXIMUM - 37.000 MINIMUM OF VALUES IN COLUMN C3 MINIMUM 5.5000 013905 ZINTERVAL 50 PERCENT CONFIDENCE, SIGMA-5.8581. DATA IN C3 C3 N - GO MEAN - 23.492 ST. DEV. - THE ASSUMED SIGMA- 5.8581 A 50.00 PERCENTC.I. FOR MU IS < 22.9818* 24.00171 5.88 2INTERVAL 95 PERCENT CONFIDENCE* SIGMA-5.8581* DATA IN C3 C3 N 80 MEAN 23.492 ST. DEV. - THE ASSUMED SIGMA- 5.8581 A 95.00 PERCENTC.I. FOR MU IS ( 22.0073* 24.9761> 5.88 'INTERVAL 99 PERCENT CONFIDENCE* SIGMA-5.8581* DATA IN C3 C3 N 60 MEAN 23.492 ST.DEV. - THE ASSUMED SIGMA- 5.8581 A 99.00 PERCENTC.I. FOR MU IS < 21.5398* 25.44371 5.86 BLI 12/7/82 -56- TABLE VIII STATISTICAL DATA REFERENCE FOR Figure 5 013906 REGRESS C3 ON 1 PREDICTOR IN COLUMN Cl THE REGRESSION EQUATION IS V 41. - 0.23* XI COLUMN COEFFICIENT -- 41.24 XI Cl -0.236 ST. DEV. OF COEF. 17.25 0.229 THE ST. DEV. OF Y ABOUT REGRESSION LINE IS 5 5.355 UITN < 60-- 2> 53 DEGREES OF FREEDOM R-SQUARED * 1.3 PERCENT R-SQUARED 0.1 PERCENT. ADJUSTED FOR D.F. ANALYSIS OF VARIANCE DUE TO REGRESSION RESIDUAL TOTAL DF 1 58 59 SS 36.37 1933.33 2024.74 MS-SS-'DF 36.37 34.23 T-RATIO CDEF/S.D. 2.39 -1.03 BLI 12/7/82 -57- 013907 NOTE THE P0LLDWIN6 IT ft NORMAL PROBABILITY PLOT FOP C* APPARENT VIiCOTI TV N;COPES OP C PUT IN C4 PLOT C VS C4 C 4. 0* FIGURE 40 0.0* &u 8 16. 0-*" ! 1 IS. 0* 8.04 33 3* 38 34 3 6 * 3 4. 04 -3.0 -8.0 MIST06RAH OF C8 NIBBLE OF INTERVAL 6. 8. 10. 1. 14. 16. 18. 0. . 4. NUMBER OF OBSERVATIONS 1 1 3 18 18 9 4 1 1 -1.0 -0.0 Nscorts of Av 1.0 .0 3. Figure 41 58 013903 NOTE THE FOLLOW I MS Ii ft NORMAL PROBABILITY PLOT FOP C*:. YIELD POINT NSCOPES OF C3 PUT IN C3 PLOT C3 VS C3 C3 48.04- Figure 42 33.04- 88.04- 8 81.04- .14.0* 3* 2 3 8 8 43 5* 8 3 7 7.0+ 0. 0* -3.0 -8.0 -1.0 -0.0 Nscorts of Yp 1.0 8.0 HISTOGRAM OF C3 (Yp) MIDDLE OF interval 4. 8. 18. 18. 20. 84. 83. 32. NUNBEP OF OBSERVATIONS 1 0 8 3 18 13 10 8 Figure 43 tf 59 APPENDIX II Tabulated Fann Viscosity & Settling Data 013909 & -60- TABLE IX FANN VISCOSITY AND SETTLING TEST RESULTS (Farm Data Based on 10 lb/bbl Suspensions) BLI 12/7/021 Sufi* IdMtlflcattM SVB"2-76 SVB 11-76 SVB 6- 74 X Bentonite 50 50 50 50 50 50 (1) (2) fllxer Time Av Minutes Cps 10 19 (4). (5) _____ K . X Settle Ib/lOOft Ib/lOOft lb/100ft| 1 hr. 48 hr. 33 11.9 9.9 0 14.4 (7) X Settle 1 hr 48 hr. 25 69 40 37 57 11.9 10.7 0 12 19 57 10 16.3 26.5 10.3 8.5 0 14.4 27 69 40 38.3 60.5 11.8 12.4 0 16 22 61 10 12 19 6.4 6.4 4 30.4 24 71 40 22.3 39.5 12.9 11.4 0 9.6 27 71 SVB 9-73 SVB 3-73 50 10 10.3 16.5 6.3 4.6 3.2 33 51 79 50 40 14.8 24.5 9.7 8.9 0.8 21.6 27 70 50 10 5 5 0.7 1.2 15.2 48.8 67 80 50 40 8.8 12.5 4.1 4.5 8.8 36 58 77 SVB 2-76 0 5 25.8 22.5 1.2 Flosal 2-82 ......... 0__________ 50 50 10 30 27.3 27 33.5 3.6 12.9 % 50 30 29 40 13.0 50 40 28.5 41 12.7 Flosal 2-82 SVB 3-73 0 0 30 26.5 15 5 16 14 2.0 0.7 (1) Suspension prepared with Multi-mixer (3 discs) (2) Av - centlpoise 9 1022 sec -1 (3) Yp - lb/100 ft.2 based on 1022 and 511 sec -1 (4) K - lb/100 ft.2 based on 1022-170 sec -1 (5) K lb/100 ft.2 based on 10.2 -5.1sec -1 (6) X Settle of 10 lb/bbl Suspensions containing 44 lb/bbl M03 (7) X Settle of 3 lb/bbl suspensions containing 13 lb/bbl WO3 12.9 6.1 19.3 23.6 22.8 20.0 10.5 3.2 2.4 0 0 0 0 16 16 20.fi 4 8 8 5.6 36 39 39 6 15 17 41 64 53 54 41 49 50 47 70 013910 TARIc X SETTLING TESTS 10 lb/bbl ASBESTOS AQUEOUS SUSPENSIONS (44 lb/bbl W03 WEIGHTING AGENT) -wi 12/7/G2 SampIt Prepared In Multi Identification Mixer tMlnutes*) Flosal/Bent. 2-82 10 1 hr. Flosal/Bent. 2-82 30 Flosal/Bent. 2-82 Flosal only SVB/Bent. 2-76 SVB/Bent. 11-76 cIn SVB/Bent. 6-74 r1o SVB/Bent. 9-73 SVB/Bent. 3-73 40 30 10 10 10 10 10 0 4.0 3.2 15.2 SVB/Bent. 2-76 SVB/Bent. 11-76 SVB/Bent. 6-74 SVB/Bent. 9-73 SVB/Bent. 3-73 40 40 40 40 40 0.8 8.8 SVB only/2-76 SVB/only/2-76 SVB only/ 3-73 50 3.2 2.4 16 2 hr. 0.8 0 8.0 5.6 20.8 1.6 1.6 12.8 5.6 4.8 26 PERCENT SETTLE 3 hr. 4 hr. iJL 0.8 0.8 1.6 0.8 10.4 7.2 24.8 0.8 2.4 1.6 12.0 8 27.2 0.8 3.2 0 1.6 13.6 28.8 0.8 4.0 2.4 15.2 8.8 7.2 32 3.2 16.8 10.4 9.6 34 4.8 18.4 11.2 12.0 6 hr. 0.8 0.8 2.4 0.8 1.6 14.4 30.4 1.6 4.8 0.8 4.6 20.0 12.0 13.6 24 hr. 48 hr. 1.6 4.0 72 hr. 4.8 4.8 8.0 5.6 8.0 10.4 5.6 8.0 8.8 24.0 5.6 14.4 14.4 30.4 40,0 20.0 34.4 33 33 33 42.4 4.8 12.0 4.8 16.0 48.8 12.0 16.0 9.6 21.6 53.6 16.8 19.2 13.6 26.4 29.6 16.0 36.0 16.0 40.0 16 20.8 36 20.8 36 rimt VT SETTLING TESTS 3 lb/bbl ASBESTOS AQUEOUS SUSPENSIONS (13 lb/bbl W03 WEIGHTING AGENT) or 2/7/82 Sawplt Prepared In Multi- Identification Mixer (Minutes) Flosal/Bent. 2-82 Flosal/Bent. 2-82 Flosal/Bent. 2-82 Flosal/only/2-82 SVB/Bent. 2-76 SVB/Bent. 11-76 SVB/Bent. 6-74 SVB/Bent. 9-73 SVB/Bent. 3-73 ' 10 30 40 30 10 10 10 10 10 1 hr. 6 15 17 41 25 27 24 51 67 SVB/Bent. 2-76 SVB/Bent. 11-76 * 40 40 19 22 SVB/Bent. 6-74 .sweent 9-7? , SVB/Bent. 3-73 SVB only 2-76 SVB/only/2-76 SVB/only 3-73 40 40 40 5 50 5 27 27 58 39 39 64.4 2 hr. 9 20 23 45 34 36 36 60 67 26 27 37 38 62 46 46 66.4 PERCENT SETTLE 3 hr. 4 hr. 5 hr. 6 hr. 11 13 15 16 23 26 28 29 26 28 30 31 46 46 46 .47 39 42 45 46 41 45 47 49 43 47 50 51 64 64 - - 70 71 72 73 30 35 36 38 33 36 '38 40 41 44 47 49 43 47 50 52 65 66 49 51 50 52 68 68.8 67 68 52 52 52 53 -- 24 hr. 31 42 43 47 62 63 65 79 79 50 54 63 64 74 53 54 70 48 hr. 41 49 50 47 69 69 71 79 80 57 61 71 70 77 53 54 70 72 hr. 47 54 72 73 75 79 81 61 65 73 . 73 78 53 Ig T n rt Trtuuc f'*1 f'LI tcif/Bk FANN RHEOLOGICAL PROPERTIES OF (1:1) RATIO SUPERVISBESTOS (Feb.-76)/BENTONITE AQUEOUS, SUSPENSIOUS (10 Ib/bbl SUSPENSION -11.4 qm/400 ml WATER) Saapli Identification 5VS* - Feb. 76 last Performed Initial Temp C mixing Allowed to Stand 5 25 18 6000 9 15 sec. 27.5 3000 9 30 sec. 23.5 2000 5 45 sec. 100 0 60 sec. 60 9 75 sec. 30 9 90 sec. 21 18 9 8 Temp. C 23,5 remixed 600 09 15 sec. 300 09 30 sec. ____ 2.... 32 29 200 09 45 sec. 27 1000 9 60 sec. 23 60 9 75 sec. 12 3q9 90 sec. 1OO0 9 105 sec 10 Multi*M1xer Time (Minutes) 10 15 20 25 29 30 35,5 38.5 18 18 18 18 37 44.5 52 58 33 41.5 49.5 54 30 38 26 32 45 49.5 37 40.5 12 15 11 14 20 21 17 18 24.5 24.5 24.5 24.5 .. 2 38 35.5 s)>t 2 47 44 41 2 54 51 46.5 2 59.5 56.5 51 28 33.5 38 41 13 17 20 21.5 12 .15 _ 17 17.5 r>r> A n *7 30 40 18 66 62 55 45 23.5 20 24.5 2 69 63.5 56.5 45.5 22.5 19 35 44 18 72 67 59 48 25 20.5 24.5 2 75 67 58.5 47 24 18 - 40 45 18 72 67 59 48 24,5 20.5 23 2 74 65.5 57.5 46 23.5 19 50 49 18 82.5 74.5 65 52.5 27.5 21 23.5 2 85.5 74 64.5 49 25.5 19 TAL-- XI. CONTIHUED -LI 12/7/32 Staple Identifies!ten SVB - Feb. 76 Ittl NrfMwl 100 60 120 sec. 100 69 13$ sec. 5 23 23 100 e@ 195 sec. 100 e9 25$ sec. 100 e9 315 sec. 100 e9 375 sec. 100 e9 435 sec. 6 69 450 sec. 23.5 23.5 23 22 21,5 11 3 q9 465 sec. 9.5 600 8? 480 c. 300 9 495 sec. 31 28.5 Xemo-lc__________ pH '24.5 9,29 Multi-Mixer Time (Minutes) 10 15 20 25 28 41.5 36.5 39 27.5 42 36 38 30 41 39 35 40 38.5 27.5 27.5 41 40 34.5 33 36 34.5 35 32.5 34.5 32 27.5 41 31.5 33 31 29.5 27 40.5 30 26 41 29 11 14 15 31.5 30.5 16 29.5 28.5 15 28 27 13.5 10 12.5 13 13 11 10 37 47 35 44 54.5 50 57 52.5 61 55.5 65.5 58 26 9,30 25.5 9.24 26 9.23 26 9.23 26 9.19 27 9.18 40 40.5 39 35 33 31 30 29 15.5 12.5 69 59.5 25 9.15 50 40 38.5 34 31 29 27 25.5 13 10 72.5 61 25 9.10 O 03 I-* . TABLE XIII an 12/7/82 FANN RHEOLOGICAL PROPERTIES OP (1:1) RATIO 5QPERVISBEST0S (Nov.-76)/BENTQNITE AQUEOUS.SWW10HS, (10 Ib/bbl SUSPENSION - 11,4 gm/400 ml WATER) Sample Identification SVB- Nov. 76 foat Nrfiw4 Initial Temp C aftW! mixing Allowed to Stand 5 26 18 6009 0 15 sec. 3006 0 30 sec. 22 18.5 2009 9 45 sec. 1009 9 60 sec. 6e 9 75 sec. 39 9 90 sec. Temp. C remixed 600 99 15 sec. 300 00 30 sec. 200 90 45 sec. 1009 0 60 sec. 69 0 75 sec. 16.5 14 7.5 . 6,5 24 2m1n. 24.5 21.5 20 17.5 8.5 3e0 90 sec. 100e@ 10^ sec. 8 18 Mu1t1M1xer Time (Minutes) 10 15 20 25 28 18 30.5 27 30 18 45 42 24.5 21 11 39.5 33 17 9.5 24 2 32,5 29.5 15 24 2 46.5 44 28 24 11.5 10.5 24 41 34 18 15 34 30 40 18 60.5 57.5 52 42.5 22 18.5 24 2 63 59 52.5 42.5 22 19 An 35 40 40 18 73 69 61 49 -l 26 21 24 2 76.5 68.5 60 47 24.5 20 n 50 46 18 77.5 71.5 63 51 26.5 21 24 2 80.5 71 . 62 48 25 20 m TABLE XIII CONTINUED uLI 12/7/G2 Staple MeatlflcitlM SVB-Nov. 76 last tarfiml 5 100 ei 120 sec. 100 e9 13$ sec. 18 18 100 e9 195 sec. 100 et 255 sec. 100 e9 315 sec. ... 18-5 18 18 100 et 375 sec. 100 et 435 sec. 6 et 450 sec. 18 17.5 8 3 e9 465 sec. 7 600 0 480 SfC. 24 300 et 495 sec. Taap. C pH -^2 25 9.34 Multi-Mixer Time (Minutes) 10 15 20 25 30 35 40 50 24 33.5 38.5 39.5 40 24 33.5 37.5 38 38 24.5 24.5 24 23 ' 33 32 30.5 29.5 34 31.5 30 28.5 33.5 31 28.5 26.5 34 31 29 27 23 10.5 29 13.5 27 14 25 25.5 13 14 10 12 12 10 10 32 46 56 65 68 30 25 9.30 43 25 9.23 52 25.5 9.20 58.5 26 9.16 60.5 26 9.16 -67- T*"'E XT" 1^/7 'L,>' FANN RHEOLOGICAL PROPERTIES OF 0:1) RATIO SUPERVISBESTOS (June-74) /BENTONITE AQUEOUS SUSPENSIONS (10 Ib/bbl SUSPENSION -11.4 gm./400 ml MATER) HI T Sample 14m! If let If SVB* - June 74 leal NrfMMi Initial Temp. oC after mixing Allowed to stand 5 27 23,5 Multi-Mixer Time (Minutes) 10 15 25 30 29 23,5 33 23,5 39 ` 23.5 35 40 50 40 43 24' 23.5 -68- 600 e 915 sec. 300 o 930 sec. 200 e 945 sec. 100 0 960 $ec, 6 e 975 sec. 3 0 990 sec. Temp C Redispersed In HMltlrmlxer...... 600 915 sec. *} 300e 930 sec. 200e 945 sec. 1OO0 960 sec. 18 14.5 13 11 5.5 5 2 min. 19.5 15 5 15.5 13* 24.5 31,5 39 20,5 28 35 25.5 33 16 22 27.5 8 7 23.5 2 min. 24 2 min. 11.5 IQ 23,5 2 min. 2 min. 31 14,5 13 23,5 38.5 21.5 28 36 20 26 33,5 17 22 28 44.5 53 41,5 50 38 45.5 32 37.5 16.5 14 23.5 19 16,5 23.5 44.5 42 38.5 32 54 51 46.5 38 6e 975 sec. 3e 990 sec. 6.5 8 5.5 7.5 11.5 10 15 12,5 14,5 13.5 20 q 16.& 1OO0 9105 sec. _____ _LZ____ 22.5 JU____ -31 ,L- 37 lABLt XIV CONTINUED 12/7/82 - in in rCsO ICDO ccot* CCOO CO oCO ceng in r- eg -- CinM CTl cf in iCnM CfmOm OV o m CO in jmm CO r*~ in CO CO oCO CoO eCTgi irn- C--M in ir*n3" *3- r-- in CM o> CO oCO in 00 CM C0M0 C0M0 CoVoJ Cs. CM PCnVJ- in eg icno* in rr- icno* co VCOO P*^ in CM rC*h* +<scj/) iCnVI o CM m in in CCVMJ CeVgJ CCVOI CO CVI CVJ CM eCVgI irn"* CM rr--** mo>* iocno CO9 eg 00 eing eg 9 O m r-- f*N- in inV inr fv* r^' Cn. CO in* CM eCMg ieng *C*O* crC in in m in CO CO co co rC--O in in CO co iri in eOg in CM C* 0* i <oD (ft g VCft * * u(ft uCft u (ft . (oft o(ft uCO o(ft #0 u(ft u0(f)t E5 oeg icno in apm*m iiCnnM ifmnm CO fisn* co icno o 3- o CO O* cr O o <B> Gj cL Oo !Oo ofomm Ofomm Oo oo r" CO oo ooCO K G~ | mt *sr U Oc31 J 0C>O0 69 mj i T"3LE / FANN RHEOLOGICAL PROPERTIES OF (1:1) RATIO SUPERVISBESTOS (Sept.-73) /BENTONITE AQUEOUS SUSPENSIONS (10 lb/bbl SUSPENSION -11.4 gm/450 ml WATER) SlRplc Identification SVB - Sept. 73 fast Perfarmed Initial Temp. oC after mixing Allowed to stand 600 e 015 sec. 300 e 930 sec. 200 e 945 sec. 10 27 24 hr. 40 29 24 hr 30.5 27.5 25 MULTI-MIXER TI HE (MINUTES) ' 100 0 960 sec, 6 975 sec. 3 0 990 sec. Temp C Redispersed In Multirmtxer 600e 915 sec. 3000.930 sec. 2000 945 sec. 100 960 sec. 6q 975 sec. ..... 30 990 sec. 21 2 min. 20.5 18.5 17.5 15 7.5 6.5 22 10 10 21 2 min. 29.5 2 min. 2 min. 2 min. 27 25.5 22 10.5 10 ___________________ BLJ 12/7/82 * o - ;jmnd ------- CO '-O TABLE *vI 12/7/82 FANN RHEOLOGICAL PROPERTIES OF (1 til RATIO SUPERVISBESTOS (Mar.-73)/BENT0NITE AQUEOUS SUSPENSIONS (10 Ib/bbl SUSPENSION - 11.4 qm/400 wl WATER) Staple 1 dentIfletlion SVB- Mar. 73 Ittl Perfereed Initial Temp C affpr mixing Allowed to Stand 6008 9 16 sec. 3008 9 30 sec. 2008 9 45 sec. 1008 9 60 sec. 68 9 75 sec. 38 9 90 sec. 5 25,5 ON 10 7 5.5 4 2 Temp, C remixed __ 24.... ' 600 89 15 sec. 300 09 30 sec. 200 09 45 sec. 1008 9 60 sec. 60 0 75 sec. 3e0 90 sec. 100e9 105 sec. 9.5 7 6 4,5 nC 1.5 4.5 Mu1t1*M1xer Time (Minutes) 10 15 20 25 26 29 on ON ON Of! 10.5 7.6 6.5 5 2,5 i. 12,5 9.5 9 7.5 3.5 2 24 2 10 7,5 6.5 3 24 2 12 9 8.5 57 2.5 3.5 23 57 30 30 Oil 15.5 12.5 11.5 10 5 4 24 2 15 12.5 11.5 10 r3 4.5 10 35 40 28,5 ON 10,5 15,5 14 12.5 6 5.5 24 2 17.5 15 14 12 6 5.5 1? 50 35 ON 23.5 21 19,5 17 8.5 7,5 24 2 23 20.5 19 16.5 3 7 17 FABLE XVI CONTINUED 2 5 .0 1 1 01*6 I OS <M3**0 CM P-% pH paw ph r-- pH 10 r" in ID N P- CO CM in o CM 1J m m in O CM CM CO r* CO CSJ CM paw CM ID in CD in S" CM O* m CO o CO o Oo o O o in m UO o CM ID CO r- CM o> IA M CM W 44 3 e iO CM ** 1- t X zm 1 4-> r-- 3 pH o in in a pH p^ mm in in ph p^ in in m* in in CO CO in in m in <- CM in o in m 9 CM r9 CM Cr> CM o> in in ro V o CO oC paw CM in in m in ac m in <' in m O in m CM CM pH co CM oC 5 m *u M ** N5 * & 9t o o Oo a m 8 8u 0) v w in in in * in CM n <3 * g s oo m V w M tft in in CO CO ttr Oo' oo o *1 o in v e> IO 9 U in ID ar o CO 0 uU MM o CO g ar u < o g IO ro VDu sc n. H-- * * 5 fl V> mm CO P*M u y(0 CO 00 72 .ABU XV.. FflNN RHEOLOGICAL PROPERTIES OF SUPERVISBESTOS (Feb.-76) AQUEOUS SUSPENSIONS (10 lb/bbl SUSPENSION - 11.4 gm/400 ml WATER) Sample Identification SVB Feb.-76 Tati Firforad Initial Temp. oC after mixing 5 27 Allowed to stand ON 600 q @15 sec. 48.5 300 e @30 sec. 35 200 0 @45 sec. 28 100 @60 sec, 19.5 -Isi CIO 6 0 @75 sec. 19 3 0 @90 sec. 18.5 Multi-Mixer Time (Minutes) 10 20 30 50 30 ON 51.5 37 29 21.5 18.5 16 35 ON 53 38.5 31.5 25 21.5 16 42C ....44..... ON ON 52.5 59 39 43.5 32 26.5 23 36 30.5 22 15.5 16 Temp C Redispersed In Multi-mixer s 600 @15 sec. 300 @30 sec. 200 @45 sec. 100 @60 sec. 21 2 min. 47.5 33.5 26.5 18.5 21 2 min. 21 2 min, 21 21 2 min. 2 min. 51.5 37 30 22.5 53 39 32 25.5 52 38 31 25.5 60 43.5 35 30 60 @75 sec. 3 @90 sec. TOO0 @105 sec. 16 15 17.5 18 15 21.5 18.5 15.5 24.5 19 18 14 13 24 31.5 BLI 12/7/82 * 2 c .6 l0 fABLt XVI i CONTINUED j I 12/7/82 IHULC aVII 1 FANN RHEOLOGICAL PROPERTIES OF SUPERVISBESTOS (Nov-76) AQUEOUS SUSPENSIONS (10 Ib/bbl SUSPENSION - 11.4 oro/400 ml WATER) SMRflt MmitfflcatlMi SVB Nov-76 Tttl Nrfimi Initial Temp. oC after mixing 27 Allowed to stand 24 hrs 600 e 015 sec. 300 9 030 sec. 43,5 32,5 200 e 045 sec. 25.5 100 0 050 sec, 17,5 6 e 075 sec. 18 3 090 sec. 14 Temp C Redispersed in Multirmlxer 600 015 sec. % 3009 030 sec. 2009 045 sec. 22 2 min. 42.5 32 25.5 1000 060 sec. 6e 075 sec. 17.5 13.5 39 090 sec. 100 9105 sec. 12 17.5 Multi - Mixer Time (Minutes) 10 . -2Q__ 30 50 30 30 40 44 24 hrs 24 hrs 24 hrs 24 hrs. 46 33.5 49,5 37,5 52.5 39.5 56 42 27 18.5 16 31 23 17,5 32 26 20 34 29 17 15 13,5 14.5 12.5 22 22 22 22 2 min. 45,5 34 27.5 19 14 13.5 2 min. 48.5 37 29 20,5 16 14 2 min. 2 min. 52 39,5 55.5 41 32 ' 32.5 26.5 19.5 14 27.5 15 12 19.5 22 26 28 DLT <2/7/cc oJ o --si 0t3d 25 I2/7/S2 jnt1.,v.d) i i-i i . -! >x 3inO ID O) 00 3CM CM cm in CO 00 I co CO CM cm 3 ICT' 3oco KO CM ID in co CM CM I CO c3o- I CM CM n C 0) X 3 1I CM CSJ CM in in in vo vo 4-> I $ CO co j O co CM CM in S3 U"> <n O) IX) in in in 0 mw in a\ in 5i co Sd CM *3- CT> 3 IT) fM. IDI in in I O) co in O co sa o in cn co G\ CM .1 Mk u uw A V) in CM *> <S> / oo o uOtnf u v> u 0) M o> min CM in co & oo uu u V) 0v)* ut o0> o v| tn o0) tn a a>n u01 M u ft) w in r* co CO o CO OV r- CM e> (Sc oo CO oi o o CO oo CO CM u o a a> H -76- ABl IX FANN RHEOLOGICAL PROPERTIES OF SUPERVISBESTOS (June-74) AQUEOUS SUSPENSIONS (10 Ib/bbl SUSPENSION - 11.4 gm/400 ml HATER Staple Identification SVB --June 74 Tost Performed Initial Temp C ftAir mixing Allowed to Stand 600e 9 15 sec. 3000 0 30 sec. 2009 9 45 sec. 1009 9 60 sec. 6e 9 75 sec. 3e 0 90 sec. Temp, C remixed 5 22 ON 41 28 22.5 15.5 14.5 14 22 2 riin. HultlrMIxer Time (Minutes) 10 20 30 50 22 22 22 21.5 ON ON ON ON 43 45 48.5 51.5 30 31.5 34 38.5 24.5 26 28 33 17 18.5 21 26 17 16.5 19.5 24 16 15.5 18.4 19 22 22 22 21.5 2 21.5 2 *600 99 15 sec. 300 99 30 sec. 200 99 45 sec. 1006 9 60 sec. 600 75 sec. 40 28 OLLn 15.5 15 42 29.5 24 16 13.5 45 33 27 19.5 16.5 47 34 29 22.5 17.5 51 37.5 31 26.5 18 3o0 90 sec. 1000 0 105 sec. 13.5 14.5 13 15 15 19.5 I 14.5 22 14.5 25 9LI i2/7/82 ft C c a rv c -78- TABLE (continued) XIX SmmIc 1dentIflea!Ion SVB June - 74 Tttl Ptrforaod 100 e(? 120 sec. 1000 135 sec. 100 00 195 sec. 100 eO 255 sec, 100 e0 315 sec. 100 00 375 sec. 100 00 435 sec. 6 @0 450 sec. 3 e0 465 sec. 600 0 480 sec. 300 e0 495 sec. 200 0 510 sec. 100 0 525 sec. 6 0 540 sec. 3 0 555 sec. Temp, C pH 5 14,5 14,5 14 -14 14 14 14 11 11,5 37,5 27,5 21,5 ... 15 11 12 23 5.29 10 15 14,5 14,5 14.5 14.5 14 14,5 10 11 38,5 29 23,5 17 13 12.5 23 5.41 20 IS IS 17.5 15 15.5 15,5 15,5 11 10 42 31 25.5 18,5 14 14 23 9.41 30 21 21.5 20 50 25 LJ nn . rJ 1C 13 17 17,5 17 17.5 17 17,5 12 11,5 11 10 42 32,5 46 33 26 28.5 19 12 11.5 nL n 21,5 14 12 23.5 9.42 BLI 12/7/82 % 03 ro . si... CO 1 ____ 1 )Ic 3 r~ FANN RHEOLOGICAL PROPERTIES OF SUPERVISDESTOS (March-73) AQUEOUS SUSPENSIONS HO Ib /b b l SUSPENSION - 11.4 qm/400 ml WATER) 3000 <? 30 sec. 2009 @45 sec. 4VQ9e->)I ion CCMM O LD CCOO iCOM o> ID in CCMM CM in . r-*. m CCOO in C1M0 in 00 LO in *3" Cn. sE VE oCO CCMM o in 5- CCTMv iCCnMM in in in uo CO CCMM CM in CC oCO CM mwo in in re- in 1-- wsX. sEt> oCM CCMM o in 0CO0 rC-%M CM in in CO CM CCMM CM m CCOO CM CM r-- m I-- in rc*o"* 4-> i o tn uo CCMM ZoSi CCOO <CM c- Cr--M in r-- iron-- CCMM CM CO <CM ra--\ icno CO Cr--M CO m in CeMg ror in oC%M CM ir> in ro" in CO CCMM & CM in CCMO CCMO iV*"O* CM in o m a- i w oU " *e0 a. e > 2o vf-- -- *9xfi" -o4-> X f*Jc--*-2i *a**, *o 5 oV) mr-- & oIoD m oi/i ow owMr oo iCns. <B> oor-- ID oCTY <8/ CO o<_> Csl i2i -Xo 1s_ uIA m <s> 1oo0 300 0@ 30 sec. uv>r u(A mer OIO uM irn. 9 uIA Oan w mo & oCoM <s> oo a> io <Bj e> CO oo i co xsuuIQi:: CscO>o -79- IABLE XX (continued) SMpll 1dentIflealIon Ttl Parfaraal SVB-March 73 100e9 120 sec. 100 e9 135 sec. 100 9 195 sec. 100 9 255 sec. 100 9 315 sec. 100 9 375 sec. 100 9 435 sec. 6 9 450 sec. 3 e9 465 sec. 600 e9 480 sec. 300 e9 495 sec. 200 9 510 sec. 100 9 525 sec. 6 9 540 sec. 3 @9 555 sec. Temp, C PH 5 11 11 11 11 11.5 11.5 9 9 32.5 22.5 16 11.5 9.5 10 23 9.38 10 13 13 12.5 13 13 13.5 10 10.5 33.5 25 18,5 13.5 11 10.5 23.5 9.38 20 30 14 15.5 14 15.5 13.5 13.5 15.5 15.5 13.5 14 15.5 15.5 9 10.5 10.5 9.5 37 39 27 29.5 21 14.5 22.5 16 12 12 12 10 23 9.38 23.5 9.37 50 17.5 17 16.5 17 17 17.5 10 9.5 42.5 31.5 25 18 10.5 9 24 9.38 15 Li 12/7/82 % M ------------------ 92 T" : ; FANN RHEOLOGICAL PROPERTIES OF (1:1) RATIO FLQSAL (Feb.-82) BENTONITE AQUEOUS SUSPENSIONS (10 Ib/bbl SUSPENSION - 11.4qm/400 ml WATER) BiT 12///82 Sampta Identification Flosal-Feb.82 lost Performed Initial Temp C aftpr mixing 5 .. 27 Allowed to Stand ..ON 600e 0 15 sec. 46 3000 0 30 sec. 34,5 2009 9 45 sec. 29,5 1000 0 60 sec. 26 6e 0 75 sec. 39 0 90 sec. Temp. C remixed - ?n ...16 24 2 min. 600 00 15 sec. 49 300 6@ 30 sec. 38,5 200 60 45 sec. 33 1000 0 60 sec. 60O 75 sec. 28,5 21,5 3e0 90 sec. 1OOq0 105 sec. 18,5 31.5 Multi*M1xer Time (Minutes) 10 15 20 25 32 39 ON ON on 55 54,5 59 43 42.5 48 39 39.5 44,5 34 35,5 38,5 22 20 24 2 54,5 44 42 29 25 24 2 54,5 44 41,5 28.5 24 24 2 58 50 47 37,5 29.5 26 38.5 36.5 28,5 25 57 41 29 25 41.5 30 47 ON 58 50.5 46 40 28,5 25 24 2 58 49 45 39.5 20 21 39.5 35 40 50 ON 59 46.5 44 39.5 50 46 ON 61.5 51.5 48 40.5 23.5 21 24 2 57 49 45,5 27 24.5 24 2 60 52.5 . 48 38.5 27.5 26 39 40.5 26 24 .40_.5 14.5 I 1 ? /7 /P '" m oO sr <sfr to d CO to to to co CO CO o CO co in to to a> CO CM VO in CM oi CT> cn CO CO CTi CO to to to CO CO CM o ID CO CO to to CO CM cn CO in VO CM cr> 01 59< 1 C OirNiTuIt.NEU EXDX * cn cn CO CO 5? to CM 3- in to o co CsJ CO CM VO o r-"* sr a- r" VO CM Or (Q/>) +j 3 C Ol E r* t-- s- 0) X -yr" / 1 4-> r*" sMmm o to r*1* *3" C&M to rv CO to in in 00 00 ro CO CCJ* d- to Ck to to or CO to VO <3* vO3" co o to to in 5 CM to VO O <- *3* CO CO CM < n *3" ps. ef CO to VO CM to CO VO CM d CM in CO VO 1 d- CM d CO CO 00 CM to to to to a> CM to tn fmm co CO CO to CO CO CO CO to 3 VO cr CO CM m in CM CO o CM to s- cn VO CM cn 0o 8 MM o CM k 8 0u s g MM m in m Ot in CM G> 881 0 Ju o w V* 0 U0 M 0 0u u Ms in m o r* cn n ivn in o mCOt g o ' % o ex oo 8 n 88 CO #< 0X I-- Q. | 5 il 82 W1 ...-LE 1 '.I 12/7/82 RHEOLOGICAL PROPERTIES OF FLOSAL (Feb. 2-82) AQUEOUS SUSPENSIONS (10 lb/bbl SUSPENSIOH-11.4 gn/400 ml WATER) Si*pl Identiclealion last Performed Flosal 2-82 Initial Temp. oC after mixing Allowed to stand 600 e PI5 sec. 300 e 030 sec. 200 0 945 sec. ............ .. ............ --...............-- 100 0 960 sec, 6 0 975 sec. 3 0 990 sec. Temp C Redispersed In Multirmlxer QOOe 915 sec. 3000 930 sec. 2000 945 sec. 1000 960 sec. 6e 975 sec. 3o 990 sec. 1OO0 9105 sec. LI.-- 30 43C 24 hrs. 56 36.5 31 29 25 24 24 2 min. 53 34 28.5 23 20 M ............. 16 Multi-mixer Time (Minutes) . w M CD CO TABLE XXII (continued) Smpli Identification Test Performed Flosal 2-82 100 0 120 sec. 100 1 135 sec, 100 Q 195 sec. 100 @ 255 sec. 100 0 315 sec. 100 @ 375 sec. 100 (? 435 sec. 6 0 450 sec. 3 q0 465 sec. 600 00 480 sec. * 300 00 495 sec. Temp. C pH 30 15 15 11 5 11.5 11 10 9.5 5.5 5 485 33.5 26 9.53 Multi-mixer Time Minutes JLI 12/7/82 f--1 CO CO FANN INSTANT READING TEST RESULTS (1:1) ASBESTOS/BENTONITE 10 lb /b b l SUSPENSIONS) j | ncmm * f1 SVB 2-76 V i/i eoo0aA) Time o f e Reading < 5 seconds 9 15 seconds CM Mix Time Minutes 40 40 42 76 CM ooCO < VooO 3 FANN e READINGS 100 e 70.5 45 59 58 38 49 48 6e 23 22.5 38.5 20 CD 06 86 69 09 CO VO CO CO CM in in McoooA I Flosal 2-82 < 5 seconds 0 15 seconds < 5 seconds(l) 0 15 seconds (1) 20 20 22 64 58.5 60 44 62 47 40 39.5 59 40 34.5 50 CM 29 26 CO CM rCO* *COr CCMM g- 85 01 J93 4 (1) A fte r shearing a t 170.4 sec -1 fo r 5 minutes 013935 Fann dial reading = * Shear Stress expressed as lbs/100 ft.2 013936 Fann speed (rpm) Times 1.7034 * (y) * Shear Rate expressed as sec'1 Apparent Viscosity ) Shear Stress Shear Rate r y a . (l3 Ibs./lOO ft.2 [yj sec-1 lb. - sec 100 ft.* X 478.8 dynes-sec cm2 = cps Yield Point (Yp) represents that point where the slope of the . shear stress - shear rate curve intersects the shear stress axis and is expressed in Ibs./lOO ft.2 Plastic Viscosity i/tp) represents the tangential slope at any given point on the shear stress - shear rate curve and is expressed as cps. Mrf . iTz&l y Power Law - applies to logarithmic plot of shear stress and shear rate where a linear relationship exists and is defined as: r -xyn where 'T - shear stress y * shear rate K Is a measure of fluid consistency; the higher K the more viscous the fluid. n Is the slope of the shear stress - shear .rate plot and a measure of the degree of non-Newtonian properties of the fluid. n<l for pseudoplastics and n = 1 for Newtonian systems. *> IL 013937 013938 0) F/GUAt 3 % i o CO co co 013940 (3) 013941 013942 013944 ^ 013946 (?) 013947 6*). 013948 (//>} f/6-Lin.z. n 6 Ik S ystcm Sf/tars f)ssetrore iter<ers Ufo/Tv*.nr~ / - -iXk)k! >(3WS (\z) 6feero 33s- - i/(j3/jg (to 0G6ET0 ,/ lnn-9 /jf 1 m C5 co o PROPERTY Reflectance (%) Magnitite (%) , Dry Bulk (lb./ft. ) Wet Bulk (10O./250 ml.) Wet Bulk (2g./l.) Wet Screen (Floe.) Cum. % +65 " " +100 " " +200 " " +325 Wet Screen (Disp.) Cum. % +65 " - +100 " " +200 " " +325 Available Fiber (%) Ultimate Fiber (%) AEC #lf|? (ml.) m AEC #or Fann (F-S)u; AV PV YP ASBESTOS PRODUCTS FOR DRILLING FLUIDS SUMMARY OF PHYSICAL PROPERTIES SUPERVISBESTOS "WgX~'Saiip'leT~ June July Aug. SeptT 70.0 70.0 70.5 2.0 1.6 1.4 26.4 24.7 26.8 --. 820 675 800 71.0 1.5 28.4 - 520 ___ VISBESTOS 1973 Q.C. Samples Feb. March June Aug. 67.0 1.9 9.2 186 365 67.5 1.8 9.0 162 320 67.5 1.6 8.5 167 400 69.0 1.4 8.9 165 465 OLD FLOSAL OFTa!------------------- City Wdwd. Enid 72.0 71.0 70.0 3.0 3.1 3.6 8.5 8.9 8.8 100 201 99 195 200 - 7.0 6.9 6.1 11.3 12.1 9.2 28.4 28.5 24.7 45.5 50.9 40.2 8.9 14.3 31.7 43.9 5.6 6.0 5.0 9.4 8.7 7.6 21.6 19.2 17.1 31.2 28.7 26.1 5.8 10.0 22.5 29.4 49.8 54.5 53.6 49.4 93.4 92.2 79.1 80.5 0_ 23 20 13 4 32 37 34 22 12 3 18 12.6 15.1 28.7 42.5 8.5 15.9 30.8 43.9 14.1 18.8 34.8 46.9 9.2 14.2 30.0 44.2 6.4 9.5 18.7 28.8 5.3 7.6 16.8 22.5 9.0 12.2 23.2 34.3 4.2 8.0 18.0 27.8 44.1 48.4 45.0 80.1 83.0 85.6 . F. S. F. S. F. S. 9 15 9 15 15 22 6 8 7 10 11 16 5 13 4 10 7 12 46.3 79.2 F. S. 7 13 58 4 10 44.3 53.6 67.9 74.4 52.5 38.5 58.4 44.8 68.6 50.0 77.1 66.8 13.1 16.2 29.8 37.9 18.3 13.6 21.8 16.8 30.2 27.0 36.4 35.7 48.0 46.7 44.7 77.2 80.2 71.5 ^Fann F&S is the Fann viscosity at 5 lb./bbl. in fresh water or in 125 Ib./bbl. MaCl ^AEC #1 Specification - 20 ml. max. *3)AEC #2 Specification - YP * 15 max. AV 15 min. fv41'AF & UF tests do not really apply to "Canadian" type asbestos. NEW FLOSAL "577T 71.0 2.1 5.8 177 280 ATLAS AZ-20 S77T" 68.0 2.0 9.6 86 185 7.4 20.1 39.0 51.7 3.7 7.7 17.6 27.2 48.4 88.5 52 6 4 4 35.3 44.6 56.6 67.0 4.1 6.6 13.7 27.4 54.C 72.0 - - ATLAS #1092 1UJ7J * 70.5 1.2 6.4 111 245 19.2 29.5 46.8 57.3 2.2 4.0 11.9 18.7 60.3 84.6 80 5 3 4 PACIFIC 7EX2 7EX3 9773 " 9/73 58.0 5.1 9.9 183 250 61.0 5.0 7.2 233 455 16.2 27.2 41.1 51.4 29.4 37.5 54.1 64.5 14.3 16.9 31.6 46.2 26.4 30.3 45.2 62.3 96.2^ 99.2(4) 67.7 95.1 00 14 8 11 Long Fibers 20 14 12 Long Fibers 11/27/73 H. B. Rhodes SUPER V15BEST0S - TYPICAL CHEMICAL ANALYSIS Component MgO SiO A1 Fe 2 3 Loss on Ignition (C02 & H20) Weight % 41.9 41.8 0.5 1.4 14.0 99.6 013955 SUPER VISBESTOS - TYPICAL SPECTROGRAPHIC ANALYSIS Component Ag A1 As Au B Ba Be Bi Ca Cb Cd Co Cr Cs Cu Fe 6a Ge Hf Hg In Ir K La Li Mg Mn Mo Na Detection Limit, Wt. % 0.001 0.003 0.01 0.002 0.006 0.003 0.001 0.005 0.002 0.006 0.01 0.01 0.003 N.A.(l) 0.001 0.006 0.01 0.005 0.03 0.02 0.03 0.03 N.A. 0.01 0.1 0.001 0.003 0.003 0.03 Analysis, Wt. % 0.0002-0.002 0.08-0.8 N.D. N.D. N.D. N.D. N.D. N.D. 0.008-0.08 N.D. N.D. 0.008-0.08 0.02-0.2 -- 0.004-0.04 0.8-8.0 N.D. N.D. N.D. N.D. N.D. N.D. -- N.D. N.D. Major 0.008-0.08 N.D. N.D. Component Ni Os P Pb Pd Pt Rb Re Rh Ra Sb Sc Se Si Sn Sr Ta Te Th Ti T1 U V W Y Yb Zn Zr Detection Limit, Analysis, Wt. % Wt. % 0.003 0.03 0.08 0.003 0.005 0.005 N.A. 0.03 0.02 0.03 0.01 0.01 N.A. 0.001 0.002 0.01 0.01 0.05 0.03 0.003 0.2 0.1 0.003 0.01 0.01 0.01 0.02 0.006 . 0.08-0.8 N.D. N.D. N.D. N.D. ' N.D. .------------- N.D. N.D. N.D. N.D, N.D. --------- --- Major N.D. N.D. N.D. N.D. N.D. 0.004-0.04 N.D. N.D. N.D. N.D. N.D. N.D. N.D. N.D. 1 N. A. - Not analyzed. N.D. - Not detected.