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PLAINTIFF'S EXHIBIT
BOELTER
WlON'MLMAL CONSULTANTS
Corporate Office re Corporate Center
5300 Higgins Road Suite 301
Ridge. IL e00*S-5~:
Mr eiC-4700 fax Mr o2-3i:r
Regional Office Chicago
FIBER RELEASE STUDY INDUSTRIAL FITTINGS POWER WIRE BRUSH
November 11, 1996 BAI Project 141BA-4602
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TABLE OF CONTENTS
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EAS.E
EXECUTIVE SUMMARY.................................................................................................... Objectives ...............................................................................................................
Background ............................................................................................................ Sample Results .......................................................................................................
1 1 1 1
METHODOLOGY..................................................... PCM Sampling Procedure.......................... Personal Samples ...................................... Average Room Air Samples ..................... Background Air Samples for TEM Analysis Background Air Samples for PCM Analysis Light Microscopy Analysis .......................... Electron Microscopy Analysis ................... Statistical Comparisons.............................. Laboratory Accreditation ............................
DISCUSSION OF FINDINGS ................................ Isolation Test Chamber.............................. Background Sampling Results................... Selection of Fittings.................................... Gasket Removal Test Method................... Sampling Results During Test...................
CONCLUSIONS................................................................................................................... 9
APPENDICES
A Compilation Spreadsheets and Graphs * TESTING RESULTS
B Compilation Spreadsheets and Graphs PRE-TEST BACKGROUND RESULTS
C - PCM Laboratory Reports
_
D - TEM Laboratory Reports
E - Original Photographs
FIBER RELEASE STUDY INDUSTRIAL FITTINGS POWER WIRE BRUSH
EXECUTIVE SUMMARY
Objectives
The purpose of the study was to determine the concentration of fibers in the air while gasket material was removed from flange faces using a flat blade scraper and the flange faces prepared using a power wire brush.
BacJatmund
'
The study was performed using intact flanges from industrial fittings. The fittings and flanges had been in service many years and were obtained from a decommissioned power house.
The study was conducted in an isolation chamber to eliminate outside influences. The study was conducted at the rate of one {1) fitting per hour over an 8-hour period.
The study was conducted on October 2,1996 by Mr. Fred Boelter. This report presents the results of the study described herein.
Sample. Results
All samples measured concentrations of fibers in air well below the U.S. Department of Labor Occupational Safety and Health Administration (USDOL-OSHA) 8-hour TimeWeighted Average (TWA) Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter (f/cc). Sample results are presented in the accompanying tables.
Fiber Release Study Industrial Fittings/Power Wire Brush November 11. 1996 Page 2
METHODOLOGY
PCM Sampling Procedure
Samples were collected and analyzed following NIOSH Method 7400. Air was drawn
through a 25mm, conductive cowl cassette with a 0.8 micron mixed cellulose ester (MCE)
filter for collecting airborne particulate. The cassette was connected to a dedicated Gilian
servo-drive pump. The pump was used to maintain a flow rate of two (2) liters per minute
(Ipm) for both personal and area room air samples.
'
A Brooks rotameter was used to calibrate the pumps prior to and post sample collection. The rotameter was calibrated against a primary standard.
The samples were sealed, labeled and shipped to the laboratory for analysis. Samples were signed by BEC, placed in a UPS shipping envelope, sealed, tracked by UPS, and arrived at the laboratory by next day air.
Peiggnai Samplas
Personal samples were collected by attaching the cassette in the breathing zone of the
individual performing the work for the duration of the test. The sampling pump was worn
on the individual's belt.
H_r
Average Room Air Samples
The isolation chamber was subdivided into 3,600 one cubic foot (1ft3) modules. For purposes of identification, each module.was assigned a discrete, consecutive number.
To determine the average room air concentration, eight (8) of the modules were selected using a random number generator. A sample cassette was located in the center of the respective module for the duration of the test.
Background Air Samples forTEM Analysis
Prior to conducting the test, the room was sampled to verify cleanliness. Five (5) samples were analyzed by transmission electron microscopy (TEM) following AHERA Protocol.
Just prior to collecting the samples, a "leaf blower" was utilized to aggressively disturb the isolation chamber's interior surfaces.
Air was drawn through a 25mm. conductive cowl cassette with a 0.8 micron mixed
cellulose ester (MCE) filter for collecting airborne fibers. The cassette was connected to
a dedicated Gast high volume pump. The pump was used to maintain a flow rate of 10
liters per minute (Ipm). '
-
" ' - --
A BGI rotameter was used to calibrate the pumps prior to and post sample collection. The rotameter was calibrated against a primary standard.
Fiber Release Study - Industrial Fittings/Power Wire Brush November 11, 1996 Page 3
The samples were sealed, labeled and shipped to the laboratory for analysis. Samples were signed by BEC, placed in a UPS shipping envelope, sealed, tracked by UPS, and arrived at the laboratory by next day air.
Background Air Samples for PCM Analysis
Simultaneous with collecting the five (5) samples for analysis by AHERA Protocol, three (3) additional air samples were collected in accordance with NIOSH 7400 for PCM analysis "on*site" in the BEC office. The same analytical procedures were followed in the BEC office as were used in the laboratory. An Olympus Model CH*2.phase contrast microscope
was used for the BEC analyses.
Lioht Microscopy Analysis
Samples were analyzed in accordance with NIOSH Method 7400. Total fiber counts were determined by phase contrast microscopy (PCM) in accordance with the NIOSH Manual of Analytical Methods, Fourth Edition, dated 8/15/94, A Rules. Values for PCM analysis are provided in the Appendix A and Appendix B spreadsheets.
Only fibers longer than 5 microns which have a length to width ratio equal to or greater
than 3:1 are counted. PCM analysis counts all fibers meeting the specified dimensions.
The analysis is not specific for asbestos but is the method specified to be used in the
OSHA regulations.
The PCM laboratory reports are presented in Appendix C.
Electron Microscopy Analysis
AHERA Protocol transmission electron microscopy (TEM) analysis was performed on all background samples to verify the cleanliness of the isolation chamber prior to beginning the test. The sample analysis was performed as described in the Federal Register Vol. 52, No. 210, the Asbestos Hazard Emergency Response Act (AHERA Protocol).
Small squares were cut from each filter, processed appropriately, placed onto 200 mesh copper screens (grids) and transferred to a modified Jaffe Wick Washer containing acetone solvent. After the appropriate processing time, the grids were examined with a JEOL 1200EX or 100CX TEM. Grid openings from each sample were scanned at 20,000 X.
When fibers or structures of various shapes were encountered, they were assessed for morphological characteristics and crystalline structure with selected area electron diffraction (SAED).
The TEM laboratory reports are presented in Appendix D. -
- --
Statistical Comparisons
Data was formatted in spreadsheets for analysis. Statistical functions were performed including maximum, average, minimum, standard deviation, and variance.
m.
Fiber Release Study industrial Fittings/Power Wire Brush November 11, 1996 Page 4
The spreadsheets in Appendices A and B present the data and summarize the statistical analyses performed.
Laboratory Accrsdjiaiiap
The samples were shipped to and analyzed by R. J. Lee Group, Inc. in their Monroeville, Pennsylvania laboratory. R. J. Lee is accredited for TEM analysis by the National Institute of Standards and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP) as Lab #101208. R. J. Lee is also accredited for PCM analysis by the American Industrial Hygiene Association (AIHA) as Lab #8204.
Fiber Release Study - Industrial Fittings/Power Wire Brush November 11, 1996 Page 5
DISCUSSION OF FINDINGS
isolation Test Chamber
Testing was performed in the Boeder Environmental Consultants' (BEC's) Isolation Test Chamber. The chamber is 20 feet wide by 20 feet deep and is 9 feet in height. The chamber was constructed of 6 mil polyethylene sheeting to physically separate the activity being tested from outside of the chamber influences. The chamber is shown in Figure 1.
The chamber was a static environment. FIGURE 1 - BEC Isolation Test Chamber During the test, there was no air movement into the chamber and there was no air movement out of the chamber. During cleaning, the room was ventilated with
HEPA filtered air. Entry into the chamber was only through an access airlock.
Background Sampling Results
Prior to conducting any tests, the isolation chamber was systematically cleaned. Following the cleaning, a series of background samples were analyzed from five (5) area sampling locations in accordance with AHERA protocol.
Background samples were collected under "aggressive'' conditions with analysis by TEM in accordance with AHERA Protocol.
Results of the Pre-Test Background sampling are shown in the following table:
STATISTICAL FUNCTION
Aggressive Air TEM (s/mm2) - Background -
maximum
AVERAGE MINIMUM STANO. DEV. VARIANCE COUNT
e.4 8.4 8.4 0.0 0.0
5
The levels met the AHERA Clearance Criteria of an average of less than seventy structures per millimeter squared (<70 s/mm2) for the 5 samples and the room was considered clean. Results are shown ip-the spreadsheet presented in Appendix B.
Selection of Fittings
Four (4) fitting with a total of eight (8) flanges were selected-for the power wire brush
industrial fitting test. Fittings which were selected for the test were as shown in the following table:
Fiber Release Study Industrial Fittings/ Power Wire Brush November 11, 1996 Page 6
HOUR
1 2 3, 4 5 6 7 8
TABLE 1 * FITTINGS SELECTED
FITTING/FLANGE
FLANGE
GASKET
NUMBER
DIAMETER (in.) DIAMETER (in.)
3lD 9 6 3/4
3lC
9 1/16
6 13/16
15A
9 1.16
6 7/8
15B 9 6 9/16 '
18A 9 5 3/4
18B 9 6 13/16 22C 7 * 5 5/16
22A 7 3/4 4 3'4
All fittings were obtained by Mr. Boelter from a decommissioned power house.' All fittings had intact gaskets and flanges and were carefully cleaned prior to being used in the test.*2
Gasket Removal Test Method
A work bench and hoist was placed in the center of the test chamber. The four (4) fittings selected for the test (See Table I) were all placed in the isolation chamber.
Personal and average room air samplers were started prior to beginning the testing. The samplers were stopped after completion of the testing.
Testing started at about 8:00am and was concluded at about 5:00pm ("test cycle"). There was about a one hour break starting at about 12 noon. During the testing, no one left or entered the isolation chamber.
Each hour during the test cycle, one of the eight fittings was positioned in the center of the room on the work bench ("cycle event"). A typical setup for an event cycle is shown in Photo 1.
PHOTO 1 - Test setup for Power Wire Brush. Fitting placed on work bench.
Each of the eight cycle events were essentially the same. During the hourly cycle event, similar procedures were followed as described in Table II:
The decommissioned power house was located in Peoria. Illinois.
2 The fittings were carefully blasted with glass beads to remove surface corrosion, rust, pamt, insulation, etc. The gaskets were left intact. A light coat of clear lacquer was spray appneo to the fitting after cleaning to prevent rusting. The edge of the flange was masked off during spraying to protect the gasket. If not removed, tne surface corrosion, rust, paint, and insulation would have interferea with tne analysis.
4*
Fiber Release Study - Industrial Fittings/Power Wire Brush November 11, 1996 Page 7
STEP 1 2 3 4 5 6 7
TABLE II - TYPICAL HOURLY CYCLE EVENT ACTIVITY
Place fitting on work bench Remove bolts holding flange together Using hammer to separate flange Removing flat blade scraper to remove gasket material Removed gasket Using a power wire brush, "face" both flange surfaces Finished fitting
PHOTO 1 2 3 4 5 6 7
Thumbnail photographs depicting the vanous steps described in Table II follow below. Full size photographs are presented in Appendix E.
PHOTO 2 Removing bolts. Fitting #31A is shown.
' PHOTO 5 - Removed gasket. PHOTO 6 - "Facing" the flange. PHOTO 7 - Finished fitting.
Fitting #22C is shown.
Fitting 15A is shown.
Fitting #15A is shown.
Sampling Results During Test
Results of 8-Hour Time-Weighted Average Permissible Exposure Limit sampling are:
STATISTICAL FUNCTION
MAXIMUM AVERAGE MINIMUM STAND DEV VARIANCE COUNT
_ PCM. Analysiay N10SH 7400 (Total t/ec)
- Personal Samglas-
Average Room Air
0.C23 0 022 0.021 0 001 0 000
2
0.C20 0.017 0.015 0.001 0 000
8
Fiber Release Study - Industrial Fittings/Power Wire Brush November 11,1996 Page 8
All sample results show the concentrations to be well below the current OSHA Permissible Exposure Limit of 0.1 f/cc as sampled over an 8-hour time-weighted average period of time. Refer also to Figure 2 for a graphical presentation of the air sample results.
Sample Number
Random Arta
Paraonal 8 hr-TWA
Figure 2 - Graphical presentation of the air sample results.
The Appendix A spreadsheets and charts present and depict the results of the testing in detail.
Fiber Release Study - Industrial Fittings/Power Wire Brush November 11, 1996
Page 9
CONCLUSIONS
Gaskets were removed and the flange faces of eight (8) fittings were processed at the rate of one (1) per hour. Eight (8) room air samples and two (2) personal samples were collected during the processing.
All sample results show the airborne concentrations of fibers to be well below the current
OSHA Permissible Exposure Limit of 0.1 </cc as sampled over an 8-hour time-weighted .
average period of time.
'
Respectfully submitted,
BOELTER ENVIRONMENTAL CONSULTANTS
Frederick W. Boelter, CIH, PE, DEE, QEP Reviewed by,
Enclosures
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APPENDIX A Compilation Spreadsheets and Graphs
TESTING RESULTS
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Compilation Spreadsheets and Graphs PRE-TEST BACKGROUND RESULTS
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APPENDIX E. Original Photographs
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-Photo 1Test setup for Power Wire Brush. Fitting placed on work bench.
-Photo 2Removing bolts. Fitting #31A is shown.
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-Photo 3Separation of flange. Fitting #31A is shown.
-Photo 4Removing gasket. Fitting #31C is shown.
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-Photo 5Removed gasket. Fitting #22C is shown.
-Photo 6"Facing" the flange. Fitting #15A is shown.
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-Photo 7Finishec) fitting. Fitting #15A is shown.
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