Document v1vnRzBENwxmrnqQbdDOJ5D3E

tom FLORES ENVTP.ONMENTAL CONTROL ; J--' lW 1' < ' MR. A. A. RAMBIKUR ENVIRONMENTAL CONTROL cc: . T. B. Bonney - Pittsburgh Mr. Wayne Genter - Point Comfor' February 7, 1974 RS: PHOTOMICROGRAPHS OF ASBESTOS FIBERS IN FLAMEMASTIC FLAME RETARDANT Enclosed are four photomicrographs taken of a slide prepared from the membrane filter worn by the painter spraying the flame retardant^. As indi cated on my December 27 report, the level of asbestos fiber concentration was well below the threshold limit value, nevertheless, some fibers were found as photos 2, 3 and 4 show. However, the majority of the filter is represented by photo 1. Reprints of these photomicrographs have been obtained so that Mr. Tom Bonney and Mr. Wayne Genter may have access to this information. TF:wc Enclosure TOM FLORES ALCOA 409810 0053 This FhCi07IV?pfl NOT APPROVED For Pub:.;c:ton m Any J AfunCo. o' America Fo.nt Cemferi, 1 exes /?ffc'7c> A/o. Z 409810 0055 This Photograph NOT APPROVED For Pub.ic :t on in Any f. od:a A:ummum Co. ol America Point Cemfert, Texas C' /V0, ^ 409810 0057 This i hstern' nh n OVEDZ' D i\ For Fuj.;c:i dh in Any [ cd:a Aluminum Co. of Amirica Point Comfort, 1 exes P//C/V A/O.JZ c 409810 0059  nj , iofo"r"ch N 0 T A P p R r v! C Fcr FulUc. in ,> r/>ni LI I.rnni!! : lil-1r-1!, Oi nr;ncj Fo.Pi u.. !crt, lexos 409810 0061 THOMAS B. BONNEY TO: C/c /?y 7^Li j / zfj y<$^, y^ ^ *(c/ /*'U<J(tota sf* 1 '0>1 ry/"/&** rj*>n~id 't^-O ^.t'hlsfi oU<r***sj y (<3UI~JI y&'fasr' M 6f M iSfM. C*L-HI^! ~t~ jyd/~ u/-P X&. ~zfc C-f-n^/y' **i T^v1 -j^ccj/s. Ovrufyes, ujl^^s foi*~<<{ -f/s cUf Jfij 7^/id<sf aJLu**r&f hy/ 7*T jgj, ^ jt-hy yeyr-e- pr* C-Cryi (fiyjt'^ejf'^>-x./ '7*Aujf~ C~f^ . f~ Y -yy, -//# &(- y9 brf'S-l cy??*t -rfvjf y^M^i /j a. f<rt> </ 4>*74 *>(- d-Y^t <nt~Ucr*y. J'mr^m a^r'^/,<^ qM-o . Q ALCOA 1501 Alcoa Building Pittsburgh. Pennsylvania 15219 409810 0062 MR. T. B. BONNEY - 7 AB FROM C. L. PITTMAN \ PITTSBURGH OFFICE - 4 WP TO MEMORANDUM January 17, 1974 RE: PRECAUTIONS WHEN SPRAYING FLAMEMASTIC OSHA requires very special precautions when spraying materials containing asbestos if airborne asbestos exceeds certain prescribed limits. The fire retardant, Flamemastic, which is sometimes sprayed on our electrical cable ladders contains asbestos and raises the question of whether or not special precautions are required. This matter was referred to Mr. T. B. Bonney and a copy of his reply is attached. Note that he feels that asbestos from the spraying of Flamemastic does not constitute a hazard but he does recommend the interim use of certain respirators. C. L. PITTMAN CLP:jss Attachment cc: Plant Chief Electrical Engineers Plant Industrial Hygienists T. B. Bonney - 7 AB L. C. Drapela - 3 WP H. D. Keefer - 4 WP R. W. Plummer - 20 AB 0 ALCOA 409810 0063 SF-496S (flev 1| ee) FROM THOMAS B. BONNEY PITTSBURGH OFFICE - 7 TO MR. C. L. PITTMAN PITTSBURGH OFFICE - 4 WPH January 11, 1974 RE: SPRAY APPLICATION OF FLAMEMASTIC On the basis of air sampling tests conducted by Analytical Research Laboratories, Inc., and Pt. Comfort personnel, we do not consider it essential that applicators wear air-supplied respirators. Although the OSHA regulation requires the use of a supplied-air respirator when spraying asbestos, the respirator is intended to be used to keep exposures below the permissible exposure limits. Since the airborne asbestos concentrations generated during the application of Flamemastic, even without the benefit of a respirator, are below prescribed limits, we reason that further reduction of asbestos exposure is not required. We have discussed this matter with Mr. Costa of Alcoa's legal staff and he is in agreement with this interpretation. Pt. Comfort apparently chooses to provide their applicators with supplied-air respirators for their personal comfort because of the odor and the exposures to other components of the flame retardant. There is no reason for them to discontinue this practice. As a matter of fact, we would recommend that applicators wear at least an approved filter respirator such as MSA's Dust-Foe, 3M's 8710 or other similar types. This will afford our employees a degree of comfort and will assure them of protection until we have a better idea of typical exposures during spraying. Additional sampling data will better describe the expected range of contaminant concentrations. Although we are confident of the data we now have, we would prefer some greater depth should we be required to defend our position. We would appreciate it if Mr. Rambikur would arrange for additional sampling when Flamemastic is scheduled to be applied to the cable trays at Pt. Comfort. A total (dry) weight of material collected on the filter as well as a fiber count should be determined. The total particulate data will determine if exposures other than asbestos are of any concern. Thomas B.. Bonney TBB:mh cc: Mr. S . W. Marshall, Pt. Comfort Mr. A . A. Rambikur, Pt. Comfort Mr. C . F. Scott, Pt . Comfort 0 ALCOA 409810 0064 sr-4?i6 (*v n-ee> TOM FLORES ENVIRONMENTAL CONTROL December 27, 1973 TO MR. A. A. RAMBIKUR ENVIRONMENTAL CONTROL cc: Mr. W. Genter/Mr. S.W. Marshall Mr. C. F. Scott Mr. C. L. Pittman - Pittsburgh ------ ^Mr. T. B. Bonney - Pittsburgh RE; ASBESTOS DUST TEST ON FLAMEMASTIC FLAME RETARDANT Samples were taken at R-45-9Y motor control center while spraying the cable trays with flamemastic flame retardant material. Two samplers were used, one on the man doing the spraying and the other one was placed at the northeast corner of the room with the face of the filter facing the wall. This was to prevent contamination of the filter by a direct hit from the spray gun. A fine fog was visible in the room while spraying as well as the pungent odor of the vehicle used in the mixture. Both men working in the room wore hoods with purge air. A noticeable amount of material was collected on the filters, but upon examination under the microscope the asbestos fibers on both filters were well below the required level. Results below: Date ______ Test ______ 12-20-73 1 2 Time Sampled _________________ 71.17 mins. 57.62 mins. Location ____________ On man By wall Concentration Fibers/ml .938 .023 Time Weighted _____ Avg. c-r *-> - .139 .0028 TF:wc ' TOM FLORES 409810 0065 FROM THOMAS B. BONNEY PITTSBURGH OFFICE - 7 TO MR. C. L. PITTMAN PITTSBURGH OFFICE 4 WPH January 11, 1974 RE: SPRAY APPLICATION OF FLAMEMASTIC On the basis of air sampling tests conducted by Analytical Research Laboratories, Inc., and Pt. Comfort personnel, we do not consider it essential that applicators wear air-supplied respirators. Although the OSHA regulation requires the use of a supplied-air respirator when spraying asbestos, the respirator is intended to be used to keep exposures below the permissible exposure limits. Since the airborne asbestos concentrations generated during the application of Flamemastic, even without the benefit of a respirator, are below prescribed limits, we reason that further reduction of asbestos exposure is not required. We have discussed this matter with Mr. Costa of Alcoa's legal staff and he is in agreement with this interpretation. Pt. Comfort apparently chooses to provide their applicators with supplied-air respirators for their personal comfort because of the odor and the exposures to other components of the flame retardant. There is no reason for them to discontinue this practice. As a matter of fact, we would recommend that applicators wear at least an approved filter respirator such as MSA's Dust-Foe, 3M's 8710 or other similar types. This will afford our employees a degree of comfort and will assure them of protection until we have a better idea of typical exposures during spraying. Additional sampling data will better describe the expected range of contaminant concentrations. Although we are confident of the data we now have, we would prefer some greater depth should we be required to defend our position. We would appreciate it if Mr. Rambikur would arrange for additional sampling when Flamemastic is scheduled to be applied to the cable trays at Pt. Comfort. A total (dry) weight of material collected on the filter as well as a fiber count should be determined. The total particulate data will determine if exposures other than asbestos are of any concern. Thomas B. Bonney TBB:mh Mr. S. w. Marshall, Pt. Comfort Mr. A. A. Rambikur, Pt. Comfort Mr. C. F. Scott, Pt . Comfort ALCOA 409810 0066 (KV. It-**) MR. T. B. BONNEY - 7 AB C. L. PITTMAN PITTSBURGH OFFICE MR. W. Li. GENTER POINT COMFORT OPERATIONS November 14, 1973 RE: SPRAY TEST FOR FLAMEMASTIC You recently inquired as to whether a representative from Pittsburgh would witness the planned spray test for Flamemastic when measurements will be made to determine whether or not asbestos fibers from the Flamemastic would constitute a hazard. Mr. Bonney is overseas; but in referring to his letter of October 11, 1973, on this subject, I gather that he did not plan to send anyone to witness the test since Mr. Rambikur's staff is experienced at these tests. I also discussed this matter with Mr. George Farrah and he said that it was his understanding that no one from the Environmental Health Laboratory at Merwin would witness these tests. Since no one from the engineering group plans to participate in the tests, you are free to proceed as soon as you have the material and can make the neces sary arrangements with Mr. Rambikur. C. L. PITTMAN CLP:js s cc: T. B. G. H. S. W. A. A. Bonney - 7 AB Farrah - ATC Marshall - Point Comfort Operations Rambikur - Point Comfort Operations fcr: H. D. Keefer F ALCOA 409810 0067