Document vB9kLE74pLn600VrYzJK7Genb

Ttxe IDir~^Corporation 996 Wcsr Avinuc 26. Lo AncclU. CAiiroflNiA 90069 Ca>u: OYNATHERM * 2!3> 229.2419 A^ / \ r ^ r> m ~ ^ '; j* i* Cc j' r >v- & rvv^ ' , H ^ -A-v V/'""tfi'v'<n- `f Tei^o'rt. f?jlSTEVt.. /Uxj<r pTos CoticotAig> "Te^r\ /aul b*J6 Las fLeptirzTA<jZ&xo'r i-Carr or nr CeTTVK. b/9h^> Mr. W. D. Steindorf, Buyer, Point Comfort Operations, Aluminum Company of America, Point Comfort, Texas. 77978 May 3, 1973 l3o -5 i/ Dear Mr. Steindorf: I am enclosing the copies of the photographs requested by Mr. Genter. I'm sorry they were not available earlier, but it took some time to obtain the negatives and have prints made. I hope they will be of assistance to you. With regard to the reference made by Mr. Genter to Volume 38 of The Federal Register No. 66, dated April 6, 1973, we have the following comments: 1. It is our understanding that the effective date of these regulations with respect to asbestos has been moved ahead and they presumably will go into effect in October of this year. 2. We feel that the intent of the regulation is described on page 8821 (enclosed) where it states "The promulgated standard applies to those uses of spray-on asbestos materials which could generate major emissions of particulate asbestos material." Since the tests we have had performed have shown no emissions of asbestos fibers occurring in the application and use of Flamemastic 71A, we are of the opinion that the use of the material falls under those sections of the presently existing Rules and Regulations cited in our previous letter. 3. The spray-on materials referred to in the regulations are undoubtedly the fragile low-density fibrous insulations applied to a thickness of two to four inches on steel beams in high-rise buildings and factories. These materials do produce major particulate emissions both in their application and when such installations are demolished. Flamemastic 71A is not basically an insulation material due to 77 Continued APC 005238 Mr. W. D. Steindorf -2- May 3, 1973 the de-rating problems inherent in the insulation of power cables, and therefore it has little in common with the above-mentioned materials. This is our interpretation of the existing and proposed Rules and Regulations. We would appreciate any comments you may have. Very truly yours, THE DYNA-THERM CORPORATION /cr Enclosures Roger L. Peterson, Assistant to the President/Research. APC 005239 RULES AND REGULATIONS .i.'lci'i.- s ilciuolition otuTntiiHiK, ;uui CIvo mciMire.-. Liken to comply witli the Uu- The. proposed i.lapilanl vo ...i ),*/( nurCiW.tn: of roadways with n.'-bexliiA Lul- rc.m of Muiimid oucupaUunai Safely limited crnliislnu* limn a iinn.i.i,- -,r Initx. Thu Adi'.iui'.dt-a'.or will continue 10 amt Hi'allli A,liii;ni...l:-a|.nm rcv.uloLim.s to .'.oiiric.'i bv stipulation that .'.urn <-r::i invcviguio oilier e\t.i mg and r.cif protect the lii-altli of persons who work slops roulil not exceed tin- amoi.u r.-, a i.a n sources of iv.mjcj.Ios cmU.tun and If any in proximity u. Uimii*. anil opi'ti ;.tniwie would be emitted from, tl.e r.ouroc if tin* of them arc fotuul to be major sources, areas will pi event Uic (lump.'', ami storage source were equipped witii a Inline. l.l'.rr, t'.ie standard will bo revved to cover areas from oeing major .sources of asbes or, id some cases, a wct-coilcnt.on air- Utetu. tos emissions. cleaning device. Tlilii would Lave required As applied to mines, tlie proposed Tlie pro;xjsc<l standard would have ap a standardized cxni.-o.ion-nieai.uriMt t< -s.- standard would have limited the eiui-- plied to bt lbiiigs, .structures, or facilities pique. wliich Is not current!/ available. sious from tlr.liin : operations and p;o- within wliich any fabricating or manu The promulgated standard iiron.bits vi .i- lnbited visible omissions of particulate facturing operation is carried on which b'.c emissions which contain .'e.hcv.os ar.d mutter from mine rim.is surfaced with involves the use of xsbestos materials. provides the oj>Lion of using specified asbestos i.uiiiuj. T'.ie Bureau of Mir.es Comments received on tlie proposed alr-c!eanlng methods. Tlie existence of has prescribed lieaith arid safety regula standard indicated that the requirements particulate asbestos material in a ear. tions iJO CFTI 55.5) for tire purpose of for fabricating and manufacturing oper stream vented to the atmosphere can bo protecting life, the promotion of health ations were confusing. Much of the con determined by collecting a sample or. a and safety, and the prevention of acci fusion was created by the use of terms filter and analyzing It by microscopy dents in open pit metal and nonsnetaiiie such as "any," "continuously," And techniques. The proposed standard stated mines. As related to asbestos mines, these '`forced gas streams." The promulgated that the air-cleaning requirement would resrutatious prohibit persons working in standard is more definitive as to applica not be met if a number of listed .`aulus, a mine from being exposed to asbestos bility of the provisions. Tlie promulgated c.g., broken bags, leaking gases, thread coticcntratior.s which exceed the thresh standard prohibits visible emissions from bare bags, existed and it required that old limit value adopted by the American the rune manufacturing operations collection hoppers on some baghouscs r.c Conference of Governmental Industrial which, in the Judgment of the Adminis emptied without generating visible emis Hygienists. The regulations specify t!:at trator. are major sources of asbestos. The sions. Comments received suggested that respirators s'.iaU not be used to prevent promulgated standard docs not cover this negative approach tended to make persons from being exposed to asbestos fabr.cation opera! ions. Of all fabrication the quality of air-cleaning operations de where environmental measures are avail operations, only thcee operations at new pendent upon the ability of ETPA to an able. For dialling operations, the regula construction sites are considered to be ticipate and to Include in the standard tions require that the holes be collared major sources of asbestos emissions. The all the factors which would constitute and drilled wet. The regulations recom Occupational Safety ar.d Health Admin improper methods. Since the intent was. mend that haulage roads, rock transfer istration regulations specify chat all and Is. to require high quality air-clcan- points, crushers, and other points where hand- or power-operated tools (l.e. saws, tng operations, the promulgated standard dust (asbestos) is produced sufficient to scorers, abrasive wheels, and drills) requires proper Installation, use. opera cause a health or safety hazard be wetted which produce asbestos dust be provided tion. and maintenance without precisely down as often as necessary unless the with dust collection systems. In the judg defining the means to be used. dtut is controlled adequately by other ment of the Administrator, implements-' " Tlie proposed standard would have means. In the judgment of the Admin non of these regulations will prevent prohibited the spraying of any material istrator, Implementation of these regu fabrication operations from being a containing asbestos on an7 portion of lations wall prevent asbestos mines from major source which must be covered by a building or structure, prohibited the being a major source which must be cov the standard promulgated herein. spraying of an7 matenal containing as ered by the standard promulgated here The proposed standard would have in. Furthermore, the public is sufficiently prohibited visible emissions of asbestos removed from the mine work environ paruculate material from tlie repair or ment that their exposure should be sig demolition of any building or structure nificantly less than that of the workers other than a sl.ogle-fa.-r.ily dwelling. in the work environment. Accordingly, Comments Indicated that the no visible the promulgated standard dees not apply emission requirement would prohibit re to drilling operations or roadways at pair or demolition m many situations, mine locations. since it would be Impracticable, if not For asbestos mills, the proposed stand- impossible, to do such work without cre ird would have, applied to ore dumps, ating visible emissions. Accordingly, the )pon storage areas for asbestos materials, promulgated standard specifies certain ailings dumps, ore dryers, air for proc- work practices which must be followed :.s.sinigb ovr.et,. aa.;..r f.mor et.xinhaau*si,tuin,gs poa~rticulate ywhen demolishing certain, buildings or bestos in an area directly open to the atmosphere, and limited emissions from all other spraying of any material concainutg asbestos to the amount which would be emitted if specified alr-cieanu-.g equipment were used. Comments re ceived pointed out that this standard would: (1) Prohibit the use of mater.als containing only the trace amounts of asbestos which occur in numerous nat ural substances, (2) prohibit the use of materials to which very small quantit.es of asbestos are added in order to enhanco their effectiveness, ar.d <3> prohibit the naterial from work areas, and any mlll=^!tn;ctures. The standard covers instltu- ng operation wliich continuously gen- tlor.al. industrial, and commercial bulid- rates lr.p'.ant visible emissions. The lr-ES or structures, including apartment romulgated standard prohibits visible houses having more than four dwelling missions from any par: of the mill, but . does not apply to camps of asbestos tilings or open storage of asbestos orea units, which contain friable asbestos ma terial. Tnls coverage is based on the Na tional Academy of Sciences' report (52) he Bureau of Mines' regulations pre- which states. "In general, s.ngle-famlly ausly referenced r.r.d regulations issued r the Occupational Safety and Health dminist.-ation (20 CFH 1010.93a) proct workers from the hazards of air con- residential structures contain only small amounts of asbestos Insulation. Demoli tion of Industrial ar.d commercial build ings that have been fireproofed with mmants in-tho work environment. The tcupauonai Safety and Hoaith Admin'ration regulations were promulgated i June 7, 1072. The regulations are inr.tlcd to protect Lhc health of employees w asbestos exposure by means of en tering control-, (l.e. isolation, cnclocs. and dust collection) rather than by asbestos-containing materials will prove to lie an emission source in tlie future, requiring control measures." Apartment houses with four dwelling units or less are considered to be equivalent to singlefamily residential structures. The stand ard requires that the Administrator bo use of materials in which the asbestos is strongly bound and which would no: gen erate particulate asbestos-*---.!..-icrur Thepromulrated standard applies to ti-.o*e uses of ssrav-on asbestos rr.-.;er..i.s which could cer.er.-.tc minor cm: o.or.s of particulars asbestos material. For ..-.ass spray-ou materials used to insulate or fireproof buildings, structures, pipes, and conduits, the standard limits the asbestos content to no more than 1 percent. Ma terials currently used contain from 10to SO-perccnt asbestos. The truant of the 1-percent limit Is to ban the use of ma terials which contain significant quanti ties of asbestos, but to allow the use of materials wliich would: (1) Contain trace amounts of asbestos which occur in numerous natural substances, and (2) include very small quantities of asbestos rsonal protective equjpment. It Is the notified at least 20 days prior to the com (less than 1 percent) added to enhance Ogmcnt of the Administrator that mencement of demolition. the material's effectiveness. Although a l FEOERAl REGISTER, VOL 3(, NO. AS--FRIOAT. APRIL A, 1971 APC 005240 igels-For. Approval-EWO 2-73 '>"r REQUEST FOR AUTHORIZATION ^ XLCOA Date July 31, 1973 Rea. No. PR~670 Name of Company Aluminum Company of America Works Location Point Comfort Brief Description Auth. No. Total Cost Estimate $ ___ 30,000 APPLY FIAMEMASTIC TO MCC TRAY pproval is recommended by: /:/ St a) esident of ibsidiary Co ivision General anager ittsburgh Review by: , /Date t PRIMARY REASON FOR EXPENDITURE Profit Adding: I | Cost Reduction gX] Profit Maintaining (Sustaining Operations) l | Add'l. Capacity Research & Development I | Cost Reduction & Add'l. Capacity Combined Environmental 1 1 Other: (Explain) ACCOUNTING DEPARTMENT USE ONLY When completed, cost will be charged as follows: jpital Expenditures Comm. .icilieies Planning Comm. ? 4461 (Rv. >72) Ry Name Name Date GENERAL EXECUTIVE APPROVAL. Date-------------------------------- Date APCFINAL APPROVAL 005241 SUMMARY STATEMENT The $30,000 requested will be used to apply a flame retardant coating to cable trays in vulnerable areas of the Alumina and Chemicals Plant. Such a program has been recommended by the Pittsburgh Electrical Engineering Division. DETAILED STATEMENT Much of the conductor insulation used at Point Comfort is PVC or cross-linked polyethylene. Both of these materials burn quite readily if sufficient heat is applied and are usually not self-extinguishing if installed in: a. Vertical cable ladders b. Horizontal cable ladders in confined spaces when the ambient temperature has been raised by an intense fire. Serious raceway fires have occurred at Bauxite and Point Henry and have prompted studies and recommendations by Pittsburgh Electrical Engineering Division. The use of flame retardant spray coatings is preferred over the installation of fire-detection devices or the installing of CO2 or foam fire-extinguishing systems and has been recommended for areas of vulnerability requiring protection. A review of Point Comfort's Alumina and Chemicals Plant has resulted in determining initial priority in applying coatings to cable trays. All motor control centers and certain vulnerable areas at R-110 (cable vault, load center No. 4, etc.) and R-300 (certain trays in the cell room area) will be treated. Firestops will be made in several locations where tray exits buildings and on certain vertical risers. MCC's to be treated are R-25-3Y, R-30-5Y, R-32X, R-33-1Y, R-35T-4Y, R-35-5Y, R-42X, R-45-8Y, R-45-9Y, R-53X, R-55-5Y, R-55, R-60, R-70Y, R-73X, R-81X, R-81S, R-84X, R-84Y, R-84, R-300, R-301, R-327X, No. 4--R-110, No. 4 load center, R-110, and padding air building R-110. (See drawing G-006000-PC) Flamemastic, a tradename by Dyna-Therm Corporation, is the material which will be used. Flamemastic is a non-flammable, water-base compound consisting of thermo plastic resinous binders, flame retardant chemicals, and inorganic incombustible reinforcing fibers. Application is by a heavy mastic pump and gun. MCC R-319X was sprayed in 1971 as a field test with Pittsburgh Engineering. This project has been recommended by Pittsburgh Electrical Engineering Division and is programmed to be carried out throughout the company. This is the initial phase of the program at Point Comfort and additional applications to smelting MCC's and other areas will be made in the future. APC 005242 FROM A. A. RAMBEA'JR ENVIRONMENTAL CONTROL September 26, 1973 TO cc: MR. WAYNE CENTER ENGINEERING Mr. C. L. Green Mr. C. F. Scott Mr. T. Flores Dr. P. R. Atkins - Pittsburgh RE: SPRAYING CABLE TRAYS WITH FLAMEMASTIC FLAME RETARDANT Considerable delay has been encountered in obtaining clarification a3 to whether EPA regulations permit use of Flamemastic for coating cable trays in Refining. The writer originally objected to use of Flamemastic cn the basis of a paragraph in the Federal Register, Vol. 38, Number 66, April 6, 1973, Section 61.22(e): "e. Spraying: There shall be no visible emissions to the outside air from the spray on application of materials containing more than 1 percent asbestos, on a dry weight basis, used to insulate or fire proof equipment and machinery except as provided in paragraph (f) of this section. Spray-on materials used to insulate or fire proof buildings, structures, pipes and conduits shall contain less than 1 percent asbestos on a dry weight basis." It seemed that the last sentence was the pertinent one, "Spray on materials......... shall contain less than 1 percent asbestos (I Flamemastic contains 7% asbestos and was to be sprayed outdoors on cable trays. However, we now have a copy of a letter from EPA's Region IX, San . Francisco (attached), in which they state that our type of spraying "is included under the provisions......... for equipment and machinery" which requires that no visible emissions be generated. Since Dyna-Therm Corporation has supplied us with a report from an independent analytical laboratory stating there were no visible asbestos fibers found on the sample filter, the writer withdraws his objections to use of Flamemastic for fire retardation at Point Comfort Operations. It is suggested that all personnel in the immediate vicinity be supplied with respiratory protection and that the spraying be monitored to insure that there are no visible emissions. In addition, Mr. T. Flores, extension 277, should be notified when spraying is to occur so he may monitor the atmosphere with personnel > samplers. A. A. RAMBUCUR A PC 005243 I -42C3 (V ti-S' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX lOO CALIFORNIA STREET SAN FRANCISCO. CALIFORNIA 94111 ` Mr. Robert Groves, Senior Vice-President The Dyna-Therm Corporation 11120 Sherman Way Sun Valley CA 91352 JUL 2 7 1373 Dear Mr. Groves: This is in response of your request of June 25, 1973 for a determination of the applicability of the National Emission Standards for Hazardous Air Pollu tants (NESHAPS) to the spraying of material containing more than 1% asbestos for the purpose of providing fireproofing of electrical cables. Section 61.22 (e) of the NESHAPS regulation applies to the spraying of asbestos for purposes of insulating and fireproofing. Sprayirtg of electrical cables is included under the provisions of this section for equipment and maSKLnery. Therefore", no visible`emissions to the outside air are allowed from the spray on application of Flameastic 71A. Questions regarding this determination may be directed to Mr. Stanley Zwicker of our Permits Branch (415-556-3450). Sincerely, Richard L. O'Connell Director, Enforcement Division A PC 005244