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PLAINTIFF'S EXHIBIT BIR-83 REPORT of ASBESTOS TESTING OF BIRD INC. ROOFING PRODUCTS CONDUCTED FOR A PENDING COURT CASE REPORT #11? W. B. R. ENGINEERING Inc. Prepared by: KP Environmental & Management Consultants 134 IARCROFT DRIVE CHERRY HILL. N. j. 04034 8usin: (609| 354-9372 Home. (609) 428-1629 Distribution: Ms-. Brenda flock, Atty. Kelly, Harrington Co. (4 copies) Report Issued: November 24, 1986 TABLE OF CONTENTS PAGE I. INTRODUCTION .................................................................................. 3 II. TEST PLAN...................................................................................... 5 III. RESULTS & CONCLUSIONS .......................................................... 7 IV. DATA SHEETS................................................................................. .. l4 V. REFERENCES........................................................... Appendix W.B. Rossnagel's Asbestos Resume Test Report 22,437 W.B. Rossnagel's Asbestos Testimony in Washington, D.C. 2 I INTRODUCTION Ms. Brenda Flock, Attorney for Kelly, Harrington, McLaughlin & Foster, 260 South Broad Street, 1700 Atlantic Building, Phila delphia, PA 19102, requested W.B.R. ENGINEERING INC.* to conduct a series of asbestos tests on 2 roofing products manufactured by Bird Inc., Perth Amboy, New Jersey. These products were: A. Bird Inc. Plastic Cement B. Bird Inc. 45 lb. Asphalt Base Sheet The purpose of these tests was to examine the products and determine the extent of ACM (Asbestos Containing Materials) normally on the surface and which would become airborne if the material were abraided (such as in cutting, sawing or demolishing of a built-up roof made with these products). It should be noted that the normal "built-up" 2, 3 or 4 ply asphalt roof would, by design and installation, normally encapsulate all the asbestos fibers in both the asphalt base sheet (also called tar paper, asphalt paper, etc.) and the hot mopped-on sealers used to secure the asphalt base sheets to the roof and to each of the other base sheets. When the asbestos fibers are encapsulated there is no health hazard. Figure I on Page 5 shows a typical 4 ply "built up'" roof of the typical materials. When this type of roof is demolished, damaged or "ripped off" in a storm, routinely repaired or is modified by drilling, saw cutting, etc., the surface sealing of the asbestos materials can be disturbed. To simulate a surface disturbance, the A4 and B6 samples were abraided with a scalpel type razor knife. This was done by scraping the knife at right angles to the flat surface. In this way a small surface area of the material was removed so that the SEM and PLM microscope analyses could determine the extent of the exposed fibers (if any). It should be noted in this analysis that the term "fiber" and "asbestos fiber" are extremely important. "Fiber" means the result may include asbestos, fiber- ' glass, rock wool, etc. fibers--while "asbestos fiber" means the result includes only the 6 basic types of asbestos fibers. This abraiding/scraping procedure was determined by W.B.R. ENGINEERING INC. as the most accurate and fairest way to evaluate the exposure and/or breaking loose of asbestos fibers which might occur under such abraiding actions. It should be noted that wind * W.3.R. ENGINEERING INC. is the present engineering consulting firm of W.B. Rossnagel, P.E. who on 6/2/86 sold his former firm ROSSNAGEL & ASSOCIATES (now operating at the same Medford, NJ location as the ROSSNAGEL & ASSOCIATES Division of Northeastern Analytical Inc.). That facility has been a N.J.D.E.P. Certi fied Lab since 1973* 3 and normal air currents would -rapidly disperse airborne asbestos fibers. Remember, over 90% of all airborne asbestos fibers come from vehicular brakes. Levels of 3i000 to 9)000 asbestos fibers per cubic meter of air have been shown to be present in over 200 tests conducted by W.B. Rossnagel in homes, schools, parks, parking lots, shopping centers, etc. He presented that data at the USEPA Public Hearings on asbestos in Washington, D.C. on May 7, 1984. See M262B in the Appendix. With a level of 3000 to 9i000 asbestos fibers per cubic meter of air as an average non-industrial exposure? and -considering a person breathes at least 3 to 9 cubic meters of air a day, then one can expect to breath at least 9,000 to 27,000 asbestos fibers every day. That perspective is necessary as the reader reviews the results in this report. In SECTION II is the TEST PLAN. In SECTION III are the RESULTS 8c CONCLUSIONS. In SECTION IV are the DATA SHEETS. Note: 1. This report pertains only to the samples or source tested or the inspection or other work actually done. Information contained herein is not to be reproduced outside of the Buyer's company, in whole or in part, without the prior written approval of W.B.R. ENGINEERING INC., or the Buyer. 2. The liability of W.B.R. ENGINEERING INC., with respect to the services charged for herein, shall in no event exceed the amount of the invoice. 4 TYPICAL "BUILT- UP` ASPHALT ROOF 4 fIT R.QQF TtPKH. CM STRUCT!Oaj YdSite vivnui mrsLUEv if fitcH is less tMa/ /a/ex per foot HOT g&SffgQ------- - ______________ ?5-)k skgf ____________ iSLMulht^t__ Z is )b, SU-d fa /b 8a> SEALER- C sv&sTmra - or svfLFACg roof/vl MftrtiR/fiilS FPFkW M. tw$ CftN 0 SnpL^GAlCRZTRtWOQQ) ETC Often Ease slvecf is flail-cd or S*d>reA uliih n\cU[ clip W-SftdJ. of > h*t OSfkah' s*ict", II TEST PLAN The plan, developed by W.B.R. ENGINEERING INC., to test the 2 Bird Inc. products for asbestos fibers, is shown on the following page. Scanning Electron Microscopy (SEM) was used in order to also include the short (under 5 micron) fibers and thin (less than 5 micron diameter) fibers which are not seen in the conventional lower cost PLM (Polarized Light Microscopy) analyses. W.B.R. ENGINEERING INC. selected Structure-Probe Inc. of West Chester, Pennsylvania to conduct that important analysis. The PLM analysis was also done by them. The samples were de livered personally by W.B. Rossnagel to Mr. Gene Rodek of StructureProbe on November 12, 1986. When analyzing bulk materials (such as the Bird Inc. produc like Plastic Cement and 45 lb. Asphalt Base Sheet) for their type and quantity of asbestos, the basic USEPA Test Method is by Polarized Light Microscopy (PLM). Another USEPA Test Method is by Scanning Electron Microscopy (SEM). This is a much more expensive and accurate test which is conducted at much higher magnification. The SEM Method is done at 6,000 to 20,000 magni fication. It will see the -"thin" and "short" asbestos fibers not seen in the basic PLM Method. Both of these methods were used in this study. i There is another basic asbestos test method. It is the NIOSH Test Method 239 or 7400--called Phase Contrast Microscopy (PCM). It was not utilized in these tests because it is an air borne test method. In the PCM test from 240 liters (in NIOSH Test Method 239) to 2,000 liters (in NIOSH Test Method 7400) of air are passed through a special Metracel filter which is then dissolved with a chemical. Then the asbestos fibers are counted at 400 magnification to determine the asbestos concentration in the air which passed through the filter. Since the plaintiff mentioned PCM testing, W.B.R. ENGINEERING initially contemplated to use it as another reference point in looking at the fibers on the surface of the 45 lb. Asphalt Base Sheet. However, W.B.R. ENGINEERING INC. decided not to conduct a PCM test on a bulk sample because it would not be the normal or approved test method. W.B. Rossnagel personally picked up the lab results and samples on November 20, 1986 and wrote up the analysis results on November 21-22, 186. In doing the abrasion with the scalpel knife, the surface was scraped 5 times. As the penetration of the scraping went deeper, the fibers which became exposed were proportional to the depth of the abraiding. Therefore, the final SEM analysis was made at abraiding locations near the surface because that was deemed a "worst case" test. This abraiding activity on the test samples confirmed the thorough encapsulation of the asbestos fibers and other fibers and particulates in the asphalt coating. 6  C *.A L C.* A. A*CftTQt W. B. R. ENGINEERING Inc. Envi/onminUI t MtmgtmtM ConiutUnti~ 124 lAICtOfT 0iv( Cnilir HJU. N. J. 01024 Iumm. 1*091 224-9272 rt.a*. |*09i 421-1*29 tree 0 *HA TA ifeClNCAATlOH AIR WATER - ENERGY INDUSTRIAL HYGIENE . NOISE WASTE QC.IC* or AIN I ckcnot / HOt.t POkUUtlON CONTNOL TITCMN *picir ic axiom * / onawimo./ re*Mir* MAMA4LMINT Nov. 12, 1986 TOt Gene Rodek Structure Probe Inc. , West Chester, Pa. I1 i-r.T plan i-'on mi.i' in:. 6> mini- ii;h|iiii-t.- TEST MATERIAL TYPE OF TYPE OF SMa TEST . . i'LMi XLliX REMARKS A Plastic \ SEM on / 3. PLM on Cement* \ement / cement a\one / alone 4. S$m oh ceir1 A, 4. PLM on cement aft X it after it ha/ d\ied has dried oyr 45 \b. on 45 lb. /aper arid paper and /iEtec \ after / abrasion \ abrasion B 45 lb. 5. SEM on 5. PLM on Asphalt 45 lb. 45 lb. Base sheet sheet Sheet* surface surface 6. SEM on 6. PLM on 45 lb. 45 lb. sheet sheet surface surface after after a b r a i u 11 abrasion Asbestos CoilLuillilH Material* A Scanning Electron Microscope? Polarized Li^lit Microscope iv.-.i * Manufactured by inra [nc. This worn to do done unuor i. .n.s-.. I...G i :li:k 1 :.G i.'.j. Purchase timer #',1, dated Nov. 12, 19 U 6 . MJ NC 1204* PA PC # 1142.1 7 NT PC .0474* rerr /r raxr xo rou xgally know what rnt mouum is - NA PC 17424 LAB PROCEDURE W.B.R. ENGINEERING INC. instructed Structure-Probe to prepare the samples for SEM/EDS and PLM by the following procedure. A thin 1/32" coating of the plastic cement was applied to glass cover slips and to a portion of the asphalt base sheet. The samples were then allowed to dry for 48 hours in a Class 100 Laminar Clean Air Hood to prevent contamination. The samples were designated as follows! 1) Plastic cement alone 2) Plastic cement on 45 lb. asphalt base sheet (after abrasion) 3) 45 lb. asphalt base sheet 4) 45 lb. asphalt base sheet (after abrasion) Samples 4 and 6 had their surfaces abraded 5 times by superficial scraping with a scalpel. The samples were then mounted onto a spectrographically pure carbon holder, followed by coating of the sample with evaporated spectrographically pure carbon using a SPI-Modul* Carbon Coater #12151. The SEM examination was employed using a JEOL Scanning Electron Microscope. The entire sample was observed at various magnifications from 100X to 10,000X in order to determine a relative number of fibers per unit area on the surface. Several tentative fiber classes were chosen to represent the various observed sizes, shapes, surface features, etc. The SEM, along with its associated X-ray Detector and Multichannel Analyzer provided the information for the elemental analysis of the specimen. An EDS spectrum was recorded for each class. The micrograph accompanying each spectrum shows, the area on a given fiber that represents the actual spot analyzed. Samples 3 and 4, as requested, were not analyzed by this technique. For the PLM portion of this study, sections from each sample were viewed using a Vicker's Instruments, Inc. M4l PhotoPlan Light Microscope. Due to the opaque nature of the sample material, the surfaces were viewed using Polarized Reflected Light. The surfaces were observed and photomicrographs ' were taken at various magnifications. 7.1 ill RESULTS & CONCLUSIONS RESULTS The results of the tests are shown in Table I belowr \. TEST A MATERIAL TYPE OF SEM^TEST TfPE OF PLM # TEST FIBER COUNT Plastic Cement* \ SEM on/ \ cement / Xtlone/ 4. 'SEiy'on .ceta^nt amrit has Xried yon 45>J.b. /paper and / after \ / abrasionX -- 3. PLM on cement alone PLM on cement \ after it has driec1 ion 45 lb paper anc after abrasion -- -- COMMENT -- No fibre material observed No fibro material observed B 45 lb. 5. SEM on -Asphait" 4'5 l'b." " Base sheet Sheet* surface .-- 10 fibers/ mm2 " Small_ nu " ber of n asbestos fibers 0 6." SEM on 45 lb. sheet surface, after abrasion -- 7.5 fibers/ mm2 served Small nu ber of asbesto? fiber bundles which mo were exposed 5. PLM on No fibro 45 lb. material sheet surface MW* observed -- 6. PLM on Confirms 45 lb. small nu sheet surface `----------- ber of asbestos after fiber bu abrasion dies exposed. TABLE I A Scanning Electron Microscope # Polarized Liffht Microscooe Test A further explanation of Table I and its backup photo micrographs (shown in Section IV) followst TEST A This PLM test showed no asbestos fibers on the surface of the Bird Plastic Cement and none after it had been abraided. It should be remembered that the USEPA considers any PLM reading of less than 1$ asbestos as being a "non-asbestos" material. One reason for that is that surfaces of bulk materials can become covered with perhaps . 1$ or .5$ of asbestos materials if they, are stored or handled in areas where the ambient airborne asbestos levels are significant. This may occur in heavily traffic or industrial areas because 90$ of all airborne asbestos is believed to come from vehicular brake linings--and it can settle out on the surface of the bulk materials. Another reason is that the basic PLM test accuracy justifies having such a lower limit on its application. ! 9 TEST B SEM Test (Sample) 5 on the 45 lb. sheet surface showed an average of 10 fibers/mm2 (millimeter squared). The scanning was done at 100-1,000 magnification. The fiber counting was done at 500-6,000 magnification. The photomicrographs were made at the magnification shown on each picture. The EDS* (Energy Dispersive X-ray Spectroscopy) analysis is described further along with the SEM and PLM analyses in SECTION V. This means that an average of 10 fibers (not all of which were asbestos fibers)/mm2 were seen in the scan. The EDS spectra and the physical nature of the fiber shown in Exhibit A, Pages 1 and 2,- show the fiber not to be asbestos. It could be fiberglass, rock wool or any of over 60 similar crystaline materials. Exhibit B, Pages 1 and 2, show the control (or background material of the Plastic cement) used in drawing the afore mentioned conclusion. Exhibit C, Pages 1 and 2, also show a non-asbestos fiber. From these and other photomicrographs, the conclusion was made that the fibers on the surface of the 45 lb. Asphalt Base Sheet were not asbestos. SEM Test 5 on the 45 lb. sheet..af.t.er.-abraiding-showed -an . average of 7.5 fibers/mm*. Exhibit E, Pages 1 and 2, shows a small bundle of asbestos fibers. The ESD spectra and the physical nature of the fibers confirm these are Chrysotile asbestos fibers. These asbestos fibers were not coated. Most of these fibers were exposed by the abraicjing action--but most were still partially secured to the asphalt base sheet. * The "x" on the microphotograph indicates the exact location where the ESD X-ray beam was aimed. 10 PLM Test (Sample) 3 shows there are no asbestos fibers in Exhibit G. PLM Test (Sample) 4 shows there are no asbestos fibers in Exhibit H. PLM Test (Sample) 5 showed no asbestos fibers present on the surface of the base sheet in Exhibit I. PLM Test (Sample) 6 showed some fibers (they ar iut of focus because they were partially exposed above the surface of the base sheet) in Exhibit J. However, because the regular PLM analysis could not be made (because light would not show through the base sheet) and a Reflective PLM test had to be done, that method was unable to confirm if these were asbestos fibers. However, it was confirmed in the SEM Analysis that the Test (Sample) 6 fibers were asbestos. The Table of X-ray Emmission and Absorption Edge Energies at the end of this SECTION III provides additional information on the SEM analysis. 11 CONCLUSIONS CONCLUSIONS Test A showed no asbestos fibers on the surface of the Bird Plastic Cement and none after it had been abraided. Test B showed 10 fibers/mm^ but no asbestos fibers on the surface of the Bird 45 lb. Asphalt Base Sheet. After abrasion, this test showed 7.5 asbestos partially or ully exposed on the disturbed surfac SWSE JgZSa. 'S' J?'7 Sfi the exposed fibers were still secured to the asohaxu oc^-r. When one considers 7*5 asbestos fibers/mm^, it should be noted that that number converts to 625 asbestos fibers/square inch. It should also be understood that the 3,000 to 9,000 asbestos fibers per cubic meter* which a person breathes in normal air in homes, schools, parks, parkinj `v./lv Tkt-'-W-J centers, etc. (see further information and ] constitutes a much greater hazard in breath: >1 _ /< " j 'f1 il j, average of 625 asbestos fibers per square ii ^ ^ *** uM r7? to be exposed but mostly still secured in the j. xat a "worst case" surface abraision of the Bird 45 lb. Asphalt Base Sheet. Remember, a person breathes at least 3-9 cubic meters of air a day. A -jogger can breath up to 50 cubic meters of air a day. For additional perspective, a normal person will * a cubic meter in a cube 39" x 39" x 39" 12 also breath about 50,000 fiberglass fibers a day, about 500,000 viruses a day and over 1,000,000 bacteria a day. 13 IV DATA SHEETS Section A SEM/EDS Data in Exhibits A through F Section B PLM Data in Exhibits G through J 14 x4,'f h P< < ^: uJ> w-- f V, V i 1 A1 i i i ; ii i . *. .I v* I INf 4; ! v; i/; ii JflUWtawvJL^ tl.000 1/1 2CEV/m LT= 240 Rf= BTWJcnMc moaewc Sd*/'*-'} J" T'* 1^8 yJet) structure Pwoae.ua l--jw <4 /'/4//7S/>y^/pr ^98 ii *>< * vfn/jrL ii ____________ 346 333^ 20.4430 15 V. h Hf STRUCTURE PROBE. MC rj.&- K U j-o** Tt 5"L^r'9.'1 STRUCTURE PROSE, me l! ii !I II i[ ; ci.&q 5 .1/1 ;2DEV/CH L~r- 2*0 R~= 246 6MFE 113.240 16 SmuCTUM PIKMK.MC. 17 Aj? .INC. ^MOV <J9|8^B jT~ ^ r.^ STTWCUK moaeMC i-o^ \/i^0V/^S/ 8 a*i .1+4 c no/: Se ~?. 07 , '** I'/fAv 18 19 K\ Ptf of Z i ii .1 -I ;i structure probe, me 'Si4*-/,uO J" t/6 \ 4 -36 J'<- yjco -86. 0.030:1/1 2dEV/CK Lf= 2:R|s- ' 4KF5 iiD.40, 20 i Il |! i1 ! ii: <1' i! I' ! i !!! i! <I 1s iI ii I i ! ! ! ii i I ii structure moo.Mc. S/fz*/"-!/ R \ iM: : !l 1 i :fe f Msfefes '""if 4:ilr-Sli^- II .1 : ____ 'iZr.o STRUCTURE PROSE, mc. 36 &.&B. %/i .;2eEV/Q4 ' LT=: 2. RT* *' t. * 278 . 4W=5 23.480' 21 (fUrt V. 0 X liTinnnr structure probe, mc S4*^<-6 C rt/hw ) cWOV 1 S t983 l-A 'filo ll ;| .( U- 11 STRUCTURE PROBE, me os*v 5^L r//^0V jl 3 1986 lifft, f/Jttfa, ij !i 1M *1 It M tl il i:! I ;! ii ll I 'iijjl i i i il 2KF5 .iiq.i40| 11J 1 I *1 *% M M ft M 1 *1 *1 -J 22 23 STRUCTURE PR08E.WC. S4 t, fu3t/t l A 9 tub .`-6 *1 ^ aTHUCTURE PROSE.MC. u-mvi 5P*7 /Yv &ti* t Q . I . I 'ti i ' -`Pi |~J. r>- ; I I1j1 i * > ,l i; : !i ! :< t i : .1 :! I ' |:I ii :! ii |i i; : | 11 -I .: , ' 1 ' `r 1 'I 11 l! ii i! !! *. : l! : :! jll i ; !i >n! !!.; j i| i i t 1 :< II -'1i !i ':fli*- 5 -!.! =; i i i ; !. il ;i. ; ii; 11 1li1 .Li:`1.i1 ,!i iIlS'iPj j'i! 11 ' ; ! II /ij!.jI- -'iifiM*!l|. il '1! j t;'!;. ;! I !' i; i ' j! 1 i:!i : ! i `i ! -v pi " !| :! ''i ; -f *i i: ii :: 'V II, ;i , ! !l !' ffraocruRt PHoat | i, V* ,3 c-k------ a^a_ <n"ucnjncmo,, <i ;ili : !l .i; :! ii !> it! 4ii ;i i!;: ! " 'I -I ii i I 'I i i: 'i ' I I. i! ! 'I i o.eaa i/i . 2ms& tr= 2$a rt= . S3e ,sa<ps 23.m. 25 thibit F il .'I il ;l il smicnjne poa.(wc LC F//1 ^ 3 ,fr4/pc'HjOV f9 19911 U-C ^260, 'I ii :! ;i ;i :i gnmcnjHerwag.--^ AT KV Ad*/ v< ^A< /V*.*-' ifr t S l!)(i njhM. 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P38 3 (1 rw 3 133 3 1*0 J J 16 3HOT 0 *78 ran 3 3I( ST4Z -----3877" ' 3 1 )3) rn u --STM '"}I'J69 "1 37.137 3.3U 34) 3.JI3 3 BH 1 3 339 3.437 _ mu Vl91 1I l " 75 757 ~*7ai8S'*lZgJZ 1 44J J 1U3 --3*595" 4 130 :--TOT-:--TiSI- "ftnL 38777 75793"^ 36 <57 '""`l (&4 *J * "llij " 4 100 ----731r~ 4 133 ' 4 Ut -"tJTiTlt___ 77877 75*591 36777'" 31 >13_. "77M7 -- 3IiW HHj 079 --nor-- 3 937 " I7M" 1*557 * 510 4 343 * 100 ! IT55 4(13 1153 i *4 X# KUft 37855*" 38851 * '"4 109"" 1 1783 4193 Zftvji____ JO 151 !ZB?5Ll 3* 9&J 4 796 5-817" 1 1'5I5~' l 5*775" 1-----58T1-- 585?" *6 B j 37 443 ___ u;' 1 >'S6 5 930 '. *247 . *674 *; La f3 ^ 37 771 3fl 937 4 6*0 tix 5383 *m ! .5*90 * t97 0 63! *S Ct "*ft 60 Ka 61 Wm " U *66 3ft 060 31 1*7 38 437 39 ??3 40 711 . 77837 il )43 40 447 41 999 43 *77 45 ISO 4 13* * 033 * ft 413 >?' --j-tM ft )?1 ___ 1|i|iSJ0UK0_*__ 1 ftftsO j>838 I fy ft 603 ft ni 1___ *779 ij1? w 25 4 _ .. ___ f1'^* --E8 Si;jft 1 | --- ?09fE^ --5tn 39 911 ift 3ftft ift 13* ___ y5i_ ___ *2* mIZjs4sL_ ) 1?) 1 Int> niIp 1 i--r*5r*8 17873" 8 987 4i 498 ft 4*ft \u: ?*H 1*33 1131 fti Od ftft !u 6ETS8 43 3ft) A4^?6n"' 15878" 78877" --56751" U> 33ft rrm 47 948 *3 640 ft o*ft 6 713 Iw ) >*ft t 10? 3*4 ) iU ) )i4 i 111 " ist~ ft i iA IT'S ftii) : ) Hfi 854 ,; ?*? *Ai | ] iF j ""j Kl rj1'\ 4j r* i) 3(3 43 Ii] ft* so6 1 ft h! : r 7 910 ft 746 :*--* t*7 ftp" 4 r. il 113 44 898'" ft) ift) 1 too 1 tU 1 6ft) 1 1 3471 *T" U!v 8? lm i6 o ^0 406 *7 010 57777 "" (9 JH 55777 fti jij "3 3 4i4 8 too 14) 8190 1 13ft)'" ft 4 34 [ 1849 ft ))ft !--nr ITT^ lft)ft ------T38T8 71 Lw 43 887 87*775 --srssr: ""3 ftfti" 1 )6i ft&i) 10 143 87777 15818 IM 77 HI 44 387 ' 63 163 148*7 5 HI 5871 ` 1 Jii Iflftli - -84U >0 136 )3 T* 74 1 1 5) 00* ""*5 '34 58 156 ft) ii6 8) *98 I58T8 11*5 (in 57*5 ' ft W 1 75153 ftftJt 8 889 me ftftu 10 703 11 179 --i 6K 71815" r--rw ------1871" )ft flf 89 HI ftft iftft i--itnr a &fti ra'l i 16 Hi 71 13 75*477 --11489 --ntm ) &\ 87 177-- --rrr" 1--73 155" T873 75851 f ififtft) 77883 75188" 77785" ------18TT- )) 1. 64 339 >3 436 ! 78898" 11)4 1 lo 106 f6'5i% '7510 *1T)i9 "" 77*877" !&*i riM'-* )ft h 35 t lira; ftl )l U }ii 88 i87 10 154 77 187 15 616 1 "77 119 8b to] 13 ift) --78786 to 77] 1 --13 ill ' --IST79 ftii 1)13 IU) [6787 M 069 11 A4Q TT871 17711 ~~11 349 . TT5U" m.'7" 77775" r>nWi9 13 IS 11 7*5 Tl 447 1 "17758" 3 i33 ___ *f ] --its nr* 17 Ml " mu Ij S3* 71717* 1* 698 --THT3 34ft "Hjr _"_"__1jiiiir?j1o790*n{1 17 U 1. fti Jo Ift At --75777 64'155 -- --75'3'l'i --87871" ^T6 4 ? i --JT1S7-- B 7|1 83 Ti7 --BITSt-- 83 711 --*4 U6 nrsvi nrsiT 11 179 TTT55 13 0?t IT 171^ "81787" l^^cj 44_ 15 7*5 87A? ... . 1 i! ii* 3 8>< ift)4t zs i1; Ift 34ft ` u 2*_ Ift ?W>11 ift 71* -- ntn fyjtj 1|-------|-f*-4--7-j-m-- ift 764 1 S Am "'I) fi' ~~ITTTT~ *81849" 58878 14 119 ~ 87885" 'ibiin --ms* u9S" U Ii3 ma "`U lift " --{ Hft rtw" --UTil IftCTI 17 Jj) 17 6&4 n 4* 7 4 19 8007 13 103190" ' 1} IS 15 733 14 Uft 17 64* "Ift 444 11*117 49 A< 15777 "197 875 "resTsn* ~13 ftftfl" Ift HO 78155" ""14184 II Ml *0 Tr 97 1 74 164 491 " "768830" 13 iCl ~ "W'lW 1 1*631 Til IT 16 --inn " jn? 3 HI ftl J, M QTf-- 108 195-- 117 ill IJ JM ' ""Tl ft*5 18877 1 mss T8771 1 7578" ------3877" "TTT3-------- --T7 m-- III 781 9lV___ W 4QJ 877774" lilsn ' 101 ftftJ 118 BIT "171 769 rr8T7 TPP7 l)}l) 18*175 1 JBT81 ... 11 \u 76131 1 rr,W 147 ' 18177 TO 7 _ `""P T3T" "71 498" nr?9i i__ 1 J Aj? " "3t aw11 il 77*787" 3 SS7 ------JT85" ---9* Am "ronnr" 879750" "T71T78 107 fi -- "777733 8786* ii 6. --10O 1 *878 190" "m75T" ITTT5 nrwr ma l 399 Ift JW Ij 961 Mi)} 18*57* 7701 ~ --78 475" 73 73 7TET" 319 --"81''1S81Z" 77 9M " 73 UO ?ns7 -art- rnTwTm Tv ~nro] " '"74747 ms] M 0)0 It tJI 755B" 31 REFERENCE Scanning electron microscopy (SEW) us?s a highly focused electron beam (lass than lonm diameter) which can be scanned in a raster on the sample surface. The intensity of secondary electrons produced at each point is used to form a picture of the sample. Magnification factors from 10X to IOO.OQOX can be obtained. . - The depth of field is inherently quite large which allows the micrographs to be in focus at all points across a rough surface. In addition, the SEN does not sutler from the light microscope problem of 1 iqht reflecting off at odd angles and being lost from view. Micrographs are marked with full identification. The sample number/description and area designation are noted on the top one or two lines. Next is the magnification and finally the microqraph sequence code. The first number in the code refers to the sample being examined' while the letter refers to a particular area on chat sample. The final 4 digits are used for our work records. When a tilt angle (often 45*) is Imposed upon the sample, the rusulting micrographs should be viewed with cha Polaroid print tab at the cop and all dimension measurements made parallel to the short side of the micrograph. dome foreshortening is expected in the 'longer* viewing'direction if a tilt is imposed. Energy dispersive x-ray spectroscopy (EPS) is an effective metnoa tor analyzing tor tne main components as well as low-lavel (nominally Q.ll) contaminants in relatively thick (several micron) layers. The x-ray spectra display an intensity versus energy plot of x-rays given off by the sample bombarded by the electron beam of the SEM. The vertical scale is x-ray Intensity at etch energy position. The spectrum is usually recordad at a acala calibration of 32,000 counts full scale. Small peaks are then recorded on the aame chart at ona or two higher sensitivities. The horizontal acala runa froa 0 to 20 kav and the x-ray paaka which appaar on tha spectrum have energies In tha aama range. Each element amlta x-rays of characteristic anargiea ao It is a simple matter to relate an x-ray peak to its corresponding alaaant ualng tha attached table of Major X-Ray Emission Energies. Only those elements sodium and heavier on tha .Periodic Table are Included In this study. Except whan a 'windowless' detector la employed, the EOS technique doee not detect x-caya originating froa tha light elements. The area analysed la noted on tha spectrum. A magnification on the spectrum label (usually that of a higher magnification photograph attached to tha spectrum) indicates that tha electron beam waa scanned in a raster on the sample while the spectrum was collected. 'Spot* indicates that tha beam scan was disabled to allow analyais of tha particular spot noted on tha micrograph. '' Polarised light mlcroscopy/disparslan atalnlno (PLM/DS) is a method for determining the unique optical crystallographic propartiaa of various crystal phaaas in a sample. PLM/DS is an Invaluable tool in the identification of crystalline, materials such as asbestos. It is basically a particle Identification technique based oi> the difference between refractive' index dispersion of a particle and of tha liquid medium in which the particle la Immersed. Two different procedures are baaed on the use of stops in tha objective back focal planai both procedures give colored particle boundaries. An annular atop shows a color consisting of wavalengtha near that at which particle and medium match in refractive index> a central atop shows colors complementary to those shown by tha annual atop, that is, light of wavelengths refracted by tha particle in that medium. These effects make it possible to systematically identify transparent substances by their dispersion colors in known refractive index media. Tha procedure has bean applied to refractive index determination, identification of quarts in lung tiaaua, determination of toxic duets, particle counting, identlficatlon of glaaa fragments, identification of asbestos, mineral characterisation, identification of settled duet and fiber identification. 32 APPENDIX W.B. Rossnagel's Asbestos Kesum Test Report .'P,/i <7 W.H. Rossnagel's Asbestos Testimony in Washington D. C. PROFESS IUNAI. RESUME ON ASltFSTOS Two years U.S.N. - M Months Hadur School. Four years Stevens Institute of Technology. During college formed Hossnagel Television. Operated TV service while employed at Bendix, HcAvoy Target Co. and Kearfott. At Kearfott was Assistant Manager of Experimental Assembly Shop; where contamination problems were a major problem in final testing of Polaris Gyros. First worked with asbestos as it was a contaminant in the crucial balancing of the gyros. Spent long hours studying (under microscopes) the various types of asbestos dust and fiberglass contaminants. In 1900 designed 11,000 sq. ft. indoor shooting range with asbestos insulation and sound deadening materials. Like other engineers and architects, little was known then of the health problems with asbestos. During early 1900's lwas Koliubility Test Manager at Walter Kidde Cu.) work on air contamination problems in gyros and uarly electronic "clean rooms" was well recognized. Part of committee that wrote Rev. A to FEDERAL STANDARD 209 entitled, "CLEAN ROOMS". By 1968, had over 30 published articles, three on air contamination and clean room problems. In 1900, after 1^ years as Quality Cuntrol and Tost Manager at VECTOR DIV. UNITED AIRCRAFT in Trevose, Pa. (early leader in computer chip manufacture), joined the RE-ENTRY A ENVIRONMENTAL SYSTEMS DIV. UF GENEHAL ELECTRIC ill Ph11 adolphia, I'a. For Jg years was in charge of J25 persons handling all the component Quality Control and Test fur Mindte Man Missiles and space satellites. This work involved miniatur ized electronics; all made in clean room environment. Special experience on testing and contamination problems meant being a lung-distance traveler. In early 1970 Minute Man program development ves completed, left CENEKAL ELECTRIC and formed KOSSNACEL A ASBUC IA 1'i.S. Within a few months this new firm was conducting all types of airborne tests, including asbestos; as well as clean room tests in hospitals, etc. By 1970 R0SSNACEL A ASSOCIATES vas larger than all other air testing firms in New Jersey. In 1977 R0S5NACEL A ASSOCIATES vas picked by N.J. Dept, of Health to conduct airborne and bulk asbestos tests at Ramtown School in Howell Township, N.J. Those tests brought the school asbestos problem to the forefront with national media coverage. Within a month after that, wrote first article on asbestos, entitled, "ASBESTOS CEILINCS--AKE THEY SAFE OK NOT?" Has been a leader since then in all aspects of asbestos removal/encapsu lation/enclosure/repair work by performing the following! 1. Wrote the first asbestos removal specification in the country in 1977. 2. Performed test work from California to Egypt--also asbestos testing/ consulting in schools, hospitals, ships, tunnels, manufacturing plants , homes, etc. 3. Switched ROSSNACEL A ASSOCIATES' annual seminar in 1982 from general air pollution problems to concentrate on 3 subjects: ASBESTOSF0RMALDE11Y0E-F1BERCLASS, Seminar had Dr. Selikoff as keynote speaker in 19B3 and 1'id-i. lliis was the lirst rogulucly scheduled annual asbestos seminar in country. 4. Provided key testimony at several N.J. asbestos Public Hearings and at USEPA Asbestos Public Hearings or. May 7, 19dJ in Washington, O.C. 5. Was selected to da asbestos inspection and testing for major N.J. State buildings in Trenton. 0. By end of 19B4, had 10 published articles or papers on asbestos problems. 7. Prepared and conducted test programs for: a. cleaning a former, asbestos gasket manufacturing plant far resale. b. simulating test of asbestos gasket removal exposure during assembly and disassembly uf U.S.N. pipe flanges. 8. Had provided court testimony in several asbestos workman's compen sation casas. ROSSNACEL A ASSOCIATES had conducted asbestos tests m over 000 schools in seven states. Conducted original majur twsL program fur Sears in their auto brake shops. As a leader in that aspect of asbestos vurk, conducted the first asbestos seminar just far autu/truck/cailroad brake overhaul/ repair pursons In conjunction with the N1LFISK COMPANY. In Summor of 1985 spent two 4 day periods giving testimony in a Ban Francisco asbestos court case. In January 1980 ROSSNACEL A ASSOCIATES was selected to write the asbestos remuvai specification fur Martin Luther King School in Philadelphia. This difficult project (because school had been closed fur five years due to asbestos contamination) included removal of over 715,000 sq. ft. of asbestus for $5 million. In Hay 17110 RUSSNAGEl. A ASSOCIATES held lt 14th Annual Air Pol lution/Cuntaminatiou Cuntrul Seminar in King uf Prussia, Pennsylvania. This seminar has been the leading annual asbestos meeting in the metropolitan area. Hr. Richard Young, Editur of POLLUTION ENGINEERING Magazine, was keynote speaker. On June J, 1980 sold KOSSNACEL A ASSOCIATES to forcer employee, William Dolan. The new firm will operate as the KOSSNACEL A ASSOCIATES divi sion of NORTHEASTERN ANALYTICAL COKP. v. B. kossnagcl has brought a unique level of expertise, as a licensed professional engineer In four states anJ as a Seniur Humber uf tno American Society for Quality Cuntiul, to provide ^rrjhsucjjyirahial of the airburne asbestos risk in our country today. - Naa> EsaUnd Rapt Gifford Pfaciiian En*,, Inc. X. O. lax 1017 Mja'dulowo* Conn. 06457 X (203) 346.1223 (603) 632*7567 ROSSNAGEL & ASSOCIATES me." Engineering & Testing Consultants 234 RT. 70 MfDFORD, N. i. 01055 (609) 654-1441 Midwi,*rn OHica Danto Enviio. ConiulUnli 4022 StonaKavan Rd. f South Euclid, Ohio (216) 362-1719 AIR WATER . ENERGY INDUSTRIAL HYGIENE . NOISE WASTE STACK * EXHAUST TESTING DESIGN OF AIK/WATER/NOISE POLLUTION CONTROL SYSTEMS PLM BACTERIA / MOLO / FUNGUS / SPORES SPECIFICATIONS / DRAWINGS WATER / WASTEWATER / SLUDGE ASBESTOS TEST REPORT #22,437 CHEMICAL.ANALY.SCS. R.C.R.A. CAS CHROMATOGRAPHY. l.R. a A.A. ENVIRONMENTAL IMPACT STUOIES Nov. 8, 1985 To: Moss-, Powers & Lezenby 7 East Main St. Moorestown, NJ 0805? Lab Report # 19,229 Attention: Mr. Ed Moss, Atty. The results of the analysis of the bulk sample(s) ^-^mitted on Oct. 29. 198S to ROSSNAGEL k ASSOCIATES for analysis by Polarized Light Microscopy (PLM) and Dispersion Staining are shown on the following page. If you wish a further analysis, ROSSNAGEL k ASSOCIATES can con duct any of the tests or analyses shown on Page 3 of this report. Other Comments: Some asbestos fibers were -found below the surface of the material. Cellulose was Analysis by: Skip Harris 7 ^ Industrial Hygienist ROSSNAGEL k ASSOCIATES the primary fiber type inside the layers. This material is1 not friable. The asphaltic * surface coating had to be re Approved by: W. President ROSSNAGEL k ASSOCIATES moved by scraping to expose the asbestos fibers. SH/jar cc: Notes: 1) This report pertains only, to the sample or source tested. Information contained herein is not to be reproduced out side of the Buyer's company, in whole or in part, without the prior written approval of ROSSNAGEL k ASSOCIATES, or the Buyer." 2) The liability of ROSSNAGEL U ASSOCIATES and its divisions, with rerpoct to the service:-. charged for herein, shall in no event exceed the annum, of the invoice. CO 7 CO GO ULJ CSI CO CO co Eh co ft Cm P,, J -f z 2 O *i CoO on- | Iliio <1 o O G-< z X cd a> H ft Q u to CO Mc 05 at x op ft p 0) x p o ft ft t>0 G al ft co C fot (0 P 0) ft fwt Q + c fot ft at E fot ft o in ft H ft G c a> MJ 0) o T3 at P z M Ei 0) 03 03 03 E rH rH r--i O a ft ft P CO E nj 2 CO co CO O o x p a> 2 <u rH 0) (-1 cu a a] - c fot ft CO at p at f>t1 co <u ft at ft G p< o p fot O a fat) o c Form IfRA-214-4 F Page 2 of 2 V} VJ. *J _ Sl <* lT' -- p u't r % OO I < < t 5. sifr 0-0 0 \a a 0} N TD H 0) C -P a> at CjD Q) op E -P OG XX iH C\) ft Ca> --P' E a) ft xi at E <d 3 PC & p fat) p<u ft c E <U at -- co a: a Xi H CO rH o o CD O P f0t3 CO a(0t rH ft CD rH XHI (0 CO o pG O H ft fftt CO >: P <30 E 'O 03 G H X 03 0) +> H ft -HP i--OI OCO T3 ft > O XP5 OP Xft OOQ fct rH U H CO o o 03 p CO o CO 2 03 0f3tT--J G at CO (0 03 ca 03 p ft CO HH two at pp 03 03 (XH fct ft2 o H rH3H 03 P* XP03 oo P G 03 CO 03 P ft o pG 0E3 03 faott P Xp03 020 w ft CM rv? ft at ft ft p <U ft c 0C3O 0P3 "-P" at f0pt3 XE3 C 03 o <H o -p c CO o ft CO G P f0t3 p 03 ft TD 2 03 C C o E XCO --03 at C l< p (0 03 X CO < ft at p o Eh p c 03 o p 03 ft CO rH X- WO at p H Gp 03 03 CO CO 03 P 03 p P at- 3O fPt P X rH H at ft*H P P 03 03 P X at X E 3 G P 03 p C 03 C2 co P2 03 O ftIXP *a rt c ft at c ,, ft _ ca p03 aot C>fOtfrfHtt CD co TC3 at co -P 2 O zO aJHNn :i T3 0) > C P ft ft < fe TESTIMONY OF W. B. ROSSNAGEL, P.E. PRESIDENT ROSSNAGEL & ASSOCIATES 234 ROUTE 70 MEDFORD, NJ 08055 (609) 654-1441 at the USEPA PUBLIC HEARINGS ON ASBESTOS on May 7. 1984 in the NORTH AUDITORIUM OF THE HEALTH & SERVICES NORTH BUILDING 330 Independence Avenue, SW Washington, DC ROSSNAGEL & ASSOCIATES EagiaH9 4 Taitiaf Coasulliatf Air * Wttar * Hoist 234 It. 70 M4(af4, N.J. OIOSS (609) 654-1441 BACKGROUND My name is Bill Rossnagel. I am President of ROSSNAGEL & ASSOCIATES in Medford, New Jersey. We are one of the largest asbestos testing/consulting firms in the 9 state area from Massachusetts to Virginia. We did all the testing at the famous Howell Township, N.J. Ramtown School in 1977* That is the incident that triggered off the concern over asbestos in schools. We have tested asbestos in over 500 schools! in ships, tunnels, colleges, hospitals, state capitol buildings, etc. A further list of our experience is in the Appendix. My own work with asbestos goes back 25 years when it was a pro blem in testing Polaris Gyros. Like thousands of other- professional engineers (and architects), back in the 1960's I designed buildings which used asbestos containing materials. It was the right thing to do under the building codes of that time. In 1970 I founded my firm and we began doing bulk and airborne asbestos tests. In 1984 we were involved with the EPA in testing on the major Ambler, PA asbestos tailings waste pile project. TESTIMONY There are 5 basic points- points in my testimony today. My first point isi 1) The USEPA, OSHA and the medical people have published the Airborne Asbestos Allowable Limits in a way which is misleading to the public. You probably are aware the limit, for 40 hours a week exposure (called the TLV-or PEL4), is now'2 fibers/cc or 2 fibers/milli liter (both designations mean the same) in the workplace. SUMMARY OF ASBESTOS REQUIREMENTS - in fibers/ml or fibers/cc Primary Requirements Code from 6/72 to 7/76 Code from 7/76 to Now Proposed Code 1. Allowable Maximum Limit 10 fibers* 10 fibers* 5 or .5 fibers* 2. Allowable TV/A (Time Weighted Average) for . 8 hours exposure per day 5 fibers* 2 fibers* 5 or .1 fibers* * fiber defined as larger than 5 microns in length and having an aspect (length-to-diameter) ratio of at least 3:1. SLIDE That designation makes the public think the level is near zero. They should have better explained what is shown on the following pages. TLV - Threshold Allowable Limit - maximum concentration of a contaminant that an adult male can be safely exposed to for 40 hours a week, 50 weeks a year. PEL - Permissible Exposure Limit - maximum concentration of a con taminant that an adult male can be safely exposed to for 40 hours a week, 50 weeks a year. O SLIDE 2. 2 fibers/cc 3 2,000,000 fibers/cubic meter SLIDE 3 and a person breathes 3-9 cubic meters/day (or more). Let's take the example of a relatively low outdoor/indoor airborne concentration of asbestos fibers. Let's assume a recognized very low concentration of .003 fibers/milliliter, which is the same as 3>000 fibers/cubic meter. If a person breathes at at Lo^BreaUTin^^aoacj^^ 3 cubic meters/day x 3,000 = 9,000 asbestos fibers/day 9. cubic meters/day x 3,000 =27,000 asbestos fibers/day This is illustrated in Slide 4 which is also shown on the following page. That is the way test data and the allowable limits should be presented. They should talk about numbers of 9.000 to 27,000 asbestos fibers a day that you and I, in this meeting today and travelling to and from it, will breathe, If the majority of the public knew that fact, they might take :e removing asbestos from some buildings with very, A md a non-friable cementitious type asbestos ceiling reach of the students. One more quick c accused of being "agj firm recommended ovei Yn l9Sl alone. L- ASSOCIATES has often been t simply is not true. Our stos removal work in schools I also want to state that I have talked with persons suffering with mesothelioma, and who later died from it--only then can one really appreciate this American tragedy. 3 Rev. 2  Air Witif >jy PERSPECTIVE ON THE AIR WE BREATHE SLIDE LOW BREATHING CAPACITY t RATE. Z *2f/i0ur.s z 3 ci>bkK<fexs/&j Jjf tbc Airborne asfees-fo3 /evcl is a Very louj tO^-fib<rs/ milltli^Tj theft vrd*T Ms cofidrhc* a f>ers&l UJi'U iteA+itf. .003 * 1,000 000*3 sy}0*0 Ajb*$b*5 4&*rj/d*Y* fe ti'fers/miiutis.*60 tnw+es* 24 floors s ^ cvlk, wters/dey Jf the. dirWnc t *sbtshx /eve) is a. very levy .003 pikers/ Hftilli'te^+UeA vi)dcfJ _ thi`5 CorJiitCA a petf$#/I &J/// kr^c&kt . 0o'3* ,, / oop, o^o 7 27;<tt> dJbes403 -fibers / dUy HIGH BREATHING CAPACITY 4 ROT p'e?`xlh figure T s.v. * S L ID E .5 / Hera is my second pointi 2) The EPA issued 2 asbestos guideline manuals in 1979, referred to in the industry as the Part I & II "orange" books, and another guideline "blue" book in 1981. The only presentation in all 3 of their books on the ambient asbestos levels was this EPA graph shown on Page 5.1 (Also Slide 6) While the footnote on this EPA slide explains the data shown was by 2 significantly different test methods', the EPA ignored PCM (Phase Contrast Microscopy) data it had which would have helped provide a comparison based on similar test methods. The EPA disregarded the PCM data used by over 5 governmental agencies or profession societies (see Page 10) for over 25 years. 5 Rev. B Figure 1. Companion of measured airborne asbestos concentrations in three settings. Asbestos insulation wotipUcoe bolero 1970 (Nienolaoa porionoi commumesuan. 19931 School building* (Constant, si si 1992) Ouiaoor ambient aw L* (Nicholson. i at 1971| "3 ZZZZZ) 0.1 1.0 10 100 1.000 10.000 100.000 1.000.000 10.000.000 Monograms par cubic motor 35% 75% Percentiles 'Levels in asbestos workplaces were derived from measurements using phase contrast microscopy (PCM) while levels in school buildings and outdoors were measured using electron microscopy (EM). PCM and EM measurements are not directly comparable. PCM measures all fibers whereas EM can distinguish between asbestos and nonasbestos libers. In addition, EM has a better capability than PCM for detecting small fibers. In order to translate the workplace PCM measurements (expressed as fiber counts) into values of asbestos mass (nanograms) that are approximately comparable to EM measurements. 30 fibers were assumed to equal one nanogram. This value is an average obtained from many comparisons of PCM and EM measurements taken at the same location (industrial settings) and time. Values for individual samples range from about 10 fibers per nanogram of asbestos to well over 100 fibers per nanogram, depending on the average size of fibers and the relative number of asbestos and nonasbastos fibers in the air (Versar 1980 and William Nicholson, personal communication. 1982). SLIDE 6 h-5 5.1 SLIDE 7 And -the EPA did not make it easy for the industry and public to understand this graph. You will note the "X axis" is in the units "nanograms/cubic meter". Less than .01% of all the airborne asbestos made to date have .the units used by the EPA. The EPA should have added thevwidely used "fibers/cc" as shown in this graph we overlaid on the EPA graph (using the EPA conversion factor of 30il)i The EPA used nanograms/cubic meter which requires an expensive Transmission Electron Microscopy (T.E.M.) Analysis. The cost of T.E.M. is 7 times that of PCM. i 6 Rev. B s 3 V<0 > 5 3 x wl taUi -* ?! 5:3c m S3 g; si 2s You" will note also that our data shows a much higher level of ambient asbestos, almost equal to the level in the schools. We have been unable to find out where the EPA ambient data was taken--but it mus have been a very pristine location. All our over two hundred airborne asbestos tests in homes, stores, outdoors, parks, parking lots, playgounds, etc. show the ambient level in urban areas to be as shown on Page ?.' This is over a hundred times higher than the EPA ambient level shown'on Page 9* The EPA has done little to explain to the American public that the average American will breathe perhaps 9*000 to 27,000 (or more) asbestos fibers TODAY. If you have a son who shoots baskets near a busy street--or a friend who jogs along a road, they may breathe up to 50tC(QO asbestos fibers in a day. This may be the first time many of you have heard this--because the agencies' have rarely compared the test results to the amount of air (3-9 cubic" meters) that a person can be' expected to breathe every day. Please do not conclude from Pages 5*1 and 7 that the asbestos levels in all schools is equal to the ambient level. The graph 3hows the 25% and 75f percentiles. Of course many hundreds of schools h'd to have asbestos removed because they are extreme cases beyond thpercentile limits. My third point ist '3) The EPA should have told all this to the American public--and particularly to the school board members . anquishing over the costly decisions on -whether to remove, enclose, encapsulate or do nothing about the asbestos in some school ceilings and pipes. They should also have <been told that after the asbestos has been removed the airborne level of asbestos in the school* will not be zero--but will be equal to the ambient level in that neighborhood as' shown on Page 9. : For example, in a city school surrounded by 2-4 story "brownstone" or similar houses, the street becomes a "canyon" holding-high levels of airborne asbestos from co the vehicular brakes. If it has not rained for several days,., that level could be proportionally high as shown M by Ambient Level 3 on Page 9* a Rev. B CO waM W WHENASBESTOS l< I REMOVED, THE CO o Li! J 1 %. 1^ ' . ' * SLIDE 10 SLIDE 9 My fourth point isi if) If the EPA had better explained the airborne asbestos levels, then they could have better explained the conflicts arising when they state that even 1 asbestos fiber can cause mesothelioma....yet the EPA algorithm v allows a risk level of 12 out of 162. The EPA has also opposed airborne asbestos tests--even those tests (designated as NIOSH Test Method 239) which have been accepted in courts for years and has been used by the following 5 agencies each for over 25 years a) Occupational Safety & Health Administration b) National Institute of Occupational Safety & Health c) American Industrial Hygiene Association d) American Conf. of Gov't. Industrial Hygienist e) UlS. Bureau of Mines V 4 Since asbestos is primarily only a problem when it is airborne, what is more accurate to test it than an airborne test very similar 'to the way in which a person breathes, as shown in these slides: S LID E 12 SLID E 11 The EPA has consistently opposed airborne asbestos tests. . The major concern is not whether a school ceiling has 5% or*'50% asbestos as indicated in the bulk test. I would rather have my childre in a school with 50% asbestos which is bound in tight (non-friable) than in a school with friable 5% asbestos ceilings. The question is how much of that asbestos is friable and becomes airborne because of: vandalism building vibration I temperature changes air movement sloppy maintenance roof and pipe leaks drying out of A.C.M. t other causes To determine that one needs an air test; after the bulk test has confirmed the material to contain asbestos. 10 Rev. B My fifth and final point isi 5) The EPA established the June 27, 1983 school inspection deadline--but they did not require a copy of the school's asbestos "Notification Sheets" to be forwarded to either the EPA or the applicable state agency. The present EPA audit of schools shows that many schools did not comply with those June 27, 1983 requirements. Other agencies also have outlined in detail the shortcomings of the EPA's Asbestos Control Program. 11 Rev. A