Document wrJ48OeqDNEe2MM2mKXBBygnJ

V* ENVIRONMENTAL PROTECTION AGENCY PUBLIC HEARINGS ON PROPOSE EMISSION CONTROL STANDARDS FOR ASBESTOS, BERYLLIUM AND MERCURY -- '_L jifii'Ci I'im^nia rirnmi-T iy^** =" STATEMENT OF MR. WARREN "DARRELL, DIRECTOR OF MANUFACTURING, INDUSTRIAL PRODUCTS DIVISION, GAF CORPORATION My name is Warren Darrell and I am Director of Manufacturing for the Industrial Products Division of GAF Corporation. I have oempiete line responsibility for the operation of 15 of our company manufacturing operations in a variety of different product lines, encompassing mining, papermaking, rock crushing and textile type operations. Two of the plants in our division are directly related to asbestos fitted, one being our asbestos mining and milling operation just north of \ Hyde Park, Vermont, and one being our asbestos paper manufacturing facility ^ in Erie, Pennsylvania. 1Ql'*, T ** 11111 g'i|uMu luimy ^ y \ In^nri plnnt* n*ni"jnf mhTT*TJ` fivrv -t riv -i *`"ii,if-rnJ-- -^m-n 196^ -I-have had -corporate fespnnrlhnjty far the- operations of aghastan mining and -raMing-faellitles . ^ as* A-t*.*. ~Zo <Jm'* g/tti ISiofi i i mjt A^r AilfA/itct omJ cA-'-y, /ttUOf*. of 0 osrmJvtJ' . The proposed national emissions standards on asbestos, if enacted, j I would affect lU GAF plants nationwide. As Mr. Fraser has pointed out, GAF feels it can comply with the proposed EPA regulations at all the plants, with some exceptions at the Hyde Park, Vermont, asbestos mining and milling facility. We believe that In order-Pe--inygrg-cra)lianoe the ^pC-A^ GAF 21640 2 yn-rt' ` * 11111testimony of 'Johns-Rahviiie Corporation ,, 1 i i n) . I 111 --- Hyde Park is a key GAF plant. Not only does it produce material for tlQrt BT our domestic.,customers amd "forsigm but also produces the asbestos fiber required in many of the products we manufacture ourselves. I would like to discuss this mine in light of the proposed standards since it is representative of other asbestos mines in the United States. The largest single source of air borne emissions there is from the ore dryer exhaust. About two years ago, we installed a dust collecting device that has reduced those emissions by over 600 per cent. We are striving for even more improvement and, in fact, have engaged engineering consultants for recommendations. 'fi' eeffwp* udiliiieii il "JTTil!i i In inii lij lln gnirai nun it tn rlrtinrin 1 nr flu l ufl'Ull H.WrtTfcr yi GAF 21641 5 ' We have coupleted a study of what else is required EPAv Vfe feel we have the known technology to overcome all tout the following emissions: 1. The emissions which come from the depositing of material on the tailings pile fro* the conveyor. 2. The wind-blown emissions from the unconsolidated portions of the tailings pile. 3. The emissions involved with the building up and feeding to the min of the wet rock which has been through the primary crushing operation. Judging by what we have been able to determine from our own studies and from contacts with the major chrysotile asbestos producers in Canada, there is no known technology to a-T-rnllrlrtihlrT Therefore, we suggest that additional studies be made by the government to determine first of all whether a real hazard exists. If these findings are substantiated CAF, of course, would cooperate in any farther studies to learn how the problems can be technically resolved. O'5 Meanwhile, through research and tests we are striving to increase our knowledge of asbestos. For example, at one of our laboratories we are investigating what we call "vegetative stabilization," a process to ao gn>W*w\ stabilize mountains of tailings pile. With grass or some other^sub- -- GAF 21642 1 would now like to discuss briefly the emissions which emanate t As we transport fresh tailings oile to new locations from the tailings pile./[ the oldei""luidiuliu bed ynCBMeOtoSbac tbecome consolidated and inert and project no fibrous problem, tailings ii T11 ^T~i>WW--PtiW|nnirriinMlieBnflMiai)nnriniiib^iiwiiirtiiiriirumn H ~ *a ti* Me A In the area of the pile where fresh tailings are being deposited, this consolidation eMVt does not develop until another location on the pile is used for depositing the tailings. Last year GAF installed equipment at Hyde Park which was designed to increase the extraction of asbestos fih^e/in the host rodk. Some of the asbestos fi^e separates from the host rock and is in a free fibre form, but the majority of filj^, has not been separated and clings to that rock -rru t*t . i ' . rather tenaciously. ./Our tests indicate that the amount of asbestos fitpg that goes out with the rock to the tailings pile dump constitutes less than one-half of one per cent of the total material. Further, our observations indicate that because of the loose and gravely nature of much of the material going to the tailings dump, rain and melting snow leach much of this free fit^. down below the surface so that it is not available for emissions riPuCTljL r-(h ~r*jf - ' y 1 ri't~ ffaacct, during the winter season last year lOli inches of snow covered the area. Although we have no measurement of the amount of asbestos nore content in a given quantity of air at any point from the tailings and out to our property line, our judgment is that the amount of asbestos fibre in the emissions is quite small and well below the newly adopted Federal Occuptational Health and Safety Act (OSHA) standards of five fibres per millter. In addition, we feel that the visible emissions are primarily "petti -.o GAF 21643 5 rock dust from the host rock rather than asbestos fibres. This rock-dust constitutes 99 per cent or nore of the material going to the tailings pile. Should it develop that technology cannot be found to control the visible emissions from the tailings pile, we will then bu 'fUiu*cod.to evaluate the future e Park mine. Our overriding concern, after aU, is with the health of our employees. If it is shown that in the b_e_st interest of ! 1 our environment and people that operations should cease, Anc there is no question what will occur. __ _ ^ /? M- Incidentially, we think the lack of a definite procedure for determining #5 '/#' tf* 9*' asbestos content is a problem in the proposed rules. "The emissions from a .*"* o , r|f t* rfli* v ^ tilling npnrall nn are iimitedAo the amount which would // be emitted if the exhaust were passed through a specific fabric filter. There is nl method specified, however, to determine whether an emission from a manufacturing site is below or above the value for the cloth filtration unit. How can yew prove that an effluent from a plant which has a visible .are, emission of non-asbestos fumes (plasticizer or asphalt^ which^SS* liberated from an asbestos felt operation,falls within the accepted limits? In other words, if we process an asbestos felt which In itself does not liberate a *4 .4 SJ -_________ ^ _ # AS %_ I. . . . , . . ..... GAF 21644 6 exposure. From what we read, apparently there are non-occupational connections with croddolite fi^je such as that produced in South Africa* We mill and mine chrysotile fi^e in a sparsely inhabited section of Vermont. We know of no non-occupational connected medical problems due to emissions from this mining and milling operation. Recent regulations promulgated by OSHA allow a concentration of five fibres of a given length per mill later of air for the environment in which an occupation can be conducted without the use of respirators and other devices of that type. It is to be assumed thtt this allowable con centration has been determined by the authorities to be safe. We would judge that the concentration of asbestos fit^js in the wind-blown emissions from our tailings pile would be less than that which has been adopted by A similar situation exists in connection with the wet rock storage pile. Therefore, in addition to the changes in definition requested by Mr. OnJ Fenner of Johns-Manvilie Corporation, we request that Section 6122, Par. b(l) of Sub Part B not be applicable to asbestos ore dung>s, open storage areas or tailings dumps. Further, we recommend that studies be made of these GAF 21645 7 areas to determine the existance or non-existence of a real hazard. We also recommend that before repulations are adopted studies be made of chrysotile asbestos fibers to determine whether there is a health problem in relation to human beings. Another of ff'.M s proposed repulations merits comment. Paragraph 61.23 (d) of Sub Part B defines the fabric' filters to be utilized as "woven cotton fabrics having airflow permeabilities not exceeding 20 cubic feet per ndmite.'1 Some GAF plants manufacture non-woven filtration media from fibres other than cotton. We believe that thg'filter media wo mannfaa+nre is of excellent quality and can be employed so that it is at least equally as effective as woven cotton media. We suggest that the repulations be rewritten so as not to exclude these avdandcx types of filtration media from the asbestos emissions field. As stated, C-AF agrees with Johns-Kanville that all references to material and/or particulate matter in the definition should be worded "asbestos containing material." As in waste products, we recommend an additional definition of this phrase. For example, "waste products mean any asbestos containing material which is intended to be discant'faeied and not reprocessed or reused in any way." 4 1- * 1 1 - ? ' - 4` i. f ^ Ci' 3r' Tr -i". f- t''* t ? j t : -r pi. P-.-- .. Also, a slight change could clarify the defintion of visible emissions (61.21 (j) ) by adding, "any emission containing asbestos that is visually detestable." <r?G? GAF 21646 8 We further question the wording of Section 61.22 (e) (1,2) which states: "The spraying of any product which contains asbestos on any portion of a building or structure or an area directly open to the atmosphere is prohibited." This, we feel, is too broad a aantriirHoe because it eliminates the spray application of bituminous roof coatings and adhesives that contain asbestos fiber. Both asphalt cutback coatings and cements as well as asphalt and tar emlsions that contain from three to ten per cent of thoroughly wetted and dispersed asbestos in the liquid binder are used extensively in roofing and waterproofing service. Modern methods call for applying these materials by a spray nozzle which: in no way produces hazardous emissions of asbestos fiber. These are not atomizing sprays that form fine mist particles, but they deliver a sheath or solid liquid fan which does not create emissions to the atmosphere. Once the fluid is on the building, the material dries and the asbestos is en trapped in a bituminous matrix that prevents it from entering the atmosphere. We think there is no technical justification for imposing a restriction on the method of application. Of course, we concur with limitations on spraying of asbestos con taining compositions that have the potential to liberate asbestos particles that become airborne. But, for now, we suggest that an alternate warding be provided for Section 61.22 (e) (1,2) that will permit fluid applications of paints, coatings, and adhesives. 3>' - r- rr/*-/*-r. GAF 21647 In conclusion, GA? reiterates its recognition of the desirability and necessity for effective emissions control. With the exceptions I have discussed, we support spA's national emissions standards on asbestos. Ve suggest that the tailings pile section and mine road section be deleted until modern engineering offers an answer to these problems. In any event, C-AF will continue its own search for practical environmental controls at all plants. Thank you. GAF 21648 memo: FROM: Bob Bettis 1/26/72 To: Paul Weiner Here's a draft of Mr. Darrell's SPA testimony. When it is typed, please have two copies sent over to me. Bob vJ*^ X GAF 21639