A PRELIMINARY REPORV

              OK ASBJIRTOS

      IN TI1L DULUTH, NJNi;bSOTA,ARKA.
       OFE1CE OF TECHNICAL  ANALYSIS
OFFICE OF ENFORCEMENT AND GENKK/J  CO
     ENVJUONME^TAL PROTECTION AGL^CY
               January, 1974

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r
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                                               AUENCt

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II.  Air
     Water

     A,    /'•'::; 1 v£c/j_ of _ \".-j-et^.££?lr_?.-'^_ar''>  about:  4o% complete.	Duplicate
                     'r1 contractors shows:

          1.    A definite preserve of  asbestiform fibers in
               19 saiapiit.! (44%).
          2.    A possible presence in  7  samples (16%).
          3.    A definite absence in  17  samples (40%).

     B.    W? t:or supply__ gy_steian _a£f££t^ed_:

          1.    Dafinitely:  Daluth, Silver  Bay, Beaver Bayy  and
               IVo Harbors, Minnesota, and  Superior, Wisconsin.
          2.   Strong possibility:  Grand Marais,  Aurora, and
               Cloquet) Minnesota, and White Pirre, Michigan.
          3.    These water  supply PJ^Sterns serve not more than
               153,232 people.

     C•    Asbentiform fiber identity  and size:

          1.    Fibers found by both independent EPA contractors
               iu all buc tnree samples  were identified as being
               the asiphibole  "grunerite-cummingtonite" similar
               to that found  on the Mesabi  Range.
          2,   Fibers were  found to be predominantly shorter than
               5 micrometers.
     A.   Analyses of air sagpj.es  exclusive of stack samplesand
          court-ordered samp1es :

          1.   First sampling effort:

               a.   Analyses by Battelle  95% completed (106 samples),
                    but they will  not  stand behind the sample preparation
                    technique used ro  obtain those results.
               b.   Reanalysed 33  of those  samples which results they
                    will support.

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                                 11
          c.   Onl-y the remits or  L:h2  ro?-.nalysis have
               bec-r, cc.-i'-.iuerc--l in this  interpretation
               of the data, sJ. though  there  is  no
               significant Difference betvaon  the results
               obtcrLr.eo oithc-r tdr.ie.

     2.   .Second c..u'"p3 ir.g eiiort:   Analyses by two other EPA
          contractors are Hi complete.

&*   Concentrations of Fiberr-, ir.ti;e_^Air_aj^ Silver Bay

     The samples usc-d for comparative purposer, have been taken
under different scr.i.piin? conditions and for different programs.
Generally the data ware generated during research programs where
sampling and analytical methods were  being  tested for validity.

     Keeping the limitations of the analysis in mind, the
following conclusions have been determined:

          1)   Amph.i bole concentrations  measured down-
     wind of the Reserve Mining processing  facilities
     are not uniquely high.  Chrysotile  concentrations
     equal to or greater than the Silver Bay amphibole
     concentrations have been measured  in Ohio and
     California near asbestos plants.

          2)   The average concentration of two back-
     ground (or clean site) samples measured, in the
     Silver Bay area are ten times  greater  than the
     urban mean chrysotile concentration.   The average
     amphibole concentration for the  background site
     in Silver Bay is greater than  98.8% of the 314
     chrysotile concentrations measured in  55  U. S.
     cities during the 1969-1972 period.

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                       TABLE OF CONTENTS
                                                                    l^age

Introduction                                                          -L

Chapter I
    Prelirainary Interpretation Of Analytical Data Reported To
    Date On Levels Of Asbentiform Fibers In The Water Supplies
    Of The Duluth Area And Western Lake Superior Basin

A.  SUMMARY OF FINDINGS AND TENTATIVE CONCLUSIONS

    1.  Summary of Findings                                           1

    2.  Summary of Tentative Conclusions                              5

B.  INTRODUCTION                                                     10

C.  WATER SAMPLING EFFORT - WESTERN LAKE SUPERIOR BASIN              10

D.  ANALYTICAL EFFORT                                                12

E.  RESULTS OF ANALYTICAL EFFORT

    1.  Findings                           '•                          14

    2.  Tentative Conclusions                                        23


Chapter II
    Preliminary Analysis Of Data On Asbes, i.iforui Fibers In
    Air From Silver Bay, Minnesota

A.  INTRODUCTION                                                     27

B.  SOURCES OF DATA                                                  28

C.  DATA FROM THE EPA MEMBRANE FILTER NETWORK                        32

D.  DATA FROM THE EPA SAMPLING EFFORT IN MINNESOTA                   32

E.  COMPARISON OF SILVER BAY DOWNWIND DATA TO OTHER
    DOWNWIND-OF-SOURCE LOCATION DATA                                 37

F.  COMPARISON OF SILVER BAY BACKGROUND DATA TO URBAN
    CONCENTRATIONS                                                   40

G.  COMPARISON OF SILVER BAY BACKGROUND DATA TO NON-
    URBAN AND REMOTE DATA                                            42

H.  CONCLUSION ON THE SILVER BAY AMPHIBOLE CONCENTRA-
    TIONS                                                            42

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                                 iv

 Chapter III
     Preliminary Estimate Of The Occurrence Of Asbestiform And
     Other Potentially Hazardous Fibers In The Taconite Industry

 A.   INTRODUCTION                                                     46

 B.   THE GENERAL GEOl^OCY AM) MINERALOGY OF THE
     BIWABIK IRON FORMATION                                           47

 C.   DISTRIBUTION OF TACONITE MIKES ALONG THE
     MESABI RANGE                                                     48

 D.   ASBESTIFORM MINERALS OTHER THAN GRTJNERITE--
     CUKMINGTONITE ALONG THE MESABI RANGE                             49

 E.   ASBESTIFORM MINERALS EXPECTED IN EMISSIONS
     FROM LOADING PELLETS                                             50

 F.   TACONITE MINING IN STATES OTHER THAN
     MINNESOTA                                                        51

 G.   POTENTIAL POLLUTION ASSOCIATED WITH ACT-
     IVITIES OTHER THAN THE MINING AND MILLING OF
     IRON ORE                                                         51

 H.   CONCLUSIONS                                                      5rt
 APPENDIX I       ANALYTICAL METHODOLOGY USED BY EPA
                  CONTRACTORS                                         57

*APPENDIX II      ANALYTICAL RESULTS REPORTED TO DATE
                  FOR WATER AND AIR SAMPLES                           81

 APPENDIX III     STATISTICAL ANALYSIS OF THE ANALYTICAL
                  RESULTS                                             82
 *Due to its bulk, Appendix II can be seen on file in the
  Office of Technical Analysis

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                            INTRODUCTION
     The data upon which this analysis is based are the analytical
results obtained to date from the contractors and cooperators.   The
analysis were about 50% completed as of November, 1973.  Table  I
shows the EPA contractors as of that date.  On that date about  366
samples had been completed, reported, and submitted for clearance
and about 163 remained to be analyzed.  This accounting does not include
the stack samples or process samples to be analyzed.  Table II  shows
the number of samples handled from each locale.  Since the results are
only about half completed, conclusions included herein must be
viewed as preliminary, pending completion of all samples and final
detailed analysis and interpretations of the results.

Definition of Asbestos

     "Asbestos" is defined by the n  S. Geological Survey as a  term
applied in commerce to naturally fibrous silicates that are amenable
to mechanical separation into fine filaments of considerable tensile
strength and flexibility.A   These fibers have, by virtue of unique
combinations of physical and chemical properties, a great variety of
industrial uses.
/!_  United States Mineral Resdurces,  D. A. Brobst and W. P. Pratt,
    eds.; U. S. Geological Survey Professional Paper 820, p. 64, 1973.

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                          vi
Classification of Asbest os_

     The silicate minerals called asbestos vary greatly in their
physical and chemical properties.  The minerals are
classified as follows:^
CHRYSOTILE                                    AMPHIBOLES
      l
  ACTINOLITE   AMOSITE   ANTHOPHYLLITE   CROCIDOLITE   TREMOL1TE
      GRUNERITE       CUMMINGT
CUMMINGTONITE
   7~ Evaluation of Carcinogenic Risk of Chemicals  to  Man;
Monograph,  International Agency  for Research  on Cancer,
vol.  2,  1973.

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               CliAPTER I
    PRELIMINARY INTERPRETATION OF
   ANALYTICAL DATA REPORTED TO DATE
 ON LEVELS OF ASRESTIFORM FIBERS IN THE
    WATER SUPPLIES OF THE DULUTH
AREA AND WESTERN LAKE SUPERIOR BASIN

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                        CiiAPTFR  I

                    TASLE OF  CONTENTS


A.  S\J:;/:A:;Y OF IT-DIMCS AKI; TENTATIVE  CONCLUSIONS
                                                »
    1.  Summary of Fi/idings                                    1

    2..  Summary cf Tentative  Conclusions                       5

B.  INTRODUCTION                                              10

C.  WATER SAMPLING EFFORT - WESTERN LAKE  SUPERIOR BASIN      10

D.  ANALYTICAL EFFORT                                         12

E.  RESULTS OF ANALYTICAL EFFORT

    1.  Findings                                              14

    2.  Tentative Conclusions                                23

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A. stii-giAKY OF FILINGS A'.n
   -1' S1M1ARY C~ riNDIKC'i

        The air iytical re::-.: Its-1 preo'intly  in h«md  address  the  extent of
   at.bcstifor,:, fiber cone,: •:?>' :i scion of wrier samples  collected by EPA in Into
   June and early July of  Li;7^, as determined by  electron microscopy par forwci
   by two ET'A-contractor  ].-,bo,'.ator ies ,  the University  of  California School  i.-f
   V'ublic Heal-'.h (UCSPII)  ;t l^rV'jKry, California,  and  McCrone Associates,
   (KCCA) of Chicago, 111 l^ois.  Only those results  for which analyses were
   coiapieted by both laboratories are reported  on here, and any conclusions
   drawn at this Lime must  reuiain subject to change  until all samples
   collected at various points and localities are completed.

        While the overall June/July EPA water sampling program produced
   samples at various points in the water source-supply-distribution chsin
   from 30 major locations  in the Western Lake.  Superior Basin — covering
   12 cities and communities in Minnesota, 2 in Wisconsin, A  in Michigan,
   as well as additional  Minnesota locations, including well  water and
   surface supplies from  rivers and lakes — analytical results reported by
   both laboratories to date yield only the partial  coverage  indicated in
   Table B, and as summarized below.  _!_/
Total # water samples:
(Western Lake Superior Area)
UC School of Public Health ..
McCrone Associates *......».,
(US Army ERDLATOR Samples)
UC School of Public Health .,
McCrone Associates. 	 	 	 ,
Total Received/Completed...
Received (
. ... 88
	 79
.... 11
	 9
187
Completed to date
45
54
11
9
119
Total * of analyses completed for duplicate
 samples taken at the same location and
 comprising the basis' for the tentative
 conclusions reached in this report:
                                                          86  for 43 water
        The 86 data points above represent  analytical findings reported by
   UCSFH and MCCA to date of asbestifomi fiber levels found in 43 water samples.
   including 8 ERDL.ATOR  treatment unit  samples.   Neither laboratory had
   knowledge of  the type or origin  of any sample, each sample being marked
   solely with an identification number which was decoded by EPA on receipt
   of the analytical results.

        Excluding results for  the experimental runs of the US Array ERDLATOR
   Treatment Unit (Diatomaceous Earth Filtration) , findings respecting
   asbestiform fiber levels for duplicate samples from identical locations
   are now in hand for 35 separate  locations in the Western Lake Superior
       See  also  Data  Appendix

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                Table  B — Listing of Number and Type of Water Samples  Received
                            and Status of Completion of Electron  Microscope Analyses
                            by Both EPA-Contract or Labs, by  Major Sampling  Location. 2/
                    Over-all Sampling Program1

                  Number £• Type of"Sample Received/Completed
                                                             Samples Received and  R^S
                                                             Reported by Both Lahp *,•
                                                             Duplicate Samples Tsk<.\
                                                             the Same Locations  -  to
 a,
 v.
Lii.
Is),
-0.
21.
24.
28.
29.
30.
               » 6 Type of  Sample
/•^ cation*	   Received       	  	
                         (See  Legend)
Silver Bay     3-DS/2-EFF/3-IN
jl-iaver Bay     3-DS/2-EFF/2-IN
Duluth         11-DS/10-EFF/3-IN/2-HYD/
               2-WW
               3-DS/2-EFF/2-IN
               2-DS/2-EFF/2-IN/2-HYD
               2-DS/5-JN
               4-DS/2-EFF/2-IN/2-HYD
               2-DS/2-EFF/2-IN/2-Hyd
               2-DS/2-EFF/2-IN/2-HYD
               2-DS/2-EFF/2-IN/2-HYD
               2-DS/2-EFF/2-IN
               2-DS/2-EFF/2-IN
               2-DS/2-EFF/2-IN
               2-DS/2-EFF/2-IN
               2-DS/2-EFF/2-IN/2-HYD
               2-DS/2-EFF/2-IN/2-HYD
               2-WW
Two Harbors
Ashland,Wis.
Cloquet
Superior,Wis
VMts Fine, Mich
Eagte Harbor, "
Grand Marais
Virginia
Eveieth
Aurora
Hoyt Lakes
Minneapolis
Ramsay,Mich.
U&n. P&L Well
Fond du La c Wen 2-WW
Lslosvocd School, Mch,  2-DS
NE Exp.Station 2-DS
Gooseberry
  State Park  2-DS
Edibeck Carpgrf.  2-DS
Elde's Cojnar^rrg 2-DS
Beaver River  2-RW
Stewart River 2-RW
Baptism River 2-RW
St.Louis River 2-RW
Wild Rice Lake  2-LW
Pike Lake     2-LW
Birch Lake    2-LW

 Subtotal - 30  major locations:
              56-DS/38-EFF/37-IN/8-RW
              6-LW/16-HYD/6-WW
 Add ERDLATOR
  Samples:    20
                                                Analyses
                                               Completed
                                             2-DS/1-EFF/2-IN
                                             2-DS/l-EFF/l-IN
                                             8-DS/7-EFF/1-IN
                                              2-WW
                                             2-DS/l-EFF/l-IN
                                             2-DS/l-EFF
                                                             Total    Total
                                                            Received Completed
 All completed
2-DS/l-EFF/l-IN
1-DS/l-EFF/l-IN
2-DS/1-EFF/2-IN/1
1-DS/l-EFF
1-DS/l-EFF/l-IN
 All completed
 All completed
1-DS/l-EFF/l-IN/l
                                          1-DS
                                          1-DS

                                          2-RW
                                          2-RW
                                          2-RW
                                          2-RW
                                          2-LW
                                          1-LW
                                          1-LW
    8
    7

    28
    7
    8
    1
    10
    8
    8
-HYD 8
    6
    6
    6
    6
-HYD 8
    8
    2
    2
    2
    2

    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
                                              36-DS/23-EFF/22-IN/8-
                                              RW/4-LW/4-HYB/2-BWivV 167
                                              20
                                                                20
          Total for all samples	  187
 4
 2

16
 2
 2
 6
10
 2
 0
 4
 0
 0
 6
 6
 0
 0
 0
 0
 0
 0

 0
 0
 0
 2
 2
 2
 2
 2
 0
 0
                                                                        86
                                      (Pei
 ( 50% '
 (Ji'-v •

 (.IT';
 (29-; '
 (2;?:.
( 100',' ,
(100% ';

 ( \ y *' ^
 (50%. •

 ( 0*0
ClOO'o i
(100% j

 ( 0% )
 ( 0% i
 ( 0% }
 ( 0% '
 ( 0% )

 ( 0%; }
 ( 0% )
 ( 0% )
 (100% )
 (100% )
 (100? )
 (100% )
 (100% )
  (.0% )
 < 0% )
                              70        ( 42%)

                              16        (100%  )

                                        ( 46%  )
   * = Minnesota locations unless  otherwise shown
   Legend:  DS = Distribution  System/EFF = Effluent/ IN = Influent/ RW
            LW = local lake water/ HYD  = Fire hydrant/ WW = well water
  2/ See also Data Appendix
                                                                     = River water

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           The  tabulation of fiber counts and size distributions  summarized  below
      is  restricted to locations from which duplicate samples were received  and  reporieo
      on  by both EPA-contractor laboratories to date.  Results of samples  for which .inaJx
      of  the duplicate remains outstanding will be reported after they  are received ar.u
      evaluated*,
      Table C --
Asbestiform Fibers and Fiber Size Distributions  Found  in
Duplicate Samples via Electron Microscopy  Analysis  performed
by University of California School  of  Public  Health and
     McCrone Associates, Inc., of Chicago,  111.  o/
   I feation*
I,Silver Bay
"-'  ^eever Bay
'..Duiuth
 :'.Two Harbors
 -  Silver Bay
 ' .Superior,Wis.
 J.Jeno's *1 (Duluth)
 ] .   "    £2
:1.   "    #3
 ^.Superior,Wis.
M.Cloquet
1 ri    "
± -j«
• it    "
.T.Superior, Wis.
'B.White Pine, Mich.
"'.Grand Marais
.jO. Aurora
M.Hallett We 11, Duhith
i.2,Ashland,Wis.
'3.Superior, Wis.
'>4    "        "
U' -* •*
l:.r>.Grand Marais
26.Aurora
27.   "
'.''.Hoyt Lakes
JV.  "
•/)  "    "
;i .Beaver River
•v  Stewart River
• ''.Baptism River
31.St. Louis River
Vi.wild Rice Lake
   Type
   Sample
     DS
     DS
     DS1
     DS2
     DS3
     DS4
     DS
     IN
     DS
     EFF
     EFF
     EFF
     EFF
     IN
     DS
     IN
     DS
     DS
     DS
     IN
     ww
     DS
     IN
     HYD
     IN
     EFF
     DS
     IN
     EFF
     DS
     RW
     RW
     RW
     RW
                               Number of Fibers
                               UCSPH     MCCA
                               (Millions of Fibers
                                 per liter water)
2.0
3.0
5.0
2.0
1.0
1.0
2.0'
.5
.3
.7
1.0
.1
.7
BLACL**
•II
II.
It
11
11
II
11
4.37
5.29
2.76
6.08
2.26
1.47
2.53
1.47
1.10
3.87
.6V
.71
.37
.39***
.93***
.98***
.39
.18
.25
.26
BLACL**
                                  it
                                  it
 Fiber Length -  Percent  Distribiitj
    UCSPH	MCCA	^
<3    3-5   >5    <3     3-5   >5
    [Micrometer size classes)
                         «
                          3.2   -
                          2.6   -

                          1.5
                         10.2   6.1

                          9.1   3.6
                          7.1   -
                          4.8   -
                                                                              6.7   6.7
                                                                              9.1
                      LW
                                   Continued next page with US Army ERDL.ATOR results)

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(Tabulation continued)
JLS ARMY ERDLATOR RESULTS

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IN
EFF
IN
EFF
EFF
EFF
EFF
EFF
Number of Fibers
UCSPH MCCA
(Millions
.3
,2
.0
.3
.1
.3
BLACL**
BLACL**
per Liter)
2.04
6.05
8.24
.39
.99
.46
BLACL**
BLACL**
Fiber Length
UCSPH
3
50.0
100.0
54.8
83.3
100.0
100.0
-
-
3-5
25.0
-
2.3
15.0
-
-
-
-
- Percent Distribur.i
MCCA
5 3 3-5
25.0 96.2 3.8
100.0
2.3 95.3 2.0 1
1.7 100.0
- 100.0
- 100.0
_
. -
  *  Minnesota  location  unless  otherwise  indicated
 **  BLACL means "Below lowest acceptable counting limit"; this  is a variable  ericounte-x
     from sample to sample, is dependent on other suspended particulates  content  of  £;>' ,
     fie samples, and may comprise anywhere from "more than zero" to  "less  than 50,001)'
     fibers.
***• Chrysotile asbestos fibers were found in these samples;  no amphibole fibers.

  3/ See also Data Appendix
            A detailed discussion of findings in hand for individual sampling
     locations is presented'in E. RESULTS OF ANALYTICAL EFFORT - Item 1. Findings,
     The tentative conclusions arising from the findings are summarized below, and
     are addressed in additional detail in E.2. Tenttrtr^et€3i?a£sr$35fias.

            A map showing the approximate locations of the water sampling points
     for which both labs reported analytical results to date appears on the fol-
     lowing page, with a legend categorizing the findings thus far reported.

-------
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Area, comprising 70 analyses completed as compared to 167 samples
received, a completion percentage 01 about 42 percent.  If ERDLATOR
results are included, the completion rstio is 46 percent.

     The individual water source/supply areas sampled for which results
have been reported by both laboratories are identified in the tabulation
below, along with an accounting of results still outstanding as well as
indicated completion ratios.
2. SUMMARY OF TENTATIVE CONCLUSIONS

     In view of the fact that analytical results respecting the presence
or absence of asbestiform fibers, as presently in hand, comprise only
about 46 percent of the total data base, all conclusions drawn below
must be viewed as tentative.  Aside from considerations of statistical
validity, it is entirely possible that for given locations for which the
partial results presently available show an absence of fibers may, on
examination of samples for which results remain outstanding, show their
presence.  Notwithstanding these obvious shortcomings, it is patently
desirable — and reasonable — to advance tentative conclusions respecting
levels of water contamination by asbestiform fibers in the Western Lake
Superior Basin area.

     1)  Results reported for 43 duplicate water samples analyzed by
         electron microscopy by two independent EPA contractor labs
         show a definite presence of asbestiform fibers in 19 samples
         (44%), a probablp p^qence in 7 samples (1G%), and a definite
         absence in the remaining 17 samples (40%).  4/

         a) The definitional framework relied upon in framing these
            tentative conclusions is as follows:

            (1) All conclusions relating to the presence or absence
                of asbestiform fibers refer to water sampled in late
                June - early July of 1973, and thus reflect levels
                then prevailing.

            (2) A "definite" presence of asbestiform fibers is assumed
                where both EPA contractor labs reported finding asbesti-
                form fibers greater than the "Lowest Acceptable Counting
                Limit" for any duplicate samples which they both examined.
                (See (3) below)

            (3) A "definite" absence of asbestiform fibers is assumed
                where both EPA contractor labs reported finding no
                asbestiform fibers in any duplicate samples which they
                both examined.  This is identified as  "BLACL", meaning
                "Below Lowest Acceptable Counting Limit" — a variable
                encountered from sample-to-sample which is dependent
                on other suspended particulates content of specific
                samples, and may comprise anywhere from "more than zero"
                to "less than 50,000 fibers".

kj Derived from Data Appendix Tables III - V.

-------
           A "probable"  presence of asbestif ora fibers is assumed
           where one T,:'A contractor lab reported finding no asbesti-
           form fibers (BLA.CL.) ,  whereas the other reported fiber
           levels above  "ELAGL".  This divergence is encountered in
           a total of 7  out of  the A3 duplicate samples examined
           by both labi:, and its significance is discussed later.

    The asbestiform fibers found by both EPA contractor labs for all
    but three cluplicat i__s rtagles  we re identified as amphibole ashes tojs
    fibers i n_ t lie "grin i e r ite_ r_£"'-Ti;m A^L? tonite" series of fibrous mine ral
             _              _ _
    of the type found in various Geposlts in the Iron Range.  In three
    samples,  all from the Cloquet area,  one lab found not amphibole but
    chrysotile asbestos fibers, a serpentine asbestos such as is used
    in most asbestos-containing manufactured products; the other lab
    saw no asbestif orm fibers in these three samples.

3)  In the absence of _ medical studies showing that asbestif orm fj.ber
    ingestion is beneficial to human health, and in the presence of
    a variety of scientific studies affirming that asbestif orm fiber
    inhalation is hazar doua to human health, the conclusion dictated
    by prudence is that the absence of such fibers from drinking water
    supplies is clear ly preferable to their presence.

4)  This conclusion forms the basis for arranging the analytical
    results respecting gsbestif orm fiber content for varjLous^localities
    for which duplicate samples have been reported on by both EPA
    contractor labs in a fashion ranging from "Contaminated" to
    "Not Contaminated^.  Table D shows these sampling pointy without
    intermediate ranking reflecting degrees of severity of contamination.

5)  Pending development of a consensus by medical authorities respecting
    "harmful" versus "acceptable" levels of asbestiform fibers in water
    destined for ingestion, it makes little sense to attempt to rank
    analytical results for the several sampling points by "intermediate"
    degrees of severity of contamination by contrasting, say, 3 million
    fibers per liter versus 1 million fibers per liter.  Whatever
    degree of precision would obtain from such an attempt could be at
    least partially obliterated by the lack of precision in presently
    available electron microscopy techniques for determining numbers
    and sizes of asbestiform fibers in water.

6)  The only certainty which obtains at this point in time is the
    certainty of the electron microscopist who sees an asbestiform
    fiber under his microscope and identifies it as such beyond the
    shadow of doubt, using his equipment to its full capability,
    and drawing on his knowledge and experience with full confidence.
    Beyond that certainty, we find ourselves at the "frontier" of the
    state-of-the-art, and attempts to impart precision beyond that
    which is deserved are not warranted at this point in time.

-------
 7)   Thus,  while  for  7  of  the  43  samples  reported  on here,  no asbesti-
     form fibers  were i ouiid  by one  lab., V7hereas the other did see and
     identify  ssbestlforni  fibers., cannot  be  dismissed or taken lightly.
     Although  the corroboracive validity  present for the other 36
     samples is here  lack!mr,  the presumption should be that asbesti-
     fonn f 1 hers  were J-na.vci present  in the  water  at the time th
-------
Table D  — List of Water Sampling Voints for which Electron Microscopy
            Analytical Results Presently in Hand for Duplicate Samples
            Examined by Two EPA Contractor Labs Show the Presence or
            Absence of Asbestiform Fibers  5_/

  a) Contaminated — Definite Presence of Asbestos Fibers
1.
2.

3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.

15.
16.
17.
18.
Duluth
ii

ii
it
ii
ii
ii
it
ti
ii
ti
ii
tt
Silver

ii
Beaver
Area —
ii __

ii __
ii __
ii 	
ii 	
it 	
ii __
ii __
ii 	
ti __
ii __
ii __
Bay

ii 	
Bay
Two Harbors —
Superior ,Wis . —
Arlington Water Pumping Station; tap off west pump
Fire Station at 3501 Woodlawn Ave.; tap in fire
truck bay
Duluth Airport; custodian closet tap, main floor
Duluth Pump. Station, 4424 Grand Ave.; north pump tap
Jeno's Diatomaceous Filter #1
ii it n j»2
It II It JiO
Duluth Raw Lake Water before ERDLATOR Run #8
11 " " before " Run #9
11 " " after " Run #9
11 " " after " Run //7
" " " after " Run #7
" " " after " Run //9
Standard Gas Station, Corner of Highway 6; and
Outer Drive; outside tap eastside of building
Pump House influent; tap off incoming line
Jim's Shell Station, Hwy. 61; car bay tap
Fire Station sink tap, 7th St. and 2d Ave.
Underbill Service Center, 2915 Hill Ave., tap in
                          meter shop, Superior Power & Light Co.
    19.   "      "   — Water Plant effluent; tap in laboratory sink

  b) Probably Contaminated — Probable Presence of Asbestiform Fibers

     1. Superior, Wis. — Lake Superior water tap outside water treatment
                          plant Superior Power & Light Co. (from Cloquet Pipeline)
     2. White Pine,  — Town site heating plant; boiler room tap.
          Mich.
     3. Grand Marais, — Municipal building and fire station tap in
          Minn.           fire truck bay
     4. Aurora, Minn. — Water Plant intake
    *5. Cloquet.Mirin. — Raw well water; intake tap inside building in
                          pumphouse
    *6.   "      "   — Influent - Northwest Paper Co. Lake Superior
                          influent tap in plant off pipeline
    *7.   "      "   — Well water - fire station Cloquet Ave. and 5th St.
                          (sometimes uses Lake Superior water from pipeline)

         * Fibers found in these samples were chrysotile, not amphibole,
           raising the possibility that contamination occurs via an
           asbestos-containing manufactured product, such as asbestos-
           cement pipe, or from some other source.

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Table D — Continued
  c) Not Contaminated — Definite Absence, of Asbestiform Fibers
     1.
     2.
     3.
     4.
    Duluth Area
    Ashland,Wis.  —
     5. Superior,Wis.—

          611      it
       .              —

     7. Grand Marais —
     8. Aurora       —
     9.   "
    10. Hoyt Lakes
    11.   "
    12.
    13.
    14.
    Beaver River —
    Stewart River—
15. Baptism River—
16. St.Louis Rvr.—
17. Wild Rice Lake-
Hallet-.i. Well (Jeno's) 59th Ave.W. Tap off pump
DuJuth Raw Lake Water, after ERDLATOR Run #8
             "    "    after ERDLATOR Run //8
Water utility office; tap in basement at 320 E.2d St.
Superior Power & Light Co. well; intake for water
  plant; tap in laboratory sink.
Superior Power & Light Co. (well); fire hydrant,
  underbill service center near building 2900 Kill Ave.
Water Plant Intake; tap off spigot on intake pump
Water Plant effluent; outside tap
City Hall; utility room tap
Water Plant; intake tap in main building
Water Plant; effluent tap after punip, main building
  basement
Police Department; garage tap
Stream sample off Highway 61 near Beaver Bay
Kwy. 2, N. of Two Harbors, downstream side of bridge
Eckbeck State Park near Finland, Minn.
Hwy. 2 bridge, 200 yards downstream of bridge
Dam Rd. off Minn. Route #4; sampled at the dam
J>/ Derived from Data Appendix Tables I, III, IV, and V.

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                                     10
B.    INTRODUCTION

     On June 15, 1973, a news release issued by the Environmental
Protection Agency in Washington, D.C. announced that high concentrations
of asbestos fibers had been discovered in the drinking water supply of
Duluth and several communities or. the Minnesota shore of Lake Superior. 6_/
The source of these fibers was believed to be the discharge of taconite
tailings by the Reserve Mining Company at Silver Bay, Minnesota.  The
Reserve Mining Company, an equally-owned subsidiary of ARMCO and REPUBLIC
Steel Companies, mines low-grade iron ore (taconite) at Babbitt, Minnesota,
and converts it into high grade pellets at Silver Bay, Minnesota.  In
operation since 1956, the Company dumps waste ore tailings, exceeding
60,000 tons per day at full production, into Lake Superior at Silver Bay.
The abatement of this pollutiong discharge is the subject of a civil action
filed by the U.S. Department of Justice in February 1972, at the request
of the Environmental Protection Agency, in the U.S. District Court for the
District of Minnesota, naming Reserve Mining Company as the defendant.
Trial commenced August 1, 1973, and is still in progress at this time.

C.   WATER SAMPLING EFFORT — WESTERN LAKE SUPERIOR BASIN

     Immediately after issuing the news release, the Environmental
Protection Agency began efforts to secure samples of water thought to be
contaminated with asbestos fibers.  A field operations center was established
in Duluth, and personnel of EPA Region V proceeded to collect water samples
at more than 30 sites in the Western Lake Superior Basin Area, covering
various representative points in the water source-supply~distri'.»utioa
setting of 12 cities and communities in Minnesota, 2 in Wisconsin, 4 in
Michigan, as well as 14 additional Minnesota locations comprising well
water and surface supplies from rivers and lakes.  Tj

     Concurrently, the Agency commenced a search across the United States
to locate analytical talent and facilities capable of processing large
numbers of water samples to yield an early determination of the nature
and extent of the asbestiform fiber contamination problem.  The search
soon resulted in the painful realization that meaningful answers to the
problem would be long in the coming.  Few laboratories had ever tried to
determine asbestos content of water; even fewer investigators had ever
looked for asbestiform fibers with an electron microscope.  Some who had
done the latter had familiarity solely with techniques designed to deter-
mine asbestos dust levels in occupationally-exposed segments of the population.
By mid-July of 1973, it was apparent that the Agency found itself at the
frontier of knowledge and that no quick answers were possible or even
within sight.


fj "Asbestos Fibers Found in Duluth Water Supply5', U.S. Environmental
   Protection Agency News Release, dated June 15, 1973

Tj See Data Appendix Table I

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                                      11
     By early July, more than 700 water samples had been collected and
were awaiting analysis.  The exact locations are identified in Table I
of the Appendix, together with collection dates, sample sizes, container
types, preservatives used, and laboratories receiving the samples for
analysis.  For convenient overview, the sampling locations are summarized
in alphabetical order below, together with an indication of the type of
sample taken, coded as follows:  DS = Distribution system sample; IN =
Influent water; EFF = Effluent water (such as from a water treatment plant)
HYD = Fire Hydrant Sample; RW = River water; LW = Lake water from local
lakes; WW = Well water.

                               Table A

                Alphabetical Summary of Water Sampling
                Locations and Sample Type Categories ^/

     Ashland, Wis	     IN/EFF/DS/HYD
     Aurora, Minn	     IN/EFF/DS/HYD
     Baptism River, Minn	     RW
     Beaver Bay, Minn	     IN/EFF/DS/HYD
     Beaver River, Minn	     RW
     Birch Lake Reservoir, Minn	     LW
     Cloquet, Minn	     IN/DS/HYD
     Duluth, Minn	     IN/EFF/DS/HYD
     Eagle Harbor, Mich	     IN/EFF/DS/HYD
     Eckbeck State Park, Minn	     DS
     Elde's Corner Spring, Minn	     DS
     Eveleth, Minn	     IN/EFF/DS/HYD
     Fond du Lac Well, Minn. 	     DS (WW)
     Gooseberry State Park, Minn.  ...     DS
     Grand Marais, Minn	     IN/EFF/DS/HYD
     Hallett Well, Minn.  	     DS (WW)
     Hoyt Lakes, Minn	     IN/EFF/DS/HYD
     Jeno's Filter (Duluth), Minn. ..     IN/EFF
     Lakewood School, Minn	     DS (WW)
     Minneapolis, Minn	     IN/EFF/DS/HYD
     Minn. Power & Light, Minn	     DS
     NE Exp. Station, Minn	     DS
     Pike Lake, Minn	     LW
     Ramsay, Mich	     IN/EFF/DS/HYD
     St. Louis River, Minn	     RW
     Stewart River, Minn	     RW
     Silver Bay, Minn	     IN/EFF/DS/HYD
     Superior, Wis	     IN/EFF/DS/HYD
     Two Harbors, Minn	     IN/EFF/DS/HYD
     U.S. Army ERDLATOR Unit 	     IN/EFF
     Virginia, Minn. 	     IN/EFF/DS/HYD
     White Pine, Mich	     IN/EFF/DS/HYD
     Wild Rice Lake, Minn	     LW
JB/ Derived from Data Appendix Table I

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                                       12
D.   ANALYTICAL EFFORT

     By raid-July 1973, EPA had arranged to secure.the services of three
laboratories thought capable of snaking determinations respecting the
nature and level of asbestifonn fiber contamination in the water supplies
of the Western Lake Superior Basin area.   Two of these laboratories,
WALTER C. MCCRONE ASSOCIATES, INC. of Chicago, Illinois,  and the SCHOOL
OF PUBLIC HEALTH OF THE UNIVERSITY OF CALIFORNIA at Berkeley had had
prior experience in identifying asbestos  in water.  The third lab,
BATTELLE COLUMBUS MEMORIAL INSTITUTE at Columbus, Ohio, had had prior
experience, and a continuing contract with EPA, respecting the determination
of asbestos levels in air samples collected by the Agency under a continuing
national air sampling network program effort.  All three laboratories were
deemed to have the analytical equipment necessary to make valid determinations
in the problem at hand.

     Of the 769 water and filter samples  collected by early July, some
268 were filter samples; the remaining 501 were water samples suitably pre-
served. 9/  About 300 of these actual water samples, comprising duplicates
of the original samples, were sent to the three EPA contractor labs named
above.  Another 93 water and filter samples were sent to the EPA Water
Supply Research Laboratory at Cincinnati, Ohio, for analysis by optical
microscope, and 33 samples were sent to the EPA National Water Quality
Laboratory at Duluth, Minnesota, for analysis by that facility's
investigators.  About 168 water samples remain in the custody of EPA
Region V at its Minnesota-Wisconsin District Office.  Additional details
of sample disposition are contained in Appendix Tables I and II.  Appendix
Table II is an alphabetical listing of samples remaining in the custody
of Region V.

     From the beginning of the search for analytical capability, the Agency
realized that it was crucial to pinpoint  the identity, dimensions and levels
of asbestiform fibers as these were present in the water actually being
ingested by the people in the affected communities, with the greatest
possible, precision.  This approach alone  would secure the factual basis
essential to informed decision-making by medical authorities respecting
the significance of such contaminants to human health, when ingested.

     There were severe doubts that optical microscopy had either sufficient
power of resolution and definition or the essential versatility of electron
microscopy, particularly in the sub-micrometer size ranges of particles.
These doubts were proven justified via a comparison of results obtained
by optical microscopy versus those obtained by electron microscopy; there
was a statistically significant lack of relationship between the two sets
of results, obtained by examination of duplicates of the same water samples.

     With electron microscopy, too, there were dangers that certain methods
of sample preparation could yield inaccurate information on numbers of
asbestiform fibers and their size distributions as actually present in the
water ingested, because the preparation techniques had the potential of
breaking fibers into two or more pieces and of separating fiber bundles
into individual fibrils, thus artificially multiplying the number of fibers
actually present.

9/ From Data Appendix Table 1

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                                      13
     Time — rather than accuracy — thus became the tradeoff.   One of the
three EPA contractor labs, RATTELLE MEMORIAL INSTITUTE of Columbus, Ohio,
and largely completed its vmter analyses by the end of August 1973;
however, its sample preparation procedures essentially were those followed
to date for determining asbestos dust levels in air, using scnication
techniques (shaking by sound waves) to prepare samples for examination
under the electron microscope.  The number of fibers subsequently observed
under the electron microscope way or may not have resembled the number
actually present in the water ingested; most likely, they did not.
BATTELLE reported no fiber size distributions, i.e. reported no data
on the length and width of the fibers found, but instead constructed asbesti-
fonn fiber mass concentrations, expressed-in nanograms per liter of water,
and reported these together with total numbers of fibers calculated to be
present in each sample.

     When subsequent analyses were reported on by MCCRONE ASSOCIATES and
the UNIVERSITY OF CALIFORNIA SCHOOL OF PUBLIC HEALTH, using essentially
identical techniques which differed from BATTELLE'S, and it became apparent
that the fibers found in the water samples analyzed were predominantly in
the shorter length category (i.e.  0 to 5 micrometers), mass concentration as
 a  means of expressing levels of asbestos contamination was largely abandoned
in favor of total fiber counts and individual size distributions.  The
rationale was that mass concentration was a potentially misleading indicator
of asbestiform fiber contamination, since a single large fiber present in the
water destined for ingestion could, if broken up into multiple shorter fibers
by sample preparation techniques, be too easily misconstrued as constituting
the presence of a great number of smaller fibers.  Therefore, the work done.
by BATTELLE has not been continued, and the results as reported have not been
used in defining the extent 'of asbestiform fiber contamination of water
supplies in the Western Lake Superior Basin area.
                                    *
     The discussion of analytical results which follows below relies
exclusively on the analytical findings reported to date by MCCRONE
ASSOCIATES, INC. and the UNIVERSITY OF CALIFORNIA SCHOOL OF PUBLIC HEALTH.
Neither lab had knowledge of the type or origin of the samples examined,
each sample having been marked solely with an identification number which
was decoded by EPA on receipt of the contractors' analytical findings.
The results discussed below represent approximately 46 percent of the total
analytical program contracted for, and the principal investigator of each
of the two labs has testified on the results of his findings as a Federal
witness in the litigation ongoing in Federal District Court.

     Owing to the fact that each of the two EPA contractor lab s above is
currently engaged, at the direction of the Federal Court conducting the
Reserve Mining trial, in asbestiform fiber analyses of Court-collected
air and water samples, the timing for completion of analyses for the
original EPA-collected Western Lake Superior Basin area water samples is
uncertain and may well extend into the early part of 1974.  Until these
outstanding results are secured, the coverage is incomplete and will
remain so.

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                                      14
E. RESULTS OF ANALYTICAL EFFORT

   1. FINDINGS

        The analytical results presently in hand address the extent of
   asbestifonn fiber contamination of water samples collected in late June
   and early July of 1973.  Appendix Table 1 sets forth the exact dates and
   locations for the individual water samples.  Analyses were performed by
   electron microscopy by two EPA contractor laboratories, the UNIVERSITY OF
   CALIFORNIA SCHOOL OF PUBLIC HEALTH at Berkeley (UCSPH) and WALTER C.
   MCCRONE ASSOCIATES, INC. of Chicago, Illinois (MCCA).  Only those water
   samples for which analyses were fully completed by both labs are reported
   on here — a completion percentage of roughly 46 percent, as explained
   below.

         The  overall June/July 1973 EPA water sampling program, as pointed
   out previously, included water samples  from more than  30 distinct locations
   in  the Western  Lake  Superior Basin, drawn from various locations in  the
   water source-supply-distribution  chain.  The analytical results thus far
   fully reported  by both contractor labs  yield only the  partial coverage
   summarized below, and  shown in detail in Table B.  10/
       EPA Contractor                     Total Number  of  Water  Samples
    and Water Sample  Category	     Received     Completed  to Date

   Western Lake Superior,excl.  US
    Army ERDLATOR Treatment  Unit:

      UC School of Public Health	     88              45
      McCrone Associates...;	     79              54

   US Army ERDLATOR Treatment  Unit
   Runs (Diatomaceous Earth)	      :

      UC School of Public Health	     11              11
      McCrone Associates	      9               9
        Total Received/Completed	    187             119

        Total number of analyses  completed  for duplicate
        samples taken at the same location  and comprising
        the data base of the findings  and tentative
        conclusions presented in  this  report	   86  for  43 water
                                                                         samples
     107 See Data Appendix Tables I, II, IV, and V

-------
                                   15
     The 86 data points above represent the sum total of analytical
results reported to date by UCSTli and MCCA of asbestitorm fiber levels
and size distributions found in -'i'? water samples, including 8 U.S. Army
ERDLATOR Treatment Unit samples designed to t^st that unit's fiber removal
efficiency when operating on rrv Lake Superior water sampled near EPA's
National Water Quality Laboratory at Duluth.

     The individual water source-supply-distribution areas and points
sampled in the overall June/July 1973 progran are shown in Table B,
together with an accounting of  the status of completion of analyses for
each of 30 major locatiorvs.  While 119 analytical results have been reported
to date, out of a total of 187 samples received, only 86 of the former
relate to sampling points from which duplicate samples were taken and for
which the analytical results have been fully reported by both labs to
date — a net completion status of approximately 46 percent,  ll/

     Table C gives a detailed accounting of the analytical findings,
reported by each of 35 geographical locations, plus 8 U.S. Army ERDLATOR
Treatment Unit samples, for which duplicate samples were examined by
each of the two labs.  The dimensions addressed are numbers of asbestiform
fibers per liter of water and percent distributions of fiber lengths for
three classes;  1) less than 3 micrometers:  2) 3 to 5 micrometers:  and
3) longer than 5 micrometers.  In the absence of agreement by medical
authorities respecting the human health significance of asbestiform fibers
of various lengths when ingested, the grouping of these data into the
three length classes indicated must be viewed as arbitrary, presented
primarily for convenience.  Appendix Tables III and IV comprise, the bflsi<-
data reported by the two labs from which the above groupings were con-
structed, and from which different size groupings may be computed as the
needs arise.

     Where Table C indicates the presence of asbestiform fibers, these have
been identified by the labs as asbestiform fibers of the amphibole family
in the grunerite-cummingtonite series of fibrous minerals of the type found
in various deposits of the Iron Range.  Three samples, all from the Cloquet
area, constitute exceptions; one lab found chryeoti-le asbestos fibers, which
is,a serpentine variety of asbestos used in most asbestos-containing manu-
factured products, such as auto brake linings, asbestos cement water pipes,
etc., but found no amphibole fibers.  The other lab found no asbestos
fibers of any type in the duplicates of these 3 samples.

     Both labs used identical criteria for defining what constitutes a
fiber; this working definition identified as a fiber any particle with a
length to width ratio (aspect ratio) of at least 3 to 1.  Morphology,
electron diffraction patterns, and other techniques were then employed to
provide identification of such fibers as asbestiform fibers of a given
asbestos class.
ll/ Derived from Data Appendix Tables I, III, IV, and V

-------
              Table B — Listing  of  Aumb.-r  and  Typ;;  of Water Samples Received
                         and  Status  of  Completion  of Electron Microscopy Analyses
                         by Both  KPA-Oni.ractor bibs,  by Major Sampling Location.
                 Over-all  Sampling Program
Samples Received nnd  Rosi'i.
Reported by Both i.nhs  f'o
Duplicate Siimplos Taken  fi<
the Samp Locntions  -  to




1
• I
_>.

4.
*~
6!
• .
• > .
j *
H).
f t
1.2.
; ;-5 .
VI.
5.
!6.
' 7.
o!
. 9.
20.
21.

22.
23.
24.
25.
26.
27.
28.
29.
30.








Nuaibftr 5- Type of Sample R<
tt & Type of Sample
Location* Received
(See Legend)
Silver Bay 3-DS/2-EFF/3-IN
Beaver Bay 3-DS/2-EFF/2-IN
Duluth 11-DS/10-EFF/3-IN/2-HYD/
2-WW
Two Harbors 3-DS/2-EFF/2-IN
Ashland , Wis . 2-DS/2-EFF/2-IN/2-HYD
Cloquet 2-DS/5-IN
Superi or , Wi s . 4-DS/2-EFF/2--IN/2-HYD
Write Pine, Mich. 2-DS/2-EFF/2-IN/2-Hyd -
Eagfe Harbor, " 2-DS/2-EFF/2-IN/2-HYD
Grand Harais 2-DS/2-EFF/2-IN/2-HYD
Virginia 2-DS/2-EFF/2-IN
Eveleth 2-DS/2-EFF/2-IN
Aurora 2-DS/2-EFF/2-IN
Hoyt Lakes 2-DS/2-EFF/2-IN
Minneapolis 2-DS/2-EFF/2-IN/2-HYD
Ramsay , Mi ch . 2-DS/2-EFF/2-IN/2-HYD
Hfim. P&L Well 2-WW
Fond du Lac Well 2-WW
F pfra^rwH ^V^irrvl Mw^t O T"\ C
NE Exp. Station 2-DS
Gooseberry
State Park 2-DS
Eckbetk Carpgid . 2-DS
Elde's ComsrSpcig 2-DS
Beaver River 2-RW
Stewart River 2-RW
Baptism River 2-RW
St. Louis River 2-RW
Wild Rice Lake 2-LW
Pike Lake 2-LW
Birch Lake 2-LW
Subtotal - 30 major locations*

56-DS/38-EFF/37-IN/8-RW
6-LW/16-HYD/6-WW
Add ERDLATOR »
Samples: 20
Total for all samples 	

* = Minnesota locations unless otherwise
Leqend: DS ~ Distribution System/EFF =
"l/*G11f«.*t/J / f * f\ '•'•"I Y\ "1 £5 t" O rl *"*" "
.- Ut; .* Vt/U / *-•(* it;t j.G L ^y


Analyses Total
Completed Received

2-DS/J -EFF/2-IN
2-DS/l-FFF/l-IN
8-DS/7-EFF/1-IN -

8
7

2-'Arl'.' ^8
2-DS/l-EFF/l-IN
2-DS/l-EFF
Al % CG1Fi;^r]t(5"tGCl
All completed
2-DS/l-EFF/l-IN
1-DS/l-EFF/l-IN
2-DS/1-EFF/2-IN/1-HYD
1-DS/l-EFF
1-DS/l-EFF/l-IN
All completed
All completed
1-DS/l-EFF/l-IN/l-HYD
—
—
—
—
—

1-DS
1-DS
—
2-RW
2-RW
2-RW
2-RW
2-LW
1-LW
1-LW


36-DS/23-EFF/22-IN/8-
7
8
7
10
8
8
8
6
6
6
6
8
8
2
2
2
2

2
2
2
2
2
2
2
2
2
2


RW/4-LW/4-HYD/2-WW 167

20


shown

20
07
O 1

Effluent/ IN - Influent/ RW


Total
Completed

4
2

16
2
2
6
10
2
0
4
0
0
6
6
0
0
0
0
0
0

0
0
0
2
2
2
2
2
0
0
— , 	

70

16
PA
oo



( Per '.•••'.;
Comp 1 •-; i. '

( 5( )''•_!
( 2C %

( 57^0 ;
( 29?;
( 2%'. •
( IOC1 -',
( 100;;
( 2?"',
( o-...
( 50,;
( 0, j
( 0,'e
( 100'v
( 1 (:> )•;.'.
( o;1,'
( o;:
(' 0°0
( o;'
( 07,
( O/

( O/o
( o;o
( 0%
( loovo
(100%
( lOO/o
( 100%
( 100%
( o;.
( 0;;i


( 42%:

(100%
f .,0,
'iO,.i

= River water
          LW = local lake water/ HYD = Fire hydrant/ WW = well water


JL2/  Derived from Data Appendix Tables I - V.

-------
              Table  B —
          Li si Ing
                                    of ^ui'ibcf Lnd Typo of Water  Samples Received
                            and Status of tk/npletion  of Electron Microscope Analyses
                            by Both EPA-Ci.ri tract or  Labs, by  Major Sampling Location.^/
  Over-all Sampling Progrem

Number & Type of Samp 1 e Re c:ej ved / Co nip1 e t ed
                                                              Satrrples  Received nnd Ro?s I
                                                              Reported hy  Hoih LiUis fo\
                                                              Duplicate Samplos Taken <\
                                                              the  Same Lor.ntions - to *!,•
 Location*

.  Silver Bay
.  Beaver Bay
,  Duluth
  .
)2.
i 3.
!'i.
 5.
16.
"7.
 0.
,9.
20.
21.

22.
23.
24.
25.
26
27.
28.
29
30.
  _
» & Type of Sample
 Received	
           (See Legend!'
3-DS/2-EFF/3-1N
3-DS/2-EFF/2-IN
11-DS/10-EFF/3-IN/2-HYD/
 2-WW
3-DS/2-EFF/2-IN
2-DS/2-EFF/2-IN/2-HYD
2-DS/5-IN
4-DS/2-EFF/2-IN/2-HYD
2-DS/2-EFF/2-IN/2-Hyd  -
2-DS/2-EFF/2-IN/2-HYD
2-DS/2-EFF/2-IN/2-HYD
2-DS/2-EFF/2-IN
2-DS/2-EFF/2-IN
2-DS/2-EFF/2-IN
2-DS/2-EFF/2-IN
2-DS/2-EFF/2-IN/2-HYD
2-DS/2-EFF/2-IN/2-HYD
2-ww
                                              Analyses
  Two Harbors
  Ashland.Wis.
  Cloquet
  Superior.Wis
  Wite Pine, Mich
  Eagfe Harbor, "
  Grand Marais
  Virginia
  Eve let h
  Aurora
  Hoyt Lakes
  Minneapolis
  Ramsay, Mich.
  ftfim. P&L Well
  Fond duLac WeH2-WV
  Laksvocd Sdiod, !«*, 2-DS
  NE Exp. Station  2-DS
  Gooseberry
    State Park  2-DS
  Ecfeedc Carpgid .  2-DS
  Elde's CoOTrSprig 2-DS
  Beaver River  2-RW
  Stewart River 2-RW
  Baptism River 2-RW
  St. Louis River 2-RW
  Wild Rice Lake  2-LW
  Pike Lake     2-LW
  Birch Lake    2-LW

   Subtotal - 30 major locations:    .  . .
                56-DS/38-EFF/37-IN/8-RW
                6-LW/16-HYD/6-WW
   Add ERDLATOR   t
    Samples:    20
                   Total
                  Received
                                                                          Total
                                                                         Completed
2-DS/1-EFF/2-IN
2-DS/l-EFF/l-IN
0-DS/7-EFF/1-IN  -
 2-IW
2-DS/l-EFF/l-IN
2-DS/l-EFF
 All completed
 All completed
2-DS/l-EFF/l-IN
1-DS/l-EFF/l-IN
2-DS/1-EFF/2-IN/1-
1-DS/l-EFF
1-DS/l-EFF/l-IN
 All completed
 All completed
1-DS/l-EFF/l-IN/l-
                            1-DS
                            1-DS

                            2-RW
                            2-RW
                            2-RW
                            2-RW
                            2-LW
                            1-LW
                            1-LW
8
7
28
7
8
7
10
8
8
HYD 8
6
6
6
6
HYD 8
8
2
2
2
2
2
2
2
2
2
2
2
2
2
2
4
2
16
2
2
£
10
2
0
4
0
0
6
6
0
0
0
0
0
0
0
0
0
2
2
2
2
2
0
0
                            36-DS/23-EFF/22-IN/8-
                            RW/4-LW/4-HYD/2-WW  167
                            20
                                                                   20
        Total for all  samples	  187
                              70

                              16
                                                          86
                                                                                      ( 29%
                                                                                      ( 25"<
                                                                                     ( 10r;;<
                                                                                     ( 100;.'-
                                                                                       (  ov,
                                                                                       ( soy:
                                         ( o;:
                                         (• o%
                                         ( o'-
                                         ( o:-.'
                                        (100%
                                        (100?o
                                        (100%
                                        (100%
                                         ( o?,
                                         ( 0"o
 * = Minnesota locations  unless  otherwise shown
 Legend:  DS ~ Distribution  System/EFF ~ Effluent/ IN ~ Influent/ RW = River  water
          LW = local  lake water/ HYD = Fire hydrant/ WW = well water
 121  Derived  from Data Appendix Tables I - V.

-------
                                      17
        As Table C reveals, both labs were in agreement in 36 out of the
   43 water samples respecting the presence or absence of asbestiform fibers;
   that is, both found a definite presence of such fibers in 19 of the samples
   of which they had examined duplicates, and a definite absence of such fibers
   in 17 samples.  Three of the 7 samples for which one lab found a presence of
   asbestiform fibers, whereas the other lab found none, involved the Cloquet
   area samples which contained chrysotile asbestos fibers; the remaining 4
   samples were found by one lab to contain amphibole asbestos fibers. __

Table C —r Asbestiform Fibers and Fiber Si7,e Distributions Found in
           Duplicate Samples via Electron Microscopy Analysis performed
           by University of California School of Public Health and
                McCrone Associates, Inc., of Chicago, 111. 137

                        Number of Fibers
Type
Location* Sample
1. Silver Bay
2. Beaver Bay
3.Duluth
4. "
5. "
6. "
7. Two Harbors
* 5. Silver Bay
9.SuDerior , Wi s.
lO.Jeiio's *1 (Duluth)
11. " #2
12. " »3
13. Superior, Wis.
14. Cloquet
15. "
16. "
17. Superior, Wis.
IP,. White Pine, Mich.
19. Grand Mara is
20. Aurora
21.Hallett Well.Dulrth
22. Ashland, Wis.
23. Superior, Wis.
24. "
25. Grand Mara is
26. Aurora
27. "
20.Hoyt Lakes
29. "
••>/-* M ii
•jl) .
31 .Beaver River
32. Stewart River
33. Baptism River
34. St. Louis River
35. Wild Rice Lake
DS
DS
DS1
DS2
DS3
DS4
DS
IN
DS
EFF
EFF
EFF
EFF
IN
DS
IN
DS
DS
DS
IN
WW
DS
IN
HYD
IN
EFF
DS
IN
EFF
DS
RW
RW
RW
RW
LW •
MCCA
                        UCSPH
                        (Millions of Fibers
                          per 1 iter water)
2.0
3.0
5.0
2.0
1.0
1.0
2.0
.5
.3
.7
1.0
.1
.7
BLACL**
II
It
tt
ft
It
tt
Ii
4.37
5.29
2.76
6.03
2.26
1.47
2.53
1.47
1.10
3.87
.67
.71
.37
.39***
9Q#$$
.98***
.39
.18
.25
.26
BLACL**
                           II
                           II
Fiber Length -
Percent
UCSPH
<3
o/
/o
50.
35.
64.
44.
45.
3-5 >5
(Micrometer


7
8
9
1
8
60.0
32.
76.
71.
68.
56.
56.
34.
-
-
-
-
-
-
-
5
0
4
4
9
1
2







o/
/O
43.
38.
29.
39.
39.
30.
36.
16.
14.
28.
29.
41.
52.
-
-
-
-
-
-
-


7
9
8
0
6
0
4
0
3
9
4
5
6







o/
/O
5.
22.
5.
16.
14.
10.
31.
8.
14.
2.
13.
2.
13.
-
-
-
-
-
-
-
Dis
tri bul i
MCCA
<3 3-5
size classes


6
5
3
9
6
0
1
0
3
7
7
4
2







«/
/O
96.
97.
100.
98.
83.
100.
87.
92.
95.
100.
100.
100.
100.
86.
100.
100.
100.
100.
90.
100.


8
4
C
5
7
0
3
9
2
0
0
0
0
6
0
0
0
0
9
0


3.
o
fca »
—
1.
10.
_
9.
7.
4.
_
_
—
-
6.
—
_
_
_
9.
_
>5
o/

2
6
_
5
2 6.]
_
1 3.(
i
8
_
_
_
_
7 6.'
_
_
_
_
1
_
                            Continued next  page with  US  Army  ERDLATOR results)

-------
     Table C — Continued
                                         18
                              Number of Fibers    Fiber Length - Percent Distribution
US ARMY ERDLATOR RESULTS
                              UCSPH
MCCA
UCSPH
MCCA

1.
li.
3.
4.
v •
6.
7.
B.

Run »8
Run #9
Run #9
Run »7
Run #7
Run #9
Run #3
Run ^8

IN
EFF
IN
EFF
EFF
EFF
EFF
EFF
( Mi 1 1 i on s
.3
.2
.8
.3
.1
.3
BLACL**
BLACL**
per Liter)
2.04
6.05
8.24
.39
.99
.46
BLACL**
BLACL**
3
50.
100.
54.
83.
100.
100.
-
-
3-5
0
0
8
3
0
0


25.
-
2.
15.
-
-
-
-
0

3
0




5
25.0
-
2.3
1.7
-
. -
-
-
3
96.2
100.0
95.3
100.0
100.0
100.0
—
-
3-5 :
3.8 -
-
2.8 1.9

_
_ , _
— _
_
  *  Minnesota  location  unless  otherwise indicated
 **  BLACL means "Below lowest acceptable counting limit"; this is a variable encounter,' i
     from sample to sample, is dependent on other suspended particulates content of speci
     fie samples,  and may comprise anywhere from "more than zero" to "less than 50,000"
     fibers.
***" Chrysotile asbestos fibers were found in these  samples;  no amphibole fibers.

  13/  Derived from Data Appendix Tables  I,  III, IV, and V

-------
                                 19
    Communities in whose water supplies asbestiform fibers were
fcnirid to be present by both labs include Silver Bay, Beaver Bay,
Duluth, Two Harbors, -- all in Minnesota, cs well as Superior,
Wisconsin.  Asbestiform fibar counts ranged from a high of 8.24
million fibers per liter for raw Lake Superior water, sampled near
the'EPA National Water Quality Laboratory at Duluth and used in one
of the U.S. Army ERDLATOR Treatment Unit tests, to a low of .1
million fibers per liter for the effluent from Jeno's Diatomaceous
Filber #3, also at Duluth,

    Communities where one lab found asbestiform fibers to be present,
whereas the other lab found none, include White Pine, Michigan,
Grand Marais and Aurora, Minnesota, and Cloquet.  Chrysotile, rather
than aiaphibole asbestos fibers were found in the Cloquet samples, as
previously discussed.

    Sampling points for which both labs determined an absence of
asbestiform fibers include the Hallett Well at Duluth; Ashland,
Wisconsin; Superior, Wisconsin; Grand Marais, Aurora, Hoyt Lakes,
Beaver River, Stewart River, Baptism River, St. Louis River, and
Wild Rice Lake in Minnesota.

    It should be noted that several communities are listed in more
than one of the categories identified above, and caution should be
exercised in translating these largsly incomplete findings into a
basis for remedial action.  A quick reference to Table B will estab-
lish that complete analytical results, as reported by both labs for
duplicate samples which they both examined, are presently in hand
for only 9 of the 30 major locations sampled.  These include Cloquet,
Hoyt Lakes, Aurora, the 4 Minnesota river locations, Wild Rice Lake,
and Superior, Wisconsin.  For 6 of these 9 locations, no asbestiform
fibers were found by either lab.  For Aurora, Superior and Cloquet,
however, the situation is different.

    The Aurora water plant intake was found to contain asbestiform
fibers by one lab; the other lab saw none.  The Aurora water plant
effluent and distribution system, however, as sampled at the water
plant outside tap and the City Hall utility room tap, respectively,
were found to contain no asbestiforra fibers by both labs.  It would
appear desirable to subject the Aurora supply to re-sampling and
re-analysis at an early date.

    For the City of Superior, Wisconsin, the presence of asbestiforra
fibers was reported by both labs for the water plant effluent (tap
in laboratory sink) and for the Superior Power and Light Company's
Underbill Service Center at 2915 Hill Avenue (tap in the meter shop).
One lab found asbestiform fibers in the water tap outside the Superior
Power and Light Company water treatment plant (Lake Superior water
from the Cloquet Pipeline); the other lab found no fibers in that
sample.  Neither lab found asbestiform fibers in the intake water
(well water) for the Superior Power and Light Company water plant

-------
                                 20
(tap in laboratory sink) or the, fire hydrant (well water) near the
Company's Underbill Service Center (hydrant near building at 2900 Hill
Avenue).

    For 3 samples taken at Cloqutst, the lab found chrysotile asbastoa
fibers; the other lab found no asbestiform fibers.  The locations
examined included a raw well water intake tap inside the pumphouse
building, influent water from Lake Superior off the Cloquet Pipeline
in the Northwest Paper Company Plant, and a tap at the fire station
at Cloquet Avenue and 5th Street.

    The City of Cloquet recently converted to use of water from a
30 million gallons per day pipeline carrying water from Lake Superior 14/
but apparently has retained a flexibility to use well water previously
constituting the sole supply in conjunction with Cloquet Pipeline
water.  The shource of the chrysotile asbestos contamination is
presently unknown.  A review of construction contract specifications
for the Cloquet Water Line 15/ shows that the piping used was steel,
rather than asbestos-cement pipe of the type likely to contain
chrysotile asbestos.  Detailed contract specifications did call for
coating all subaqueous steel pip©  "..with coal tar enamel, fibrous
glass mat, bonded asbestos felt wrap coating per AWWA C-203,
Section AL.4,  'Steel Pipe Exterior Protection for Submarine Lines'...."
Further, the interior and exterior surface of the inlet structure
"....shall be cleaned, priir.ed and  coated with coal tar enamel and the
exterior shall be wrapped with bonded double asbestos felt wrappers...."
Pending a thorough on-scene search for the origin of the chrysotile
contamination, it would appear desirable to resample Cloquet Pipeline
and Cioquet well supplies at an early date.

    The probable presence of asbestiform fibers at Grand Marais and at
White Pine, Michigan, is indicated by the findings of one lab; the
other lab saw no fibers in the samples it examined.  Although neither
lab found asbastiform fibers in the intake water of the Grand Marais
Water Plant (tap off spigot on intake pump), one lab found such fibers
in the Grand Marais Municipal Building Fire Station (tap in the fire
truck bay).  Only 50 percent of the Grand Marais results are presently
in hand.

    For White Pine, Michigan, only 25 percent of the analytical results
are presently available.  One lab found asbestiform fibers in water
sampled at the boiler room tap of  the Townsite central heating plant;
the other lab saw no asbestiform fibers in the duplicate sample it
examined.
14/ June 28, 1973, "Report on the Duluth Water* Situation" to
    Gov. Anderson, by the Minnesota Department of Natural Resources

IS/ "Specifications for Cloquet Water Line, Cloquet, Minnesota"
    Ruble Miller Associates, .Inc., Duluth, Minnesota; "Conformed
    Contract" (undated) Set #32

-------
                                21
    Caution is again advised in viewing theso findings an definitive
for locations where results, as reported by both laba, ars not in hand
and remain to be evaluated.

    Respecting the essentially arbitrary grouping of asbcsntif orrn fibers
into the length classes discussed previously, the following findings
obtain for samples of which duplicates were examined by both EPA
contractor labs.  As evident from Table C, one lab found asbestiform
fibers longer than 5 micrometers in 16 of the 19 samples found to
contain fibers, whereas the other lab found fibers of that length
class in only 4 of the 26 samples which it determined to contain fibsrs
of any length.  For the 3 to 5 micrometer length group, the former
lab found fibers of that length in 16 of the 19 samples, contrasted
with 11 out of 26 samples for the latter lab.  Asbestiforra fibers
shorter than 3 micrometers were present in all samples found to
contain fibers of any length by either lab.

    No evidence is now in hand which could serve to explain or
reconcile the apparent divergence of findings respecting the lengths of
fibers found by the two labs.  Pending the receipt of additional results
which would form a basis sufficient for thorough evaluation, it appears
unwarranted to attribute the divergence to inter-lab differences in
sample preparation and transfer techniques since both labs employ
procedures which aim to prevent the breaking up of fibers present
in the samples to the maximum possible extent.  On the basis of the
findings presented in Table C, it is possible to generalize that the
asbestiform fibers found to be present in the samples examined to date
by both labs are predominantly of a length shorter than 5 raicronetars.

    Pending the development of precise location-by-location data, the
overall number of people exposed to drinking water supplies determined
thus far to contain asbestiform fibers remains unknown.  An upper
limit can be established by positing a "worst case" assumption to the
end that the entire population of the communities whose supplies
were found to contain asbestiform fibers to date was being served at
the time of sampling by those same supplies.  Local water supply
authorities thoroughly familiar with the layouts and peculiarities
of their individual systems will alone be able to determine how many
people were served with the supplies present in the systems at the
locations and dates of sampling.  A tabulation giving the 1970 Census
populations for the communities in whose supplies asbestiform fibers
were found to be present to date follows below; it would constitute
the "worst case" upper limit of exposure addressed above.

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                                  22
                                           1970  Population
          Community	           (UP.Iessr  othery;ise  shQnr,)_ _16/

         Silver Bay, Minn.                  3,504
         Beaver Bay, Minn.                    905
         Duluth, Minn.                     98,400 *
         Two Harbors, Minn.                 4,437
         Cloquet, Minn.                     8,699
         Grand Marais, Minn.                1,301
         Aurora, Minn.                      2,531
           Total Minnesota	119,777

         White Pine, Michigan               1,218
         Superior, Wisconsin               32,237

           Total above communities	    153,232
            * 1970 population was 100,578, but  Minn.  Dept.  of Natural
              Resources estimates that 98,400 persons are  served  through
              the Lakewood Pumping Station  IT/


16/ US Census of Population, 1970; General Population Characteristics -
     Minnesota, US Dept. of Commerce, Bureau of the Census
JT7/ June 28, 1973 "Report on the Duluth Water Situation" to  Gov. Anderson,
     by the Minnesota Department of Natural Resources

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                                23
2.  TENTATIVE CONCLUSIONS

    Although analytical results presently in hand represent approxi-
mately 46 percent of the data bose at this point in time, it is
reasonable, nevertheless,, to advance some tentative conclusions
respecting levels of water contamination by asbestiform fibers in
the Western Lake Superior Basin area.

    1) Results reported for 43 duplicate water samples analysed via
       electron nicroscopy by two indapendent EPA-contractor lab-
       oratories show a definite presence of asbestiform fibers
       in 19 samples (44%), a probable presence in 7 samples (16%),
       and a definite absence in the remaining 17 samples (40%).  IB/

    2) The definitional framework relied upon in framing these
       tentative conclusions is as follows:

       a) All conclusions related to the presence or absence of
          asbestiform fibers refer to water sampled in late June -
          early July of 1973, and therefore reflect levels of
          contamination then prevailing.

       b) A "definite" presence of asbestiform fibers is assumed
          where both EPA-contractor labs reported finding asbesti-
          form fibers greater than the "Lowest Acceptable Counting
          Limit" for any duplicate sajsplfea which they both examined.
          See c) below.

       c) A "definite" absence of asbestiform fibers is assumed
          where both EPA-contractor labs reported finding no
          asbestiform fibers for any duplicate samples which they
          both examined; this is identified as "BLACL", meaning
          "Below Lowest Acceptable Counting Limit" - a variable
          encountered from sample to sample which is dependent on
          other suspended particulates content of specific samples,
          and may comprise anywhere from "more than zero" to "less
          than 50,000 fibers".

       d) A "probable" presence of asbestiform fibers is assumed
          where one EPA-contractor lab reported finding no asbesti-
          form fiber (BLACL), whereas the other reported levels
          above "BLACL".  This divergence is encountered in a total
          of 7 samples out of the 43 duplicate samples examined by
          both labs; its significance is discussed later.

    3) The asbestiform fibers found by both EPA-contractor labs for all
       but three duplicate samples were identified as amphibole asbestos
       fibers in the 'grunerite-cummingtonite" series of fibrous


_18/ Derived from Data Appendix Tables III - V

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                     minerals of the type found  in  various deposits in the "Iron
                     Range".   (In three samples, all  frova the Cloquet area, one
                     EPA-contractor lab found chryaotile asbestos fibers, a
                     serpentine variety of asbestos used in most asbestos-
                     containing manufactured products,  such as auto brake linings,
                     asbestos cement water pipes, etc.;  the other lab found no
                     asbestos fibers (BLACL) in  tho same three samples.)

                   4) Pending agreement by medical authorities respecting the
                     significance to human health of  ingesting asbestos fibers and
                     respecting the significance and  plaxisibility of a quantitative
                     determination of an "acceptable" level of asbestiform fiber
                     content of water supplies,  prudence dictates that an absence •
                     of such fibers is clearly preferable to their presence.

                   5) Using this prudent approach makes sense, particularly in the
                     absence of scientific studies  showing that asbestiform fiber
                      ingestion is beneficial to  human health, and thus forms  the
                     basis for arranging the analytical results for various
                      localities in a fashion ranging  from "Contaminated" to
                      "Not Contaminated".  Such a ranking follows below, without
                      intermediate ranking reflecting  degrees of severity, for all
                      samples for which fiber counts were reported by both labs to
                     date.  19/
                     Contaminated — Definite Presence  of Asbestos Fibers
                     1. Duluth  Area
                          211      *t
                      «       i
3
                          511      ii
                      •        i
                     6.    "   ,   "
                     7.    "   ,   "
                     8.    "   ,   "
                     g    ti      ii
                    10 *.    "   i   "
                    11.    "   ,   "
                    12.    "   ,   "
                    13.    "   ,   "
                    14.  Silver Bay
                    15.
                    16. Beaver Bay
                    17. Two Harbors
                    18. Super!or,Wis,

                    19.   "     ,  "
— Arlington Water Pumping Station; tap off west pump
— Fire  Station at 3501  Woodlawn Ave.; tap in  fire
    trvrck bay
— Duluth Airport; custodian closet tap,  main  floor
— Duluth Pump. Station,  4424 Grand Ave.;north pump tap
— Jeno's Diatomaceous Filter #1
__  "         "         "    #2
—  "         "         "    «3
— Duluth  Raw Lake  Water,before ERDLATOR Run #8
—  "     "   "      "    , before  "     Run *9
-	, after   "     Run *9
—  "     "   "      "    , after   "     Run #7
-	      "    , after   "     Run #7
—  "     "   "      "    , after   "     Run »9
— Standard Gas Station,  corner of Highway 6;  and
    Outer Drive; outside tap eastside of building
— Pump  House influent;  tap off incoming line
— Jim's Shell Station,Hwy.61; car bay tap
— Fire  Station sink tap,  7th St. and 2d Ave.
— Underbill Service Center, 2915 Hill Ave.,  tap in
    meter shop,Superior  Power & Light Co.
— Water Plant effluent;  tap in laboratory sink
               JL9/ Derived from Data Appendix Tables I, III, IV and V

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                                25
b) Probably Con tarn j natcd --Probable  pre s e ?: c e  of  A she s t i rorm_FU)e r
   2. White Pine, MJdu
   3. Grand Marais,
       Minn.
   4. Aurora,Minn.
  *5. Cloquet,Minn.
 1.  Superior,Wis. -- Lake Superior water tsp outside water treatment, plant
                      Superior Power & Light Co. (from Cloquet Pipeline)
                     Town site heating plant; boiler room tap
                     Municipal ouilding or.ci fire station tap in
                      fire truck bay
                     Water Plant intake
                     Raw well water; intake tap inside building  in  pumphoup
*6.    "    ,   "   — Influent - Northwest Paper Co. Lake Superior influent
                    .  tap in plant off pipeline
*7.    "    ,   "   -- Well water - fire station Cloquet Ave. and  5th St.
                      (sometimes uses Lake Superior water from pipeline)

    * Fibers found in these samples were chrysotile, not amphibole,
       raising the possibility that contamination occurs via an  asbestos-
       containing manufactured product, such as asbestos-cement  pipe,  or
       from some other source.
c) Not Contaminated — Definite Absence of Asbestiform Fibers
   1. Duluth Area
   2.
        3TI      tl
    .
   4. Ashland,Wis.  -
   5. Superior,Wis. -

6         «      ii
    .

   7. Grand  Marais
   8. Aurora       ' -
   9.   "
  10. Hoyt Lakes
  11.   "
  12.
  13. Beaver River  -
  14. Stewart River -
  15. Baptism River -
  16. St. Louis River •
  17. Wild Rice Lake
                     Hallett  Well (Jeno's) 59th Ave.W.  Tap off pump.
                     Duluth  Raw  Lake Water,  after ERDLATOR Run #8
                                         "  ,  after ERDLATOR Run «8
                     Water utility office; tap in basement at 320 E.2d St.
                     Superior Power & Light Co. well;intake for water
                      plant;  tap in laboratory sink.
                     Superior Power & Light Co. (well); fire hydrant,under-
                      hill service center near building 2900 Hill Ave.
                     Water Plant Intake;  tap off spigot on intake pump
                     Water Plant effluent; outside tap
                     City Hall;  utility room tap
                     Water Plant; intake tap in main building
                     Water Plant;effluent tap after pump,main building basement
                     Police Department; garage tap
                     Stream sample off Highway 61 near Beaver Bay
                     Hwy, 2,  N.  of Two Harbors,downstream side of bridge
                     Eckbeck  State Park near Finland,Minn.
                     Hwy. 2 bridge, 200 yards downstream of bridge
                     Dam Rd.  off Minn. Route #4; sampled at the dam

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                             26


6) Until medical authorities develop a consensus respecting
   "harmful" versus "acceptable" .lovels of asbestiform fibers
   in water, it makes little sense to attempt to rank analytical
   results for the various localities by "intermediate" degrees
   of severity of contamination by contrasting, say, 3 million
   fibers per liter versus 1 million fibers per liter.  Whatever
   degree of precision would obtain from such an attempt would
   be partially obliterated by the lack of precision inherent
   in electron microscopy techniques employed to determine
   numbers and sizes of asbestiform fibers in water.

7) Because we find ourselves at the "frontier" of the state-
   of-the-art in this respect, differences in water sample
   preparation techniques, differences in analytical procedures,
   and, indeed, differences in operator experience and expertise
   — all speak against attempting to impart precision beyond
   that which is deserved.  The only certainty which obtains
   at this point in time is the certainty of the electron micro-
   scopist who sees an asbestiform fiber under his microscope
   and identifies it as such beyond the shadow of a doubt, using
   his equipment to its full capability, and drawing on his
   knowledge and prior experience with full confidence.

8) Thus, while for 7 of the 43 samples reported on here, no fibers
   were found by one EPA contractor, the fact that the other lab
   did see and identify asbestiform fibers cannot be dismissed or
   taken lightly.  Although these 7 sample results thus lack the
   corroborative validity present in the case of the other 35
   samples, the presumption should be that asbestiform fibers
   were indeed present in the water at the time the samples were
   taken.  The communities involved should have early priority
   in any future re-sampling effort, particularly also since
   chrysotile asbestos fibers were found at three locations,
   suggesting that contamination may come from asbestos-cement
   water conveyance pipe or some other yet unknown source.

9) No medical consensus presently exists respecting critical
   lengths or widths of asbestiform fibers for production of
   disease; an Occupational Health and Safety Administration
   emergency standard for occupational exposure of asbestos
   industry workers addresses inhalation limits only, and
   prescribes maximum allowable exposures couched in terms of
   asbestiform fibers longer than 5 micrometers.  As now on
   th© books -- aside from specified peak short-period exposure
   limits — the OSHA emergency standard for asbestos fiber
   inhalation limits exposure to no more than 5 fibers per cubic
   centimeter of air inhaled over 8 hours in a 5-day week,
   effective July 7, 1973, and no more than 2 fibers per cubic
   centimeter of air, effective July 1, 1976.

-------
                              27
10) In the absence of medical studies establishing that the
    5 micrometer fibor length, is critical in terms of inoestod
    asbestiforra fibers, there is no baais for assuming that any
    particular fiber length >
-------
            CHAPTER II
 PRELIMINARY ANALYSIS OF DATA ON
ASBESTIFORM FIBERS IN THE AIR FROM
    SILVER BAY, MINNESOTA

-------
                            CHAPTER II
                          TABLE OF CONTENTS
                                                                    Page
A.   Introduction                                                     28

B.   Sources of Data                                                  2«

C.   Data from the EPA Membrane Filter Network                        32

D.   Data from the EPA Scrap ling Effort in Minnesota                   ,2

E.   Comparison of Silver Bay Downwind Data to Other Downwind-of-     3-
     Source Location Data

F.   Comparison of Silver Bay Background Data to Urban Concentrations  40

G.   Comparison of Silver Bay Background Data to Non-Urban and
     Remote Data                                                      4 2

H.   Conclusion on the Silver Bay Amphibole Concentrations            42

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                              CHAPTER II
                       ANALYSIS OF ASBESTOS DATA
A. Introduction

   Chrysotile asbestos concentrations in air have been measured at a
number of locations in the United States during the past four years.
In order to place the Duluth/Silver Bay amphibole asbestos data in
perspective, the following section consists of a comparative analysis
of the ambient concentrations of asbestos in the Silver Bay
area with chrysotile asbestos concentrations measured in other places
in the United States.  Whereas the amphibole asbestos concentrations
in Silver Bay are likely to be the residuals from the minerals processed
in the area, it should be noted that the chrysotile asbestos concentrations
measured in other U. S. locations may be emitted either by point
sources  (asbestos mines, fabricating facilities, processing facilities
and the like) or by other, more diverse, human activities such as
auto braking, asbestos spraying, and building demolitions.

   The conclusions presented here should be used with great
caution.  A comparative analysis such as this one should compare
similar pollutants for different locations.  This is not possible in
this case because of the limited data on both amphiboles and chrysotile
which are available.  Electron microscope analytical techniques have not
been used previously to measure asbestiform amphibole concentrations in
the ambient air.  As a consequence, data on ambient air concentrations of
the asbestiform amphiboles have not been collected.

   The analysis which follows assumes that the two forms of
asbestos — chrysotile and amphibole — are comparable.
The significance of this assumption is not known with regard to
the objectives of the analysis which is to compare the mass
concentrations of amphibole asbestos in the atmosphere of Silver
Bay to chrysotile concentrations in other parts of the country.

   This analysis does not attempt to relate potential health
risks to mass concentrations in air.  Current research findings do
not provide answers to the question:  Are there different health
responses when humans are exposed to giv-2n mass concentrations of
chrysotile and amphibole asbestos?  The assumption that the two
asbestos groups are similar permits the undertaking of such a
comparative analysis.  However, it is important to recognize that
there are differences in fiber shape, density, chemistry, size, and
aerodynamic properties between the two forms.

B. Sources of Data

   The data used in the comparative analysis have been taken from

-------
                                    29
published and unpublished studies that have been conducted over the
last four years by:

        Battelle Memorial Institute,
        Mount Sinai  School of Medicine,
        U. S. Environmental Protection Agency, and
        State of California Air anci Industrial Hygiene Laboratory
(References are provided at the end of this section.)

   Most chrysotile measurements to date have been collected by the EPA
National Membrane Filter Network.  The Network is located in 55 cities
across the country.   A map shown in Figure 1 indicates the cities in
which the samplers are operated.  The Network, which has been operating
since 1969, has been used to monitor chrysotile asbestos concentrations
in urban areas.  The sampling sites are located in downtown areas where
the traffic and population density is substantial.  The sites are generally
located on roofs of post offices, fire houses, or other public
facilities.  Composite samples /i are analyzed quarterly.  The membrane
filters were analyzed by the Mt. Sinai School of Medicine from the second
quarter of 1969 through the fourth quarter of 1970.  Since that time,
Battelle Memorial Institute has analyzed the samples.

   Other data that are used in the comparative analysis have been taken
from various studies.  Air sampling for asbestos was conducted by
Bathe!le near sources of asbestos emissions and in urban and rural areas
at the time the electron microscopy analytical procedure was developed.

   The work performed by Mt. Sinai generally examined alleged asbestos
problem areas in New York City such as at construction sites where asbestos
is sprayed, street corners where fibers are released by auto braking, and
the like.  The EPA data for Ambler, Pennsylvania, were developed during
a field investigation of a potentially hazardous source of asbestos.
Finally, the State of California has conducted air sampling near asbestos
mills and in urban locations while developing analytical methods for
asbestos.
/!_     A composite sample for an urban sampling station is prepared in
       the following manner:  (1) a 24-hour sample is taken every twelfth
       day during a calendar quarter; (2) some scheduled sampling days are
       missed because of other priorities, hence there are not always 7
       or 8 sampling periods per calendar quarter; (3) the 5 to 8 membrane
       filters collected in a quarter are cut into pie-shaped wedges of
       1/5 or 1/8 and pieced together to form.a full-sized filter;  (4) the
       composite filter is then analyzed by the electron microscope
       analytical procedure.

-------
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                                    30
   A summary of asbestos concentrations for selected locations is
presented in Figure 2/i, to show r.he range of values-that have baen
observed.  Notice that material in Figurs 2 ia plotted on seven cycle semi-
log paper.  In aorno instances, raw data points h&vo been indicated.  In
other instances, where only a ra?ig« of concentrations was presented in
the literature, this range has b?en indicated.  Further, in some cases
where the number of analyzed samples is large, a range has been indicated
for the sake of clarity.

   The data in Figure 2 have been grouped into three categories which
are based on sampling site location.  The categories are:

   1.   Downwind-of-source locations,

   2.   Urban locations, and

   3.   Non-urban/remote locations.

This classification permits the grouping of data collected under similar
conditions and, hopefully, minimises the likelihood of comparing data that
are dissimilar.

   Caution should be taken before making comparisons between the
"downwind-of-source" data and the data found  in urban and non-urban
locations.  There are two significant reasons why the downwind-of-source
data arc unlike the other data.

   First, short-term samples at sites similar to site #3 detailed in Silver
Bay (see Section II 2 for a description of the sampling site and results
for Silver Bay) which is 700 feet from an emission source yield concentrations
which are far from representative of the long-term average concentrations at
such location because wind directional data indicate that the location is
an upwind site a majority of the time.  The data from site #3 represent
measurements which were taken to indicate the absence or presence of amphibole
asbestos near the Reserve Mining Facility.  Accordingly, the samples were
taken under atmospheric conditions that would yield high amphibole
concentrations.  Long-term measurements at the same location would yield
average results significantly lower than the  short-term peak concentration.
This relationship is true for all of the downwind-of-source data.  The
EPA National Membrane Filter Network, on the  other hand, measures
chrysotile concentrations at equal intervals  over extended periods of time.
Atmospheric conditions vary from one sampling period to another.  As a
consequence, the "urban mean chrysotile concentration"  (see Figure 2),
which is the mean of a number of long-term  (i.e, quarterly) ambient
measurements for 55 cities, is not directly comparable to the short-term
Silver Bay results.
       The data plotted in Figure 2 have been taken from the references
       that are listed at the 'end of this chapter.

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                                    31
   Secondly, samples taken at sites immediately downwind of emission
point sources measure the plurae before significant atmospheric diffusion
and dispersion dilute the pollutant.  A sampling site further downwind of
an emission source will generally measure concentrations that are lower
than those at a nearby site.  Concentrations are generally plotted as a
function of distance from a point source as isopleths which are shown in
Figure 3.

   As a result, the concentrations measured at site #3 at Silver Bay
are not representative of the concentration expected in the residential
area of Silver Bay.  On the other hand, the measurements obtained from
the EPA National Membrane Filter Network were taken at locations in
populated urban areas.  Thus, the data are not comparable directly.

   Contrary to the downwind-of-source relationship between short-term
and long-term measurements, short-term concentrations for most urban and
non-urban/remote locations are generally representative of the long-term
concentrations at a given site.  This is primarily because of the lack of
a major sole source of the pollutant.  Thus, for such areas the expected
difference between short-term measurements and the long-term mean
diminishes since the statistical variation is smaller.

     The laboratory techniques used in the past studies have not been
verified completely by EPA for reproducibility or accuracy.  Past data
were used on the assumption that the accuracy and reproducibility of the
techniques were similar to that of the techniques used to measure
amnhibole concentrations.  Certain evaluations of laboratories were
conducted.  For example, a detailed review of the State of California
Air and Industrial Hygiene Laboratory techniques and work revealed
problems that would place past data in question.

     Further, recent analyses of identical arnphibole air samples by
Battelle and Mt. Sinai yielded the results in Table 1 A.

TABLE 1 A:  COMPARISON OF BATTELLE AND MT. SINAI REUSLTS FOR IDENTICAL FILTERS

Filter          Amphibole Mass Concentrations (ng/nP)      (Mt. Sinai Result)
Number          Battelle          Mt. Sinai                (Battelle Result)
A-84               100               *
A-85                62              20                           0.3
A-97               570            3700                           6.5
A-98               950             600                           0.6
*  No amphibole fibers detected.

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                                    32
     Such variations have not been fully explained.  The comparative
analysis which follows relies only on analytical results from Battelle
for samples taken in the four Minnesota communities since Mt. Sinai did
not analyze samples other than the four shown above.

^•  Data from the EPA Membrane Filter Network
   An analysis of the results from the EPA National Membrane Filter
Network is presented because, although the data are not for amphibole asbestos,
they allow at least some comparison with levels of the more common
variety of asbestos and give some perspective as to relative concentrations
of asbestos, in so far as present data permit.  The Network has yielded
a substantial quantity of data for a number of the populated areas of
the United States.

   The distribution of chrysotile concentrations for the period starting
in 1969 and ending with the first quarter of 1972 is presented in
Table 1,  Frequency distribution plots are shown in Figures 3 through
5.   Note on Figures 3, 4, and 5 that the data are skewed significantly  in
the direction of the lower values.  Although the simple arithmetic mean
concentrations for all cities during the 1969-1972 time period is 3.2
nanograms/m3 (io~9 g/m  Or ng/m3), the median value is 1.6 ng/m3.  This relation
ship indicates that the mean is significantly affected by some high values.
However, only 14, or four percent, of the 314 samples are greater than 10

   The mean values for 187 samples analyzed by Mt. Sinai and the 127
samples analyzed by Battcllc are very similar:

   Arithmetic Mean (Mt. Sinai) = 3.3 ng/m3,

,  Arithmetic Mean (Battelle)  =3.2 ng/m3'

a difference of approximately 3 percent.  The small difference in these
results from Battelle and Mt. Sinai for chrysotile asbestos concentrations
can be contracted to recent analyses of identical amphibole ambient air
samples by the two laboratories which have yielded mass concentrations
by nearly an order of magnitude.

   High chrysotile concentrations  (i.e., values greater than 10 ng/m3)
obtained by the Network were evaluated to determine if one or two urban
areas consistently experienced high concentrations.  It was concluded
that no one urban area had high readings consistently.  As Table 2
indicates, only 2 urban areas had more than one reading which exceeded
10 ng/m3 for the 1969 - 1972 period.  Tables 3 and 4 show a ranking of
the 15 urban areas with the highest average concentration as measured
by Battelle and Mt. Sinai.

D. Data from the EPA Sampling Effort in Minnesota

   EPA conducted an ambient air  sampling program for asbestiform
amphibole concentrations in Babbitt, Hoyt Lake, Duluth, and Silver Bay,
Minnesota during June 1973.  Membrane samplers, identical to those used

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                                        33

                                  TABLE 1
Distribution of Chrysor.ile Concentration in the Ambient Air of United  States
                                     Urban Areas

Chrysotile
Concentrations
(ng/m3)

0 - .99
1.0-1.99
2.0-2.99
3.0-3.99
4.0-4.99
5.0-5.99
6.0-6.99
7.0-7.99
8.0-8.99
9.0-9.99
10.0-10.99
11. 0-11. 99
12. 0-12. 99
L3. 0-13. 99
L4. 0-14. 99
16.0-16.99
18.0-18.99
34.0-34.99
38.0-38.99
40.0-40.99
95.0-95.99
TOTALS
Samples
Analyzed by
Mt. Sinai
Number of
Samples
61
58
23
13
9
4
2
1
4
1
1
2
-
2
1
1
1
-
1
1
1
187
Percent of
Total
32.6
31.0
12.3
7.0
4.8
2.1
1.1
.5
2.1
.5
.5
1.0
-
1.0
.5
.5
.5
-
.5
.5
.5
- 100%
Samples
Analyzed by
Battelle
Number of
Samples
27
33
22
11
9
9
4
3
3
3
-
1
-
—
—
-
1
1
-
-
-
127
Percent
of Total
21.3
26.0
17.3
8.7
7.1
7.1 '
3.2
2.4
2.4
2.4
-
.8
-
-
—
-
.8
.8
-
-
-
^100%
Samples Analyzed by
Mt. Sinai & Battelle

Number of
Samples
88
91
45
24
18
13
6
4
7
*4
1
3
-
2
1
1
2
1
1
1
1
314
Percent of
Total
28,0
29.0
14.3
7.6
5.7
4.1
1.9
1.3
2.3
1.3
.3
1.0

.6
.3
.3
.6
.3
.3
,3
.3
.100%

-------
PERCENTREE
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-------
                          TABLE  2
Chrysotile Concentrations Greater Than iOng/m"  As Measured by the
     Environmental Protection Agency l-fembrane Filter Network
                             Chrysotile
Urban Area


Dayton, Ohio

Long Beach, California

Memphis, Tennessee

Memphis, Tennessee

San Diego, California

Seattle, Washington

Dallas, Texas

Ft. Worth, Texas

Detroit, Michigan

El Paso, Texas

Los Angeles, California

New York, New York

Los Angeles, California

San Antonio, Texas
:entrat3 on
££/ui3)
95.0
40.0
38.0
34.3
18.8
18.0
16.5
14.4
13.4
13.3
11.8
11.0
11.0
10.2 ,
Date of
Measurement
- 4Q 1969
4Q 1969
4Q 1969
1Q 1972
1Q 1972
3Q 1969
4Q 1969
3Q 1969
3Q 1969
4Q 1969
3Q 1969
2Q 1969
4Q 1971
2Q 1969

-------
                                     35
                                  TABLE  3
                                                     Cities
Chrysotile Asbestos Coucentrat i

Laboratory;     Ht. Sinai

Dates ;          2nd Quarter 1969 through 4th Quarter 1970

Sample Size;    4 Composite Samples
                                       Chrysotile Concentration (ng/m*')
Rank          City
1        Dayton, Ohio
2        Long Beach, Calif.
3        Memphis, Tenn.
4        Seattle, Wash.
5        El Paso, Texas
6        Kansas  City, Kans.
7        Detroit, Mich.
8        Dallas, Texas
9        Ft. Worth, Tex.
10       San Antonio, Tex.
11       Phoenix, Arix.
12       Rochester, N. Y.
13       Los Angeles, Calif.
14       San Francisco, Calif.
15       New York, N. Y.
S*£fc
95.0
40.0
38.0
18.0
13.3
8.0
13.4
16.5
14.4
10,2
8.9
8.6
11.8
5.0
11.0
Low
0.4
1.3
0.4
0.6
0.3
3.9
0.5
0.3
0.9
0.9
1.3
1.4
0.7
1.8
0.5
Average
24.3
11.3
10.2
5.8
5.8
5.7
5.1
4.9
4.6
4.3
4.3
4.3
3.8
3.7
3.3

-------
                                      36

                                   TABLE  4



Chrysotile Asbestos Concentrations for Selectgj...IL...S ^jC
Laboratory:     Battelle


Dates ;          1st and 4th Quarters 1971
                1st Quarter 1972


Sample Size:    3 Composite Samples unless otherwise shown

                                                                    f\
                                     Chrysotile Concentration  (ng/irr)


Rank         City                    High          Low          Average


1       Memphis, Tenn. (1 sample)     34.3          -              34.3


2       San Diego, Calif              18.8         3.0             10.1


3       Los Angeles, Calif            11.0         6.8              9.1


4       New York, N. Y.                9.4         1.7              6.8


5       El Paso, Tex.                  7.6         5.5              6.2


6       Kansas City, Kans.             7.4         4.0              5.8


7       New Orleans, La.      '         5.9         4.5              5.2


8       Phoenix, Ariz.                 8.8         1.8           .   5.0


9       Denver, Colo.  (2 samples)      6.5         3.0              4.8
                                                               •

10      Atlanta, Ga.   (2 samples)      8.8         0.8              4.8


11      San Francisco, Calif.          5.8      ,   3.2              4.7


12      Long Beach, Calif.             5.3         4.0              4.5


13      Chicago, 111.  (2 samples)      7.2         1.2              4.2


14      St. Louis, MO.(2 samples)      6.1         2.1              4.1


15      Jersey City, N. J.             5.8         2.3              3.5

-------
                                  37
in the EPA National Membrane Filter Network, were installed at selected
locations in the four Minnesota communities.  Maps showing the sampling
sites for Silver Bay, Hoyt Lake, Babbitt, and Duluth are presented in
Figures 6, 7, 8, and 9, respectively.  One or more meteorological stations
were operated in the vicinity of the samplers to collect wind speed and
wind direction data for the area.

   Millipore filters (0.45 u) were used to collect the samples, which
were analyzed by Battelle Memorial Institute.  The analytical method used
in the program is described in Appendix I.

   The results for thirty-one (31)   samples are reported in Table 5.
The analyses are classified as "re-runs" since they are the product of
a second attempt by Battelle to analyze the amphibole mass concentrations
gathered during the June sampling program.  Problems with the first-run
analyses left those results in question in as much as Battelle refused to
stand behind them.

   The analytical results of samples taken in Silver Bay have been
used in the comparative analysis.  A detailed map of Silver Bay, which
shows sampling sites #1, #3, and #4 is presented in Figure 10.  Site #1
is located 1.2 miles from the source and is referred to as a "background
site" (the sampling station was located adjacent to a road in the woods
and was distant from a significant amount of human activity).  Site #3 is
referred to as a "process site" since it is immediately downwind of the
Reserve Mining facility when oil-lake brcescc prevail.  Site #4 is so
located that it was downwind of the process part of the time and at other
times it served as a "background site."

   The data for Duluth, Babbitt, and Hoyt Lake have not been used
directly in the comparative analysis.  This is so primarily because most
attention has been directed recently to the potential health problem in
Silver Bay.  In addition, the samples collected in Duluth and Hoyt Lake
in the June 1973 field sampling program were less than adequate for a
comparative analysis for those areas because of such problems as the siting
of samplers.  Consequently, a second field sampling program was undertaken
in August 1973 in Silver Bay, Hoyt Lake, and Duluth.  Hoyt Lake, and not
Babbitt, was indued in the second sampling program because of a desire
to assess the potential emissions from on-land disposal operations.  The
samples from the second field program have not been analyzed thus far
because of analytical problems with the nylon-backed Millipore filters.

E.     Comparison  of Silver  Bay Downwind Data to Other Downwind-of-Source
       Location Data
      Asbestos  concentrations measured downwind  of known  sources  are presented
 in Table  6.  No precise  comparison can be made  between the data  for
 Silver Bay and the  other data because, as discussed in Section B,  short-
 term concentrations measured downwind of a  given source  can vary extensively
 depending upon:

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         wind speed

         wind direction

         wind varibility

     -   atmospheric stability

         the distance between sampling site and the source, and

         other factors such as topography and precipitation.

Neither:  (1) the atmospheric variables; nor (2)  the distances between
samplers and source were fixed during the data-gathering efforts that
developed the information in Table 6.

     Relevant observations that can be made from Table 6 are:

     1)  The amphibole concentrations reported for Silver Bay are
         not uniquely  high when compared to chrysotile data
         that were taken immediately downwind of known asbestos sources.

     2)  High asbestos concentrations may be observed immediately
         downwind of asbestos mills and fabricating facilities 	 the
         emission being wind-blown fibers from one or more
         tailing piles or from process exhaust stacks.

Some of the measurements reported in Table 6 were taken in residential
areas.  However, others, such as those in Silver Bay, Minnesota, and
King City, California, were not.

F. Comparison of Silver Bay Background Data to Urban Concentrations

   Long-term sampling for amphibole asbestos in the town of Silver
Bay has not been conducted.  As a result, data on annual ambient concentrations
of amphibole asbestos for the residential area of Silver Bay do not exist.
Such data are necessary to make a comparison with chrysotile concentrations
for urban areas in the United States. /!_

   However, inasmuch as the source is located within 0.5 miles of the
shopping center in Silver Bay one can reasonably assume that the long-term
concentrations there will be equal to or greater than the background
concentration detected approximately two miles from Silver Bay.  An
average background concentration of 33 ng/m3 was determined from two samples.
/I "In the Reserve Mining case a court-ordered air sampling program has
   been undertaken that is designed to yield amphibole concentrations
   which are representative of the conditions in residential Silver Bay
   on an annual average basis.

-------
                                    41
   Chrysotile asbestos concentrations for a number of urban areas are
shown in Table 7.   The average background sample of amphibole concentration
near Silver Bay is greater than 98.8% of the measurements reported by EPA
for 55 United States urban areas.  The av?.rage background concentration for
Silver Bay is ten times the urban mean chzysotile concentration for 55 U.S.
cities.
         TABLE ?  :  Reported Asbestos Concentrations in Urban Areas

                              Range of
Location
Berkeley, Calif.
Auto Braking
Sites, NYC
EPA Urban
Network
(55 Cities)
World Trade
Center, NYC
Philadelphia
N.Y.C.
Dayton
Houston
San Francisco
Pittsburgh
Wash., D.C.
Asbestos
Form
Chrysotile
Chrysotile
Chrysotile
Chrysotile •
Chrysotile
Chrysotile
Chrysotile
Chrysotile
Chrysotile
Chrysotile
Chrysotile
Concentr
Low
22
32
0.1
3.5
45
1.7
0.4
4.0
1.5
2.0
1.6
atioa(ng/o3)
Hi£h
72
165
95
365
100
65
11
6.0
40
8.0
40
Number of Mean Median
Samples (ng/m^) (ng/m3)
2 — — —
6 76
314 3.2 -C2.0
22 40 21
7 __ 	
17 ~ — —
7 — — __
4
3
3 __ 	
4 	 	

-------
G.  Comparison of__S_il._ver_priy Background Data to Non-Urban and Remote'^Datci

    Measurements of asbestos concentrations that were taken neither
in urban locations nor downwind of known asbestos sources have been
summarized and are presented in Tczble 8.  The data are separated into
three categories, these being:

    1)  upwind sites in vicinity of asbestos point source,
    2)  suburban locations, arid
    3)  remote locations.

    The background measurements for Silver Bay are not different from
measurements taken upwind of other known point sources of asbestos.  In
addition, it is worth noting that the average background amphibole concentra-
tion for Silver Bay (33 ng/rn^, which is the average of two 8-hour samples --
see Table 8) is ten times the urban mean chrysotile concentration.  The
other background concentrations measured in the vicinity of known asbestos
point sources are also substantially higher than the urban mean chrysotile
concentration.  These observations may support the generally accepted
assumption that asbestos fibers in the ecosystem surrounding a source
will tend to remain in the area by adhesion to vegetation and other
ground level objects and not be totally removed with clearing weather
fronts.  The suspension of fibers from water bodies containing fibers
under high wind velocity conditions has also been hypothesized.

    No conclusive statement can be made regarding the reported suburban
concentrations because of the small sample size.  HOwever, the data
appear to be more representative of urban locution data thandata reported
for upwind sites near asbestos point sources.

    The remote concentrations reported for Frankfort, Kentucky were
measured near a fish hatchery that was at the time seven miles from
a paved road.  The measurements were taken at a remote site where
chrysotile concentrations were believed to be extremely low.  The average
background amphibole concentration at Silver Bay (i.e., 33 ng/m^) is
412 times greater than the average of three chrysotile measurements
taken at the fish hatchery.  Additional data were not found that would
indicate if amphibole mass concentrations in the range of 0.01 to 0.1 ng/m-3
are representative of concentrations in other remote locations in the
United States.

H.  Conclusions on the Silver Bay Amphibole Concentrations

    A comparative analysis of available data on amphibole and chrysotile
concentrations has been conducted.  The results of the analysis should
be used with caution.  Many reasons support this conservative viewpoint:

    a.  The analytical techniques used to measure amphible asbestos
    are not yet standardized.  Different techniques have been used at
    each laboratory that has analyzed samples.  In addition, the
    analytical results for the laboratories have differed.  As an example,
    four identical filters that were analyzed by the Mt. Sinai School of
    Medicine and the Battelle Memorial Institute have yielded results
    that differed by an order of magnitude.

-------
    b.   The laboratory techniques that yielded past data used in the
    comparative analysis have not been verified for reproducibility
    and accuracy.   Past data was used on the assumption that the accuracy
    and reproducibility of tho techniques were similar to that of the
    techniques used to measure amphibole concentrations,

    c.   The samples used in the analysis hove been taken under different
    sampling conditions and fcr c3ifferent purposes (i.e., the EPA
    National Membrane Filter Network vs. the Minnesota studies).
    Generally, the data frora 1970-1972 wore generated during research
    programs where sampling and analytical methods were being tested
    for validity.

    Keeping the limitations of the analysis in mind, the following
conclusions have been determined:

    1).  Araphibole concentrations measured downwind of the Reserve
    Mining processing facilities are not uniquely high.  Chrysotile
    concentrations equal to or greater than the Silver Bay amphible
    concentrations have been measured in Ohio and California near
    asbestos plants.

    2).  The average concentration of two background (or clean site)
    samples measured in the Silver Bay area are ten times greater
    than the urban mean chrysotile concentration.  The average
    amphible concentration for the background site in Silver Bay
    is greater than 98.8% of the 314 chrysotile concentrations
    ir.sasursd in 55 U. S. cities during the 1970-1972 period.

-------
                                              44
                TABLE 8:   Asbestos Concentration for Background (Upwind)  Sites
          Type
       Background
          Site
Location
                 Range of
Asbestos      Concentration(ng/m^)   Number of
  Form	     Low           High      Samples
Upwind site in vicinity
of Asbestos Point Source

Upwind site in vicinity
of Asbestos Point Source
Upwind site in vicinity
of Asbestos Point Source
Upwind site in vicinity
of Asbestos Point Source
Upwind site in vicinity
of Asbestos Point Source
Port
Alleghany,Pa. Chrysotile     10

Country
Club,
Ambler,Pa.    Chrysotile     —
King City,
Calif.        Chrysotile
Remote Location
Hoyt Lake,
Minn.         Amphibole      20
Silver Ray;
Minn.         Amphibole      23
Frankfort,
Kentucky      Chrysotile
               0.03
                              30
                                                         —     57      —
                                                                        27
                                                                        42
Suburban Location
Suburban Location
Ridgewood,
New Jersey
NWQL Roof
Duluth, Minn.
Chrysotile — 20 —
Amphibole 8 11
1
2
0.12

-------
                          REFERENCES

Heffelfinger, R. F., C. W. Melton, and D. L. Kiefer, "Development
of A Rapid Survey of Sampling and Analysis for Asbestos in Ambient
Air (Final Report),"  Battelle Memorial Institute, Columbus, Ohio,
Columbus Laboratories, Environmental Protection Agency Contract
CPA 22-68-110, February 29, 1972.

Data not formally published that was developed in conjunction
with the Reserve Mining case.

Draft Report, "Asbestos Pollution Problem at Ambler, Pennsylvania,"
April 11, 1972  (Prepared by Region III of the Environmental
Protection Agency).

Nicholson, William J., A. N. Rohl, "Asbestos Air Pollution in
New York City (Final Report)," Environmental Sciences Laboratory,
The Mount Sinai School of Medicine of the City University of
New York, New York, N. Y., December 2, 1971.

Personal communications, Dr. S. David Shearer, Environmental
Protection Agency, Office of Research and Development,
September 1973.

Nicholson, W. J., Ruul, A. N. turn Ferranu, E. F., "Asbestos Air
Pollution in New York City,"  In Proceedings of the Second Clean
Air Congress. (Edited by England, H. M. and W. T. Barry), Academic
Press, New York (1971).

Stanley, R. L., et al, "Status of Analytical Methods for
Determination of Asbestos in the Environment (AIHL Report No, 151),"
Air and Industrial Hygiene Laboratory, California State Department
of Health, Berkeley, California, September 1973.

-------
             CHAPTER III
    PRELIMINARY ESTIMATE OF THE OCCURRENCE
OF ASBESTIFORM AND OTHER POTENTIALLY HAZARDOUS
       FIBERS' IN THE TACONITE INDUSTRY

-------
                            CHAPTER III
                         TABLE OF CONTENTS
                                                              Page

A.   Introduction                                              46

B.   The General Geology and Mineralogy of the Biwabik
     Iron Formation      •                                   "   47

C.   Distribution of Taconite Mines Along the Mesabi Range     48

D.   Asbestiform Minerals Other Than Grunerite-Cummingtonite
     Along the Mesabi Range                                    49

E.   Asbestiform Minerals Expected in Emissions from Loading
     Pellets                                                   50

F.   Taconite Mining in States Other Than Minnesota            51

G.   Potential Pollution Associated with Activities Other
     Than the Mining and Milling of Iron Ore                   51

H.   Conclusions                                               54

-------
                             CHAPTFK III
         PRELIMINARY ESTIMATE OF TlIF, OCCURRENCE
     OF ASBESTIFORM AND OTHER PO1TW a ALLY HAZARDOUS
            FIBERS IN TIIK TACONITL INDUSTRY
A.   Introducti on

     The geology of the Biwabik iron formation from which  iron ore
is mined along the Mesabi Range in northern Minnesota is well known
because of its economic importance.  Long-standing work by the U. S.
Geological Survey, studies by the Minnesota Geological Survey,
investigations by expert witnesses, as well as observations and
analyses conducted by the staff of the Office of Technical Analysis,
all indicate that the following questions can be answered:

      (1)  Are the five other companies currently mining taconite
     along the Mesabi Range, and the company which has announced
     it will begin operations in 1975, likely to be found  to have
     the same minerals in the same concentrations in their emissions
     to the air as does Reserve Mining Company at Silver Bay?

      (2)  Are any asbestiform minerals not present in Reserve's
     emissions expected to HP .in the emissions of the other
     companies?  If so, what are the expected concentrations of
     such asbestiform minerals?

      (3)  What asbestiform minerals are to be expected in  the
     emissions resulting from the loading of pellets of beneficiated
     iron ore into interlake ore carriers?

      (4)  Is the taconite mined by Reserve mineralogically similar
     to that mined by other companies outside of Minnesota? Would
     the same problems of air pollution by asbestiform minerals be
     expected there?

      (5)  What other sorts of mining, manufacturing, or agricultural
     activities would be expected to have high concentrations.of
     asbestiform fibers?

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                                47
B*   The General Geology and Mineralogy of the Biwabik Iron Formation

     The Mesabi Range consists of a low-lying ridge which trends
northeasterly across almost 130 miles of central and northeastern
Minnesota (Figure 1).

     A prominent type of rock in the Mesabi Range is the Biwabik
Iron Formation, made up of a series of primary sedimentary iron
oxides, hydroxides, silicates arid carbonates deposited in a
sequence of layers which ranges from 400 to over 600 feet thick
and dips underground toward the southeast at about 10°.  The
mineralogical characteristics vary considerably along the outcrop
of the formation as well as down its southeasterly dip.  This provides
a basis for dividing the formation vertically into 5 major members
and as many as 22 submembers (Figure 2).

     A massive igneous intrusion, the Duluth gabbro, occurs at the
northeastern-most end of the Biwabik Iron Formation.  During the
emplacement of this igneous body, the eastern Mesabi Range between
Mesaba, Minnesota and Babbitt, Minnesota underwent high-grade contact
metamorphism at temperatures which may have reached 700-750 degrees
centigrade (Gundersen and Schwartz, 1962).  Silicate minerals,
including amosite, as well as other minerals were formed from pre-
existing ones within about 3.5 miles of the Duluth Gabbro where this
contact metamorphism was effective.  The rest of the formation
remained relatively unchanged by this event.  The mineralogical
patterns jjxouuced by contact metamorphism of the Biwabik Iron
Formation provides the basis for dividing the formation laterally
into zones, and for predicting the mineralogy at any point
along the formation (Figures 3 & 4).

     Portions of the Biwabik Iron Formation exposed at the surface
of the earth underwent weathering for hundreds of millions of
years.  During weathering, the iron minerals were oxidized so
that a rich iron ore (hematite, Fe203)  remained as the major residue
where many other iron-bearing minerals had previously existed.
These pockets of hematite were mined as a "high-grade" primary
ore and shipped to the blast furnaces without further concentrations.
As these deposits were depleted (oxidation extended only to the
uppermost exposed layers of the formation and in limited areas
along the formation), the "low-grade" iron ores containing magnetite
(Fe30^) admixed with silicate minerals were examined for their economic
potential.  Low-grade siliceous iron ores are called taconites.
They may consist of up to 30% magnetite in a matrix of quartz and

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etita-rich granules ond >i pebbles, congiomefal'C fobnc through ou 1 ; minor hjmoli'e granule (magnetite) quartz tacontte wdn abundant mjQnet'tB-nch pebbles near \. lop ond thickly layered (magnetite) qvartz toconite neoc boltom wavy layered (silicate-magnetite) Quartz f aconite wiih obu^don) mogneiite- rich granules o"d pebblei; S'licoies o^e actmotils ond f^rronypsrjih»ne (eott) ond cumnrnojontlB (w«st] wavy layered (stiicafe'Tflogretitf} sibcote- quartz (aconite w,th abundant mog- ond ho'oblendft (eosl) and cumfrinqtoniis ond ochno!ti« (west), silicates with layered (magnetite) fayabte- quartz tccomle with l«rrohypersth«ne (eosfl ond layered (magnetite) cummtngtontfc -quartz toocnife (wsst) S fayolits -quartz tocomte *ith (errohypersthene (eosl) end cummingtanrte '-quartz bedded granw'e (magnetite) quartz- fcyctite tcconite wiih some (errohypersthene \. n^|if*-beonng granules (w«st) i \ shaty quartz -fcyolite toconite to fayalitf taccnite (eos)) ond shafy qvortz- cummingtorxfe facoftt/e to cummngtoryfe taconite (west); minor mogne'ile / m.nor foyclite, b.otite, aimandits ond pyrrhoMte (cost) ond traces of pynte, pyr- / fholite ond cumnTn^ionife («(»sl) / 1 / I layered (magnetite) faya'>f? -quartz tocomie wilh minor cummmglonite i 1 io^cred (mogne'if?) cjuGrtz tacanife with minor cunmingtoniie throughout, and // ^ede foyolife (cost) Figure 2~ After Gundersen and Schwartz, 1962.
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                            Distonco from Contact (D) (miles)
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Figure 4 - Diagram showing  the  mineralogy of the Biwabik Iron Formation
           in different metamorphic zones as a function of distance from
           the contact with the Duluth Gabbro.  Small circles indicate
           locations of specimens;  dashed lines indicate uncertainty of
           occurrence,  (after French  1968)
*  Fibrous minerals discussed herein.

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                                    43
     other  minerals.  The  Biwabik  icon  formation  also  contains  a  number
     of other  silicate minerals  associated  with the magnetite and quartz.
     When suitable  techniques  were developed vhJch made  thece rocks
     economically exploitable, th«ce  taconite oros became  the primary
     mining objective.   Recovery of the magnetite necessitated  processing
     the associated rocks  as well, fibrous  amphiboles  among them.

     C.  Distribution of  Taconite Mines  along the MeF-;.bi  Range

         Reserve Mining Company's Peter  Mitch-.-11 pit lies within Zone 4.
     (Figure 1)   The  asbestiform variety  of the amphiboly  grunerite-
     cummingtonite  (called amosite) comprises 10% to  60% of the Biwabik
     Iron Formation in Zone 4  (see Figure 4). Burrell (1973) reported
     that amosite composed about 20%  of the ore mined by Reserve. Erie
     Mining Company operates  a small  pit  (the Dunka pit) east of  Reserve's
     in Zone 4.   The  mineralogy  there is  magnetite, quartz, hedenbergite,
     ferrohypersthene, garnet, with but little grunerite-cummingtonite.
     Erie also operates  three  larger  pits in Zone 3 east of Mesaba
     (Figure 1).  In  Zone  3 the  Biwabik Iron Formation has been reported
     to contain from  20% to 50%  grunerite-cummingtonite.  All the other
     taconite mines on the Mesabi  Range lie in Zone  1.

         Erie Mining Company, the only taconite  operation in Zone 3,
     has completed  primary mining  of  their pits which lie  within  that
     zone.   By the  end of  the year, the cleanup operations currently
     underway in these pits will ba completed and no  more  ore will be
     taken  from them. Ore subsequently will be mined mainly from pits
     in Zone 2, with  some  small fraction  coming from  the Dunka  pit.
     At that time,  the emissions of amosite from  Erie's plant should
     decline to a low level maintained by the small volume
     of rich ore mined from the Dunka pit.*  Erie Mining Company  is
     aware  of the asbestos problem and plans to step  up its existing
     program of revegetating  the tailings dumps.   This should further
     stabilize the  tailings and control this source of amphibole  and
     other  silicate particulates to the air and water.

         The process water used to carry tailings to the  dumps is recirculated;
     little runoff  enters  the surface drainage.   The  company also has
     a program underway  to further raduce emissions of particulates  to
     the air from stacks on the pelletizers.

         Thus, amosite  is not expected to present a  significant threat
     as a pollutant at any other taconite mine along  the Mesabi
     Range  other than at Reserve's.
*  See the section on asbestos in air samples for levels around Erie's plant.

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D.   Asbestiform Minerals Other Than Crc'inerite-Cummingtonite
     Along the Mesabl Ramie"  "     "       ~~~~"~


     Crocidolite and actinclite are other asbestiform amphibole
minerals which occur along the Messbi Range.  Crocidolite, the
asbestiform variety of the f,:r;phibolc rxebeckite, has been reported
present in Zone 4 in "minute." amounts (Gundersen & Schwartz, 1962;
White, 1954).  The amphiboio actinolice has been identified in
amounts of up to 5% in "cno <1 (Gundd-rsen & Schwartz, 1962) .  The
presence of these minerals recognised as asbestos contributes to
the overall level of asbestos pollution of air and water and
increases the analytical problems of determining particle identity
and quantity.

     Additional minerals not classified as asbestos may behave as
such physiologically because of their size and shape.  Greenalite,
minnesotaite, talc, and hornblende are such minerals which occur in
the Biwabik Iron Formation.  The mineral greenalite occurs in the
relatively unmetainorphosed part of the formation, and thus occurring
through Zone 1 and 2 and into Zone 3  (see Figure 4).  It composes up
to 20% of the formation in Zone 1.  Greenalite has not been included
among the asbestiform minerals which have been considered to be
hazardous in the past, in spite of the fact that its structure is
that of a serpentine, which is the mineral family containing the
principal commercial asbestos mineral chrysotile.  In light of the
medical testimony that the health effect is primarily related to the
sice olid shape of a. particle, there is reason to believe that high
concentrations of greenalite may present a significant health problem
along the western-most 100 miles of the Mesabi Range.

     The same is true of the mineral minnesotaite, which may make
up as much as 40% of the taconite ore in Zones 1 and 2.  Minnesotaite
commonly occurs in small, fibrous shoeves about 50 microns long from
which smaller individual fibrils can be seen to radiate.  Minnesotaite
has a structure and crystal form similar to that of talc, and, there-
fore, can be expected to pose a potential air pollution problem.
Talc itself occurs in the formation in Zone 1 in amounts less than 5%.
The effects of fugitive dust in talc mills on the respiratory system
of exposed workers is well known.

     The amphibole hornblende is present in Zone 4 in amounts up to
5% according to French (19&8) .  Dr. Irving Selikoff has described an
incomplete study done at Mt. Sinai Hospital which indicates preliminarily
that the lungs of workers engaged in driving a tunnel in New York City
through rock containing hornblende are heavily loaded.  They have also  found
surprisingly high levels of hornblende in the lungs of residents of
New York City.  The residents were most likely exposed by the rock the
city is built upon, for hornblende is not used as commercial asbestos.

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                                50
     An estimate of the long tons of asbestiform minerals mined and
milled by each operator shipping pellets in 1972 allows an assessment
and comparison of the attendant potential hazards involved.  Table
II summarizes the tons of pellets each operator shipped from the
Mesabi Range during 1972.  Such an estimate can be made if it is
assumed that:

     (1)  The ratio of ore mined to pellets shipped is 3:1, most
     operators must mine and process 3 tons of ore to produce 1 ton
     of pellets.

     (2)  The asbestiform minerals identified in the Biwabik Iron
     Formation are present in the ore mined in amounts equal to the
     median percentage abundance reported in the literature for those
     minerals.

The comparison on Table II shows that almost as much asbestiform and
potentially hazardous minerals are produced as pellets.  Until medical
research identifies some threshold dosage of asbestos below which no
health hazard is likely to result, the potential for the various health
problems caused by amphiboles, and other silicates not now recognized
as hazardous, but which are emitted by taconite operations from all
zones of the Biwabik Iron Formation, remains problematical.

E*   Asbestiform Minerals Expected in Emissions from Loading Pellets

     Green taconite pellets are heated to greater than 1100°F in the
pelletizing furnaccc for periods of up to 6 hours.  This firing melts
silicate minerals, and when tho pellets are removed from the
furnaces, the silicates are quenched to a glass.  Glass has no
crystal structure, and consequently no crystalline fibers would be
expected to be emitted during the handling of pellets.  Small sub-
sequant pieces of silicate glass may be emitted during pellet-
handling, however, as something less than onehalf of one percent
of the pellets break during handling.  The pellets themselves then
are not expected to be a source of asbestos emissions.  The potential
for silicosis among workers occupationally exposed to emissions
during pellet-handling must be considered, however.

     An additional potential hazard may exist due to the possible
emissions of asbestiform minerals from the handling of so-called
"natural" ore.  This ore is ground only to 0.75 inches, and is
handled wet, so it is not expected to be a potential source of air
pollution.  Twelve million long tons were shipped by rail from the
Mesabi Iron Range in 1972, or about 29% of the volume of pellets
shipped from the Mesabi Range during the same period.

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F •   Taconite I- i r\ing_j.n 01l^r Statcs

     The mineralogy of the Biwabik Tron Formation is not unique.
Similar iron fonnationn are found on the Marquette Range, Menominee
Range and the Iron River District, all in Michigan, and on the
Penoche-Gogeb.ic Range which lies primarily in Wisconsin  (Figure 1) .
French  (1968) has noted tb-t except for a lesser abundance of hematite
and the presence of fayallte in the highly metamorphosed taconite  .
of Zone 4, the Eiwabik lfvon Formation is virtually identical
mineralogically to those iron forir.etions in other states which have
been described by James (1955) and interpreted by him to have formed
simply by progressive regional metamorphism.  The amphibole minerals,
as well as the silicates greenalite, minnesotaite, and talc,
occur on these iron ranges, and are expected to have grain sizes
comparable to those of their counterparts on the Mesabi Range.

     Table II  lists the amount of pellets produced from taconite
mined from these iron formations.

G.   Pollution Potential Associated with Activities other^ than the
     Mining  and Milling of Iron Ore

     The occurrence of airphiboles in geologic settings other than in
iron formations is too widespread to cite by individual industry or
location.  The fact that arnphiboles occur in igneous and metamorphic
rocks in substantial volumes as well as in the soils produced by the
weathering of  those rocks, makes it probable that amphiboles can be
found in large quantities over a significant fraction of the country.
It is particulajc.ly important to note tnat amphiboles are common in
both igneous and metamorphic rocks associated with ore deposits.  Thus,
problems similar to those attributed to amphiboles on the Mesabi
Range arising  from the mining and milling may be expected wherever
those activities are conducted.  Independent efforts by the U. S.
Geological Survey and Battelle Memorial Laboratory for OAWP are
underway to  identify all mines which are expected to be sources
of asbestos.

     Chrysotile is not nearly as abundant as the amphiboles.  The U.S.
Geological Survey has cataloged more than 50 chrysotile mines and
prospects in the 50 states.  Nine mines were listed as significant
producers in 1966  (Table III).  The emissions from, and environmental
concentrations around, these sites have never been determined.  However,
monitoring of  air and water quality is currently being conducted at
the chrysotile mine near Lowell, Vermont, for Region I by the Quality
Assurance and  Environmental Monitoring Laboratory, NERC, Research
Triangle Park, North Carolina,  A similar investigation should be
conducted at the sites of several of the largest mines and processing
plants.

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-------
                                70
small; sovae method of concentration is therefore necessary.  Much
of the solid content of the water is organic, e.g./  plant debris,
bacteria, etc., and unfortunately this is also concentrated along
with the asbestos,  an ashing stage was therefore introduced into
the process to destry this organic material,  which is of no interest
in the analysis.  Two methods of processing such specimens have
already been described, (7,s) both of which have some undesirable
features.  The method selected for these samples combines the best
features of the published techniques.  The water sample is thoroughly
shaken to redisperse any solid material which may have settled out
during storage.  A 200 ml sample of this is filtered through a 1000 A
pore size membrane filter.  This pore size is adequately small, since
fibers even shorter than this are unlikely to follow the tortuous
path through such a inembrance.  It is necessary to assist this
filtration by applying a vaccum to the clean side of the filtration
equipment.  Filtration tiire is variable, depending on the cleanliness
of the water.  Times varying between 15 and 90 minutes are observed;
in some cases the filtered volume is reduced, since complete blackage
occurs.  Pressure filtration methods are used for some very dirty
samples.  The membrane filter is then placed in a silica crucible,
covered with a silica lid and this is heated to about 450°C for
a period of more than three hours.  The filter residue after ashing
is dispersed in 4 ml of freshly distilled water, and agitated gently
in an ultrasonic vibrator for 10 minutes.  One ml of this suspension
is added to a specially designed centrifuge tube which contains a
carbon coated electron microscope grid.  The suspension is deposited
uniformly on the electron microscope grid by operating the centrifuge
at 8300 g for a period of 30 minutes.  The grid is removed from the
centrifuge tube and, after drying, is ready for inspection in the
electron microscope.

Fiber Counting

     The grid is examined at a direct screen magnification of 25,000
times at an accelerating voltage of 80 kv.  Using a series of
calibration circles scribed on the microscope fluorescent screen,
asbestos fibers are placed into size categories according to their
length and diameters.  A minimum of 10 grid squares (200 mesh size)
is examined, and all asbestos fibers in this area are counted.  One
problem in fiber counting is caused by the presence of large amounts
of other material, consisting mostly of fragmented diatoms.  As a
magnification of 25,000 the area of sample examined amounts to some
40 square metres, on which fibers perhaps as small as 3 mm are being
sought among other material.  This illustrates the main difficulty
of the technique — that of manual counting of very widely spaced
fibers; a method for which there is no substitute on samples such as
these.  However, counting times of about 2 hours are adequate to
size  the 10 grid squares required.

-------
                               69
     Where:   the No.  of fibers  counted  =  5  (occasionally 10)

             Grid area factor = 1.84 for  grids  with thick
               bars,  or
                                1.34 for  gr:ds  with thin bars

     The mine tailing sample (slurry) was analy/.ed as follows:

     1.    The sample  was shaken well to disperse the larger
     solids  which had settled to the bottom.

     2.    One ml was  removed quickly with a pipette.

     3.    A  1:100 ml  dilution was made  in a volumetric flask
     using glass-distilled water.

     4.    Ten ml of the dilution were added to  approximately 100 ml
     glass-distilled  water previously put into  the funnel of a
     glass Millipore  filter holder with an  0.8u pore size, 47 mm
     diameter, Nuclepore filter in place.

     5.    The filter  assembly was gently  rocked to disperse the
     sample.

     6.    The diluted sample is filtered  as described in Appendix A.

          The filtrate was filtered through an  0.2u pore size
     Nuclepore filter.  Both filters were prepared for and examined
     by electron microscopy.  The method  of calculation is as
     follows:

     No. of  fibers on filter x 452 X 129.4  X 1.34 XI
                                5                  .0001
                                                fibers/liter.

          A solid sample of tailings from the Reserve Mining
     Company operations on Lake Superior was requested by me.
     This sample was labeled "Tailings - West Launder Delta,"
     6/27/73.  A portion of this sample was ground in a mortar
     and the powder analyzed by X-ray diffraction by Mr. Robert
     Jack in the Department of Geology and Geophysics, University
     of California, Berkeley.

E.   Ontario Research Foundation, Sheridan Park, Ontario, Canada:
     Analysis of Water, Sediment and Air Samples for Asbestos.

Water Samples

     The amounts of asbestos in water samples are usually very

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                                68
     The procedure for analysis of asbestos fibers in water
differs from the analysis of asbestos fibers in air in the
following aspects.

1.   The participates in water can be collected directly on
a Nuclepore filter; that is, the transfer technique from a
Millipore filter  (sample collection filter) to a Nuclepore
filter  (filter used for electron microscopy) as described in
Appendix A is not necessary.

2.   The sample size used for analysis of fibers in water is
in the range of one liter while approximately 5000 liters of air
are sampled for analysis of fibers in air.

3.   In the analysis of fibers in water, correction for a
segment removed for analysis by other methods is not necessary;
that is, the normalizing factor described in Appendix A is not
necessary.

     A sequential filtration using 0.8u pore size and 0.2u pore
size Nuclepore filters was used for collection of particulates
from the water samples when it was found that many fibers were
very small and some could pass through the 0.8u pore size filter.
The sequential filtration will be used on all water samples until
sufficient data on the percent breakthrough of small fibers through
the 0.8u Nuclepore filter is obtained.  The number of fibers/liter
calculated for both filters for all samples are reported as well
as their totals.

     The formula for calculation of the fibers/liter in water is
from Appendix A and refers to 47 mm diameter filters:

     No. of fibers counted X Total fields in grid X
                             No. of fields counted

     Effective area of filter X Grid Area Factor X
     Area of disc

     	1	 = f/1
     Vol. sampled

     For a typical sample:

     No. of fibers counted X 452 x 129.4 x   1
                              5           1 liter
                                        fibers/liter

-------
to line on their flat side rather than on edge.   There is,
however, a finite possibility that some laths will be on
edge and, due to the very small size of many of  the fibers
of interest, the approximation to a square fiber will not
give more than a slightly high bias to the mass  readings.
Also presented on the computer printout is the calculated
number of fiber per liter of water, the calculated mass of
fiber per liter of water, the size distribution  of the fibers
based on length and width, ana the distribution  of fibers
by aspect ratio.  The program automatically assigns the
longest dimension of the fiber to the length and excludes all
fibers with an aspect ration below three.

     Electron micrographs are being taken of the samples as
they are examined to show the typical appearance of the
amphibole fibers and the electron diffraction patterns by
which they may be identified.

D.   Mr. Jack Murchio, School of Public Health,  University
of California, Berkeley, California:  Analysis by Electron
Microscopy of Asbestos Fibers in Water Samples

     The method of analysis of the water samples is one adapted
from the method developed in this laboratory for analysis of
asbestos fibers collected from air on membrane filters.  This
method is appended to this report as Appendix A  (and is Appendix
A from a report entitled "Asbestos Fibers in t-he Ambient Air
of California," to the California Air Resources  Board).
Modifications necessary to adapt the method to the analysis of
asbestos fibers in water will be reported in the Method Section.
the method of analysis of the mine tailings is also described
in the Method Section.

METHOD
     One liter of a water sample is filtered through an 0.8 u
pore size, 47 mm diameter, Nuclepore filter.  The filtration
method is described in Appendix A.  A 500 ml aliquot of the
filtrate is filtered through an 0.2 u pore size, 47 mm diameter,
Nuclepore filter.  The particulates on both filters are prepared
for and examined by electron microscopy as described in Appendix A.

-------
                                 66
portions of the sample is minimal.   Techniques involving transfer
of a liquid suspension directly to  the electron microscope grid
are more subject to error since in  the drying process there is
frequently a size separation as the meniscus of the drying drop
recedes.

     The samples, after preparation as described above, were
examined on the JEM 200 Electron Microscope using an accelerating
voltage of 150 kV at a magnification of 17,OOOX on the M3 range
of the instrument.  This magnification was chosen since it is
at this magnification that the intermediate lens aperture is in
focus in the specimen plane.  It is thus possible, by inserting
the aperture and switching to the diffraction position, to
obtain a selected area electron diffraction (SAED) pattern of the
fiber being examined with no other  adjustments to the microscope.
In this way it is possible to spot  check individual fibers very
rapidly while measurements are being made on them.

     A considerable amount of time  was spent with a sample of
the Reserve Mining Company tailings and with Samples Numbered
AM0081A and AM0090A to familiarize  the operators with the
morphological appearance and also the diffraction patterns of
the amphibole asbestiforms present  in these samples.  Following
this initial familiarization, the remaining samples were examined
and measured, the length and width  of each fiber being recorded
while the fiber was viewed directly on the screen.  Interpolation
from a screen scribed at half-centimeter intervals allows an
accuracy of measurement on the screen of approximately + 0.05 cm.
There is a calibration-factor between the magnification range on
the photomicrographic plate  (which  was 17,OOOX) of 0.86:  That
is to say, the image as observed on the fluorescent screen is
0.86 times 17,OOOX.  Measurements of the individual fibers were
read into a voice recorder to permit the operator to devote his
entire attention to the screen and  to prevent any possibility
either of duplicating the count on  one fiber, or of missing
fibers and of the operator losing his dark accomodation by having
to stop to write data.

The recorded data were transcribed  onto punchtape and were
computer processed to give listings of the length and width of
the fibers, together with a computed mass of each fiber computed
on the basis of density times length times width squared
(D x L x W^) with the value of 3.40 taken as the mean density of
the amphibole fibers.  Because many of the araphiboles are lath
shaped rather than square in cross  section, this figure may
well be slightly high, since the laths will, in general, tend

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                                     65
     The following detailed procedure was employed to generate
the standard curve:

     (1)  A weighed amount of amosite was placed in a 600 ml
     beaker and sufficient water containing 0.1 percent Aerosol
     OT was added to make a stock suspension which would contain
     4 ug/ml after the amosite was uniformly dispersed by
     ultrasonic treatment.

     (2)  After ultrasonic treatment aliquots were taken from
     the original stock suspension and further diluted with water
     containing Aerosol OT to create appropriate concentrations
     from which aliquots could be taken and filtered to deposit
     the desired quantities on 25-mm diameter HAWP Millipore filters.

     (3)  The filters bearing the various concentrations of amosite
     were then carbon coated and prepared for examination in the
     electron microscope as described in Steps 4 through 9 in the
     outlined procedure for handling liquid water samples.

     C.   Mr. Ian Stewart, McCrone Associates, Chicago, Illinois:
     Methodology for Determination of Amphibole Asbestos in Duluth
     Water Samples

          The samples were received in two forms:  (1) filters
     which had been taken on the site; and (2) one-liter polyethylene
     bottles of the water,

          Our initial attempts were to use the filters taken at
     the site since this would involve less suspicion of possible
     loss of sample due to adherence to the walls of the container
     or contamination of the sample during furhter handling.  Un-
     fortunately, the filters as we received them were too heavily
     loaded to be usable for electron microscopy without further
     preparation.  We, therefore, prepared our own filter samples
     by filtering small volumes (typically in the range of 30-200 ml)
     of the water onto 13 mm diameter Millipore filters.  A section
     was then cut from the Millipore filter approximately 2-3 mm.
     square and was placed facedown on a previously carbon-coated
     electron microscope grid and the membrane filter dissolved
     using acetone in a Soxhlet extractor.  Previous work with this
     technique has shown us that there is very little risk of
     contamination in transfering the filter on the electron
     microscope grid to the Soxhlet extractor; and, furthermore,
     by dissolving the filter in situ on the grid, the risk of losing

-------
          2.    Filtered Water Samples

     (1)   The as-received sample is a membrane filter through
     which three (3)  liters of saupled water were filtered.

     i2^   A 30° radial section is cut from the filter and thus
     represents 1/12  of the residao filtered from 3 liters of
     water or that residue from 250 ml of original sample.

     (3)   The radial  section is placed in a 15 ml test tube and
     the test tube in turn is placed in the low-temperature asher
     for 2 days.

     (4)   After ashing has been completed, 10 ml of water containing
     0.1 percent Aerosol OT is added to the ash residue and treated
     ultrasonically to disperse the suspended ash.

     (5)   The ultrasonically treated suspension is poured into a
     600 ml beaker, the test tube is rinsed with water containing
     0.1 percent Aerosol OT into the 600 ml beaker, and the sample
     volume is diulted to 250 ml with water containing 0.1 percent
     Aerosol OT.

     (6)   The 250 ml  is then subjected to ultrasonic treatment.

     (7)   Next aliquots (25, 50, 75, and 100 ml) are filtered through
     25-nun (0.45 u) !LV.\T Millipore filters.

     The sample is then processed in the same manner as is the liquid
air sample (Steps 4 through 9).

          3.   Generation of Standard Curve for Water Samples

     A sample of UICC amosite was obtained from Dr. Leineweber of
Johns-Manville.  When the sample was examined in the electron microscope,
the asbestos particles were found to be quite similar with respect to
morphology and particle size to those seen in the Duluth samples.
Consequently, this amosite sample was employed as a standard material
in the generation of the standard curve which relates counts made
in the electron microscope to micrograms of amphible type asbestos on
25-mm HAWP Millipore filter.

-------
                                63
B.   Procedure Employed in the Analysis of Water Samples

     1.   Unfiltered Water Samples

(1)  The as-received 1 liter water saff.ple is agitated by
rolling one hour on mixing rollers.

(2)  A 250 ml aliquot is taT:en from the liter sample, 2.5 ml
of 10 percent Aerosol OT is added, and it is ultrasonically
treated in a 600 ml beaker to disperse the suspended particulate
uniformly.

(3)  Aliquots (25, 50, 75, and 100 ml) are filtered through 25-mm
HAWP Millipore filters (o.45 u).

(4)  The filter bearing the residue is allowed to dry and then
200 A of carbon film is vacuum deposited over the residue on  the
filter.

(5)  Then 3 x 3-mm squares are cut from the filter and the
filter material is dissolved away in an acetone, bath.

(6)  The remaining carbon film bearing the filtered particles
is picked up on a 200 mesh electron microscope support grid.

(7)  Counts are made in the electron microscope at 20,OOOX
by scanning 5 to 10 grid openings systematically.  WVien a
fiber is encountered in the path of a scan one count is
registered.  If a single fiber traverses the path of more than
one scan it is counted as many times as it is encountered.
This "intercept counting" approach minimizes uncertainty
arising from large variations in fiber lengths when performing
mass determinations.

(8)  The average counts per grid opening obtained from the
sample are translated by means of a standard curve to micrograms
of asbestos on the 25-mm filter.
 (9)  Taking into consideration the aliquot which was filtered
 on the 25-mm filter calculations are then made to express  final
 results in terms of micrograms asbestos per liter of original
 sampled water.

-------
                                62
The modified procedure is as follows :

(1)  Two 45° radial sections are cut from the nylon web
supported membrane filter.

(2)  The collected particulate is removed from each 45°
radial section of the filter by ultrasonification in 100 ml
of water containing 0.1 percent Aerosol OT.

(3)  The combined solution from Step 2 was duluted to 900 ml
in a clear plastic bottle.

(4)  The bottle containing the 900 ml of diluted solution was
placed on mixing rollers for one (1) hour.

(5)  A 250 ml aliquot was removed from the bottle and
ultrasoned for two minutes.

(6)  A 10 ml aliquot was filtered onto a 25-mm HAWP
Millipore filter.

(7)  After thoroughly rinsing with water the particulate
deposited on the filter was leached with 10 ml of 0.1 N
HCL and then again rinsed.
prepared for electron microscopy by coating with carbon.

(9)  A 3 x 3-mm square was cut from the filter and the
filter material dissolved away to leave the carbon film
bearing the deposited particulate.

(10) The carbon film is picked up on 200 mesh electon
microscope grid and counts are made at 20,OOOX magnifi-
cation in the electron microscope.

(11) The ug/m^ of amphibole is calculated using data
obtained from standard curve and the total volume of
air sampled.

-------
                                     61
     (8)   The supernatant liquid containing small suspended
     particles not sedimonted by centrifugation is poured
     into a 100 ml graduate.

     (9)   Steps 6, 7,  and 8 are repeated twice to extract as
     much asbestos as  possible from extraneous particulate.

     (10)  The combined supernatant extractions in the 100 ml
     graduate are then diluted to 100 ml and mixed by ultra-
     sonification to create a uniform suspension.

     (11)  JQiquots (usually 70 and 30 ml)  are filtered through
     25-ml Millipore filters.

     (12)  The filters  are cut in half and coated with a carbon
     film by vacuum evaporation.

     (13)  A 2 x 2-mm square is cut from the carbon coated filter
     bearing the deposited asbestos and the filter material is
     dissolved away in an acetone bath to leave the carbon film in
     which the extracted particles are supported.

     (14)  The carbon film is picked up on a 200 mesh electron
     microscope support grid and examined in the electron
     microscope at 20,OOOX where counts are made as described
     in Steps 4 throngh 9 in the procedure for analyzing
     liquid air samples.

          2.   Revised Procedure for Air Samples

     When it was discovered that appreciable amounts of amphibole
filters were being lost during centrifugation an alternate method
for removing extraneous material from the sample was sought.  It
was found that 0.1 normal hydrochloric acid removed sufficient
quantities of the masking material to expose the fibers to view in
the electron microscope.  Consequently, a modified procedure was
developed which employed hydrochloric acid leaching as a substitute
for centrifugation.  Ashing was also eliminated from the procedure.

-------
                                      60
III.  Compilation of Actual Procedures Followed by EPA Contractors

      A.   Procedures Employed in the Analysis of Air Samples
           by Battelle Memorial Institute,  Columbus,  Ohio

           1.   General Procedures

      The collection of airborne particulate were made by EPA on membrane
 filters containing an insoluble web support.  The web cannot be shed
 in the low-temperature asher, consequently, it was necessary to remove
 the collected particulate from these filters by ultrasonic treatment,
 redeposit the particulate on a 0.45u white plain Millipore filter (HAWP)
 and subject the redeposited material to low-temperature ashing.  Then
 the procedure which was developed for chrysotile was followed.  The
 detailed procedure which was first used in the analysis of air samples is
 as follows:

      (1)  A 10° radial section is cut from the as-received membrane
      filter bearing the collected air particulate.

      (2)  The collected air particulate is removed from the as-
      received filter sample in 10 ml of water containing 0.1 percent
      Aerosol OT by ultrasonic treatment in a 100 ml beaker.

      (3)  The dislodged particulate is then deposited on a 25-mm HAWP
      Millipore filter.

      (4)  Steps 2 and 3 are repeated three times to extract as much
      particulate as possible from the surface of the filter.

      (5)  The redeposited particulate on the Millipore filter is low-
      temperature ashed for 48 hours in a 15 ml test tube.

      (6)  The 10 ml of water containing 0.1 percent Aerosol OT is
      added to the ash in the test tube and ultrasonic treatment is
      employed ot disperse the ash residue uniformly.

      (7)  The resulting suspension is then centrifuged at 800 G for
      20 minutes.

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                                 59
     determined grid openings on each grid prepared are
     scanned (approximately 8 openings)  until at least
     50 fibers ate counted and sized.

     2.   An upper limit of mass concentration is cal-
     culated the same way as does McCrone Associates.
     The same assumptions are made.

          L x W^ x 3.3g/cmJ x Area - Volume =
                            Upper limit of Mass/Vol.

     3.   A lower limit of mass concentration is cal-
     culated by using a third dimension factor of
     0.15u.  This factor is chosen because it is the
     most probable value for width for these fibers,
     and it is also the limit of transparency of
     fibers as seen under the microscope.

          L x W O.lbu x 3.3g/crr.3 x Area - Volume factor =
                                  lower limit of Mass/Vol,

     4.   The upper and lower limits differ by up to a
     factor of 2.  These two numbers are averaged and
     this average value is reported as the mass con-
     concentration .

C.   Battelle Memorial Institute
                            «**.
     1.   The prepared grids are placed in the electron
     microscope.

     2.   Counts are made in the electron microscope at
     20,OOOX by scanning 5 to 10 grid openings systemati-
     cally.  When a fiber is encountered in the path of
     a scan, one count is registered.  If a single fiber
     intersects the path of more than one scan, it is
     counted as many times as it is encountered.  This
     "intercept counting" approach minimizes uncertainty
     arising from large variations in fiber lengths when
     performing mass determinations.

     3.   The mass concentration is read from a standard
     curve generated by weighing out different amounts
     of a standard amosite sample, preparing grids and
     counting in the same manner as above.

     4.   This mass value is then multiplied by a volume -
     area factor to arrive at mass per unit volume.

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II.  Summary of Methodology Used by EPA Contractors for the
     Determination of Mass Concentration

     A.   McCrone Associates - calculation

          1.   A small amount of the water sample (30-200 ml)
          is filtered through a 13nun, 0.45u millipore filter.

          2.   A section,  2 to 3mm square, is cut from the
          filter.  This section of filter is placed face
          down on a carbon-coated grid and the mcmbrance
          filter dissolved using acetone in a Soxhlet ex-  •
          tractor.

          3.   The samples on grids were examined on a JEM
          200 Electron Microscope using an accelerating
          voltage of 150KV at a magnification of 17,OOOX.

          4.   Approximately 50 fibrs are counted and sized.

          5.   Mass is calculated by the formula L x W^ x
          3.4g/cm^ x 4.5 x 10^ approximately = Mass/Vol.

               L = Length

               W - Width (thickness assumed to be equal to
               the width).

               3.4 g/cm^ = Density factor

               4.5 x 10^ = Area factor for grid and filter size
               and for volume of water filtered.

          The assumptions implicit in this are:

          1.   The fibers are deposited in uniform abundance on
          the grid such that the number of fibers counted in
          a few grid openings are representative of the number of
          fibers on all grid openings.

          2.   The particle size distribution of those counted is
          representative of the particle size distribution of the
          whole sample.

     B.   Mt. Sinai Cancer Institute

          1.   Rub--out procedure followed.  Fibers are trans-
          ferred to the electron microscope grids and pre-

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               F.  X   I2IH/L.     EERKELEYxE.M.
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                                                           HE3SS.
                                                                 n
                                                                 13
                                                                 31
                                                                 r
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                                                                 tn
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                                                                33
                                                                n

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                                    57
I.   A Statistical Analysis of the Validity and Accuracy of
     Using Optical Microscopy to Estimate the Number of Asbestso-
     Like Fibers in Water as Determined by Electron Microscopy
     To determine the value of optical microscopy (OM)  in estimating
results obtained from electron microscopy (EM)  a limited series of
paried OM-EM observations were obtained.  Jack Huchio,  School of
Public Health, Berkeley, used SM methodology (17,000x magnification)
and DeLeon, also of the School of Public Health, employed the NIOSH
optical technique at 450x.  A third set of data, an optical determina-
tion at lOOOx will be forthcoming shortly.  Since each OM-EM reading
in fibers per liter was for a single sample, these data (N = 28 pairs
of observations) were subjected to least-square regression analysis.
The regression coefficient, r, was emp'.jyed as a measure of predictive
value.  Perfect predictability between these estimates would be
reflected in a high r value (r Ranges from 1. to 0.0) .  Good agreement
(r = .5) would imply that OM could be used as a rapid and relatively
inexpensive estimator of true fiber quantity.

     Time estimates for OM vs. EM analysis time are approximately
1/2 hour vs. 1 day and cost estimates are about $15 versxis $200
respectively.  Thus, if OM predicts EM with even imperfect accuracy,
the former could be used in an Agency program to screen water supplies
outside of the Duluth area.

     Figure A-l shows graphically a plot of the two methods for paired
samples.  The fitted line appears anomalous because many data points
fall on the x axis and are obscured by it.  The correlation coefficient
for these data was .16 .and r is not statistically significant at the 1
or 5% level of confidence.  It can be concluded that OM cannot be
employed to estimate EM with respect to fiber counts.  OM counts, for
these conditions, bear little more than a random relationship to EM
counts.

     The poor relationship between OM and EM counts is due to the size
distribution of the asbestos fibers (generally smaller than 1 micron)
and the inability of the optical microscope to resolve the vastly more
numerous smaller particles.

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                             APPENDIX I

                          TABLE OF CONTENTS

                                                             PAGE
  I.   A Statistical Analysis of the Validity and Accuracy
      of Using Optical Microscopy to Estimate the Number
      of Asbestos-Like Fibers in Water as Determined by
      Electron Microscopy .. 	 .........    57

 II.   Summary of Methodology Used by EPA Contractors for
      the Determination of Mass Concentration .......    58

      A.  McCrone Associates - Calculation .........   58

      B.  Mt. Sinai Cancer Institute ............   58

      C.  Battelle Memorial Institute 	  59

III.   Compilation of Actual Procedures Followed by EPA
      Contractors ......................60

      A.  Procedures Employed in the Analysis of Air Samples
          by Battelle Memorial Institute, Columbus, Ohio .  .   60

      B.  Procedures Employed in the Analysis of Water
          Samples by Battelle Memorial Institute, Columbus,
          Ohio	   63

      C»  M£ . loll SttiWdtL, I'icCX'Cuie AafeOCj-, CjiiCQCjO ,
          Illinois:  Methodology for Determination of Amphibole
          Asbestos in Duluth Water Samples 	 ....   65

      D.  Mr. Jack Murchio, School of Public Health, University
          of California, Berkeley, California:  Analysis by
          Electron Microscopy of Asbestos Fibers in Water
          Samples	67

      E.  Ontario Research Foundation, Sheridan Park, Ontario,
          Canada:  Analysis of Water, Sediment and Air Samples
          for Asbestos	   69

      F.  Mt. Sinai School of Medicine, New York, New York:
          Asbestos Sample Preparation and Analysis
          Methodology	73

      G.  DeLeon - NIOSH Method	76

      H.  Procedures from EMventions, Inc., Rockville, MD.
          (Not Submitted)	80

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          Appendix  I
ANALYTICAL METHODOLOGY USED




    BY EPA CONTRACTORS

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APPENDICES

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                                       56
                           REFERENCES CITED
Burrell, S. (1973)  Mineralogy of Reserve Mining Company Ores.  Unpub. report.

French, Sevan M.,  (1968)  Progressive Contact Hetamorphism of the Biwabik
        Iron Formation, Mesabi Range, Minn., Minn. Geological Survey
        Bulletin 45, U. of Minn. Press, Minneapolis.

Gundersen, James N. and George M. Schwartz,(1962)  The Geology of the
        Metamorphosed Biwabik Iron Formation, Eastern Mesabi District,
        Minn., Minnesota Geological Survey Bulletin 43, Univ. of Minn.
        Press, Minneapolis.

James, H. B. (1955)  Zones of Regional Met amor phi. sm in the Precsmbrian
        of Northern Michigan, Geological Society of America Bulletin, v. 66,
        p. 1455-1488.

Marsden, R. W., Emanuelson, M. W., Owens, J. S., Walker, N.E., and R. F.
        Werner  (1968)  The Mesabi Iron Range, Minnesota, in Ore Deposits
        of the United States, 1933-1966, Bridge, J. D., ed; p. 518-537.

White, D. A. (1954)  The Stratigraphy and Structure of the Mesabi Range,
        Minnesota; Minnesota Geological Survey Bulletin, pp. 38, 92.

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                            35
3.   No significant emissions of asbestiform minerals or
other silicates are expected from the handling of pellets
of beneficiated ore.  Hovrever, the potential for silicosis
developing among workers occupationally exposed to emissions
during handling of pellets must be considered.

4.   The taconite mine by Reserve Mining Company, and occurring
in Minnesota on the Mesabi Range, is mineralogically similar
to that occurring in Wisconsin, Michigan, and Wyoming.  There
are at least five plants in Michigan, one in Wisconsin, and
one in Wyoming about which air and water pollution are expected.
None of the plants have a capacity greater than 35% of that
of Reserve Mining Company's plant, but a health hazard may exist,
and these sites should have high priority in any future sampling
programs.

5.   Other activities expected to emit high concentrations of
asbestiform fibers are numerous.  Many, many mines operate in
rocks containing amphibole minerals which are produced as a by-
product.  Sampling at selected sites should be done in the future.
Soils formed from rocks containing asbestiform minerals are
widespread and are expected to contain those minerals themselves.
The occupational and environmental exposure levels in all of the
above cases are unknown.  An effort of a magnitxide similar to
that dedicated to determining the ambient levels of asbestos
in air in urban areas must be made if we are to accurately determine
the levels of exposure in each of the above cases.

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                                 54
     Soils containing asbestiform minerals are a largely
uninvestigated source of potentially hazardous air pollution in
the United States.  The medical literature reports that, in
Bulgaria, soil near a serpentine mine contained chrysotile and
amphiboles.  Farmers working the land in this area have been
exposed to fibers found in the soil and a significant number were
found to have heavily loaded lung tissue as a result.

     That soils are locally significant sources of asbestiform
minerals must be considered in selecting control populations for use
in epidemiological studies.  In northeastern Minnesota, for
example, igneous and metamorphic rocks containing amphiboles and
volcanic rocks containing some serpentine are exposed at the surface.
Background concentrations of asbestiform minerals there are expected
to be significantly higher than in those parts of the state where
tills of sedimentary virgin or sedimentary rocks themselves are
exposed at the surface.

H.   Conclusions

     1.   No other company currently mining taconite along the
     Mesabi Range handles as much amosite annually as does Reserve
     Mining Company.  Reserve handles 2.5 times as much amosite
     as does the next largest producer.

     2.   Amosite is not the only asbestiform mineral present
     in emissions from Reserve Mining Company; crocidolite and
     actinolite are axpect-.ed to occur in small quantities as
     well.  Additional minerals not now classed as asbestiform/
     and whose potential as a health hazard are unknown,
     are:  hornblende, minnesotaite, greenalite, and talc.
     Respiratory diseases are known to be prevalent among workers
     in talc mills with fugitive dust.  When the contributions
     of these minerals to the emissions are considered, two plants
     are expecting to emit a larger tonnage of potentially hazardous
     fibers annually than does Reserve Mining Company.  Those two
     companies are:  Erie Mining Company and U. S. Steel's Minntac
     plant.  The other three companies on the Mesabi Range all emit
     about half the tonnage of potentially harmful fibers that
     Reserve Mining Company does.  Even these emissions must be
     viewed with alarm, however, if there is no threshold
     concentration associated with the incidence of mesothelioma,
     or other serious diseases resulting from exposure to asbesti-
     form minerals.  Air emissions from all these plants should
     have priority in any future sampling program on the Iron Range.

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Identifi cation

     Identification of chrysotile asbestos fibers gives risa to
little difficulty.  The fiber itself has a characteristic tubular
appearance (Figures 1, 2),  and in moct cases (depending on previous
history) such fibers give an equally characteristic electron
diffraction pattern (Figure 3) .   Thr.r, pattern can be compared with
that obtained from specimens of known chrysotile.  The appearance
and single-fiber diffraction patterns of the other varieties are
subtly different.  A standard of Amosite is shewn in Figure 4, and
its single-fiber diffraction pattern in Figure 5.  The tubular
morphology of chrysotile is not present, and the diffraction
pattern is more regular than that of chrysotile.  Crocidolite is
shown in Figure 6.  The morphology is similar in this size range to
that of chrysotile, i.e.,  very long thin fibers, though it does no
have the tubular appearance.  The single-fiber electron diffraction
pattern (Figure 7) shows fibrous morphology, and is quite different
in appearance from that of chrysotile.  Tremolite is shown in Figure
8, and its single-fiber diffraction pattern in Figure 9.

     Whilst it is not economically to identify the asbestos type
of every fiber by electron diffraction in all samples; the technique
can be used whenever doubt exists through observation of the fibrous
morphology alone.

Standard Samples

     Plank samples of distilled water have Leea processed in order
to demonstrate that asbestos is not being introduced as a result of
the analytical procedures.   It is very easy to think of possible
sources, such as airbore material, or contamination form furnace
insulation, etc.  In these blank samples 100 ml of distilled water
were filtered and the samples processed in the same way as for the
other specimens.  In one of these samples, no fibers were detected,
and in the other one only 3 fibers.

     In further standardization experiments, a known suspension of
fibers in the size range of interest was added to membrane filters
prior to ashing.  These samples indicated that the method was
satisfactory, giving confidence in the results obtained on the
actual samples.

Particle Size Considerations

     The techniques used have been developed on the premise that
the fiber lengths are in the size range of the transmission electron
microscope, i.e., .Olum up to about 20 urn.  Samples so far examined
have confirmed this, though in the case of sediment samples and some
air samples an optical examination is also necessary.

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                                72
Levels of Detection (Water Sampl es_)_

     The level of detection for fiber concentrations in this type of
measurement corresponds to the detection of one fiber in the area
counted.  This is equivalent to about lo'* fibers p?r liter.  At the
fiber Lengths observed, this figure corresponds to about 2 X 10
micrograms per liter, or 1 part in 5.10-1-' bv weight.

     The lowest level of detection using this method depends to a
large extent on the time which is spent on counting particles.  This
time can be reduced if the samples were initially concentrated to a
greater extent, e.g, by filtering more than 200 ml of the original
specimen.  Unfortunately, the amount of other material in the water
dictates a limit to the degree of concentration possible.  Above
this, the final electron microscope sample grid becomes so loaded
with other residues that most of the area is obscured and anything
approaching an accurate fiber count is not possible.  This limit-
varies widely between water samples from different locations, and in
several samples it has even been necessary to allow heavy material
to settle before final preparation of the microscope grid from the
ashed residues.  In other samples it has been only possible to force
100 ml of water through the membrane filter before complete blockage
took place.  In some cases all of the ashed residues were of small
particle size, and here the only recourse was to prepare an electron
microscope specimen with a reduced proportion of ashed residues, and
to spend more time counting the fibers.

     It is most important to realize that many diatomaceous fragments
appear at low magnifications to be linear and fibrous.  Diffraction
patterns and the morphology under higher magnifications are the only
means of rejecting such artifacts from the fiber count.

Calculation and Presentation of Results
     The fiber counts and measurements obtained on each sample are
processed by a specially written computer program, with results
being expressed in appropriate units for air, water or sediment
samples.  Typical computer outputs for the three cases are attached.
The mass concentrations shown are determined by assuming the X-ray
density for the principal type of asbestos present.

     A typical number - fiber length distribution is also shown.
On this cumulative curve it can be seen that above a particular fiber
length, no fibers were counted.  Fibers above this upper limit of
length correspond to only a few percent of the total number counted,

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                                73
so, the error in the total number reported is very small.  However,
those few fibers above the upper limit of size contribute progressively
more to the total mass present.  For example, because of their low
numbers, very large fibers at the 104 per liter concentration level
would not be found in these measurements, but they could contribute
significantly to the mass concentration.  The measured number-size
distribution would allow cloner estimates to be made of the mass
concentrations, but this d r> c, procedure which requires a considerable
amount of computation.

F.   Mt. Sinai School of Medicine, New York, New York: .Asbestos
Sample Preparation and Analysis Methodology

Ashing

     Samples collected on rnembrance filters are prepared for ashing
by cutting a I cm square of the filter and placing it, dust side down,
on a clean microscope side.  Two or rhree drops of acetone are added
to the square to partially dissolve the filter and to fix the material
to the glass slide.  The sample is ashed in a low temperature activated
oxygen asher for 10 minutes to one hour, depending on sample composition.
(The cleaner samples will require the longer ashing period.)  It is
best to stop the ashing before complet combustion of the filter to
minimize any loss of sample mineral material.

Rubout Procedure

     Following ashing, the samples are dispersed in a nitrocellulose
film and mounted on formvar coated electron microscope gruids.  The
dispersal is accomplished by a "rubout" technique in which asbestos
fibers are broken into individual fibrils.  This procedure allows
positive identification of chrysotile asbestos to be made on the
basis of morphology alone.  Moreover, large agglomerates of mineral
particles, which could obscure the presence of asbestos fibers of
fibrils, and to which asbestos fibrils could be attached, are broken
into particles sufficiently small to allow all asbestos fibrils to
be seen.

     The rubout is accomplished by placing a large drop of 1% solution
of nitrocellulose in amyl acetate on the ashed residue.  The flat
surface near the edge of a clean watch glass is used to grind the
residue into submicron sized particles.  This grinding usually takes
from 5 to 10 minues, depending on the amount of residue present.
Typically, the amyl acetate will evaporate in less than 5 minutes
and additional drops of pur amyl acetate must be added to complete
the rubout.  (Adding the 1% nitrocellulose solution will result in
an undesirably thick film.)  During the final stages of the rubout,

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the solution and residue arc dispersed over several cm of the microscope
slide.  After dispersing the ashed residue, some of which still remains
on the watch glass, another urop of the nitrocellulose solution is
placed on a second clean slide.  Duriny the dispersal of this drop
over several cm of the slide,  the major portion of the residue remaining
on the watch glass is removed.  By this procedure, less than 10% of
the residue will remain on the watch glass.

     The two slides are placed in contact and the ground residue and
nitrocellulose solution further dispersed.  The residue typically
is spread over the width of the slide for a distance of from 5 to
7 cm.  The two slides are thn pulled apart.  No pressure need be
exerted during this procedure as surface tension will hold them in
contact.

     With practive , a uniform film is thus produced which can be tested
by viewing against a light.   (We earlier did particle counts to verify
uniformity, but visual appearance proved to be as reliable an indicator
of uniformity.)  If the film is not uniform, amyl acetate can be added
and the above procedure repeated.

Mounting

     The edges of the slide with the attached film are scrap ed with
a scalpel blade.  By carefully dipping the slide in water at an angle
of from 30° - 50°, the nitrocellulose film can be floated onto the water.

     Several procedures can b
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                                75
Electron Microscope Scanning and_ Coyr.i.i nc;

     Typically, 8 grids are prepared from each sample ashed using
material from widely separated portions of the prepared films
from both slides.  A single square of each grid is scanned at
40,000 X magnification to determine thn quantity of chrysotile
present.  The identification of chrysotile is on the basis of
morphology, either that of the classic tubular structure or that
of altered chrysotile (as a result of either beam damage or physical
damage prior to collection).  Here the structure exhibits a dense,
irregular, inner region, sometimes with a thin capillary, and an
electron transparent irregular outer region.  To gain experience in
recognizing various forms of chrysotile, one can select an unaltered
fiber and watch it deform in the electron beam.  The use of carbon
coated films can reduce this damage, but in practice this procedure
has not been found necessary.

     The length and diameter of each fiber are estimated with the
aid of fiducial marks on the viewing screen and the mass of chrysotile
per grid square determined.  The total area of film prepared is used
to calculate a dilution factor from the rubout.  (Typically, 1 cm  of
membrance filter sample is dispersed in 25 cm^ of film.)  Knowing the
air volume passed through a given area of filter paper, the concentration
of chrysotile asbestos in the sampled air can be obtained.

     In practice, a reasonable statistical variation exists between
the number of fibrils found on different grid squares.  The variation
exceeds that expected on pure statistical grounds as occasionally
clumps of fibrils, resulting from the incomplete dispersal of a
fiber bundle, are seen.  However, greater variation occurs in the
volumes seen on different grid squares as one large fibril can contribute
100 times the volume of a small one, hence, the need for counting
several grid squares.  Eight lOOu X 100 U squares have proved to
be sufficient.  The inaccuracies inherent in the sample preparation
do not warrant additional effort in scanning.

Calibration

     The above procedures are calibrated by processing filters prepared
with known amount of chrysotile.  Here both clean membrane filters
and filters previously used to collect ambient air samples are used.
Triple air jet milled chrysotile is dispersed in f^O to which Aerosol
OT has been added.  The solution is subject to ultrasonic energy and
diluted so as to produce a concentration of about 1 nanogram of
chrysotile per cc.  This solution is filtered through the membrance
filter until 10 to 50 ngms of chrysotile is collected per cm^ of filter.
The above procedure is then followed as in the case of collected air
samples.  Recoveries range, typically, from 30% to 50% of the added
chrysotile and this factor is applied to the data from the processed samples,

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                                76
Clean Room Procedures

     It has been found that strict adherence to clean room procedures
must be followed.  All sample processing should take place in a
filtered air environment.  The water used should be filtered thorough
0.22u membrane filters.  Blank controls must be run routinely to
assure absence of contamination.

G.   Del eon - NIOSH Method

Introduction

     In the early epidemiologic studies of the asbestos industry by
Fulton (1935) and Dreesen  (1938) , the impinger was settled upon as
the standard method for appraising dustiness.  Since few fibers were
seen it was necessary to count both grains and fibers to obtain a
statistically useful count depsite the assumption that asbestosis
was caused by fibers.  This inconsistency notwithstanding, dust control
based on impinger results has greatly reduced the incidence of
asbestosis where it has been conscientiously applied in the asbestos
textile industry.  However, a number of investigators (Lynch and
Smith, 1955; Doll, 1955) have suggested other health hazards associated
with asbestos, and a more relevant and sensititve method is required
for estimation of the hazard, especially in industries using only
part asbestos in their product.

     A further weakness in the impinger method is that it is not
amenable to long personal samples.  It is believed that personal
samples best approximate the worker's actual exposure, and Roach (1966)
has recommended a sample duration of ten work shifts for mineral dusts.

     New methods were therefore needed, and among those studied were
fiber counts at 430X phase contrast on membrane filters that had
been made transparent.  This paper deals with the development and
standardization of this method.

     The principal variable which needed to be considered was the
mounting procedure in relation to maximum transparency and the
effect of time on the dimensional stability of the mount.
Methods using immersion oil, airplace glue or acetone were found
to be either too cumbersome or resulted in an imperfectly cleared
or mottled filter, particularly as viewed with phase contrast optics.
In methods which involved the application of liquid over the dust
deposit the movement of the meniscus across the deposit sometimes
caused redistribution of the dust.  The use of a 50-50 mixture of
diethyl oxalate-dimethyl phtalate was attempted and found to result

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                                77
in satisfactory clearance.  However, since this medixim dissolved
the filter, the migration of particles resulted in changing counts
with time and needed to be examined to evaluate the method.

Sampling Procedure

                                                   (R)
     Samples for count are collected on Killipore     type AA filters
by personal samplers operated by battery powered pumps worm by the
employees, and as simultaneous samples collected in conjunction with
impingers.  The filters are contained in plastic filter holders and
are supported on thick pads which also aid in controlling the distribu-
tion of air through the filter.  Several methods of admitting air to
the filter have been attempted.  With the face cap removed and the
filter completely exposed, the air may enter the filter evenly, but
large high velocity particles and foreign objects may also hit the
filter and possibly cause damage.  As an alternative, the face cap
may be left in place and the small plug removed.  The passage of air
through this 4 mm opening at a flow rate of 2 liters per mirute produces
a velocity of 265 cm/sec, which yields an impaction parameter of
0.081 for 1 micron (u) unit density spheres.  Although this impaction
parameter would predict a very low collection efficiency of 1 u
particles by impaction, some larger particles would tend to be impacted
on the center of the filter.  This was found not to affect count
distribution, which is dominated by small particles; however, it does
result in obscuring a small portion of the filter, particularly if
many large particles are present, as in friction product plants.  The
third alternative was to drill six additional 4 mm holes in some face
caps and to fit these perforated caps to the filter holder during
sampling.  This reduced the velocity to 38 on/sec thus eliminating
the impaction problem' while still protecting the filter from damage.

Mounting the Sample

     The mounting medium used in this method is prepared by dissovling
0.1 gm of membrane filter material per ml of a 1:1 solution of
dimethyl phthalate and diethyl oxalate.  The exact proportions of
the 3 components are not critical, but the medium must have as high
a viscosity as possible without being difficult to handle.  The index
of refraction of the medium thus prepared is ND = 1.47.

     To prepare a sample for microscopic examination, a drop
of the mounting medium is placed on a freshly cleaned standard
(25 mm x 75 mm) microscope slide, using a dropper or applicator.
The volume of the drop is approximately 0.05 ml.  A wedge-shaped
piece about 1 cm by 2 cm is excised from the filter using
a scalpal and forceps, and placed duet side up on the

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                                78
drop of mounting solution (Figure 1).   A #1-1/2 cover-slip
carefully cleaned with lens tissue ic  placed over the filter
wedge.  Slight pressure on the covers!ip achieves contact between
it and the mounting mediarn.

     Clearing of the filter with this  method is slow, requiring
about 15 minutes.  The r ample may be examined as soon as the
mount is transparent.

     The transition of the dust-supporting substrate .from
translucent, solid membrane filter cellulose ester material to
a transparent, optically homogeneous gel is very gentle, and
at no time does a meniscus sweep across the dust deposit.
Rather, the substrate slowly softens beneath the dust, and there
is no opportunity for washing away or redistribtuion of the dust.

     The optical homogeneity of the resulting mount is nearly
perfect, with only a slight background granularity under phase
contrast, which disappears within 1 or 2 days.

Stability

     Observers noted a reduction with time in apparent con-
centration for samples mounted with only dimethyl phthalate
and diethyl oxalate.  By observation,  this loss was due to the
migration of the dust particles outward from the center through
the gelatinous ruo.tGjTj.al of tli£ fiA^u mount, with & ciecreasy in
aread concentration. .To determine the magnitude of this loss,
a group of samples was mounted using 1:1 dimethyl phthalate
and diethyl oxalate only, and counted at one day to three-day
intervals for periods ranging up to 76 days.  Counts were displayed
as fractions in percent of the original, or first day counts
(Figure 2).  At the end of one week, samples mounted by this
method yielded only 75% of their original values.  By 30 days
after mounting, the counts using this method had declined to
40% of thier first day value, and continued at this level with no
further decline until counting was terminated 76 days after
mounting.

     A group of samples mounted in the method described in the
section "Mounting the Sample" using high-viscosity mounting
medium were counted at one-day intervals for eleven days.  No
loss of areal concentration was apparent over this short period
and a second group was similarly mounted and counted for a
period of fourty-six days.  The composite of these two series
in shown in Figure 2.  No loss of concentration was detectable
during the first 30 days, but the count declined to 85% of its
original value by the 46th day, when the series was terminated.

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                                79
     A 6 mm square of membrane filter with a vaccurn-deposited
film of carbon was mounted in the manner described to provde
a macroscopic observation of the distortion of the filter areas.
After a few days, the square began to disintegrate at the edges,
but the major portion shoved no discontinuity during the initial
30 day period.  By the end of 62 days, most of the square had
disintegrated and the fragments migrated over an area 16 mm by 17
mm.

Evaluation

     The filter samples mounted in the manner previously described
are evaluated in terms of grain and fiber concentration, and fiber
size.  Binocular research microscopes equipped v/ith fixed mechanical
stages have been used.  Phase contrast optics fitted to these
instruments include an Abbe condenser with roatating phase turret
and a 4 mm "high-dry" achromatic objective used for all membrane
filter determinations.  In all cases 10X Huygens eyepieces, one
of which contained a Forton reticle at the level of the field-limiting
diaphragm, were used.  The left half of the Porton reticle field
served to define the counting area or field.

     A ribbon filament illuminator was cirtically adjusted to
provide Kohler illumination through a clear blue filter.

     Twenty fields located at random on the sample were counted
and total grains, total fibcrc, fibers greater than 5 u, and
fibers greater than 10 u were recorded.  Any particle having an
aspect ratio of 3 or greater was considered a fiber.

Recording of Data

     Since it was recognized early in the study of the asbestos
products industry that the large number of samples to be collected
would present a burdensome data processing problem, the data were
collected on forms designed for transcription to punch cards (Figure
3).  Computer programs were then written to calculate dust
concentrations and to produce statistical summaries consisting of
mean, standard deviation, median, etc., for any group of samples
by plant, operation, job, type, etc.  These programs, written in
Automath  (Fortran II) are applicable to any problem using the sample
and count forms as source documents.  Additional analyses possible
are correlation and regression of simultaneous samples and Poisson
index of dispersion of field counts for various counters.

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                                80
Summary

     A method for sampling and counting asbestos dust using
membrane filters has been developed and evaluated.   The mounting
medium developed clears the filter gently so as not to
redistribute the dust deposit, and produces a mount with adequate
dimensional stability for a period of thirty days.   This method
has been used in developing environmental data in connection
with the Public Health Service study of the asbestos products
industry, and is recommended for research studies in other dusty
trades although not for application to Threshold Limit Values.
A system of data handling involving electronic computer processing,
which is also applicable to other studies, was discussed.

References

     Doll, R. Mortality from Lung Cancer in Asbestos Workers.
British Journal of Industrial Medicine, 12;  81-85 (1955) .

     Dreesen, W. C., J. M. DallaValle, T. I. Edwards, J. M.
Miller, and R. R. Sayers.  A Study of Asbestos in the Asbestos
Textile Industry.  Public Health Bulletin No. 241,  u. S.
Government Printing Office, Washington, D. C. (1938).

     Fulton, W. B., A. Dooley, J. L. Matthews, and R. L. Houtz.
Asbestosis.  Pennsylvania Department of Labor and Industry,
Special Bulletin 42 (1935).

     Lynch, S. A.  A More Rational Basis for Air Sampling
Programmes.  Am. Ind. Hyg. Assn. J., 27, 1 (Jan.-Feb. 1966).

Note

                (R)
     Millipore     filters are named in this paper since the
method was developed using this brand of filters.  However,
this does not imply endorsement by the United Stated Department
of Health, Education, and Welfare or the Public Health Service.
Similar techniques may be developed for other filter brands.

H.   Procedures from EmVentions, Inc., Rockville, Maryland

     (Not submitted)

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                       81
                  APPENDIX II
ANALYTICAL RESULTS REPORTED THROUGH SEPTEMBER,

       1973, FOR WATER AND AIR SAMPLES*
                       *Due to its bulk, APPENDIX II can
                        be seen on file in the Office of
                        Technical Analysis ,  EPA.

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       APPENDIX III
STATISTICAL ANALYSIS OF THE




    ANALYTICAL RESULTS

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                      APPENDIX III
                    TABLE OF CONTENTS
                                                                Page
A.  Replication Reliability and the Validity of Ordering
    of Numeric Assignments for Selected Battelle Air Data       ^2

B.  An Examination of Inter-operator (contractor) variability
    in Electron Microscope Fiber Counts on Replicates of the
    Same Sample                                                 84

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                                  82

A.  Replication Re3.lability end the VcJ 'ditv_ci Ordering of Numeric
    Assignments for Selected^crtrirell ^ /.i.r_JDpty.


         Subsets of paired air samples analysed by Battelle for fiber
concentrations were statistically examined to obtain answers to the
following general questions:

         (1)  What kind of relative variability exists between
    analytical results obtained for suVsamples taken from a single
    synoptic sample replicate (i.e., subdivisions of two filter pads
    from a single location.}

         (2)  What kind of absolute variability exists between
    analytical results obtained for subsanples taken from a single
    synoptic sample replicate (i.e., subdivisions of two filter
    pads from a single location.)

         These questions bear on the reliability and replication-
validity of a sample value.  Both parametric and non-parametric statis-
tical tests were performed to obtain estimates cf this variability.

         A rank correlation analysis was performed (on split samples)
to determine if the ordering of quantitative values for a given
analytical run was approximately constant for two replicates of a
single sample.  This test was run for two data sets and the results
are given below in Tables 1 and 2.  The correlation coefficients, Rho,
for these two runs were .86 and .66, respectively, and are indicative
of good relative agreement between the order of assigned values on two
separate replicates.  Thus,, the analytical assignments are the some
regardless of when the analyses are performed.

         With respect to the absolute numerical values assigned to sub-
samples, data for selected samples were subjected to a paired "t" test.
This test asked the question, "Are numeric values assigned to a. sample
constant when analyses are performed on two separate subsamples?"  Results
of this analysis are given below in Talbe 1 and Table 2:

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Table 1:
                                   83
         Sample

            1
            2
            3
            4
            5
            7
            8
            9
           10
                       First RAT- i  Battellc Air Samples

                               Subsample 1             Subsample  2
                       .09
                       .03
                       .06
                       .06
                       .01
                       .07
                       .02
                       .02
                       .02
(1.0)
(5.0)
(3,5)
(3.5)
(9.0)
(2.0)
(7.0)
(7.0)
(7.0)
                                      (Rhc)
     .19
     .03
     .07
     .01
     .02
     .07
     .02
     .01
     .02
Results of Rank Correlation
            r^ .663
            »*«  good serial agreement
Results of Paired "t" Test
            t - .508 with Sdf
            • %.  no significant difference between
                in Subsample 1 and Subsample  2.
     Rank

     (1.0)
     (4.0)
     (2.5)
     (8.5)
     (6.0)
     (2.5)
     (6.0)
     (8.5)
     (6.0)
                                                                   values
 Table  2:
                      Rerun:  Battelle Air Samples
             Sample //

                1
                2
                3
                4
                5
                6
                7
                8
                9
               10
                       Subsample 1
                            
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                                   84

         From these results it is possible to conclude that both the
relative and absolute analytical results obtained for air subsamples at
a single point are in good acjreement.   Thus, the data can be used to
estimate relative, and possibly, absolute levels, of fiber mass within a
given area.  The results of these analyses do not speak to the accuracy
of the measurement or to the size, type, or chemistry of the fiber mass
present.  These analyses do not reflect the errors stated by Battelle
to invalidate the first set of air data analyzed (10 samples) nor to
validate the second analyses (of 31 samples) said by Battelle to be valid.

B.  An examination of inter-operator (contractor) variability in
       Electron Microscopic fiber counts on_ rejplicates of the
       saiae sample

         For the Duluth asbestos study, the various Government contractors
(McCrone, Inc.; Jack Murchio, The School of Public Health, University of
California, Berkeley) were supplied split samples of water from a given
location and McCrone received filter pads of material filtered in the
field as well.  These were analyzed using electron microscopes (EM)
and with the data being both the number of fibers/liter and the length
and width distribution of those fibers.  Of the samples analyzed to
date, only 13 samples have been completed by both contractors for all
parameters to be estimated.

         The data on fibers/liter from these 13 samples have been
subjected to two-way analysis of varianca.  This test permits the
estimation of the statistical significance due to two factors:
contractor effect and sample effect.  The questions asked of the data
were, "are there significant differences in counts produced by the
various contractors,, and are there significant differences da« to samples?:
Significant differences between contractors could possibly mean that they
are counting asbestos in different ways but comparisons would be invalid.
Significant differences between samples are to be expected a_ priori since
the number of fibers per unit volumes should vary from sample to sample.
It is cautioned that these are preliminary and partial data so that the
following results must be accepted as tentative, pending completion of
all samples.

         Raw data are given in Table 1.  Results of this analysis are
given in Table 2.  The F value for columns  (= contractor) is not
significant while the row variation (= between individual samples) is
significant at the 5% level.  These results are encouraging since they
suggest that two independent analyses of the same sample produce similar
results.  The means of the data from the two operators, 2.3 X 10^ for
McCrone and 1.4 X 10^ F/l for Murchio, are  somewhat different but the
difference is not statistically significant.

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                       85




                                       Table  1




          EM-Water  Sample  Results



                      SOURCE
S ample
1
2
3
4
5
6
7
8
9
10
11
12
13
Me Crone
4.37*
- 5.29
2.76
6.08
2.26
1.47
2.53
0.25
3.87
0.67
0.71
. 0.39
0.46
Murchio
2.0
3.0
5.0
2.0
1.0
1.0
2.0
0
0.7
1.0
0.1
0.3
0.3
*                 6
 Fibers/liter X 10

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                          86






                                 Table 2
          Analysis of Varionce Table
Source      df        SS         MS
Total
Columns

Rows
Error
25
1

12
12
77.092
6.213

54.472
16.407
3.084
' 6.213

4.539
1.367

4.545 NS
*
3.320

     NS = Not Significant



     *  = Significant at 5% Level

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